Flood Risk for Data Centres in Scotland

Renewable Energy

According to the scottish government, Scotland’s renewable energy capabilities make the country an ideal location for green data centres. “Data centres are very large consumers of energy. But Scotland has enormous capacity to generate energy from renewable sources. That means there’s an opportunity for the country to become a leader in green data centres.” In 2022, renewable technologies generated the equivalent of 113% of Scotland’s overall electricity consumption. 

Cooler Climate
Scotland’s cooler climate also attracts data centre developers, with lower ambient temperatures reducing the need for mechanical cooling, improving energy efficiency and cost.

Reduction in Costs

A blog from DataVita in April 2024 highlighted the cost benefits of developing a data centre in Scotland including:

• Up to 70% reduced operational costs vs other markets, partially thanks to the cooler climate
• Savings on cost of land – data centre-ready land in Glasgow can cost up to 90% less than Slough, greater London.
• Cost-effective talent, with an average lower wage vs London, Dublin, Frankfurt or Amsterdam 

Green Datacentres and Digital Connectivity Vision and Action Plan (2021)

The Scottish Government actively promotes digital infrastructure investment. Its Green Datacentres and Digital Connectivity Vision and Action Plan (2021) outlines clear actions to attract hyperscale and edge data centres, supported by renewable energy, fibre rollout, and strategic site promotion. This commitment is reinforced by the Infrastructure Investment Plan, which backs full-fibre deployment by 2027 and highlights data centres as an area for targeted growth.

NPF4 for Data Centres

Policy 22 of NPF4 states that:

a) Development proposals at risk of flooding or in a flood risk area will only be supported if they are for: 

i. essential infrastructure where the location is required for operational reasons; 

ii. water compatible uses; 

iii. redevelopment of an existing building or site for an equal or less vulnerable use; or.

iv. redevelopment of previously used sites in built up areas where the LDP has identified a need to bring these into positive use and where proposals demonstrate that longterm safety and resilience can be secured in accordance with relevant SEPA advice.

As Data Centres are classified as “Essential Infrastructure” in line with SEPA’s Land Use Vulnerability Guidance document and the glossary of NPF4, developments of this nature are permissible to be situated within the Flood Risk Area – subject to the below key considerations.

This includes the following:

• all risks of flooding are understood and addressed;
• there is no reduction in floodplain capacity, increased risk for others, or a need for

future flood protection schemes;

• the development remains safe and operational during floods;
• flood resistant and resilient materials and construction methods are used; and
• future adaptations can be made to accommodate the effects of climate change.

Furthermore, it is vital to keep in mind that further consultation may be required with the local planning authority to justify that the site’s location is required for operational reasons as per NPF4.

All risks of flooding should be understood and addressed

As part of a valid planning application, a Flood Risk Assessment must be undertaken to assess the risk of flooding from all sources, including:

• Fluvial
• Pluvial
• Coastal
• Groundwater
• Reservoir
• Sewer

If any of the proposed development is situated within or close to the Flood Risk Area (i.e. the 1 in 200 year plus climate change extent) – a detailed FRA will likely be required which includes hydraulic modelling to understand the depth of flood water, velocity, flow paths, and the speed, duration, and frequency of inundation to the site.

There should be no reduction in floodplain capacity, increased risk for others, or a need for future flood protection schemes

It is vital that flood risk downstream of the development site is not increased following construction, and this must be demonstrated if any part of the site is shown to be located within the Flood Risk Area.

Data Centres are classified as an exception under NPF4 Policy 22a, which means that mitigation measures are permitted to support the development. This can include compensatory storage (in accordance with SEPA’s Technical Flood Risk Guidance for Stakeholders document (2022)), or raising some buildings within the site in accordance with SEPA’s Position Statement on Elevated Buildings (2025). Both of which need to be demonstrated comprehensively via hydraulic modelling.

The development should remain safe and operational during flood events

To ensure that your data centre site remains safe and operational during flood events, a full understanding of the operational cycles is required (e.g. will the facility be manned during flood events, and will safe and dry access and egress be made available during the design storm). Even with safe and dry egress, it is best practice to further understand and implement procedures and actions to prepare for a flood event. This would be presented as a flood management plan and strongly recommended. 

Flood-resistant and resilient materials and construction methods

If, following hydraulic modelling, it is determined that any units are deemed to be within or close to the flood risk area, flood resilient and resistant construction techniques (in line with the CIRIA Code of Practice for Property Flood Resilience C790) should be applied.

Future adaptations for climate change 

As per Policy 22 of NPF4, climate change must be accounted for as part of the detailed FRA, with uplifts (in accordance with SEPA’s Climate Change Allowances for Flood Risk Assessment in Land Use Planning) being applied to fluvial, pluvial and coastal sources respectively.