Written submission from Global Action Plan (DCU0056)

Global Action Plan response to the Environmental Audit Committee inquiry into the risks and opportunities to the sustainability of data centres in the UK
 

Global Action Plan is a UK climate charity founded in 1993 working on clean air, big tech and climate education. Through powerful public campaigns, trusted partnerships and evidence-led advocacy, we shift understanding, influence policy and amplify the voices of those most affected — turning awareness into action and ambition into lasting change.

Summary

1. The government’s climate and biodiversity goals do not align with the de-regulatory and insufficiently strategic approach it is taking to data centre roll-out. In particular, it seems inconceivable that data centre demand growth is compatible with carbon budgets,[1] a problem rapidly compounded by the prospect of on-site gas power for data centres. The Government must, as a first step, come forward with its long-promised[2] National Policy Statement (NPS), to set out the policy framework for decision-making regarding data centre applications directed into the ‘Nationally Significant Infrastructure Planning’ (NSIP) regime.
2. Strategic planning is further hampered by the lack of transparency and consistent reporting from data centre developers and operators about their use of resources and the impact of their activities, and by the lack of binding sustainability standards. Activity from regulators, such as the Environment Agency, appears limited to encouraging the industry to voluntarily report water consumption.[3]
3. Finite renewables capacity risks being monopolised by data centres, restricting availability for other sectors. Data centres must be required to source 100% renewable electricity for the lifetime of their operation, with strict additionality criteria to ensure that only newly added renewable capacity counts. Data centres must not be allowed to compete for renewable energy (or water) with housing developments, or other priority sectors for decarbonisation.
4. Water use is a growing concern, especially given the lack of transparency from the industry and the worsening context in terms of the UK’s water security. New research from Global Action Plan estimates that 84% of proposed data centres are located in areas of the UK that are projected to be water stressed by 2040 (and many of which are already seriously water stressed).
5. Public support for data centres is low, but there is a concerning lack of democratic participation in data centre decision making. Where data centres are proposed they are increasingly being resisted by the local community. More widely, public polling shows that data centres are considered very low priority for resources compared with other sectors. The potential for costs (both financial and non-monetary) of the rapid build out to be passed to ordinary citizens is concerning.

Energy
The new generation of ‘hyperscale’ data centres planned across the UK are on a different scale to the facilities in place today. Smaller data centres typically consume 5-10 megawatts (MW) of power, whereas the data centre recently voted for by the council in Elsham, Lincolnshire, will demand one gigawatt (GW) of electricity – 200 times the energy requirements of the previous generation and equivalent to the total output of a gas or nuclear power station.[4]

Ofgem’s recent ‘call for input’ regarding demand connection reform identified connection requests from:

“around 140 (50 GW) data centres, the majority of which are likely to receive a Gate 2 offer. 71 (around 20GW) data centres reported they have achieved financial commitment with Final Investment Decision (FID), indicating a significant volume of mature data centre projects in the demand queue” [5]

For context, peak electricity demand for the entire UK during winter 2025/26 was 45 GW.[6]

This additional demand, unless matched with new, renewable energy generation and storage poses a threat to efforts to decarbonise the UK’s electricity grid, given the challenges already posed by the anticipated doubling of electricity generation in order to decarbonise heating and transport.

Emissions
There are more than 100 UK data centres in planning.[7] Developers’ own emissions estimates show that just ten of the largest will emit as much carbon each year as that saved by the switch to electric vehicles, demonstrating the speed at which the rapid build-out of data centres will undermine decades of decarbonisation progress in other sectors.[8] These figures are self-reported and inconsistent – there is an urgent need for consistent and mandatory disclosure of lifetime emissions impacts, including across the supply chain. This applies to local air pollutants as well as greenhouse gases – the implications of diesel back-up generation on local air quality is not being sufficiently assessed.

Following recent scrutiny, the Government has withdrawn its estimate of a ‘maximum of 0.142m tonnes of CO2 (MtCO2) from 11.2GW of AI-related computing power by 2035’. Recent analysis confirms just how significantly this was an underestimate - a more credible figure, assuming just the 20 GW of ‘mature’ projects identified by Ofgem go on to be built, suggests associated carbon emissions will be ‘as high as 70MtCO2, the annual emissions of Sweden’. This is 500 times the previous Government estimate.[9]

Even facilities smaller than 1GW giants, according to their own developers, contribute hundreds of thousands of tonnes of CO2 to the atmosphere every year. Google’s planned data centre in Essex will, according to the firm’s planning documents,

“lead to a net increase in GHG emissions of 568,727 tonnes CO₂е per year during the operational phase.” [10]

These estimates assume energy demand will be met by grid electricity, the generation mix for which will vary according to time of use and the rate at which renewable energy is built.

However, developers are now looking to build on-site gas generation to meet their power needs and, presumably, to facilitate faster build-times when grid connections are not available. One developer quoted in Utility Week noted:

“Data centres can’t connect to the electricity network today… So they come to the gas network. They’re coming to us and asking for a connection to the gas network and saying they’ll build a small gas power station to power locally their data centre. And because we’ve got the capacity, we can just do it.” [11]

The first project to have been directed into the Government’s Nationally Significant Infrastructure Project (NSIP) planning regime is a proposed 300 MW data centre in Wapseys Wood, Buckinghamshire, which is not seeking a grid connection and will instead by powered entirely by on-site gas turbines ‘at least in the initial phases’.[12]

Using the Government’s own GHG conversion factors, we estimate emissions from this one data centre will be more than half a million tonnes – 532,696 tCO2e – annually.[13]

Burning such enormous quantities of gas on-site will also inevitably have a negative impact on local air quality, something that will be of concern to the two nearby primary schools and local hospital.

The emergence of gas fuelled on-site generation is particularly worrying given the absence of any National Policy Statement (NPS) that should be guiding the decision-making process of projects directed into the NSIP regime, and which should be considering carbon budgets in the round. The Minister for Housing and Planning said the NPS would be published “shortly” after regulations were laid in January, but to date this has not emerged.[14]

Water
The water footprint of AI data centres is far greater than is commonly acknowledged, and their rapid, largely unregulated growth risks exacerbating England’s emerging water crisis.[15]

Data centres that use water for cooling draw down very large quantities to manage the heat generated by densely packed servers. Cooling towers, chillers, and humidification systems are the main direct uses, while large volumes of water are also consumed indirectly through electricity production to power the data centres.

Facilities using water to cool their computing equipment may cause a significant drain on the local water supply, which could have knock-on effects on the local and national environment, straining ecosystems and intensifying competition for resources between agriculture, communities and businesses.

There is often a lack of transparency from developers on these impacts, and the Environment Agency has said that they “are experiencing barriers in gaining information about water consumption” by data centres, and “more transparency is needed”.[16]

A mid-sized 15 MW data centre may consume around 300–500 million litres of water each year - roughly equivalent to the annual domestic water use of 2,000–3,500 UK households - while a single hyperscale data-centre campus can draw around 1.5 million litres per day, comparable to the daily water needs of a town of 10,000 people, placing it among the largest industrial water users in many local catchments.[17] Thames Water, the largest water company in the country, has given even higher estimates, stating in its 2025-30 business plan that “a large facility might use anywhere between four and 19 million litres of water per day.”[18]

Roughly a quarter of this footprint is direct onsite use.[19]   Much of this is water used in cooling systems, frequently sourced from potable (drinking-quality) supplies. Some water companies have objected to data centre plans due to the use of potable water.[20]

While alternative technologies – such as direct-to-chip or immersion liquid cooling, closed-loop systems, and air economisation – can reduce dependence on potable water, their uptake remains uneven.[21]

Water consumption by data centres is expected to rise sharply, driven in particular by the rapid expansion of artificial intelligence and machine-learning workloads. Globally, water withdrawals are projected to reach between 4.2 and 6.6 billion m³ by 2027, with onsite use in the United States potentially doubling or quadrupling by the end of the decade.[22] Company disclosures already indicate multi-billion-litre annual consumption with sustained year-on-year growth.[23]

While comparable national projections are not yet published for the UK, the implications are clear. Even a modest share of this global growth would translate into hundreds of millions of additional litres of annual demand concentrated in a small number of English catchments, many of which are already classified as water-stressed. This trajectory coincides with intensifying scarcity: nearly three quarters of the world’s population currently lives in areas classified as water-insecure or critically water-insecure[24], while large parts of England - particularly the South East and East - are already experiencing structural supply deficits.

Recent economic modelling underscores the scale of the challenge: without major new investment, demand in England starts to exceed supply by 2034[25], and combined industrial, residential and digital infrastructure demand could produce a public water supply shortfall of around five billion litres per day by 2055 - more than one-third of current daily usage[26]. Crucially, the same modelling identifies rapidly expanding sectors such as data centres and AI infrastructure as under-recognised drivers of demand in already stressed regions. Yet the Environment Agency cannot currently model these impacts accurately because data centres are not required to disclose their water withdrawals or consumption. This lack of visibility means the UK is planning its water future with a major blind spot.

Against an already stressed system - one that must balance the needs of households, agriculture, industry and the environment - the arrival of a new, highly concentrated, fast-growing water user in the form of hyperscale AI campuses risks pushing several regions past their limits. It is within this tightening political-hydrological context that the escalating water demand of UK data-centre infrastructure must be understood. Using available data, we estimate that 84% of proposed data centres are located in areas of the UK that are projected to be water stressed by 2040 (and many of which are already seriously water stressed[27].

Democratic deficit
Communities are resisting data centres wherever they are proposed. Recent months have seen demonstrations at proposed locations in Buckinghamshire, Hertfordshire and Central London.[28] UK councils are beginning to pass moratoria on data centre construction.[29]

Public polling across five European countries including the UK reveals that majorities across all markets and demographics:

• support mandating new data centres be built only if new renewable energy sources are created in order to power them
• think data centres should not be built if they are powered with fossil fuels
• think that new data centre facilities should be built only if powered by renewable energy [30]

Despite being the biggest market in Europe, the polling revealed public awareness of data centres was lowest in the UK.

Local Planning Authorities will be sidelined when applications are directed into the NSIP regime. This centralisation of data centre decision making is particularly concerning given the Government has already admitted it made a “serious logical error” in approving a data centre application that had previously been twice rejected by the local council in Buckinghamshire.[31]

The use - at the developer’s behest – of a Local Development Order (LDO) in a proposed 600 MW East Havering data centre, is a concerning development. Local residents report being overwhelmed by having to review 2,753 pages of complex planning documents in a 28 day consultation period.[32]

Impact on other sectors – and energy bills
There is evidence that housing is competing with data centres for access to grid connections.[33] The inability to build housing has implications for London’s wider economic growth and ability to meet housing targets.

In Tower Hamlets, local residents are campaigning for the historic former Truman Brewery site to be converted into social housing. Instead, a proposed data centre is being pushed through by central government.[34]

The impacts on energy bills of data centres’ massive energy demands remain to be seen, though the Government has recently – and for the first time to our knowledge – acknowledged that the costs of infrastructure upgrades associated with data centre build out will likely put bills up:

“Funding these measures via network charges might lead to higher electricity bills in the short run”[35]

In the US, the increase in power bills as a result of data centre build out has been significant.[36] Regions with significant data centre activity have endured price increases by as much as 267% over the past five years[37].

Lessons outside the UK
Globally, data centres draw water from the local potable system – the network of infrastructure that delivers drinking water to a community, permitted groundwater abstraction, and increasingly from reclaimed wastewater or seawater[38]. In some cases, groundwater permits have been issued but subsequently contested by communities due to concerns over competition with domestic or agricultural water needs. In some regions, protections are emerging: in drought conditions, utilities are restricting access to drinking water for cooling, and regulators are encouraging or mandating the use of non-potable supplies[39].

Governments have also begun to act more broadly: Singapore, Amsterdam, and Dublin initially imposed moratoria on new data centres and now enforce stricter water and energy performance standards. Germany has legislated efficiency requirements.

However, the UK's political response to the environmental impact of AI-driven data centres has been notably underwhelming compared to other leading data centre hubs. Industry responses include investment in water-efficient cooling technologies, recycling and reuse schemes, siting in cooler climates, and improved reporting. Yet without stronger governance, the anticipated surge in AI workloads risks outstripping these measures, intensifying pressure on already scarce water resources.

Planning policy – lack of National Policy Statement

With an estimated 100-200 proposed new data centres in the planning system already, and 140 seeking grid connections, it is crucial that the NPS is published as a matter of priority, and that it fully acknowledges and addresses the above challenges, to ensure that the public and the climate do not end up footing the environmental bill for these facilities.

At a minimum, the NPS must include:

1. A framework for the Government to consider the cumulative environmental impacts of the rollout of data centres, in order to meaningfully assess whether new ‘hyperscale’ data centres can be built and operate within existing carbon budgets and without exacerbating local water scarcity in the areas where they are constructed.
2. A requirement for any data centre developer to undertake a full Environmental Impact Assessment for their proposed facility – including, but not limited to:
1. Scope 1,2 and 3 climate emissions which will result from both the construction and operation of their facility, including the power used by its computing equipment and cooling mechanisms.
2. The volume of water that will be used by the construction and operation of their facility, including the use of water to cool computing equipment.
3. Any potential pollution of the air, ground or water as a result of back-up generation, chemicals used in the computing equipment or cooling mechanisms, or other activities.
3. A requirement for any data centre developer to demonstrate to the Secretary of State that its facility will not cause an increase in the UK’s overall climate emissions or local water scarcity. This will be achieved by:
1. Requiring any developer to build or directly fund the construction of new, renewable generation and storage capacity, and any necessary grid connections, to completely power their proposed facility at all times.
2. Requiring any developer to describe in detail the cooling mechanisms that will be used during the operational phase of the data centre, whether or not the developer will be responsible for its operation.
3. Measures to prevent the use of ‘greenwashing’[40] in claiming the data centre is carbon-neutral, for example through the purchase of renewable energy certificates or the use of power purchase agreements which do not result in the construction of additional generating capacity. Every hour of usage in the data centre must be matched with 100% new renewable energy that is generated locally and additive to the local grid.