Technical Insight 1 June 2025

Flood Risk for Data Centres in Scotland

Scotland's data centre sector is expanding rapidly. Understanding NPF4 essential infrastructure flood risk requirements is critical for data centre developers.

By Douglas Swinbanks

Scotland’s data centre sector is experiencing rapid expansion, driven by demand for cloud computing, artificial intelligence, and digital infrastructure. The nation’s cooler climate, renewable energy resources, and improved connectivity make it attractive for large-scale digital facilities.

What is a Data Centre?

A data centre is a specialized facility housing computer systems, servers, and networking equipment for storing, processing, and distributing digital data.

According to DataCentreNews in January, £25 billion has been pledged by data centre firms and infrastructure investors over the next three to five years for UK facilities.

In June 2025, Apatura filed a planning application for a 550 MW data centre campus with integrated battery energy storage at the former Ravenscraig Steelworks in Motherwell, North Lanarkshire. The £3.9 billion project is expected to be operational by 2030.

Why Data Centre Developers Choose Scotland

Renewable Energy: The Scottish Government notes that “data centres consume substantial energy, but Scotland has significant renewable generation capacity,” positioning the country as a green data centre leader. In 2022, renewables generated 113% of Scotland’s electricity consumption.

Cooler Climate: Lower ambient temperatures reduce mechanical cooling requirements, improving energy efficiency and operational costs.

Reduced Costs: Scotland offers up to 70% reduced operational costs versus other markets, with land costs up to 90% less than Slough and greater London.

Government Support: The Scottish Government’s Green Datacentres and Digital Connectivity Vision and Action Plan (2021) outlines strategies to attract hyperscale and edge data centres through renewable energy support, fibre deployment, and site promotion.

Critical National Infrastructure (CNI)

On 12 September 2024, the UK Government formally classified all data centres — physical and cloud-based — as Critical National Infrastructure for the first time since 2015. This designation means they are essential to national security, required to maintain continuous operations during emergencies, and subject to heightened regulatory oversight and flood risk protection.

Flood Risk Considerations for Development

NPF4 Policy for Data Centres

National Planning Framework 4 Policy 22 permits development in flood risk areas when proposals are for “essential infrastructure where the location is required for operational reasons.”

Data centres qualify as Essential Infrastructure under SEPA’s Land Use Vulnerability Guidance and NPF4 glossary, permitting location in Flood Risk Areas subject to key conditions:

  • All flooding risks are identified and addressed
  • No reduction in floodplain capacity or increased downstream risk
  • Development remains safe and operational during floods
  • Flood-resistant materials and construction methods are employed
  • Future climate change adaptations are accommodated

Understanding All Flood Risks

Planning applications require Flood Risk Assessments examining fluvial, pluvial, coastal, groundwater, reservoir and sewer flooding. Detailed Flood Risk Assessments with hydraulic modelling are likely required if development falls within the Flood Risk Area.

Floodplain Capacity and Downstream Risk

Downstream flood risk must not increase following construction. Data centres qualify for mitigation under NPF4 Policy 22a, including compensatory storage per SEPA’s Technical Flood Risk Guidance and elevated building techniques per SEPA’s 2025 Position Statement on Elevated Buildings.

Operational Safety During Flooding

Understanding operational cycles is essential — including whether facilities will be staffed during floods and whether safe dry access and egress are available during design storms. A flood management plan is recommended best practice.

Climate Change Adaptation

Climate change must be incorporated in detailed assessments using SEPA’s Climate Change Allowances for Flood Risk Assessment, with uplifts applied to fluvial, pluvial, and coastal sources.

Scotlanddata centresessential infrastructureNPF4flood risk assessment
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