The full paper

Abstract

Data centres have become essential infrastructure for modern society, we are told.

They support cloud computing, financial services, telecommunications, healthcare, government administration, scientific research and artificial intelligence (AI). In September 2024, the UK Government designated data infrastructure as Critical National Infrastructure (CNI) in England, reflecting its growing importance to economic activity, public services and national resilience.^1,2

At the same time, the rapid expansion of data-centre development has prompted debate concerning electricity demand, water consumption, carbon emissions, land use, data governance, digital sovereignty and resilience. While many of these issues can be measured through technical analysis, others involve broader questions of public policy and governance.

This article proposes a framework for assessing major data-centre developments in England and Wales. It neither advocates unrestricted expansion nor opposes development in principle. Instead, it seeks to identify the principal environmental, technical, legal and societal considerations that should inform decision-making.

The document asks questions where no answers have been found. It is constructed on the Precautionary Principle.

Executive Summary

Data centres are the industrial infrastructure of the digital age. Every online search, streamed film, mobile phone transaction, cloud document, AI query and digital healthcare record depends upon them. Government policy increasingly recognises their importance to economic growth and national resilience.^3,4,5

However, data centres are not impact-free. Large facilities can require substantial supplies of electricity, may consume significant quantities of water, generate noise, create demands on infrastructure networks and raise questions concerning long-term control of information. Concerns have also emerged regarding concentration of infrastructure, resilience to future climate conditions and the growing importance of a relatively small number of global cloud-service providers.^6,7,8,9,10

Several further issues addressed later in this appraisal deserve particular attention:

• the uncertain long-term employment case for individual developments in an era of increasing automation;
• the governance questions raised when a public body simultaneously acts as landowner, promoter and regulator of major digital infrastructure;
• whether the international corporate groups operating these facilities pay a fair share of UK tax on the profits they generate;
• whether the very large sums of investment now being announced are realistically deliverable, and
• what happens to funding for necessary infrastructure upgrades if headline figures do not already include their cost; and
• the warnings some of those building the most advanced AI systems have themselves issued about the technology's risks, both from AI acting on its own initiative and from deliberate misuse by a person or group;
• the difficulty of detecting a hostile state developing dangerous AI capability, compared with the greater visibility of a nuclear weapons programme, and the possibility that a small, difficult-to-track team could achieve meaningful capability; and
• whether AI systems can be relied upon as more dependable tools than the conventional software that already, even from the most resourced developers, requires frequent urgent patching.
• whether the PFAS ('forever chemicals') used in some data-centre fire-suppression and cooling systems pose an environmental and decommissioning risk that has, on the evidence available, gone largely unaddressed by UK and Welsh regulators to date.

The key question is therefore not whether data centres should exist, but whether individual developments can demonstrate that environmental, social and governance issues have been appropriately addressed.

1. Introduction

Few forms of infrastructure have become as important to modern life as data centres, yet few remain as poorly understood outside specialist circles.

Historically, data centres were primarily associated with business computing and corporate record management. Today they underpin cloud computing, internet services, online retailing, financial transactions, telecommunications, scientific research and increasingly artificial intelligence. The UK Government has recognised this importance by designating data infrastructure as part of the nation's Critical National Infrastructure.^11,12

Demand for computing capacity is expected to increase significantly during the coming decade. Government analysis and Parliamentary scrutiny suggest substantial growth in UK data-centre requirements, particularly as AI technologies become more widely adopted.^13,14

The challenge is how to accommodate that growth while ensuring developments remain environmentally sustainable, socially acceptable and institutionally resilient.

If, when, decisions have to be taken to prioritise who receives electricity or water, are the datacentres prioritised over people. No doubt contracts exist that can be disclosed to set out what obligations have already been agreed.

Notes

1. 1. Department for Science, Innovation and Technology, Designation of UK Data Infrastructure as Critical National Infrastructure, Written Ministerial Statement HCWS89 (12 September 2024). https://questions-statements.parliament.uk/written-statements/detail/2024-09-12/HCWS89
2. 2. Department for Science, Innovation and Technology, Data Centres to be Given Massive Boost and Protections from Cyber Criminals and IT Blackouts (12 September 2024). https://www.gov.uk/government/news/data-centres-to-be-given-massive-boost-and-protections-from-cyber-criminals-and-it-blackouts
3. 3. Department for Science, Innovation and Technology, Designation of UK Data Infrastructure as Critical National Infrastructure, Written Ministerial Statement HCWS89 (12 September 2024). https://questions-statements.parliament.uk/written-statements/detail/2024-09-12/HCWS89
4. 4. Department for Science, Innovation and Technology, Data Centres to be Given Massive Boost and Protections from Cyber Criminals and IT Blackouts (12 September 2024). https://www.gov.uk/government/news/data-centres-to-be-given-massive-boost-and-protections-from-cyber-criminals-and-it-blackouts
5. 5. House of Commons Library, Data Centres: Planning Policy, Sustainability and Resilience, Research Briefing CBP-10315 (27 May 2026). https://commonslibrary.parliament.uk/research-briefings/cbp-10315/
6. 6. House of Commons Library, Data Centres: Planning Policy, Sustainability and Resilience, Research Briefing CBP-10315 (27 May 2026). https://commonslibrary.parliament.uk/research-briefings/cbp-10315/
7. 7. Department for Energy Security and Net Zero, Data Centre Electricity Consumption in Great Britain, 2020–2024 (Official Statistics in Development, June 2026). https://assets.publishing.service.gov.uk/media/6a3e9f25da47783d87723bf2/Data_centre_electricity_consumption_in_Great_Britain__2020_to_2024.pdf
8. 8. techUK, Understanding Data Centre Water Use in England (2025). https://www.techuk.org/resource/techuk-report-understanding-data-centre-water-use-in-england.html
9. 9. Water Research Centre (WRc), Data Centre Water Use Report (2026). https://h2oglobalnews.com/data-centre-water-use-report-england/
10. 10. House of Commons Environmental Audit Committee, Risks and Opportunities to the Sustainability of Data Centres in the UK (Inquiry, 2026). https://committees.parliament.uk/work/9651/risks-and-opportunities-to-the-sustainability-of-data-centres-in-the-uk/
11. 11. Department for Science, Innovation and Technology, Designation of UK Data Infrastructure as Critical National Infrastructure, Written Ministerial Statement HCWS89 (12 September 2024). https://questions-statements.parliament.uk/written-statements/detail/2024-09-12/HCWS89
12. 12. Department for Science, Innovation and Technology, Data Centres to be Given Massive Boost and Protections from Cyber Criminals and IT Blackouts (12 September 2024). https://www.gov.uk/government/news/data-centres-to-be-given-massive-boost-and-protections-from-cyber-criminals-and-it-blackouts
13. 13. House of Commons Library, Data Centres: Planning Policy, Sustainability and Resilience, Research Briefing CBP-10315 (27 May 2026). https://commonslibrary.parliament.uk/research-briefings/cbp-10315/
14. 14. House of Commons Environmental Audit Committee, Risks and Opportunities to the Sustainability of Data Centres in the UK (Inquiry, 2026). https://committees.parliament.uk/work/9651/risks-and-opportunities-to-the-sustainability-of-data-centres-in-the-uk/