Questions Before ConcreteData centres in England and Wales
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Every source cited in the paper, grouped by the section in which it first appears, with links so you can check them yourself.

Abstract

Executive Summary

2. Planning Policy in England and Wales

3. The Economic Case

5. Water Use and Cooling Technologies

6. Carbon Emissions and Climate Change

7. Energy-from-Waste and Incinerator-Related Power

8. Local Environmental Effects

  • 3M, '3M to Exit PFAS Manufacturing by the End of 2025' (20 December 2022), announcing the phase-out of all per- and polyfluoroalkyl substance (PFAS) manufacturing, including the Novec and Fluorinert product lines used as two-phase immersion-cooling fluids in some data centres. https://news.3m.com/2022-12-20-3M-to-Exit-PFAS-Manufacturing-by-the-End-of-2025
  • Damien Gayle, "'Tidal wave' of Pfas being launched to satisfy AI industry, campaigners warn", the Guardian (14 September 2026), reporting a survey by the Swedish chemicals watchdog ChemSec of the world's ten biggest PFAS manufacturers, which found that nine plan to increase production, several citing demand from AI data-centre cooling and semiconductor manufacture specifically; only Archroma and BASF (by 2028) were reported as moving away from PFAS. This appraisal has not independently located ChemSec's own underlying report or survey methodology, and relies here on the Guardian's reporting of it. https://www.theguardian.com/environment/2026/sep/14/pfas-firms-tidal-wave-forever-chemicals-ai-industry-demand-datacentres
  • Submer, 'PFAS Contamination: A Call to Action for the Datacenter Industry' (2026), describing PFAS as the chemical basis of two-phase immersion-cooling fluids and cautioning that, following bans on some PFAS formulations, manufacturers have in some cases reformulated products that remain PFAS under the broad definition while being marketed as 'green' alternatives. https://submer.com/blog/pfas-contamination-a-call-to-action-for-the-datacenter-industry/
  • Organisation for Economic Co-operation and Development, 'Reconciling Terminology of the Universe of Per- and Polyfluoroalkyl Substances' (2021), setting out the broad structural definition of PFAS now generally used in UK and EU regulatory practice. https://www.oecd.org/en/publications/reconciling-terminology-of-the-universe-of-per-and-polyfluoroalkyl-substances_e458e796-en.html
  • NFPA 2001, Standard on Clean Agent Fire Extinguishing Systems, is the industry standard governing clean-agent gases such as FM-200 (HFC-227ea) and Novec 1230 (FK-5-1-12), chosen for data-centre use because they are non-conductive and leave no residue on electronic equipment; under the broad OECD definition of PFAS referred to above, these clean agents themselves fall within the PFAS family, distinct from the aqueous film-forming foam (AFFF) more commonly associated with contamination at airports and military sites. https://www.nfpa.org/product/nfpa-2001-standard/p2001code/nfpa-2001-standard-on-clean-agent-fire-extinguishing-systems-2015/200115
  • ZVEI (German Electro and Digital Industry Association), 'PFAS and Semiconductors' factsheet, describing PFAS use in semiconductor photolithography (as photoresist surfactants and photoacid generators) and in plasma etching (fluorine-based gases used to structure silicon, dielectric and metal layers), and noting that no drop-in substitute currently exists for most such uses. https://www.zvei.org/fileadmin/user_upload/Themen/Nachhaltigkeit_Umwelt/PFAS/2-ZVEI-Factsheet-_PFAS_and_Semiconductors_-final.pdf
  • Chemistry World, 'Water regulator applies stricter PFAS limits to drinking water in England and Wales' (2024), reporting the Drinking Water Inspectorate's guidance, expected to take effect from January 2025, introducing a cumulative limit of 100 nanograms per litre across 48 individual PFAS substances for England and Wales - guidance rather than a statutory duty, in contrast to Scotland's statutory limit for 20 named PFAS substances since January 2023. https://www.chemistryworld.com/news/water-regulator-applies-stricter-pfas-limits-to-drinking-water-in-england-and-wales/4020476.article
  • Directive (EU) 2020/2184 on the quality of water intended for human consumption (the revised Drinking Water Directive) sets a total-PFAS limit of 0.5 micrograms per litre, which took effect across EU member states from 12 January 2026; the UK, no longer bound by EU directives following its withdrawal from the European Union, instead relies on the non-statutory Drinking Water Inspectorate guidance for England and Wales referred to above. https://environment.ec.europa.eu/news/new-eu-rules-limit-pfas-drinking-water-2026-01-12_en
  • US Environmental Protection Agency, National Primary Drinking Water Regulation for PFAS (final rule, April 2024), setting enforceable limits of 4.0 parts per trillion for PFOA and PFOS, with public water systems given until 2029 to comply; the EPA's own 'Proposed PFAS Rescission Rule' and a related proposal to extend the PFOA/PFOS compliance deadline, both published in 2026, illustrate that this regulatory position remains contested and unsettled even in the jurisdiction that has gone furthest toward statutory limits, and are cited here as international regulatory context rather than as a statement of UK law. https://www.epa.gov/sdwa/and-polyfluoroalkyl-substances-pfas
  • Department for Environment, Food and Rural Affairs, 'PFAS Plan' (published 3 February 2026, updated 17 August 2026), the UK Government's first dedicated PFAS strategy, adopting the broad OECD definition of PFAS and committing to a 2026 consultation on introducing a statutory drinking-water limit and to aligning with EU REACH restrictions 'by December 2028'. https://www.gov.uk/government/publications/pfas-plan
  • Health and Safety Executive, UK REACH consultations on 'PFAS in Firefighting Foam': an initial consultation on the risk-assessment case opened in August 2025, and a further consultation on the socio-economic case opened 9 July 2026 and closed 7 September 2026, with HSE's opinion on the risk assessment already published ahead of that second-stage consultation; a government decision on any restriction is still awaited. https://consultations.hse.gov.uk/crd-reach/uk-reach-restriction-on-pfas-in-firefighting-foam/
  • US Government Accountability Office, GAO-25-107401, 'Persistent Chemicals: DOD Needs to Provide Congress More Information on Costs Associated with Addressing PFAS' (reissued with revisions, February 2025), reporting that the Department of Defense's own estimate of its future PFAS-specific investigation and cleanup costs had risen to more than $9.3 billion for fiscal year 2025 and beyond, more than tripling since 2022; cited here purely as an illustrative order-of-magnitude comparator for the scale and volatility of PFAS-specific liability once quantified, and not as a claim that any equivalent liability has arisen, or is expected to arise, from UK or Welsh data-centre development, for which this appraisal has identified no comparable costed assessment. https://www.gao.gov/products/gao-25-107401
  • Natural Resources Wales, State of Natural Resources Report 2025, Pollution chapter, which identifies 'PFAS, veterinary medicines and other pharmaceuticals' as contaminants of concern in Welsh waters generally but does not address data centres as a source, and does not otherwise engage with PFAS in the context of data-centre construction, operation or decommissioning; this appraisal has not identified any other published Natural Resources Wales guidance, assessment or monitoring programme that does so, which it treats as a genuine and citable gap in Welsh environmental regulatory coverage rather than as an oversight necessarily attributable to Natural Resources Wales itself, whose statutory remit and resources are matters beyond this appraisal's scope. https://naturalresources.wales/evidence-and-data/research-and-reports/state-of-natural-resources-report-2025/pollution/?lang=en
  • North Carolina Department of Environmental Quality, GenX Investigation: Groundwater, documenting PFAS/GenX contamination of industrial and residential groundwater wells near Chemours's Fayetteville Works manufacturing facility, first identified in 2017 and the subject of a February 2019 Consent Order; this is a well-documented example of PFAS harm linked to chemical manufacturing, not to a data centre, and this appraisal has not identified any confirmed instance, in the United Kingdom or elsewhere, of environmental contamination traced to a data centre specifically. Chemours agreed a further $450 million settlement covering Fayetteville Works and three other US sites in June 2026, illustrating that liability from PFAS-manufacturing contamination remains an active and growing matter even for a case dating to 2017. https://www.deq.nc.gov/news/key-issues/genx-investigation/groundwater
  • Reporting has begun explicitly connecting the AI data-centre boom to PFAS use, including Jessica Corbett, 'Research Warns of Surge in Cancer-Causing Forever Chemicals From AI Data Center Build-Out', Common Dreams (14 September 2026), and Food & Water Watch, 'Toxic Mixture: Data Centers Turn to PFAS For Cooling' (July 2026). This appraisal has not identified equivalent UK-specific reporting or research making the same connection for data centres in England or Wales, which this appraisal treats as an emerging area of scrutiny elsewhere rather than as a topic yet addressed by UK press, regulators or campaigners in relation to domestic sites. https://www.commondreams.org/news/data-centers-and-pfas
  • New Jersey Office of the Attorney General, 'Federal Court Approves Historic PFAS Settlements Valued at Approximately $2.5 Billion' (press release, 8 August 2026); see also the joint New Jersey Department of Environmental Protection news release of the same date, and reporting in the Philadelphia Inquirer, 'Federal court approves settlements that will pay New Jersey $2.5 billion for PFAS contamination' (8 August 2026), from which the breakdown of payments between DuPont-related entities and 3M given in the text is drawn. https://www.njoag.gov/federal-court-approves-historic-pfas-settlements-valued-at-approximately-2-5-billion/

9. Digital Sovereignty, Jurisdiction and Public Trust

12. Public-Sector Data and National Sovereignty

13. Regulatory Stability and International Confidence

15. Regional Concentration and Proliferation Effects

16. Bro Tathan: Public Land, a US Operator and Unresolved Governance Questions

17. Artificial Intelligence: Warnings, Uncertainty and the Precautionary Principle