Power: who pays, and who waits?

From the paper “Beyond Planning Permission”

The full text of the relevant sections of the paper, with its own numbered notes. Note numbers match the paper.

4. Electricity Demand and Energy Infrastructure

Electricity demand represents one of the most significant issues associated with modern data centres.

Official statistics indicate that data centres consumed approximately 4.5 TWh of electricity in Great Britain during 2024, equivalent to around 2% of total grid consumption.⁵⁵

The issue is not simply total demand but also geographical concentration. More than three quarters of national data-centre electricity consumption occurred in London and the South East.⁵⁶

Concentrated growth may require:

• substation expansion;
• transmission upgrades;
• distribution-network reinforcement;
• additional generating capacity.⁵⁷

Supporters regard such investment as part of the wider digital transformation of the economy.

Others question how increasingly energy-intensive infrastructure should be balanced against broader energy-transition and carbon-reduction objectives.^58,59

6. Carbon Emissions and Climate Change

Assessment of climate impacts should extend beyond operational electricity use.

A comprehensive appraisal should consider:

• Direct emissions, including:
• backup generators,
• fuel combustion and
• refrigerant leakage.
• Indirect emissions including:
• imported electricity and
• cooling-system energy requirements.
• Embodied emissions including emissions associated with:
• steel,
• concrete,
• batteries,
• servers,
• network infrastructure and
• construction activity.

Whole-life assessment has become increasingly important because embodied carbon may represent a significant proportion of total lifecycle impacts.

Climate resilience also requires attention.

Facilities expected to operate for decades must function under future conditions that may involve increased temperatures, more frequent heatwaves, droughts and severe weather events.^84,85,86

As with water consumption, the picture on carbon emissions is clouded by significant gaps in what is measured and reported. Despite data centres being identified as one of the fastest-growing sources of UK electricity demand, they were not separately disaggregated in the Government's official projections underpinning the Seventh Carbon Budget, the statutory emissions pathway to 2040.⁸⁷

In February 2026, the Secretary of State for Energy Security and Net Zero, Ed Miliband, acknowledged in correspondence with the Environmental Audit Committee that future electricity demand from data centres ‘remains inherently uncertain’, prompting the Committee to launch a dedicated inquiry into the sector's sustainability, including whether existing carbon-budgeting and planning policy adequately account for AI-driven demand growth.⁸⁸

Rhetorically the author might ask, why is this “inherently uncertain” if there is transparency of information from the Industry?

This uncertainty is not confined to the Climate Change Committee's modelling. In answer to a written parliamentary question in April 2026, the Government confirmed that it does not disaggregate specific estimates for data-centre electricity demand within its wider projections, relying instead on the Clean Power 2030 Action Plan and the Capacity Market to balance overall supply and demand.⁸⁹

In other words, the same absence of dedicated, mandatory reporting identified above in relation to water consumption applies with equal force to carbon. Government policy is, on its own admission, being made without a clear picture of the demand it is trying to manage.

Backup and standby generation compounds the difficulty. Many large facilities maintain extensive diesel or gas generator capacity to protect against grid outages. As with water storage and abstraction, there is no comprehensive, published national record of how often these generators run, for how long, or what they emit in aggregate, whether during routine testing or at times of grid stress when their use - and their emissions - would be highest.⁹⁰

Embodied emissions from construction, servers and network hardware raise a parallel concern. Whole-life carbon assessments depend on manufacturers' and developers' own disclosures, which are neither independently verified nor consistently reported across the sector.

As with water, this is not necessarily evidence that data-centre carbon impacts are being concealed.

It is evidence that neither government nor the public currently has the data needed to state with confidence what those impacts are, now or as AI-driven demand grows.

Until reporting is put on a mandatory and independently verifiable footing, planning authorities, the Climate Change Committee and Parliament itself are being asked to take reassurances on trust rather than on evidence - precisely the situation in which, as discussed in Section 17 below, a precautionary approach is warranted.

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

Some developers have explored direct relationships between data centres and Energy-from-Waste (EfW) facilities.

Such arrangements may provide reliable electricity supplies and potentially reduce transmission losses.⁹¹

However, EfW remains controversial within environmental policy. Debate continues regarding carbon emissions, air quality and compatibility with wider recycling objectives.⁹²

The appropriate question is therefore not whether EfW is inherently beneficial or harmful, but whether environmental impacts have been transparently assessed and compared with realistic alternatives.

Waste heat: a resource the planning system has not yet asked about

Almost all of the electricity used by a data centre's computing equipment ends up as heat, which its cooling systems then reject to the air or to water.

That is a matter of basic physics rather than a finding of any source cited here, and it means that a facility drawing 150 MW is, in effect, a continuous source of low-grade heat of broadly that order.

Whether that heat is wasted or put to use is decided largely by where a facility is sited and how it is laid out - in other words, at the planning stage, before the design is fixed.

The point is not new. For combustion and energy-from-waste power plants, Natural Resources Wales has since 2014 expected applicants to show that plants are 'CHP-Ready', able to supply heat in future, observing that 'to be commercially viable for CHP, new plants should ideally be sited close to potential heat loads'.⁹³

Experience in Cardiff shows what retrofitting involves: the Cardiff Heat Network, which takes heat from Viridor's Trident Park energy recovery facility, was costed at £26.5 million, with a £6 million UK Government grant and an £8.6 million Welsh Government loan, and delivered its first heat in November 2025.⁹⁴ The Welsh Government's Heat Strategy for Wales (2024) cites the Cardiff network as an example of using waste heat; this appraisal has found no reference in it to data centres.⁹⁵

The legal framework in England and Wales is narrower than is sometimes assumed.

Schedule 24 to the Environmental Permitting (England and Wales) Regulations 2016, which carries forward requirements of the Energy Efficiency Directive, requires an application for an environmental permit for certain installations with a net rated thermal input exceeding 20 MW to include a cost-benefit analysis of 'utilising the waste heat to satisfy economically justified demand, including through cogeneration' and of 'the connection of that installation to a district heating and cooling network'.⁹⁶

Data centres come within environmental permitting mainly because of their standby generators: the Environment Agency, for example, permits large sites as combustion installations, with emergency operation limited by condition to 500 hours a year.⁹⁷ Standby and peak-load plant of that kind is largely outside the cost-benefit requirement, and this appraisal has found no example of the analysis being required for the heat produced by the computing equipment itself, which is not in itself a permitted activity.

The position may be different where a site will depend, possibly for years, on continuously running on-site generation while it waits for a grid connection, as the Cardiff East proposal described below may. Whether Schedule 24 then applies, and to what, is a question this appraisal would put to Natural Resources Wales rather than answer. It is the author's own reading of the Regulations, not an established interpretation.

Elsewhere the obligation is direct.

Under the recast EU Energy Efficiency Directive, data centres with a total rated energy input above 1 MW must use their waste heat, or other waste-heat recovery applications, unless they can show that this is not technically or economically feasible.⁹⁸

Germany's Energy Efficiency Act goes further, requiring new data centres to plan for at least 15% reused waste heat from July 2026, rising to 20% from July 2028.⁹⁹

In England, the Government confirmed in January 2026 that, under heat network zoning, a zone coordination body will be able as a backstop to require a heat source within or around a zone 'to provide heat where connection is viable'. Heat network zoning applies to England only.¹⁰⁰

This appraisal has not identified any equivalent requirement in Wales, or any reference to data-centre waste heat in Welsh or UK planning policy on data centres.

Food security, glasshouses and water reuse

The United Kingdom produces about 62% of the food it consumes, 53% of its fresh vegetables and only 16% of its fresh fruit, and the Government's own food security report records that several major supplying countries, including Spain, face increasing drought and heat stress.¹⁰¹

The Welsh Government said in December 2024 that 'there is a need now to cultivate more fruit and vegetables in Wales', including 'protected cultivation crops in glasshouses and polytunnels', and that more horticulture could strengthen 'system resilience and food security'.¹⁰²

Low-grade heat is what glasshouses need through the colder months. Proposals to pair the two already exist in the United Kingdom: the Humber Tech Park scheme in North Lincolnshire, a proposed 386 MW data-centre campus, included a greenhouse of some 300,000 square feet for growing tomatoes with captured waste heat.¹⁰³

This appraisal has not established whether that scheme has been consented or built. In the author's view - an inference, not a finding of any source - co-locating large data centres with commercial-scale glasshouses or district heat networks is one of the few ways in which a data centre's physical footprint could make a direct and lasting contribution to the community and the food system around it, and whether it has been considered should be asked of every large proposal before its site and layout are fixed.

Water offers a parallel opportunity, to be approached with more caution. Facilities using evaporative cooling discharge 'blowdown' water in which minerals and treatment chemicals become concentrated; a 2025 review concluded that such water 'can be effectively recycled', but only with specialised treatment.¹⁰⁴

Reusing treated discharges or harvested rainwater for irrigation could reduce competition with farming for water in a drought, but would first need to be shown to be safe, including in respect of any PFAS used on site (see Section 8). Air-cooled designs, such as the Cardiff East proposal below, use little process water but must dispose of more heat to the air, which strengthens the case for asking what is done with that heat. The figures can also change after an application is made: later documents for Cardiff East describe a closed-loop system, with the final choice still open, and seek an allowance of up to 300 cubic metres of water a day.¹⁰⁵

Case study: Cardiff East Park and Ride

The proposal for a data centre at the Cardiff East Park and Ride site at Pentwyn, on land owned by Cardiff Council, illustrates these points.¹⁰⁶

A report to the Council’s Cabinet in May 2021 records that the land was marketed for a logistics centre with ancillary retail, keeping the Park and Ride; that the preferred developer, Curtis Hall, is to deliver a new bridge and road link into Llanrumney in lieu of a land receipt; and that completion of the sale is subject to planning.¹⁰⁷ The Council is therefore both the planning authority and a landowner whose sale depends on permission being granted. The Wales EIA Regulations require it to perform its duties objectively and so as to avoid a conflict of interest.¹⁰⁸

The hybrid application (reference 26/00109/HYB), submitted in January 2026, seeks permission for data-centre buildings with a capacity of 150 MW and an 'ancillary energy centre (maximum 47 MW capacity)', described as a temporary energy centre needed because 'a connection to the grid may not be possible until after the data centres have been constructed and brought into use'. As first submitted, cooling was to be by air handling units using external air. The applicant's Planning Statement relies on the Welsh Government's AI Plan for Wales and on UK Government support for data centres, but contains no discussion of using the development's waste heat or of a heat network.¹⁰⁹

The Planning Statement also records that formal scoping for the Environmental Statement 'has not been repeated, given the similarities between the schemes', and that the Environmental Statement prepared for an earlier permission for commercial units on the site has been 'suitably updated'; it says this approach was agreed with the Council.

Noise is treated as a non-EIA matter on the basis that this was 'agreed with the Council during the initial EIA scoping', although the scheme now includes back-up generators and a possible temporary energy centre.¹¹⁰

The scoping opinion on which the assessment therefore rests (reference SC/21/00018/MJR, issued in 2022) was given for a 'commercial development'. It agreed that 'Energy and Sustainability' could be scoped out, while adding that the assessment 'should also consider if a local heat network is feasible'. It asked for greenhouse gas emissions to be scoped in; and it reminded the applicant that an environmental statement must estimate emissions including 'heat'.¹¹¹ The screening opinion (reference SC/21/00006/MJR) is recorded only by reference in these documents, and the two documents give different dates for it; the author has not yet located it on the public file.

In the author's view - an inference, and not a finding of any public body - a 150 MW data centre with on-site generation is a materially different development from the commercial units for which the scope of assessment was settled in 2022, particularly as regards energy demand, heat, generator noise and emissions, and the case for fresh scoping was strong.

Whether the Environmental Statement deals adequately with those matters is now also a question for Welsh Ministers, who in September 2026 issued a holding direction preventing the Council from granting permission while they decide whether to determine the application themselves,¹¹² and potentially for Natural Resources Wales if on-site generation requires an environmental permit.

Since the application was made, later documents on the register have changed its description. The energy centre, put at 47 MW in the application, had by October 2026 become seven gas turbines on ‘duty/standby’ feeding a steam turbine, with controls to keep output below 49.9 MW, just under the 50 MW point at which the Welsh Ministers, not the Council, decide. The cooling system has changed, and the air quality conclusion on generator testing has moved from ‘significant’ to not significant. The public has been invited to comment four times, each time on part of the material.¹¹³ A fuller account, with sources, is in the case study on the website for this paper, and the author and Max Wallis have made representations to the Council.¹¹⁴

The author might put the following questions in writing to Cardiff Council, as local planning authority (Head of Planning) (although they may be better sent by a local resident):

'In relation to application 26/00109/HYB:

• why was a new scoping opinion not required, when the 2022 scoping opinion (SC/21/00018/MJR) was given for commercial units rather than a 150 MW data centre with a 47 MW energy centre;
• does the Environmental Statement quantify the waste heat the development would produce and assess the feasibility of using it, as the 2022 opinion asked in respect of a local heat network;
• will the Council publish screening opinion SC/21/00006/MJR; and
• do the Heads of Terms agreed with Curtis Hall for the sale of the site allow a data centre and gas-fired energy centre, when the land was marketed for a logistics centre, and what arrangements has the Council made to keep its interest as landowner separate from its role as planning authority?'

A request via WhatDoTheyKnow for the correspondence in which it was agreed that scoping need not be repeated, for the screening opinion, and for the Heads of Terms (which the Council may withhold as commercially confidential), could follow.

To Natural Resources Wales:

'Will the temporary energy centre of up to 47 MW and the standby generators proposed at Cardiff East require an environmental permit; if so,

• will the application have to include the cost-benefit analysis required by Schedule 24 to the Environmental Permitting (England and Wales) Regulations 2016;
• does Natural Resources Wales consider that the analysis can extend to the heat produced by the data-centre equipment; and
• has it advised, or will it advise, Welsh Ministers on these matters?'

A request via WhatDoTheyKnow for any pre-application or permitting correspondence on the site could be a natural follow-up.

To the Welsh Government Cabinet Secretary responsible for planning:

'Will the Welsh Government

• require proposals for large data centres to show how their waste heat will be used, or why it cannot be, as it expects of combustion and energy-from-waste plant;
• will it consider co-location of data centres with heat networks or commercial glasshouses as part of its horticulture and food-security policy; and
• will it take these matters into account in deciding whether to determine the Cardiff East application itself?'

A request via WhatDoTheyKnow for any advice to Ministers on data-centre waste heat could follow once a reply is received.

And to the Vale of Glamorgan Council, as local planning authority, and the Welsh Government, as landowner at Bro Tathan: 'For any further data-centre development at Bro Tathan,

• will any screening or scoping opinion require an assessment of the quantity of waste heat produced and the feasibility of using it, including for heat networks or horticulture, and
• of the reuse of any process water?'

A request via WhatDoTheyKnow for any screening or scoping opinions already issued for data-centre development at Bro Tathan would establish the current position.

Notes from the paper

1. 55. 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
2. 56. 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
3. 57. 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
4. 58. 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/
5. 59. 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/
6. 84. 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
7. 85. 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/
8. 86. 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/
9. 87. House of Commons Environmental Audit Committee, written evidence: data centres and the Seventh Carbon Budget (2026), noting the omission of disaggregated data-centre demand from the Climate Change Committee's carbon budget projections. https://committees.parliament.uk/writtenevidence/151599/html/
10. 88. House of Commons Environmental Audit Committee, MPs to Examine Data Centres' Climate Impact as Miliband Says Future Demand 'Inherently Uncertain' (February 2026). https://committees.parliament.uk/committee/62/environmental-audit-committee/news/212132/mps-to-examine-data-centres-climate-impact-as-miliband-says-future-demand-inherently-uncertain/
11. 89. UK Parliament, Written Question 127433, Dame Chi Onwurah to the Secretary of State for Energy Security and Net Zero, answered by Michael Shanks MP (24 April 2026). https://questions-statements.parliament.uk/written-questions/detail/2026-04-15/127433
12. 90. Browne Jacobson, NPPF 2026 Amendments: Data Centres and On-Site Energy Generation (2026). https://www.brownejacobson.com/insights/nppf-2026-amendments-browne-jacobson-response/data-centres-and-on-site-energy-generation
13. 91. House of Commons Library, Incineration of Waste in England, Research Briefing CBP-10229 (April 2025). https://commonslibrary.parliament.uk/research-briefings/cbp-10229/
14. 92. Ibid.
15. 93. Natural Resources Wales, 'CHP-Ready Guidance for Combustion and Energy from Waste Power Plants' (version 2, September 2014). https://naturalresourceswales.gov.uk/media/2100/chp-ready-guidance-for-combustion-and-energy-from-waste-power-plants.pdf
16. 94. Resource, '£15m funding approved for Cardiff district heat network' (14 August 2020); Business News Wales, 'Cardiff Heat Network delivers first low carbon heat' (November 2025). https://www.resourcemedia.eco/article/15m-funding-approved-cardiff-district-heat-network https://businessnewswales.com/cardiff-heat-network-delivers-first-low-carbon-heat/
17. 95. Welsh Government, 'Heat Strategy for Wales' (July 2024). https://www.gov.wales/sites/default/files/publications/2024-07/heat-strategy-wales.pdf
18. 96. Environmental Permitting (England and Wales) Regulations 2016 (SI 2016/1154), Schedule 24, 'Efficiency in heating and cooling energy: Energy Efficiency Directive', paragraphs 1 to 3. https://www.legislation.gov.uk/uksi/2016/1154/schedule/24
19. 97. Environment Agency, decision document for a bespoke permit for standby electricity generating combustion plant at a data centre site operated by Amazon Data Services UK Limited (29 January 2026). https://assets.publishing.service.gov.uk/media/69846ade468d351e1406b4b8/Application_Bespoke_A001_Decision_Document_-_29012026.pdf
20. 98. Directive (EU) 2023/1791 on energy efficiency (recast), Article 26(6); for a summary, see Covington & Burling, 'The EU's Energy Efficiency Directive and its impact on datacenters' (2025). https://eur-lex.europa.eu/eli/dir/2023/1791/oj/eng https://www.cov.com/-/media/files/corporate/publications/2025/04/the-eus-energy-efficiency-directive-and-its-impact-on-datacenters.pdf
21. 99. Kristin Weiß, 'From EU Framework to National Action: How Germany Regulates Data Center Energy Use', Sabin Center for Climate Change Law, Columbia Law School (24 October 2025), on section 11 of the Energy Efficiency Act (EnEfG). https://blogs.law.columbia.edu/climatechange/2025/10/24/from-eu-framework-to-national-action-how-germany-regulates-data-center-energy-use/
22. 100. Department for Energy Security and Net Zero, 'Heat network zoning consultation 2023: summary of government response' (21 January 2026). https://www.gov.uk/government/consultations/proposals-for-heat-network-zoning-2023/outcome/heat-network-zoning-consultation-2023-summary-of-government-response
23. 101. Department for Environment, Food and Rural Affairs, 'United Kingdom Food Security Report 2024: Theme 2: UK Food Supply Sources' (11 December 2024). https://www.gov.uk/government/statistics/united-kingdom-food-security-report-2024/united-kingdom-food-security-report-2024-theme-2-uk-food-supply-sources
24. 102. Welsh Government, 'Written Statement: Horticulture policy development in Wales' (18 December 2024). https://www.gov.wales/written-statement-horticulture-policy-development-wales
25. 103. DatacenterDynamics, report on the Humber Tech Park planning application, North Lincolnshire (18 May 2024). https://www.datacenterdynamics.com/en/news/humber-tech-park-lincolnshire-uk-district-heating/
26. 104. S T Ahmad and others, 'Recovery and treatment of cooling tower blowdown water: challenges, recent advancement, and future perspectives', Journal of Environmental Chemical Engineering (2025). https://doi.org/10.1016/j.jece.2025.115399
27. 105. Water Usage Datasheet for application 26/00109/HYB, published on the Cardiff Council planning register on 6 October 2026. https://www.cardiffidoxcloud.wales/publicaccess/files/0B1B9164A37A106ADEC41E1D472E8976/pdf/26_00109_HYB-WATER_USAGE_DATASHEET-6465333.pdf
28. 106. Nation.Cymru, 'Data centre plans put on hold as ministers intervene' (4 September 2026), Local Democracy Reporting Service. https://nation.cymru/news/data-centre-plans-put-on-hold-as-ministers-intervene/
29. 107. Cardiff Council, Cabinet, 20 May 2021, agenda item 9, ‘Llanrumney Regeneration Scheme – Statutory Public Consultation and Land Disposal Update’, paragraphs 6, 7 and 24 to 27 (public reports pack, pages 359 to 363). https://cardiff.moderngov.co.uk/documents/g4316/Public%20reports%20pack%2020th-May-2021%2014.00%20Cabinet.pdf?T=10&LLL=0
30. 108. Town and Country Planning (Environmental Impact Assessment) (Wales) Regulations 2017, regulation 58. https://www.legislation.gov.uk/wsi/2017/567/regulation/58
31. 109. Iceni Projects for Curtis Hall Limited, 'Planning Statement: Cardiff Park and Ride East, Pentwyn' (January 2026), paragraphs 2.6, 2.12, 4.22-4.24, 5.6-5.8, 6.36-6.44 and 6.85, application 26/00109/HYB, Cardiff Council planning register. https://www.cardiffidoxcloud.wales/publicaccess/applicationDetails.do?keyVal=T8YL3PECJ8T00&activeTab=summary
32. 110. Iceni Projects for Curtis Hall Limited, 'Planning Statement: Cardiff Park and Ride East, Pentwyn' (January 2026), paragraphs 2.6, 2.12, 4.22-4.24, 5.6-5.8, 6.36-6.44 and 6.85, application 26/00109/HYB, Cardiff Council planning register. https://www.cardiffidoxcloud.wales/publicaccess/applicationDetails.do?keyVal=T8YL3PECJ8T00&activeTab=summary
33. 111. Cardiff Council, Screening and Scoping Opinion, reference SC/21/00018/MJR, Cardiff East Park and Ride (2022), reproduced as Environmental Statement Volume II, Appendix 1.2, application 26/00109/HYB. https://www.cardiffidoxcloud.wales/publicaccess/applicationDetails.do?keyVal=T8YL3PECJ8T00&activeTab=documents
34. 112. Nation.Cymru, 'Data centre plans put on hold as ministers intervene' (4 September 2026), Local Democracy Reporting Service. https://nation.cymru/news/data-centre-plans-put-on-hold-as-ministers-intervene/
35. 113. Cardiff Council planning register, application 26/00109/HYB, documents tab (including the Technical Note (Air Quality), combined reports, 6 October 2026, at https://www.cardiffidoxcloud.wales/publicaccess/applicationDetails.do?activeTab=documents&keyVal=T8YL3PECJ8T00 https://www.cardiffidoxcloud.wales/publicaccess/files/54C572792D4179F901419D580EE3D9FC/pdf/26_00109_HYB-TECHNICAL_NOTE__AIR_QUALITY__-_COMBINED_REPORTS-6465338.pdf):
36. 114. Questions Before Concrete, ‘Case study: Cardiff East’, representations by Dennis Clarke and Max Wallis. https://environment.cymru/papers/cardiff-east-data-centre-representations-clarke-wallis.pdf https://environment.cymru/case-cardiff-east.html