COMHAIRLE CONTAE ÁTHA CLIATH THEAS
SOUTH DUBLIN COUNTY COUNCIL

MEETING OF DEVELOPMENT PLAN MEETING

Tuesday, March 01, 2022

MOTION NO.90

MOTION: Councillor M. Johansson

This motion relates to chapter 9 Economic Development & Employment, submission SD-C195-119 on page 829 of the CE report. To reject the CE recommendation of No change and ban data centres by moving Data Centre to Not Permitted under all zoning. Reason: It has become even more clear since the last Development Plan discussions that there is no more capacity for further data centres in the South Dublin area. EirGrid announced in December that it would not grant any further connections in the Dublin area until 2028. Since this coincides with dates of this plan it would be prudent to ban all new data centres for the duration of the plan.

REPORT:  

The motion seeks to reject the CE Recommendation of no change to existing policy and provisions of the Draft Plan and proposes a ban on data centres in the County by moving Data Centres use to the not permitted category under all zoning use classes. 

The Draft Plan, for the first time has included Data Centres as a specific land use type. This means that data centres are now included in every zoning objective matrix giving very clear guidance on where they are permitted, open for consideration or not permitted. There is no zoning where data centres are permitted in principle. They are open for consideration in employment zonings, that is in EE, REGEN and MRC zonings. They are not permitted in every other zoning type. 

The Council has monitored recent discussions in the Dáil and Seanad on Data Centres energy consumption, as well as reports from the Commission for the Regulation of Utilities (CRU) and EirGrid. As stated within Section 9.3 of the Draft Plan, it is acknowledged that Space Extensive Land Uses generally have a higher carbon footprint than other uses, whether because of transport related implications or their high energy demand. 

EDE7 Objective 2 contains strong policy and criteria which must be addressed by space extensive enterprises such as Data Centres. This policy has been prepared in consultation with Codema, Dublin’s energy agency, which aims to accelerate Dublin’s low-carbon transition. 

EDE7 Policy 

Recognise the need for land extensive uses and ensure that they are located 

within appropriate locations having regard to infrastructural, transport and 

environmental considerations and the need for orderly growth. 

 

EDE7 Objective 1: 

To ensure that, insofar as possible, space extensive enterprise is located on 

lands which are outside the M50 and which do not compromise labour 

intensive opportunity on zoned lands adjacent to public transport. 

 

EDE7 Objective 2 (as amended by CE Recommendation in bold) 

To require that space extensive enterprises demonstrate the following: 

• The appropriateness of the site for the proposed use having regard to EDE7Objective 1; 
• Strong energy efficiency measures to reduce their carbon footprint in support of national targets towards a net zero carbon economy, including renewable energy generation; 
• Maximise on site renewable energy generation to ensure as far as possible 100% powered by renewable energy, where on site demand cannot be met in this way, provide evidence of engagement with power purchase agreements in Ireland (PPA); 
• Sufficient capacity within the relevant water, wastewater and electricity network to accommodate the use proposed; 
• Measures to support the just transition to a circular economy; 
• Measures to facilitate district heating or heat networks where excess heat is produced; 
• A high-quality design approach to buildings which reduces the massing and visual impact; 
• A comprehensive understanding of employment once operational; 
• A comprehensive understanding of levels of traffic to and from the site at construction and operation stage; 
• Provide evidence of sign up to the Climate Neutral Data Centre Pact.’ 

The recommendation made in the CE Report on the Draft Plan consultation amends EDE7 Objective 2 to include that sufficient capacity is demonstrated in the electricity network by a prospective developer and to ensure that power purchase agreements are those made in Ireland. This amendment has not been subject to a motion. 

It is noted that the addition made to EDE7 Objective policy as set out above accords with the recent Policy Statement of Security of Electricity Supply issues by the government in November 2021 and which requires large energy users proposing to connect to the electricity grid to take into account the potential impact on security of electricity supply and on the need to decarbonise the electricity grid. 

Also, in November 2021 in conjunction with the above the Commission for the Regulation of Utilities issued a direction to the System Operators related to Data Centre grid connection. The direction provides criteria to EirGrid, ESB networks and other service providers on how to assess new applications for a connection to their respective transmission and distribution networks to ensure security of supply and combat constraint issues.  

In respect of a potential moratorium EirGrid echo the CRU position and do not adopt a moratorium but look to adopt ‘Connection Measures’ based on the criterial set out by the CRU.  EirGrid are open to considering connections from Data Centres and will make an assessment based on the criteria outlined above. It is the understanding of the Council and confirmed by Codema, the Dublin Energy Agency that there is no moratorium in place. 

EirGrid operate and manage the electricity grid so they are best placed to assess whether a Data Centre or any other large electricity user should be granted a grid connection. EirGrid’s primary objectives are to ensure the grid operates well and to “Lead the island’s electricity sector on sustainability and decarbonisation” and have all the relevant information to make a well-informed decision on connections to ensure "a safe, secure and reliable supply of electricity on the island of Ireland" as stated in their Group Strategy. 

 

This includes assessing any potential risks brought about by connecting large electricity users. EirGrid use a 2-stage engagement procedure before granting connections and the first of these occurs before the data centre applies for planning permission. As a result, EirGrid are best placed to decide on whether data centres should go ahead or not.  

The Draft Plan, through EDE7 Objective 2 sets a hierarchy of approaches to energy which must be demonstrated by space extensive development such as data centres. This means that relevant development must in the first instance Maximise on site renewable energy generation to ensure as far as possible 100% powered by renewable energy. Where 100% is not possible they must show evidence of a power purchase agreement made in Ireland. This is a direct agreement with a renewable electricity developer in Ireland. 

Given the complex issues surrounding this type of development, it is considered that the approach taken in the Draft Plan and CE Report on Public Consultation is reasonable and appropriate at this time, to allow for any further changes to the development of Data Centres within Dublin.

CE  Recommendation:  It is recommended that this motion is not adopted