Responding to the South African Human Rights Commission’s call for public submissions on the environmental and human impact of rapid data centre expansion in South Africa, Research ICT Africa submits feedback on the evolving problem, anchoring its response in the Just AI Framework of Inquiry – specifically, its inquiries on sustainability and structural inequality.
The submission takes the stance that data centre development is not simply an infrastructure or investment issue. It is a matter of constitutional governance, requiring public authorities and private actors to ensure that South Africa’s digital transition advances human rights, environmental sustainability and distributive justice, rather than creating new forms of environmental and social inequality.
It does this by underscoring data centres’ substantial resource demands, particularly for electricity and water, and by emphasising concerning trends surrounding data centre expansion. Among these are: limited public consultation, limited transparency, and a lack of standardised monitoring and reporting on its environmental and social impacts.
Comparing data centre expansion cases in Ireland, Chile and across the United States, the authors demonstrate that regulatory and judicial bodies in other jurisdictions have begun to treat data centre expansion as a matter that engages public resource rights rather than purely private investment decisions, offering useful comparators for the Commission’s inquiry.
Combining these findings with the Framework of Inquiry’s justice-oriented recommendations, the submission ultimately affirms the Commission’s power and duty to conduct an inquiry into the impact of current and future data centres, and argues that it should equally, in accordance with its mandate, make recommendations around centres’ ongoing monitoring, the proactive disclosure of their environmental impacts, the enforcement of community consultation mechanisms prior to data centre development, and the protection of relevant human rights in the process.
