D01.02.03 MDCO Dialogue Instrument with AirTrunk on Planning Considerations for Low Frequency Noise

Dialogue Series: D01 — Low Frequency Noise During Data Centre Planning Approval
Dialogue Reference: D01.02 — Data Centre Developers and Operators
Record: D01.02.03 — AirTrunk
Date Issued: 10 August 2026
Status: Awaiting Response

Reference Research:
→A09.04 Data Centre Low Frequency Noise in Planning Approval by Local Councils

Dialogue Purpose

This Dialogue Record documents MDCO’s formal engagement with the dialogue partner to seek clarification and views on current planning considerations for low frequency noise (LFN) associated with data centre developments.

MDCO’s Current Understanding:

  1. Publicly available legislation and guidance reviewed by MDCO did not identify any specific published requirement addressing LFN assessment for data centre developments during the planning approval process.
  2. Conventional environmental noise assessment generally relies on overall A-weighted sound levels (dBA), while international acoustic practices indicate that frequency-based analysis may provide additional information where significant low-frequency sources exist.
  3. Based on publicly available information and international industry practices, MDCO understands that potential acoustic considerations may be evaluated alongside site selection, engineering design, equipment selection, environmental assessment and regulatory requirements during the planning stage.
  4. MDCO understands that predicting operational acoustic conditions during the planning stage involves uncertainties, including equipment selection, evolving client requirements and final operational configurations. Nevertheless, planning-stage assessment may provide useful information for identifying potential issues before construction begins.
  5. The rapid growth of data centre developments and advances in acoustic research may require continued consideration of how planning practices and technical guidance address potential LFN-related issues.
  6. Based on publicly available information reviewed by MDCO, MDCO has not identified a clearly established or consistently documented industry assessment framework specifying the requirements, timing, methodology and criteria for considering or assessing low-frequency noise during the various stages of data centre development.

Additional Findings from Dialogue Responses

No additional information was available from the dialogue process as of the publication date.

Dialogue Instrument Submitted

Original letter:

Ref. No.:          MDI-2026-02-03-ATRK
Date:               10 August 2026
By Email:         media@airtrunk.com, info@airtrunk.com

Ms Pei Jet (PJ) Lim
Vice President & Country Head, Malaysia
Air Trunk Malaysia Sdn. Bhd.

11th Floor, South Block, Wisma Golden Eagle Realty
No. 142A, Jalan Ampang
50450 Kuala Lumpur, Malaysia

Cc:

Mr Robin Khuda
Founder & Chief Executive Officer
Air Trunk Pty Ltd

Level 47, 88 Walker Street
North Sydney, NSW 2060
Australia

Dear Ms Pei Jet (PJ) Lim,

RE: Invitation for Developer Dialogue on Low-Frequency Noise Considerations During Data Centre Planning and Design

The Malaysia Data Centre Observatory (MDCO) is an independent research initiative examining the development of Malaysia’s data centre ecosystem from technical, environmental, planning and community perspectives.

As part of MDCO’s ongoing Dialogue series on Low-Frequency Noise (LFN) and Data Centre Development, we are engaging with developers, government agencies, communities and technical professionals to better understand how low-frequency noise is considered during the planning and design of new data centres.

MDCO would like to invite AirTrunk to contribute its perspectives as a leading hyperscale data centre developer with a significant and growing presence in Malaysia. The purpose of this invitation is not to assess or comment on the performance of any individual AirTrunk project. Rather, MDCO seeks to better understand current industry approaches to planning-stage consideration of low-frequency noise and the practical challenges associated with major data centre developments.

Enclosed is a copy of MDCO’s recent research article, A09.06 Low-Frequency Noise and Data Centre Development – Perspectives for Developers, which examines international planning practices and identifies several questions intended to facilitate constructive engagement with the industry.

AirTrunk’s development of multiple hyperscale data centre campuses in Iskandar Puteri has contributed to the rapid expansion of Malaysia’s digital infrastructure. Its Johor platform currently includes the operational JHB1 and the JHB2 development, while AirTrunk has also announced plans for JHB3 and JHB4 in Iskandar Puteri. These developments provide a relevant context for considering how potential environmental and community considerations are addressed as large-scale data centre infrastructure is planned and developed.

Separately, international experience has shown that low-frequency noise has emerged as a consideration in some data centre developments after facilities become operational. This highlights the value of understanding how potential acoustic matters are addressed during the earlier stages of planning and design, when project decisions remain comparatively flexible.

As a leading hyperscale data centre developer with an established and expanding presence in Iskandar Puteri, MDCO believes that AirTrunk’s perspective would make a valuable contribution to understanding how potential low-frequency noise considerations are addressed during project planning and design.

The questions below are intended to facilitate this dialogue.

Question 1: Low-Frequency Noise Consideration During Planning and Design

MDCO Current Understanding: Based on publicly available information and international industry practices, MDCO understands that potential acoustic considerations are often evaluated alongside site selection, engineering design, equipment selection, environmental assessment and regulatory requirements during the planning stage. Early consideration may provide greater opportunity to evaluate potential acoustic impacts and incorporate appropriate design measures while projects remain sufficiently flexible.

Question: How is potential low-frequency noise currently considered during the planning and design of new data centres?

MDCO would appreciate perspectives on matters including:

  • whether acoustic considerations are incorporated during early site evaluation;
  • how potential impacts on surrounding environments are considered;
  • how acoustic considerations interact with other planning and engineering requirements;
  • the extent to which low-frequency noise influences design decisions during project development.

Question 2: Engagement of Acoustic Specialists During Project Development

MDCO Current Understanding: MDCO understands that data centre planning commonly involves collaboration among architects, engineers, environmental consultants and specialist advisers. The timing of acoustic specialist engagement may influence the range of planning and design options available.

Question: At what stage of project development are acoustic specialists typically engaged?

MDCO would appreciate perspectives on matters including:

  • when acoustic specialists are typically appointed;
  • how acoustic specialists coordinate with architects, mechanical and electrical engineers, environmental consultants and project teams;
  • how specialist advice contributes to planning and design decisions;
  • whether acoustic assessment continues to evolve throughout the design process.

Question 3: Assessment of Potential Low-Frequency Noise Before Construction

MDCO Current Understanding: MDCO understands that predicting operational acoustic conditions during the planning stage involves uncertainties, including equipment selection, evolving client requirements and final operational configurations. Nevertheless, planning-stage assessment may provide useful information for identifying potential issues before construction begins.

Question: What information relating to low-frequency noise can realistically be assessed before construction begins?

MDCO would appreciate perspectives on matters including:

  • the types of information generally available during planning;
  • limitations associated with predictive acoustic modelling;
  • uncertainties arising from equipment specifications and operational requirements;
  • how planning-stage assessments assist subsequent design decisions.

Question 4: Communicating Potential Noise Impacts During Planning Submission

MDCO Current Understanding: MDCO understands that planning submissions seek to communicate technical information to planning authorities while also assisting broader stakeholder understanding. Communicating potential environmental impacts in a clear and proportionate manner may contribute to more informed planning discussions.

Question: How should planning submissions communicate potential operational noise impacts to planning authorities and nearby communities?

MDCO would appreciate perspectives on matters including:

  • the level of technical information typically included within planning submissions;
  • how technical acoustic information can be effectively communicated to planning authorities;
  • approaches for explaining potential operational impacts to nearby communities;
  • balancing technical completeness with accessibility for non-specialist audiences.

Question 5: Practical Challenges in Assessing Low-Frequency Noise During Planning

MDCO Current Understanding: MDCO understands that developers must balance multiple technical, environmental, commercial and regulatory considerations throughout project planning. Practical constraints may influence the information available and the degree of assessment that can reasonably be undertaken before construction.

Question: What practical challenges do developers encounter when assessing low-frequency noise during project planning?

MDCO would appreciate perspectives on matters including:

  • availability of project information during early planning;
  • evolving equipment specifications;
  • changing client requirements;
  • coordination across multiple design disciplines;
  • differences between international practices and local regulatory frameworks;
  • practical considerations that may influence planning-stage assessment.

MDCO recognises that AirTrunk operates through an international organisation with regional management teams and specialised functions. If appropriate, we would appreciate this invitation being referred to relevant personnel responsible for Malaysia operations, including planning, engineering, environmental, sustainability, ESG, stakeholder engagement, or community relations functions.

MDCO would greatly appreciate any written comments or responses that AirTrunk may wish to provide regarding the questions outlined above. As part of MDCO’s commitment to transparency, this MDCO Dialogue Instrument (MDI) and any responses received may be published and referenced as part of the MDCO Dialogue series and related research publications. To enable AirTrunk’s perspectives to be considered in the current publication, we would greatly appreciate any written response within 14 working days from the date of this letter. Responses received after this period will nevertheless be welcomed and may be considered for future MDCO publications or updates, with appropriate attribution and factual verification where necessary.

We appreciate your consideration of this invitation and look forward to the opportunity to engage with AirTrunk.

Thank you.


Yours faithfully,

(IR. DR. KOH SIONG LEE)
Director of Research
Malaysia Data Centre Observatory (MDCO)

Feedback and Responses Received

None as of the publication date.

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