The looming data centre code of conduct (DC3) is expected to be published in draft form early next year, according to Alec Bruce, Hitachi Data System's EMEA Eco-Solutions Champion. It is the result of work begun by Paolo Bertoldi of the European Union's Renewable Energies Unit (REU). This commenced in February as an EU initiative.

DEFRA involvement

Robin Murray of the UK government's Market Transformation Programme (MTP) attended. The MTP website states "The Market Transformation Programme supports UK Government policy on sustainable products. Its aim is to achieve sustainable improvements in the resource efficiency of products, systems and services where these are critical to the delivery of Government commitments in areas including climate change, water efficiency and waste reduction."

MTP is funded by the UK government's Department for the Environment, Food and Rural Affairs (DEFRA), also by the government's Sustainable Development Unit (SDU) which is part of DEFRA. In other words it 'is' DEFRA. The DC3 project is only one of its activities. Robin Murray has been closely associated with DC3, writing meeting minutes for example.

According to DEFRA's MTP information computing and technology (ICT) contributes four percent of the UK's greenhouse gas (GHG) emissions and will rise by 180 percent between 2006 and 2010.

Role of AEA

A source has said that AEA "runs the programme for DEFRA". AEA is 'a leading international company specialising in consultancy, policy support and programme management for policy implementation.' A recent AEA newsletter declares 'we are working closely with the UK Government, helping it to develop its sustainable procurement policy.' In this newsletter we find that experts from AEA work on the UK Government’s Market Transformation Programme.

It states 'MTP supports UK Government policy on sustainable products and is managed by AEA Energy & Environment on behalf of DEFRA. For more information about MTP and our programme management, technical and management consultancy services, please contact Jeremy Tait on 0870 190 6281 (e-mail [email protected]).'

This Didcot-based consultancy is writing the draft code of conduct and versions have been circulated for comment.

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Lack of supplier and operator involvement

There will be many data centre operators and data suppliers who will be wholly ignorant of this. They will find it surprising that they could be rapidly facing legislatively-backed green requirements on their activities, the preparations of which have been virtually invisible to them.

They will wonder if, in the rush to attain leading edge environmental action credibility, the UK government is riding roughshod over UK data centre operators and suppliers and failing to take account of their interests.

The European data centre code of conduct will be rolled out in the UK early next month. Its contents are unknown. Bruce is very concerned that it might be prescriptive rather proposing guidelines with a voluntary code of conduct.

According to another source there has been very little supplier involvement at a European level in the REU, meaning non-telco suppliers. The REU has been overly influenced by telcos such as Telecom Italia, Vodafone and BT. This is because they supply telecommunications to telehouses and co-location facilities, and even have investments in them. They have been concerned to safeguard and protect their investments in and the market for data centres and allied telecommunications.

It's possible that energy budgeting per data centre will become a reality at some time in the future. Bruce for example, says: "We feel legislation is coming."

That means data centre operators will have to monitor and manage their own carbon budget, and report on it to some government body whose costs will be paid for out of some form of taxation.

The contents of the guidelines will have a potentially huge impact on data centre operators and suppliers of data centre buildings and equipment. A form of data centre planning blight is beginning to affect operators.

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Enforced data centre emissions trading

Another source has also said that data centres using more than 20MW per annum of power will be forced to trade their emissions on the Energy Trading Scheme. Obviously such data centres will have to quantify their GHG emissions.

Chris Dean, the managing direcrtor of environmental consultants DMW, said: "We don't know any organisations who are being forced to trade their data centre emissions right now as part of the EU Emissions Trading Scheme as it only covers a limited number of heavy industrial applications such as iron and steel production, refineries, etc."

"The Directive is planned to cover all industry sectors that use more than 20MW from 2012 onwards, and this will catch the very large data centres that have power feeds of this size. The reason we mentioned this in our white paper is that the lifetime of a data centre is typically 20-30 years and therefore this threshold is a relevant consideration when planning for new or expanded data centres."

Interestingly the threat to data centre operators of enforced GHG emissions trading is stronger than this EU directive.

Dean said: "There's a proposal in the UK Government 2007 Energy White Paper which includes what is being called a Carbon Reduction Commitment. The proposal is that all organisations that use more than 6000MWh of electricity per year (about £0.5m at current prices) will be part of a mandatory cap and trade scheme whereby any consumption above the limit has to be traded. This limit equates to a continuous power load of 0.7MW; much lower than the EU trading scheme level and one that will catch most medium sized data centres. "

Asked to comment on this Bruce said: "It's something that makes me cautious and uncomfortable."

Prescription or guidance

It looks very much as if GHG emissions monitoring and management with possible emissions trading is in the future for data centre operators. Organisations like the Green Grid and the Climate Savers Computing Initiative (CSCI) are the wrong forums for participating in the preparation and planning of such governmental prescriptions as they don't appear to have a role in them, being too limited in focus and not pro-active enough in their activities.

Bruce disagrees concerning the CSCI: "I disagree that the Climate Savers Initiative is a misplaced forum. It boasts a broader audience than Green Grid with suppliers, NGOs and energy suppliers."

The CSCI came into existence in June this year and so has not been able to exert much influence on the EU and the UK government. It is also focused on desktop and notebook PCs and volume (x86) servers, meaning it has less presence anyway at the data centre level.

Overall there is a lack of relevant industry trade association or end-user groups active here and operators and suppliers face onrushing legislatively-backed regulations and requirements that will come like a bolt out of the blue.