Not only are 4D Data Centres members of techUK, the UKs largest trade association of technology companies, but two of our directors are active contributors to their cloud and data centre councils. The latter group which our MD, Jack Bedell-Pearce, sits on have been particularly busy over the past 3 months.
The following is an overview compiled by techUK Associate Director, Emma Fryer:
Quarterly Overview: Q1 2018
2018 started at full tilt with a plethora of consultations that had thoughtfully been issued in November and December by Government with deadlines in early January. So much for a relaxing Christmas break! So we had to collate and submit our views on simplified carbon reporting, on heat reuse, on domestic generator controls, energy costs, the Energy Technology List and Environment Agency charging among others. Additional submissions followed during February and March on the carbon impact of the internet, sector resilience to heatwaves and barriers to efficiency especially in smaller facilities. During this quarter we also held very productive dialogues with Government on Heat Network regulations, on EU ETS and on EcoDesign proposals for servers and with the Environment Agency on EPR, MCPD and domestic generator controls.
On the publications and platforms front we published guidance on GDPR with our decision tree to help operators determine whether they are data processors or not, opinion pieces on how to employ more women in the sector and why sector energy use is so contentious. We spoke at DataCloud UK/FIF on data centre energy consumption, at a EURECA project workshop on Brexit and Data Centre World on sector power and on GDPR. We appeared in The Stack, DataCenterDynamics, Computer Weekly, Inside Networks and Data Economy.
Looking ahead to Q2, we expect BEIS to publish its thinking on industrial energy efficiency, but as yet we don’t know whether a successor to the CCA scheme is in scope. We will continue fighting in the trenches to keep the CCA open, on Green Public Procurement, on EcoDesign, on ETS and on other generator regulations to try and ease the compliance burden and ensure the legislation is fit for purpose. We will also be producing explanatory briefings on MCPD, are working on Best Available Techniques for EPR, and notes on MEES and Heat Network. Just in case that isn’t enough to keep us busy we are expanding our outreach on skills and professionalism and hope to get some thought leadership out on energy consumption and the UK as a location of choice for operators and their customers.
Topics covered this quarter include the below.
|We continue to keep a close eye on progress: the negotiations moved on to the second phase and we produced a comment: Brexit: Where are we now? in January that provided a brief summary of developments since the September update to our 2016 Silver Linings report. Broader tech sector issues relevant to Brexit can be found here. On 19th March the Draft Legal Agreement was published, and my techUK colleagues provided some useful analysis. There is a 21 month transition period, citizens’ rights are secured, trade remains open, but banking agreements are ending and data flows and Irish border issues remain unresolved. We spoke on Brexit at events including a EURECA Project workshop and Datacloud UK. We will keep operators posted.||
Climate Change Agreement
|Following the publication of our third CCA report back in September our focus is now firmly on the future of the scheme. This closes to new entrants in October this year, although existing participants can continue to benefit until 2023. We are lobbying to keep the scheme open for longer and produced a draft Council Communication to present to Government in April whilst at the same time alerting operators to apply without delay if not already on board. The longer discussion, however, will be around a potential successor for the CCA, and in the next quarter we will be looking closely at the forthcoming Industrial Energy Efficiency Proposals due to emerge from BEIS.|
Streamlining Energy and Carbon Reporting
We contributed to a wider techUK input to BEIS on their proposals to streamline carbon reporting, which did not really involve much streamlining and instead seemed to add plenty of unnecessary bells and whistles to existing reporting. These were shamefully inadequate proposals for a landscape that is in desperate need of root and branch reform. Fortunately my more tactful colleague handled the submission!
Climate Change Adaptation (Resilience to severe weather risk)
We continue to work with DEFRA and the Environment Agency on sector readiness for climate change risks such as flooding and high temperatures. We hosted one of the regular meetings of the Infrastructure Operators Adaptation Forum in February and continue to focus on the best framework for the next round. We previously reported on the sector’s readiness for climate change risks back in 2016. One of the risks we identified was that operators were not systematically reviewing flood risks. We made a request for this requirement to be included in CEN/CENELEC’sTR 50600 suite and this now looks very likely. We responded to the Government’s consultation and have since submitted evidence to the Environmental Audit Committee’s Inquiry into Heatwaves, in which we explained that temperature management was business as usual for the sector, and most vulnerability to be found in ageing facilities and/or in smaller server rooms in distributed IT environments.
GDPR: General Data Protection Regulation
This quarter saw the publication of our GDPR Decision Tree for data centres, which helps operators establish whether they are data processors or not, explains associated levels of liability and responsibility, and provides useful links. This was published as the first of a “Compliance Nuts and Bolts Series” where we plan to look at different issues in turn and demystify them for data centres. techUK also produced guidance on the broader issues relating to GDPR, digital technology and Brexit in No interruptions: Options for the Future EU-UK Data Sharing Relationship. These more generic issues are handled by specialist colleagues within techUK because they impact the wider digital technology sector, not just data centres.
We regularly get queries about the sector’s failure to collect and re-use its waste heat “if your by product is heat why aren’t you using it for district heating?” is a familiar question. The sad truth is that there are significant barriers: the quality of heat, the cost of collecting and concentrating it, the lack of customers and the lack of infrastructure to name a few. Government issued a call for evidence last year and we responded in brief in January, setting out some of the issues and confirming our willingness to engage in any relevant policy dialogue.
Heat Networks (Metering and Billing) Regulations
We have good news on this front. While this piece of legislation was clearly not devised with data centres in mind, nevertheless it could apply to certain facilities if they provide waste heat to third parties (unlikely) or if their cooling configuration is segregated. We produced provisional guidance and held a workshop with BEIS back in July. They visited a data centre towards the year end to see how the legislation might (or might not!) work in practice. We then held a follow up workshop in January where they confirmed that: the legislation was unlikely to apply and even if it did, it was unlikely to pass both the technical and economic tests and that even if applied, the policy would deliver no real outcome in this context. While new sites should keep an eye on cooling and heat distribution, there was little point in retrofitting meters to existing facilities. Not a red herring but not a major concern. Updated guidance will be available early in Q2.
The Joy Of MEES
|MEES, or Minimum Energy Efficiency Standards, requires buildings to have an EPC rating of E or above if they are to be leased in future. We planned to produce guidance in Q1 as the April implementation date approaches but this was delayed due to urgent activity on Lot9 and other things that got in the way. Data centres are obliged under the regulations but energy to the white space is excluded because this is classed as an industrial operation. Discussions with operators reveal that most have existing EPCs and so far, they are all higher than E. Look out for the briefing in Q2.||
Generator Woes: IED/EPR, MCPD and domestic regulations
The fiendishly complicated legislation for MCPD and Domestic Generator Controls came into force in the UK on 30th January and can be found here: http://www.legislation.gov.uk/uksi/2018/110/contents/made. So the transposition process is over. However, the all important guidance is not yet available but is expected imminently. We have been working closely with the Environment Agency and held a very useful call to clarify some of the requirements at the end of December. We are producing our own guidance to MCPD and Domestic Controls for data centres and are continuing to work with the EA on Best Available Techniques for IED, where the permitting process is still causing significant pain for larger operators. We also produced a position statement on compliance activity in March. We have a workshop for operators to discuss compliance issues with the Environment Agency on Friday 20th April. Following that meeting we should be able to finalise our MCPD guidance and start working on a BAT document for IED.
We also contributed to a wider techUK response to an Environment Agency consultation on future charging structures – since there were areas of significant uncertainty – for instance whether they would charge by generator or by site - it was rather difficult to comment.
Tissues and Issues
Our main activity on energy costs this quarter was to respond to the BEIS consultation on Dieter Helm’s Cost of Energy Review. The Review roundly criticised government policy and frameworks, which had unnecessarily increased the cost of power, and made recommendations for far reaching reforms. When responding we largely ignored the questions, which were aimed at suppliers and responded robustly from the perspective of intensive energy consumers. We included a reference to our previous Council Communication. We are not optimistic that the recommendations will be implemented. We are considering how best to target our ongoing concerns about energy costs within government.
The professionalism steering group’s remit is to seek ways to address our technical skills shortage, raise the level of professional registration and improve recognition of existing skills within the sector. We continue to support the development of a bespoke Apprenticeship Standard for data centre technician and are currently represented on the steering group. Our outreach materials: 'Oh my God, I forgot to Study Maths' and 'Why work in a data centre?' are now being used by third parties and we have updated our explanation of the Trailblazer scheme for operators. Our next job is to publish our first set of case studies of industry role models and to work with other bodies to share resource and extend the reach of our messages.
Standards and Best Practices
We are already engaged with BSI and have a seat on TCT7/7, which coordinates standards relevant to data centres. This has been very productive: while we don’t pretend to contribute to technical aspects we do provide a policy focus. We have since been invited to join the Green Data Centres Coordination Group which monitors developments in standardisation and best practice across the industry. We are currently working on a map of standards relevant to data centres with the help of Mike Gilmore.
Sector Energy Consumption – laying some myths to rest
|In the last update we mentioned the frequency that external observers make exaggerated and poorly evidenced claims about power consumption by data centres and by ICT more generally. The worst offenders tend to be those making predictions far into the future based on (usually erroneous) assumptions and modelling and predicting that we will all have to live in caves and eat bugs because data centres will have gobbled up our entire power supply. While such scenarios can be derived mathematically they are economically and socially unfeasible. We spoke at Datacloud UK and at DataCentre World on this topic and will continue to work on this during Q2.|
APPCCG Inquiry and Report on the Carbon Impacts of the Internet
We contributed to a report by Policy Connect in conjunction with the All Party Parliamentary Climate Change Group, both at the evidence gathering stage and during the review process. The initial brief was pejorative and ill informed and we worried that the exercise might take cheap shots at the industry as others before have done. However, the approach was well-considered and made good use of sources and proffered expertise and the eventual report was balanced and well written. Rather than automatically targeting the commercial sector, where energy stewardship is already a priority and where energy consumption is transparent and accountable, it considers the sector as a whole and identifies the areas, such as distributed IT, where much more significant energy savings could be reaped with the right information, incentives and leadership. See: http://www.policyconnect.org.uk/appccg/research/staying-online-costing-earth.
Energy efficiency: EURECA project findings and expert group deliberations
The EURECA project, an EU funded initiative to improve energy efficiency in public sector data centres, concluded this quarter and we spoke at one of the final workshops. Despite our early fears, the project has clearly been well led, delivered valuable savings and generated exceptionally useful data that supports our position: 80% of the 350 public sector data centres covered were small (under 25 racks), efficiency was very variable, 40% of servers were over 5 years old and used 66% of power but only generated 7% of the output. A detailed study supporting refresh rate decision making was also produced. We can’t take any credit for this work but we include it because it will be such a useful external source of evidence to support our ongoing arguments. See the Eureca events pages for workshop outputs and the IEEE Digital Library for the refresh paper: http://ieeexplore.ieee.org/document/8263130/
We were subsequently invited to contribute to a European Expert Group meeting at the end of January to explore the barriers to improving efficiency in data centres across Europe. The main recommendations were to increase transparency, facilitate cross-border provision, encourage migration and consolidation to more efficient platforms and collate information.
Tussles with Brussels
EUETS: EU Emissions Trading Scheme
The words “EUETS” and “good news” are not usually found together, but on this occasion there have been some very positive developments for industry. After years of lobbying, but contrary to expectations, the Phase IV proposals published in Autumn 2017 included provision for member states to exempt ultra low emitters (below 2,500 tonnes). This was subsequently confirmed in February and now it is up to UK government to apply this exemption. We are therefore working very closely with BEIS to try and ensure that the arrangements are pragmatic but robust. Previous low emitter schemes were wholly inadequate, requiring almost the same level of effort as being a full participant. We met BEIS in February and have provided the officials with the (very significant) backstory on data centres, various position papers, our trusty briefing on Emergency Generation in Data Centres and our Council Communication. However our most valuable asset in this discussion is the work we did with the Environment Agency back in 2016 to determine a robust way of calculating carbon emissions from generators. This could form the basis of a model that enables operators to verify that they are indeed below the threshold.
Green Public Procurement for Data Centres (GPP)
The Commission is keen to ensure that public authorities are able to make sustainable choices when buying data centre services, but due to poor “previous” we have kept a close eye on this. We responded to an initial survey, produced a pre-emptive note assessing the pros and cons of different data centre performance metrics attended the Stakeholder Workshop in Seville on 16th November, and submitted a formal response to the proposals in December where we expressed concern that the tick box approach meant that a data centre procurement could meet all the criteria and still deliver a hopelessly inefficient service. A second stakeholder meeting was to be held in April but nothing as yet has been heard. The delay may reflect the difficulty in developing meaningful criteria for this complex area. We will keep you posted.
Death by Lot 9
This quarter saw increased activity in the trench warfare that has characterised negotiations on setting criteria for server efficiency under the EcoDesign Directive. Industry has taken on board most proposals and the Commission has made some concessions but there is disagreement on some aspects, particularly idle running. The Commission wants to set maximum power limits for idle running but industry is concerned that these may skew the market towards lower powered devices, and exclude some high performance devices (which are more efficient overall) from the EU. We have prepared a letter and a draft Council Communication, which will be circulated in April.
Events and Jollies
Risk Radar - 7th February: Navigating the Compliance Minefield.
We held a Risk Radar Briefing on compliance issues on 7th February. There was a whistle-stop tour through the main obligations placed on operators, using our Compliance Healthcheck as an aide memoire, and Homer Simpson as our hapless compliance advisor. We then focused on two requirements that are causing particular concern: GDPR and MCPD which were covered by Mark Bailey from CRS and by Julie Gartside (assisted by Alice in Wonderland) from SLR respectively. Slides are available from the website. The Compliance Healthcheck is also available online. Many thanks as ever to Future-Tech for sponsoring so generously.
|We spoke at a number of events this quarter, including DataCloud UK/FIF where we discussed data centre energy consumption and reassured operators that yes, the grid can cope, at a EURECA project workshop where we gave an update on the implications of Brexit and why Government is finding it so hard to issue clear negotiating priorities, and at Data Centre World where we debunked some myths about sector energy use and outlined the main issues relating to GDPR. We appeared in The Stack with an opinion piece on the energy conundrum, in DataCenterDynamics, with an informal guide on how to attract and retain women, in Computer Weekly on gas powered data centres, in Inside Networks on the CCA and Data Economy in association with BroadGroup on Brexit: where are we now? and Energy: how much is hot air?, among others.||
We held the first Data Centres Council meeting of 2018 on 7th February to review programme activity and set priorities for the year. Council ToR, member bios, application criteria and formal Communications are available from the Council pages of our website. Council was pleased to welcome Annalisa O’Rourke from Memset who has filled the only vacancy, bringing Council to full complement. Notes and papers are available for all Council meetings on request.
Previous activity digests can be found here, including the 2017 programme overview and those for 2016, and before. Alternatively please contact: