The Energy Efficiency Directive – In the midst of chaos, there is also opportunity.

The Chinese have a symbol which means both crisis, but also opportunity: 危机 (Wéijī).  It feels as there is a parallel with the digital infrastructure sector at the moment with the Wéiji concept.  On the one hand we see huge growth plans, and on the other, we are trying to save the planet.  This where the Fit for 55 set of policy proposals has come from and has added to the ‘chaos’.  Within that is the Energy Efficiency Directive (EED), which is what this article is focusing on. 

The European Energy Efficiency Directive

EU countries are required to achieve cumulative end-use energy savings for the entire obligation period (running from 2021 to 2030), equivalent to new annual savings of at least 1.3% of final energy consumption in 2024-2025, 1.5% in 2026-2027 and 1.9% in 2028-2030.

It’s not just a bunch of red tape; there is a real purpose behind it, and if we succeed, there could be a bouquet of benefits.

There are two elements that data centre owner / operators need to know about and act upon.  The first is the reporting piece, and the second is the requirement for large enterprises to implement an Energy Management System, or be subject to Energy Audits.  An Energy Management System in this case is not simply a piece of monitoring software; it is a combination of people, process and technology with the aim of reducing energy consumption, and increasing energy efficiency.

EED Reporting Requirements

May 15th 2024 would have been the original date scheduled by the European Commission (Directorate-General for Energy) for the first EED reporting submission.  However, the reporting deadline has been extended to 15th September 2024, and we await news of the European e-platform within which to enter data. Some member states (eg Germany) have implemented their own reporting platform, but in lieu of any such system, companies are required to submit data directly into the EU e-platform.  (An account must be created for each data centre.)

This regulation requires data centre operators, or enterprises with their own data centres (within the EU), with an installed IT power demand of 500kW and above to report on key sustainability metrics and KPIs. 

Please note the phrase ‘installed IT power demand’ – it is the sum of the nominal powers of all power consuming devices in the installation.  In practice, companies will use their IT load to judge whether they are in or out of scope.  In reality, nominal power is the power that a device or system is designed to handle or supply under normal working conditions.  This difference may be important for some, as non-operational installed equipment may be counted.

Now that there is clarity around which data centres are in scope, the next question to answer, is “how is a data centre defined?”  What if a company has a large installation in a colo, and calls it their data centre?

The EU have kindly provided us with a definition here, which means if the company does not own or lease the building, then it is someone else’s responsibility to report on, but there is an obligation to provide certain data points to the company who is responsible for reporting.

EU Definition of a Data Centre:

Eurostat definition according to Regulation (EU) 2022/132:

“A data centre is defined as a structure or group of structures used to house, connect and operate computer systems / servers and associated equipment for data storage, processing and / or distribution as well as related activities.

“A structure can consist of multiple buildings and / or spaces with specific functions to support the primary function. The boundaries of the structure or space are considered the data centre, which includes the information and communication technology equipment and supporting environmental controls, can be defined within a larger structure or building.”

What data needs capturing, and by whom?

Rather than re-invent the wheel, please see Uptime Institute’s Jay Dietrich 's breakdown of metrics and KPIs here: The Energy Efficiency Directive: requirements come into focus - Uptime Institute Blog

The companies who need to act now, fit into the following categories, with the actions that each type of company needs to take if they want to be compliant also listed.

Enterprises with their own data centres (including hyperscalers)

• Start collecting the data defined above – use tools to make this easier, and more auditable.
• When the e-platform is available, register every data centre over 500kW of installed IT power demand located within the EU.  Deadline for May 2023 - May 2024 data is 15th September 2024.

Universities, Research Centres and Government data centres

• Start collecting the data defined above – use tools to make this easier, and more auditable.
• When the e-platform is available, register every data centre over 500kW of installed IT power demand located within the EU. Deadline for May 2023 - May 2024 data is 15th September 2024.

Colo providers

• Hire an independent agent if necessary to obtain some of this information from clients.
• Work with independent agent and / or clients to leverage toolsets out there that can assist with reporting requirements and increase energy efficiency.
• When the e-platform is available, register every data centre over 500kW of installed IT power demand located within the EU. Deadline for May 2023 - May 2024 data is 15th September 2024.

Enterprises in a colo

• Regardless of the size of your installation within the colo, you may be required to provide data points for EED reporting.  Deadline for May 2023 - May 2024 data is 15th September 2024, but your colo may need this information before this date.
• Work with colo providers to leverage toolsets available that can assist with reporting requirements and reduce energy bills.
• Be prepared to share information on server and storage power utilisation, data transmission (Incoming and outgoing data traffic) and the amount of data stored and processed.
• Read up on ITEEsv and ITEUsv and find the correct way of being able to report on these.

Energy Management Systems and Energy Audits

The directive expands the scope of energy audit obligations to include all those companies, regardless of their size, which are consuming energy above a certain threshold. Therefore, small and medium-sized enterprises (SMEs) would also have to carry out an energy audit, where there is significant energy saving potential.

Under article 11 “enterprises with an average annual consumption higher than 85 TJ of energy over the previous three years, taking all energy carriers together, implement an energy management system. The energy management system shall be certified by an independent body, in accordance with the relevant European or international standards.”  And “enterprises with an average annual consumption higher than 10 TJ of energy over the previous three years, taking all energy carriers together, which do not implement an energy management system are subject to an energy audit.”

(For clarity, 10TJ is approx 2,780MWh annually, or a rolling power consumption of 317kW as Stephen Lorimer points out.)

These audits must be conducted at least every four years. They are designed to provide individual firms with valuable advice on their energy consumption.

Large businesses are exempted from this audit obligation if they have implemented energy management systems (EMS) (Article 8 (6) EED), where an EMS is “a set of interrelated or interacting elements of a plan which sets an energy efficiency objective and a strategy to achieve that objective”.

We collectively have the opportunity to significantly contribute to a reduction in environmental impact, and to reduce our operational costs, whilst also improving our respective company brands, which can increase sales.

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If your company needs to register EU data centres, then EkkoSense AI can help with our EkkoSoft platform.  If your company would like to implement an EMS, or conduct an Energy Audit, then one of our many partners can assist.  Please get in touch.

venessa.moffat@ekkosense.com

+44 7834 772877

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