Its the Law of Unintended Consequences – Some Clarity around My thoughts on Data Center Regulation

I have gotten a lot of response from the post on my thoughts on Data Center regulation.   Many of the comments in a response to an Infoworld article focused on the disbelief of regulations particularly targeting data centers.  A Greener Computing article felt that because the current administration is very tech-savvy they wouldn’t do anything to hurt data centers.  In fact the exact quote was:

I can understand Manos’ concerns, but I think he’s on the wrong track. The federal government is very unlikely to issue strict green regulations related to data centers. And if they do regulate them in some way, the regulations will no doubt be reasonable. The current administration is very technology-savvy — after all, the current Secretary of Energy Steven Chu was recently the director of the Lawrence Berkeley National Laboratory, whose work was heavily dependent on its data center. Chu did some great work related to Green IT when at the labs. He knows what can and can’t be done — and will make sure that data centers aren’t hamstrung with unnecessary regulation.

I guess for clarity sake I should state unequivocally that I do not believe that Data Centers will specifically be targeted or singled out for regulation.   Domestically here in the United States the EPA has kicked off its Energy Star Data Center evaluation which looks to study data centers as a sector, and something may come out of that, but in all honesty that wont be for some time.  I think the more immediate threat is in the efforts around Carbon Cap and Trade.  As the Greener Computing Article calls out, it was front and center at the G8 meetings.   With the UK leading the charge and the only real legislation on the books in this space, it would be hard for the other countries not to use it as the base for their programs.   My previous post focuses specifically on the fact that Data Centers will end up being significant contributing factors to Carbon metrics for companies.  Data Center Managers just aren’t thinking about it, and wont be until its far too late.  

While I am hopeful that leaders like Steven Chu and the Obama administration will weigh all possible aspects in a Carbon Cap and Trade program, the fact remains that they will need to legislate to the least common denominator and data centers are unlikely to be called out unless there is a group specifically calling attention to it.  Ergo my call for an industry wide group lobbying on its behalf.     I have doubts they will altruistically incorporate all possible sub cases into the mix without that kind of pressure.   President Obama frankly has bigger problems to be thinking about in my opinion.   

I am reminded of a quote from another excellent communicator and activist president, Ronald Reagan:

"The nine most terrifying words in the English language are: ‘I’m from the government and I’m here to help.’"

Its those times more than any other that you should put your guard up even higher.  I guess only time will tell, but one thing is certain Data Centers and IT departments will have a role to play in Carbon Reporting. 

\Mm

Coming Soon to a Data Center near you, Regulation.

As an industry, we have been talking about it for some time.  Some claimed it would never come and it was just a bunch of fear mongering. Others like me said it was the inevitable outcome of the intensifying focus on energy consumption.   Whether you view this to be a good thing or bad thing its something that you and your company are going to have to start planning for very shortly.  This is no longer a drill.

CRC – its not just a cycle redundancy check

I have been tracking the energy efficiency work being done in the United Kingdom for quite some time and developments in the Carbon Reduction Commitment (CRC).  My recent trip to London afforded me the opportunity to drive significantly harder into the draft and discuss it with a user community (at the Digital Realty Round table event) who will likely be the first impacted by such legislation. For those of you unfamiliar with the initiative let me give a quick overview of the CRC and how it will work. 

The main purpose of the CRC is a mandatory carbon reduction and energy efficiency scheme aimed at changing energy use behaviors and further incent the adoption of technology and infrastructure.  While not specifically aimed at Data Centers (its aimed at everyone) you can see that by its definition Data Centers will be significantly affected.  It was introduced as part of the Climate Change Act 2008.

In effect it is an auction based carbon emissions trading scheme designed to operate under a Cap and Trade mechanism.  While its base claim says that it will be revenue neutral to the government (except of course for penalties resulting from non-compliance), it provides a very handy vehicle for future taxation and revenue.  This is important, because as data center managers you are now placed in a position where you have primary regulatory reporting responsibilities for your company.  No more hiding under the radar, your roles will now be front and center.                             

All organizations including governmental agencies who consume more than 6000 MWh in 2008 are required to participate.  The mechanism is expected to go live in April 2010.  Please keep in mind that this consumption requirement is called out as MWh and not Megawatts.  What’s the difference? Its energy use over time for your whole company.  If you as a data center manager run a 500 kilowatt facility you account for almost 11% of the total energy consumption.  You can bet you will be front and center on that issue. Especially when the proposed introductory price is £12/tCO2 (or $19.48/tCO2).  Its real money.  Again, while not specifically focused on data centers you can see that they will be an active contributor and participant in the process.  For those firms with larger facilities, lets say 5MW of data center space – dont forget to add in your annual average PUE – the data centers will qualify all to themselves.

 

 

For more information of the CRC you can check out the links below:

• A Good Deck with a high level overview can be found here
• The wikipedia definition
• For alot of additional detail the CRC user guide is a great tool

While many of you may be reading this and feel poorly for your brothers and sisters in Great Britain while sighing in relief that its not you, keep in mind that there are already other mechanisms being put in place.  The EU has the ETS, and the Obama Administration has been very public about a similar cap and trade program here in the United States.  You can bet that the US and other countries will be closely watching the success and performance of the CRC initiative in the UK. They are likely to model their own versions after the CRC (why invent the wheel over again, when you can just localize to your country or region).  SO it might be a good idea to read through it and start preparing how you and your organization will respond and/or collect.

I would bet that you as a Data Center Manager have not been thinking of this, that your CIO has not thought about this, the head of your facilities group has not thought about this.  First you need to start driving awareness to this issue.    Next we should heed to a call to arms.

One of the items that came out during the Roundtable discussions was how generally disconnected government regulators are to the complexities of the data center.   They want to view Data Centers as big bad energy using boxes that are all the same.  When the differences in what is achievable from small data centers to mega-scale facilities are great.  Achieving PUEs of 1.2x might be achievable for large scale Internet firms who control the entire stack from physical cabling to application development,  banks and financial insitutions are mandated to redundancy requirements which force them to maintain scores of 2.0. 

Someone once decried to me that data centers are actually extremely efficient as they have to integrate themselves into the grid, they generally purchase and procure the most energy efficient technologies, and are incented from an operating budget perspective to keep costs low.  Why would the government go after them before they went after the end users who typically do not have the most energy efficient servers or perhaps the OEMs that manufacture them.  The simple answer is that data centers are easy high energy concentration targets.   Politically going after users is a dicey affair and as such DCs will bear the initial brunt.

As an industry we need to start involving ourselves in educating and representing  the government  and regulatory agencies in our space.   While the Green Grid charter specifically forbids this kind of activity, having a Data Center industry lobby group to ensure dumb things wont happen is a must in my opinion.  

Would love to get your thoughts on that.

/Mm