Energy Efficiency Compliance Checklist For Data Centres

Introduction

Navigating the complex landscape of energy efficiency regulations can be challenging for data centre operators. To assist in this process, we have developed an Energy Efficiency Compliance Checklist. This tool is designed to guide you through the key obligations arising from the Energy Efficiency Directive, the pursuant Delegated Regulation, its Annexes, and the German Energy Efficiency Act.

1. EU Energy Efficiency Framework

1.1 Key Facts

• Reporting obligations apply to owners and operators of data centres in a Member States' territory with a power demand of the installed information technology ("IT") of at least 500 kW

• Operators of data centres include operators of enterprise, colocation and co-hosting data centres:

  • Enterprise data centre operator means a physical or legal person who manages the entire data centre, including the building and the use of the information technology services delivered

  • Colocation data centre operator means a physical or legal person who manages and sells space, security, network access, power and cooling capacity in the entire colocation data centre to one or more customers who install and manage their own network or networks, servers and storage equipment and services

  • Co-hosting data centre operator means a physical or legal person who manages the co-hosting data centre space, security, network access, power, cooling, network or networks, servers, and storage equipment and part of the necessary software to deliver information technology services to one or more customers, including information technology outsourcing

• Reporting obligations only refer to the spaces and equipment that serve primarily or exclusively for data-related functions (server rooms), including the necessary associated equipment

• For each data centre that has a different physical location, a separate set of information and KPIs shall be published, even if the data centres are located in the territory of the same Member State

• Exempt: defence and civil protection data centres

1.2 Required Actions

(A) Data Collection and Reporting

• Collect data relevant to energy performance, water footprint, and demand-side flexibility

• Prepare to report this data annually, except for information subject to Union and national law protecting trade and business secrets and confidentiality

  By 15th September 2024, communicate to the European database the information and KPIs set out in the EU Energy Efficiency Framework.

  By 15th May 2025, and annually thereafter, update this information.

(B) Specific Information to Report (Information and KPIs)

• General information on the data centre: name of the data centre, name of the owner and operators of the data centre, date on which the data centre started its operations and municipality where the data centre is based

• Floor area of the data centre and installed power  

• Annual incoming and outgoing data traffic, and amount of data stored and processed within data centre

• Other performance KPIs: energy consumption, power utilisation, temperature set points, waste heat utilisation, water usage, and use of renewable energy

(C) Considerations for Colocation Data Centres

• If you operate a colocation data centre, prepare to gather the necessary information and KPIs from colocation customers, including annual data traffic, and data stored and processed

• With regard to the data traffic indicators, you may base the monitoring and measurement on any adequately reliable sources or combination of sources of data available, including data measured directly by you, data reported by data centre customers, or data provided by telecommunication operators and service providers

• If necessary, set up an anonymous internal reporting mechanism to gather KPIs from customers

• For the first two reporting periods, if you cannot monitor and gather the necessary data to sufficiently calculate the ICT capacity for servers and for storage equipment, estimate and indicate the percentage of the data centre computer room floor area that the information communicated to the European database covers

(D) Waste Heat Utilization

• If your data centre has a total rated energy input exceeding 1 MW, prepare to utilise waste heat or other waste heat recovery applications or provide justification if it is not technically or economically feasible

• Conduct a cost-benefit analysis to assess the economic feasibility of increased heat or cooling supply costs for certain newly planned or substantially refurbished data centres with a total rated energy input exceeding 1 MW

(E) Voluntary Adherence to Best Practices

• If your data centre has a power demand of installed IT equal to or greater than 1 MW, consider the best practices referred to in the most recent version of the European Code of Conduct on Data Centre Energy Efficiency

2. German Energy Efficiency Framework

2.1 Key Facts

• Reporting obligations apply to operators of data centres in Germany with a non-redundant rated electrical connection capacity of power demand of at least 300 kW

• Data centre operators are defined as a natural or legal person who either owns the data centre or the colocation space or has comparable rights of use

• Exempt: data centres that serve to connect or link other data centres, network nodes, constitutions protection authorities, Military Counter-Intelligence Service, Federal Intelligence Services, the armed forces and nuclear facilities, underwater data centres

2.2 Required Actions

(A) Climate Neutrality

• Ensure your data centre does not exceed the specified Power Usage Effectiveness (PUE) value

• Achieve the precise values set out by the law on an annual average within two years of commissioning

(B) Waste Heat Utilisation and Avoidance

• If your data centre goes into operation from 1 July 2026, ensure at least 10% reused energy (ERF - Energy Reuse Factor), increasing to 20% for commissioning from 1 July 2028

• Ensure necessary infrastructure and technology for waste heat utilisation

(C) Reporting Information to Platform for Waste Heat

• If your data centre has an annual average total final energy consumption of more than 2.5 gigawatt hours within the last three completed calendar years, submit data to the waste heat platform by 31 March of each year. The first reporting obligation has been postponed to 30 June 2024

(D) Purchase of Electricity from Renewable Energies

 From 1 January 2024, ensure 50% of your data centre is powered by renewable energy

 From 1 January 2027, ensure 100% of your data centre is powered by renewable energy

(E) Implementation of Energy or Environmental Management Systems

• Implement an energy or environmental management system by 1 July 2025

• If your data centre has a non-redundant rated electrical connection capacity of at least 1 MW, certify your energy or environmental management system by 1 January 2026

(F) Reporting Obligations

• Report information about your data centre for the previous calendar year by 31 March of each year

• You can use the electronic template provided by the Federal Government for reporting

Prolonged transmission deadline for the year 2024:

For data centres with a non-redundant rated electrical connection capacity of at least 300 kW up to 500 kW, the deadline is 1 July 2025.

For data centres with a non-redundant rated electrical connection capacity of 500 kW or higher, the deadline is 15 August 2024.

(G) Specific Information to Report (Information and KPIs)

• General information on the data centre: name of the data centre, name of the owner and operators of the data centre, date on which the data centre started its operations and municipality where the data centre is based

• Floor area of the data centre and installed power

• Amount of data stored and processed

• Other performance KPIs: electricity consumption, power utilisation, temperature set points, waste heat utilisation, water usage, cooling system efficiency and use of renewable energy

(H) Considerations for Colocation Data Centres

• If you operate a colocation data centre, prepare to gather the necessary information and KPIs from colocation customers, including annual data traffic, and data stored and processed

• From 1 January 2024, inform your customers about the energy consumption per year directly attributable to the customers

(I) Penalties for Non-compliance

• Be aware that non-compliance with the provisions may be punished with a fine of up to €100,000