Uptime Institute Position Paper Regarding U.S. Congress House Bill HR 540

Uptime Institute Position Paper Regarding U.S. Congress House Bill HR 540

The U.S. House of Representatives passed a bill on 5 March 2014 that documents new energy efficiency requirements for federal data centers. The bill requires the regulatory agencies to create and enforce energy efficiency standards for government agency data centers.

The purpose of this position paper, developed by the Uptime Institute, is to submit considerations for the creation of energy efficiency criteria for the federal government as well as commercial data centers. It is acknowledged that there are many details and concepts to be determined as the legislation is drafted and enacted. Uptime Institute offers its collective experience in the formative stages of this legislation to avoid conceptual shortfalls, implementation delays, and potentially negligible results.

Uptime Institute is a long-standing and vendor-neutral research, consulting, and certification body. It currently serves 200+ data center construction projects, from the private and public sectors, in 60+ countries.

Another key distinguishing characteristic of Uptime Institute is its Network: a global knowledge community exclusively for data center owners and operators to address—in a collaborative and experience-based environment—industry technology and management challenges for reliability, availability, and energy efficiency. The Network was founded in North America in 1993 and has since expanded to EMEA,
Latin America, and Asia Pacific.

Lessons learned from Uptime Institute field teams, clients and Network members can lend unique insight into the process of legislating data center energy efficiency.

Uptime Institute’s position is that many disciplines and stakeholders within the data center are responsible for energy efficiency. Broad elements for attention include:

  • IT hardware utilization
  • Outside air cooling
  • Water Utilization Efficiency (WUE)
  • Waste water recovery
  • Waste heat recovery
  • Airflow management
  • Power Usage Effectiveness (PUE)
  • Systematic identification and responsible disposal of comatose or ‘dead’ servers and electronics
  • Carbon Usage Effectiveness (CUE)

In addition, distinct consideration should be given to the design and construction of new data centers, as opposed to operational environments. This should include the elements above, but also include responsible sourcing and careful management of deployment vs. need to eliminate loss of stranded data center capacity.

HR540 compels development of an energy efficiency metric or adoption of an existing one. In Uptime Institute experience, energy efficiency initiatives tend to rely heavily upon the Power Usage Effectiveness (PUE) ratio. PUE may provide a useful, although limited, measurement of facilities-level efficiency, provided it is properly and frequently measured and reported.

Generally, senior IT executives tend to inaccurately use PUE as a catchall for data center efficiency. PUE is a ubiquitous facilities engineering measurement, not an effective means to manage energy efficiency in data centers overall.

Focusing on a single efficiency measurement will not assist the U.S. federal and commercial data centers in reducing resource consumption over the long term. Uptime Institute’s long-standing recommendation is a multi-dimensional assessment that considers resource consumption, performance, cost, and asset management.  A measurement system based on only one of these key elements could undermine the objective of this bill and create a financially unviable outcome.

Uptime Institute has uniquely researched holistic energy efficiency and challenged the industry to drive improved behaviors and effective management methodologies.

For example, every organization has underutilized or abandoned servers in their data center(s). Comatose servers waste power and consume capacity. Uptime Institute conservatively estimates 20% of servers are comatose and the servers ‘at work’ are often significantly underutilized.

Data center professionals have little incentive to remove comatose machines and most IT executives lack insight into the impact idle IT equipment is having on the cost structures of their organizations.

In response, Uptime Institute challenged the industry broadly to address the problem of comatose servers by participating in the Server Roundup, an initiative to promote IT and Facilities integration and reduce data center energy consumption and cost, and potentially avoid a costly and resource-intensive data center construction project.

The extent of the drain on data enters by comatose servers is evidenced by Server Roundup results: seven organizations decommissioned and recycled a total of 40,000 units of obsolete IT equipment. The case studies gleaned from Server Roundup demonstrate that removing comatose servers will have a vastly more significant impact on data center energy consumption than facilities-level, PUE-based improvements. There continues to be much to be done in this aspect alone in both the government and private sectors.

The general intent of HR 540 is laudable and timely, but there are many opportunities for unintended consequences, such as spending large amounts of taxpayer monies for marginal improvements and uncertain benefits. Uptime Institute welcomes the opportunity to contribute to this legislative effort beyond this initial high-level position response.

Please contact the Uptime Institute executive management below for additional questions and support – we are standing by to support these efforts.

Lee Kirby, Uptime Institute CTO - [email protected]

Julian Kudritzki, Uptime Institute COO - [email protected]

Scott Killian, Vice President of Energy Programs - [email protected]