Take Rapid Data Center Evolution into Account, ASHRAE TC Advises EU Regulators

ASHRAE TC 9.9 described the environmental classes from its Thermal Guidelines for Data Processing Environments to representatives of the EU Commission in 2015.

By W. Stephen Comstock, Contributing Editor, Europe & Middle East

From: ASHRAE HVAC&R Industry News,  August 9, 2018

BRUSSELS—ASHRAE Technical Committee (TC) 9.9 is calling for the European Union (EU) to take into account the rapid pace of evolution in data center technology when revising Ecodesign regulations.  In comments submitted to the European Commission on its proposal to implement 2009/125/EC of the European Parliament, TC 9.9 chair Jason Matteson, Associate Member ASHRAE, wrote, “We encourage the EU Commission to remain conscious of the velocity of evolution in the technology and data center industry and how any proposed legislation could quickly become outdated, obsolete or worse, stifle innovation.”  The TC has offered to assist the EU with further comments to align the proposed requirements with the current and future reiterations of ASHRAE’s Thermal Guidelines for Data Center Environments.

The ASHRAE TC formally submitted its comments to the Commission on July 25. The call for stakeholder feedback was from July 3 to July 31.  

According to the firm Research and Markets, the global data center construction market will grow from $14.59 billion in 2014 to $22.73 billion by 2019.  Data Center Dynamics says many companies are transforming traditional data centers into mega data centers while many others are planning to build new monster sites in the coming years.

The EU’s Ecodesign Directive (Directive 2009/125/EC) establishes a framework to set mandatory ecological requirements for energy-using and energy-related products sold in all the EU’s 28 Member States. Its scope covers more than 40 product groups (such as boilers, light bulbs, TVs and fridges), which are responsible for around 40% of all EU greenhouse gas emissions.  Since it is a framework directive, it does not directly set minimum ecological requirements. These are adopted through specific implementing measures for each group of products in the scope of the Directive.  The implementing measure that ASHRAE responded to is (EU) No 617/2013, the implementing regulation for enterprise servers and data centers.

The general scope of the ENTR Lot 9 constitutes a very wide range of products.  In previous discussions, the regulators have recognized that the complexity of the market and ongoing activities with respect to energy efficiency requires proper reflection to set the scope of the regulation realistically.

According to the Commission, the ultimate aim of the Ecodesign Directive is that manufacturers of energy-using products will, at the design stage, be obliged to reduce the energy consumption and other negative environmental impacts of products. While the Directive's primary aim is to reduce energy use, it is also aimed, they say, at enforcing other environmental considerations including: materials use, water use, polluting emissions, waste issues and recyclability.

ASHRAE TC 9.9, guided by the IT industry, created the recommended and allowable environmental envelopes that should be used in data centers.  ASHRAE briefed regulators on the guidelines in 2015, when the currently proposed implementing measures were being drafted. The Recommended Range gives guidance to data center operators on maintaining high reliability of the IT equipment while also operating their data centers in the most energy efficient manner.

At the recommended range, data center systems can be designed to operate reliably with full free cooling.  As stated in the ASHRAE guidelines, the allowable range bounds the limits at which the IT manufacturers test their equipment in order to verify that the equipment will function within those environmental boundaries. The Allowable Ranges of ASHRAE Al to A4 Classifications enable data centers to manage temperature excursions due to mechanical cooling system failures and short-term temperature excursion in free-cooling systems.

According to Roger Schmidt, P.E., Member ASHRAE, the IT subcommittee chair of TC 9.9, “Servers are just one component in operating an energy efficient data center. There are implications to operating at the boundaries of the allowable ranges of the ASHRAE Environmental Classifications. They include reduced server reliability, increased probability of failure and increased server fan speeds and energy consumption.  Operating near or at the allowable environmental limits will result in more energy being used by the data center than operating in the recommended envelope," Schmidt said.

ASHRAE publishes these ranges in Thermal Guidelines for Data Processing Environments, first published in 2004 with the most recent iteration published in 2015.  They are subject to continuous revision as IT equipment evolves.  Speaking for the TC, Matteson said, “We believe that the EU document should reference the environmental classes in the latest edition of the ASHRAE Datacom Series Book 1, Thermal Guidelines for Data Processing Environments rather than reproduce any of this material directly.”  The TC advised the Commission that the ASHRAE environmental classes and the associated footnotes are updated on a regular basis as a result of research funded by ASHRAE.  The last update was to improve on the limits of the lower moisture levels.  ASHRAE and TC 9.9 expect another update to the table as a result of research that will be reported in January 2019.

Schmidt cautioned that because of the detail in the guidelines it is easy to miss or misinterpret the table that presents the environmental classes without having the important footnotes plus appendixes that supplement it.  “Without all these components one could arrive at the wrong environmental conditions to apply to a data center,” Schmidt said.

The research and publications released by TC 9.9 over the last decade have had a profound effect on global data center design, construction and operations, said another member of TC 9.9, Paul Finch, C.Eng., Member ASHRAE.  Finch, based in the United Kingdom, has been following the regulations for ASHRAE.  “The Thermal Guidelines, in particular, have become de-facto standards written into lease agreements, licenses and form the cornerstone of many service level agreements,” he said.  “When applied correctly with the appropriate technologies the impact on data center operations in terms of availability, reliability, energy efficiency, sustainability and total cost of ownership has been shown to be transformative. It is paramount dialogue continues between these two parties as draft legislation is tabled, along with the broader data center industry."

ASHRAE also pointed out that an Annex to the proposed regulation states that idle state power for a server should be measured at the higher boundary temperature of the appropriate ASHRAE environmental class.  “This should be reconsidered as any measurements of server power should be made in the recommended range where server operation most frequently occurs,” Matteson said.  “This would be consistent with a number of benchmark standards that are summarized in the ASHRAE Datacom Series Book 12, Server Efficiency—Metrics for Computer Server and Storage, which consolidates all current server and storage subsystem energy benchmarks.  ASHRAE has made the Thermal Guidelines and Server Efficiency books available to the Commission.

The proposed regulation and ASHRAE response can be found on the European Commission’s website for feedback on Published Initiatives:  https://ec.europa.eu/info/law/better-regulation/initiatives/ares-2017-3069227_en.

Reflecting the widespread use of the ASHRAE Environmental Classifications in the IT industry, ASHRAE coordinated with DIGITALEUROPE and techUK in submitting its feedback.  DIGITALEUROPE includes as members some of the world's largest IT, telecoms and consumer electronics companies and national associations. It has 63 corporate members and 39 National Trade Associations members from throughout Europe.  techUK represents more than 950 companies that collectively employ approximately 700,000 people, about half of all tech sector jobs in the UK. These companies range from leading FTSE 100 companies to new innovative start-ups.