Our MD penned the following post (original post in italics) in October 2020 and due to even more greenwashing over the last few months has felt the need to update it.
This update written on the 9th April 2024.
The last year has been explosive in terms of data centres, back in March 2023, the EU-JRC published the 'Assessment Framework for Data Centres in the Context of Activity 8.1 in the Taxonomy Climate Delegated Act (TCDA)', this includes 106 of the EUCOC best practices and the reporting of the EN 50600-4-X Data Centres KPIs, this was followed in September by the EN 50600-5-1:2023 Data Centre Maturity Model Standard, which may become the new assessment criteria for the TCDA at its next revision (2025?)
In March 2024 the EU published its Energy Efficiency Directive (recast) and for the first time, an associated delegated act for data centres, this delegated act requires ALL data centres over 500kW to register on a EU wide portal (TBC) and to complete/report various items on their data centre (a lot of the reporting is similar to the EUCOC participation requirements) and 4 specific data centre KPIs, being total energy consumption (obtained from the total facility energy number used for PUE), the amount derived from renewable energy or EN 50600-4-3 Renewable Energy Factor (REF), waste heat enegy reuse (EN 50600-4-6 Energy Reuse Factor) and finally Water usage (EN 50600-4-9 Water Utilisation Effectiveness).
The final date for reporting 2023 data is the 15th September 2024 and subsequently the 15th May 2025 for 2024 and thereafter on an annual basis.
Since March 2024, the EU has also published two new directives, the “Empowering Consumers for the Green Transition” Directive & the “Substantiation and communication of explicit environmental claims” or the “Anti Greenwashing” and “Green Claims” Directives.
Operators should note the provisions of these and perhaps revisit their green and sustainable claims as they may be called out in the future.
So, given these *new* requirements, we revisited this post and made some changes as below (changes will appear in bold)
We noticed a lot of recent activity by some in the Data Centre Colocation sector relating to the 'greenness' of their commercial offering, we're not going to name, names, but we do want to highlight that all is not as it appears to be, and that some of them are indulging in some serious 'Greenwashing'
We've even seen some blatent and utter rubbish from one particular company (no names, no pack drill) who really should know better, who are a design consultancy.
Note: the amount of 'greenwashing' has increased since the original date of this post!
So, what is 'Greenwashing'? This definition...
' What Is Greenwashing?
Greenwashing is the process of conveying a false impression or providing misleading information about how a company's products are more environmentally sound. Greenwashing is considered an unsubstantiated claim to deceive consumers into believing that a company's products are environmentally friendly.
For example, companies involved in greenwashing behavior might make claims that their products are from recycled materials or have energy-saving benefits. Although some of the environmental claims might be partly true, companies engaged in greenwashing typically exaggerate their claims or the benefits in an attempt to mislead consumers.
You can read more about the term 'greenwashing' from this link
Now, we know that a lot of this is marketing blurb, and it is for the organisation that intends to use those services, to ensure that the prospective colocation or design and build consultancy organisation is meeting the latest energy efficiency and sustainability techniques in their operations or in their designs.
So we've compiled a series of questions an end user organisation can ask to a prospective colocation operator to drill down to the crux of the matter on all things green, energy efficient and sustainable.
- Does the building have a LEED/BREEAM accreditation? This doesn't mean a statement like 'we've worked with our architects to build to the requirements of the LEED/BREEAM accreditation', it means 'can you show me your certificate that proves that your building has been built and certified in line with the requirements of the DATA CENTRE Annexes of the LEED/BREEAM assessment models', and what level did you achieve.
- What Data Centre Metrics are you reporting? Most report Power Usage Effectiveness (PUE) but rarely in line with the actual reporting methodology as specified in the ISO 30134-2 standard, ask for the number and the calculation method and then check it is correct. Be aware that PUE was NEVER intended as a comparator metric, it is an improvement metric, calculate, implement energy efficiency measures for both IT and M&E and measure again. Ask them if this is the 'design' PUE, most commercial data centres will publish this, however this number is calculated at full load and thus, because Data Centres rarely get to full load (thats a whole other blog post), the number is in effect meaningless. Please note that there are other Data Centre KPIs available in the ISO30134 series, as well as their duplicates in the EN 50600-4 series. It should be noted that companies that have signed up to the Climate Neutral Data Centre Pact (Item 9) have agreed to use these metrics or new metrics that have yet to be defined in any reporting to the EU.
- Do you have any other 'externally assessed' data centre 'energy' certification? An example would be the Certified Energy Efficient for Data Centres Award or CEEDA, CEEDA is based upon the EU Code of Conduct for Data Centres (Energy Efficiency) and is delivered by Datacenter Dynamics (DCD) more info on the award can be found here. *link updated*
- Are you an 'Endorser' AND Participant in the EU Code of Conduct for Data Centres (Energy Efficiency) more information on this best practice guide can be found here note that you can check on this site if the organisation is an 'endorser' or a 'participant.
- Did they use the EN50600 series of Data Centre design, build and operate standards for the original building and do they use the EN50600-3-1 management and operational information standard for day to day operations [Note, that at present, it is not possible to be certified to EN50600!] You can get certified to the Data Centre Alliance Data Centre Certification which uses the EN 50600 series as its assessment criteria, more information on that certificiation can be found here.
- Power Purchase Agreements, do you have a certificate of origin from your electrical utility that states that 100% of the energy used within the facility is derived from renewable energy?
- Open Compute Project Readiness, check that the facility has been assessed for the OCP readiness assessment, this is a self assessment and ensures that the facility can accept OCP equipment.
- Immersed Compute, check that the facility is aware of immersed compute solutions, this will require some planning on their behalf with respect to feeding pipework to rack, and a viable heat distribution strategy, i.e. local (within building), adjacent buildings or an existing or planned district heating system.
- Are they a member of the Climate Neutral Data Center Pact, more information on this link
- Have they made a statement (UK Only) as a HMG Supplier as to their compliance to PPN 0621? More information on PPN 06-21 can be found here.
- Have they published their result (pass/fail) using the EU - JRC Assessment Framework for Taxonomy Climate Delegated Act (TCDA)? The framework criteria can be found on this link.*New*
Any design and build consultancy should also be aware of these, so ask the questions of them as well, if you get negative replies or statements that dont answer the questions, go somewhere else.
So, 10 easy questions to include in your tender documentation or procurement process to ascertain if your intended data centre colocation partner is as green and sustainable as they can be.
Carbon3IT Ltd can assist in a partner selection study, and perform audits (we already do assessments/audits for EU-JRC, DCD and the DCA) which will give you the confidence that you have selected the correct colocation partner.
We can also point you in the direction of data centre design and build consultancies that have offering covering the above, so you can rest assured that your new data centre will be compliant to any new rules and regulations.
Whilst the UK has left the EU, you should also be mindful of any action that will arise from the data centre and telecoms section in the EU Green Deal, the EU have already gone on record to say that 'Data Centres, can and should be carbon neutral by 2030' and due to the climate emergency, we know that HMG will be looking into this in some detail, indeed the UK public sector can seek funding from the 'Public Sector Decarbonisation Scheme' and the 'Public Sector Low Carbon Skills' Fund for energy efficiency products and training, more info in this recent blogpost here.
The EU recently published (July 21) their 'FIT FOR 55' proposals recently which included some references to data centres, which we are currently reviewing and will be included in a new blog post shortly.
Note: Article edited on the 23/11/2020 to include items 7 & 8 which had been added to the list on the duplicate linked in post.
Note: Article Updated 27th July 2021 due to some serious data centre rewashing in recent weeks and to add items 9 & 10
Note: Article updated 9th April 2024 to repair some broken links, because certain operators are doubling down on their 'greenwashing' and to advise new EU legislation that will impact on the, frankly outlandish claims some operators persist in publishing, this will no doubt result in 'greenhushing', i.e. rolling back on their claims, the next few years are going to be interesting!