Are utility-scale data center operators on a pre-emptive mission to slay energy efficiency regulations? A "gang of six" released a letter of opposition to energy efficiency recommendations under consideration by a technical committee of ASHRAE, at least begging the question of their motivations.
The signees of the open letter represent real heavyweights, not just in terms of their collective data center infrastructure, but also in their leadership in energy efficiency.
They are James Hamilton from Amazon, Kevin Timmons of Microsoft, and Urs Hoelzle of Google on behalf of utility-scale data center operators, Chris Crosby from Digital Realty Trust and Hossein Fateh of Dupont Fabros on behalf of the wholesale developer business, and Mike Manos, formerly of Digital Realty and Microsoft, now on behalf of telecomm leader Nokia.
What is their beef? On the face of it, they want to make sure that any regulatory requirements for energy efficiency at data centers be "performance based" rather than "prescriptive". A performance-based system would essentially say "you must be at least this efficient, but get there any way you want", whereas a prescriptive system says "you must do at least X, Y, and Z".
This ignores at least one thing: ASHRAE doesn't set building construction regulations, individual states do. Yes, ASHRAE recommendations do inform the setting of those standards, but clearly there is all kinds of time for deep breathing here.
Further, ASHRAE has not proposed a prescriptive standard at all - you can use water-side economizers to get your energy use down instead of air-side. (This is of particular importance to container/modular data center designs, and to anyone seeking to use liquid cooling solutions.)
What the open letter authors appear to dislike is a potential mandate to have air-side economizers in all new data centers, even though all of them are using that very technology to reach low PUEs. Their proposal that regulators simply set a maximum PUE standard belies the fact that you simply can't get into meaningfully low PUE territory without using air-side and/or water-side economizers.
Now to inject some real controversy into the debate, such as it is. As I have noted here before, a project is underway in California to set minimum efficiency standards for data centers under Title 24, the new building code determined by the California Energy Commission. I am doing the stakeholder outreach for the project, which is sponsored by Southern California Edison.
My challenge to the "gang of six" and any other interested parties: join the stakeholder group to explain why some economizer requirement doesn't make sense, for the builders, owners, and users of data centers, and in the public policy arena. Contact me!