Bureau Brussels Consulting
Bureau Brussels Consulting helps clients manage EU regulatory relationships by tracking policy developments, building alliances, and positioning executives in key networks.
Lobbying Activity
Meeting with Margareta Djordjevic (Head of Unit Energy)
16 Oct 2025 · Meeting with BeeBeeOne, an Investment firm with own innovation department
Meeting with Ana Carla Pereira (Director Justice and Consumers)
2 Sept 2025 · Women's health
Meeting with Bruno Tobback (Member of the European Parliament)
15 May 2025 · Reusable Containers, Trays and Pallets
Meeting with Ingeborg Ter Laak (Member of the European Parliament)
8 Apr 2025 · Health care, environment
Meeting with Jeannette Baljeu (Member of the European Parliament)
8 Apr 2025 · Circular Economy
Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness) and Association of Credit Card Issuers in Europe
29 Nov 2023 · digital euro
Meeting with Joost Korte (Director-General Employment, Social Affairs and Inclusion)
7 Nov 2023 · Care4everyBody, gender equality
Response to European Critical Raw Materials Act
30 Jun 2023
The European Data Centre Association (EUDCA) represents the European data centre operator community. EUDCA is happy to submit a commentary on this consultation, and wants to draw attention to the following key points: Availability of key strategic and critical raw materials: EUDCA fully supports the European Commissions measures to ensure the supply of key critical and strategic raw materials. Raw materials are indispensable for the EUs industry and data centre operations and will be necessary for the EU to succeed in the green and digital transitions. Improving the circularity of critical raw materials: EUDCA welcomes the Commissions proposal to improve the recyclability and recovery of critical raw materials as well as the reuse of products and components containing them. However, EUDCA recommends an alignment with other legislation as well as a harmonized EU approach to be developed to achieve the objectives of this Regulation. Transparency and data availability: EUDCA welcomes the establishment of new rules for the calculation and verification of the environmental footprint of critical raw materials. This could improve transparency and the ability of data centres to assess their sustainability across their entire value chain. Please find the full EUDCA feedback in the attachment.
Read full responseData centre group urges taxonomy inclusion for energy-efficient tech
2 May 2023
Message — The group requests inclusive wording for energy equipment and the addition of data centre systems to the Taxonomy. They also advocate for flexible criteria and alignment with existing gas regulations.123
Why — This would enable data centre operators to access specialized financing for critical infrastructure upgrades.4
Impact — Environmental objectives may be compromised if the rules allow equipment using high global warming potential gases.5
Meeting with Véronique Trillet-Lenoir (Member of the European Parliament)
6 Feb 2023 · Health and gender
Response to Instant Payments
19 Dec 2022
ACCIE welcomes the Commissions proposal on Instant Payments (IPs), which will help increase consumer choice regarding preferred payment methods. ACCIE appreciates that the proposal addresses consistency with existing legislation such as PSD2 and the Regulation on Cross-Border Payments. ACCIE believes IPs could be a useful alternative means of payment for peer-to-peer transactions and could unlock financial potential for consumers and organisations. However, ACCIE would like to raise the following points regarding the use of IPs: ACCIE strongly believes that consumer choice should form the basis of developing new payment methods and policies, as preferences can differ according to payment needs and between member states. The legal enforcement of mandatory adherence to the SCT Inst. Scheme risks introducing a political approach to the payments market, which could endanger fair competition in the future. ACCIE asks the co-legislators to ensure that consumers are well-informed of the risks of IPs for consumers and businesses in terms of fraud, due to their irreversible nature. ACCIE welcomes the proposal to introduce IBAN checks on IPs, as there are currently many inaccuracies in existing screening tools for cross-border IPs. These inaccuracies might directly impact merchants and consumers as fraud prevention, fraud detection and anti-money laundering and countering financing of terrorism mechanisms may not work properly or as expected. However, even with the proposed IBAN verification, consumers should be aware that IPs offer much lower levels of consumer protection than other payment methods, such as credit card payments. Finally, ACCIE would like to note that each payment method offers a suitable solution for specific transactions, and consumer preferences vary. For example, credit cards not only offer access to a dedicated and specific credit line, increasing the freedom of consumer choice, but they also have extensive security procedures, and offer additional consumer protection such as post-transaction services when a product is damaged upon delivery, not delivered, or in case of other payment-related disputes between a merchant and cardholder. For more information, ACCIE published a comparison between credit cards, debit cards and IPs on ACCIE website: https://www.accie.eu/pdf/ACCIE%20-%20Comparison%20credit%20cards_debit%20cards_instant%20payments.pdf
Read full responseMeeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans) and European Data Centre Association
17 Nov 2022 · Multimodal ticketing
Data centre association urges F-gas exemptions for safety valves
29 Jun 2022
Message — The association suggests exempting safety valves from gas release requirements as critical safety devices. They request delaying refrigerant prohibitions until low flammability alternatives are commercially available.12
Why — This would prevent increased flammability risks within critical data centre infrastructure and battery rooms.3
Impact — Environmental groups lose as high global warming potential gases continue to be utilized.4
Bureau Brussels Consulting urges faster permitting for renewable energy projects
12 Apr 2022
Message — The group requests digitalised approval processes to shorten permit granting procedures. They also urge Member States to remove surcharges on private energy deals.12
Why — Faster permitting and tax changes would lower costs for reaching carbon neutrality.3
Impact — National procurement schemes could lose market dominance to private corporate energy buyers.4
Response to Revision of the Renewable Energy Directive (EU) 2018/2001
16 Nov 2021
The European Data Centre Association (EUDCA) represents the European data centre operator (DC) community. The EUDCA is happy to submit feedback on the review of EU renewable energy rules and wants to draw attention to the following key points:
• EUDCA welcomes the review of the Renewable Energy Directive (RED) in light of a higher EU climate ambition under the European Green Deal;
• EUDCA supports the binding target of 38-40% for renewable energy as proposed in the revised RED and also believes that through a more integrated energy system, better use of waste heat and alternative sustainable hydrogen stored energy this could be achieved;
• As already stated by the European Commission (EC), the DC industry should become climate neutral by 2030 which means that all DCs should be operating at 100% of renewable energy. As a response to this, EUDCA along with other associations has created the Climate Neutral Data Centre Pact which puts the industry on a path to meet the EC’s goal through a set of five different targets;
• Apart from an overall increased target, EUDCA supports a new indicative target for renewables which should be increasingly deployed into the sectors such as heating and cooling.
• EUDCA would like to point out that a steep increase in the renewable energy target has to be supported by large-scale EU investment in green and sustainable energy production as well as to ensure the roll-out of ambitious frameworks to enable corporate clean energy procurement. Shortage of available renewable energy will lead to price increase of energy and consequent negative industry position of EU companies vs other countries.
Read full responseResponse to Review of Directive 2012/27/EU on energy efficiency
16 Nov 2021
The European Data Centre Association (EUDCA) is happy to submit feedback on the review of the Energy Efficiency Directive (EED). As a signatory of the Climate Neutral Data Centre Pact (Pact), EUDCA supports the revised EED and has attached its feedback, jointly developed with the members of the Pact.
Read full responseResponse to Energy statistics - updates for annual, monthly and short-term monthly data
3 Aug 2021
The European Data Centre Association (EUDCA) represents the European data centre operator community. The EUDCA is happy to submit feedback on updating the arrangements for the annual, monthly and short-term monthly collection of energy statistics (Annexes B, C and D of Regulation 1099/2008) and wants to draw attention to the following key points:
• Annex B on Annual Energy Statistics to the Directive includes the indication to an EU wide mandatory reporting for data centres to start in 2024 The EUDCA proposes that the EU-wide reporting shall be done through the Climate Neutral Data Centre Pact (CNDCP) initiative, starting in 2022 for each subsequent year. The gathering of the data is to be executed by the national statistical body of each country that is connected with each member of the CNDCP.
• In Annex B, it is stated that only data centres hosted by reporting units (regardless of their NACE code) with a total power capacity of 1 MW or more need to be declared for reporting. This means that the existing older and the new “Edge” data centres consisting of a few hundred kW IT capacity will be left out, while the first group is operating less efficiently than data centres of 1MW and the second group of many hundreds of edge data centres will not have any oversight. Therefore, the EUDCA proposes to lower the reporting threshold of data centres to 250 kW. This threshold would result in the inclusion of more than 80% of the total data centre capacity.
• Finally, the EUDCA would like to point out that the EU should put in place mechanisms to protect the energy market from speculation and therefore including the monitoring of energy and carbon prices into the statistics. We see that speculation raises the price of green energy significantly and jeopardises the green transition of many data centre companies. By including this we can monitor the effects on the energy transition.
Read full responseResponse to Policy Program - Digital Decade Compass
22 Jul 2021
European Data Centre Association (EUDCA) represents the European data centre operator (DC) community. EUDCA is happy to submit feedback to Policy programme – Digital Decade Compass consultation and wants to draw attention to the following key points:
• In general, EUDCA supports the direction of this document. Nevertheless, the European Commission (Commission) is still not completely familiar with the data centre industry.
• The Commission refers to the concepts such as, cloud and Edge, but it often forgets that the data centre industry facilitates them with connectivity and space. EUDCA members have larger cloud providers as customers, but also the local SI, DDOS mitigation companies, content distribution networks, telco operators and content providers. Data centres’ customers include SME and large enterprises.
• Please find below EUDCA’s three main comments on the areas that are outlined in the Commission’s Digital Decade Compass:
1. Digitally skilled citizens and highly skilled digital professionals
It is very important for data centre operators to find skilled engineers. EUDCA thinks that upgrading of skills of existing employees, retraining of people in sectors where labour demand declines, and activation of unemployed to fill all vacancies are needed. A rise in labour productivity, by speeding up automation and digitalisation, is necessary to compensate for the demand for jobs.
EUDCA wants to encourage young people to choose courses that are geared towards the digital future. An increase of the budget for STEM study programmes and tailor made study programs should be promoted like the initiative of several universities. It is important to give digital and digital-related skills a more prominent place in all study programmes which would eventually result in data centre education at middle, Bachelor and Master level.
2. Ambition: highly secure edge nodes
As the data centre industry, we support this ambition as our members can facilitate such deployment. We can bring our data centres and connectivity to the table. These nodes can be integrated in the GAIA-X ambition of our market.
Not only cloud and edge, but also colocation services are important. Many Systems Integrators and digital services companies are housed in our data centres and provide managed services, private cloud, hybrid and multi cloud solutions.
3. 75% of European enterprises have taken up cloud computing services, big data and Artificial Intelligence
EUDCA’s point of view is that this ambition level should also include data center services: colocation. IT work loads are managed by many local European Systems Integrators and digital services companies in private clouds. GAIA-X is the perfect platform to aid the development of a ecosystem of an European digital sector. Colocation data centers provide the platform for these services.
Read full responseResponse to Data Act (including the review of the Directive 96/9/EC on the legal protection of databases)
24 Jun 2021
The European Data Centre Association (EUDCA) represents the European data centre (DC) operator community. The EUDCA is happy to submit feedback on the new rules for the common European data spaces and wants to draw attention to the following key points:
• EUDCA members host several customers who regularly share and commercialise data on both B2B and B2G.
• EUDCA welcomes the aim of the Roadmap of the Data Act initiative of creating a fairer and more competitive data economy in Europe.
• EUDCA supports data sharing as a founding element to drive the future data economy.
• EUDCA believes that the Commission’s proposal shows a fair and largely future-proof roadmap, forming a strong position for European companies to avoid large platforms driving all businesses from third countries.
• However, EUDCA would like to emphasise that there is already a broad range of regulations that are already in place. Therefore, it would encourage a cautious approach when putting additional regulations in place in order not to create a regulative environment hampering innovation and growth. To avoid overregulation, uncertainty and fragmentation, the Commission should address potential overlapping legislation.
• Consequently, the Commission should clarify the aims and scopes of the different pieces of legislation around the Data Act rules.
Read full responseResponse to Ecodesign and energy labelling working plan 2020-2024
2 Jun 2021
Please find the EUDCA's submission to this consultation in the attachment.
Read full response2 Apr 2021
EUDCA Data Centre Association (EUDCA) represents the European data centre (DC) operator community. EUDCA is happy to submit feedback on State subsidies - the exemptions to approval requirement for the Green Deal and EU industrial and digital Strategies. Based on Commission’s Roadmap, EUDCA considers that exemptions to state subsides should be:
1. Aligned with EU priorities
EUDCA supports the proposed changes to exemptions that are needed to reflect EU priorities, specifically those proposed in the Green Deal, the industrial and digital strategies, given that the scope of investments would include broadband.
These investments are to be tested and monitored to create and safeguard a level playing field regarding government data centers and the free market.
More specifically, investments in government data centres are also best suited to follow the metrics provided by the self-regulatory initiative of the Climate Neutral Data Centre Pact (CNDCP), given that this self-regulatory initiative will lead towards the reduction of CO2 emissions.
2. Include connectivity for colocation data centres
EUDCA believes all broadband/ fiber/ 5G/ connectivity initiatives should be made available in all colocation data centers so that connectivity becomes available for a large number of operators.
3. In line with GAIA-X
EUDCA believes that the initiatives in the field of digital strategies must be tested against the GAIA-X framework, given that the GAIA-X ecosystems ensure optimal data exchange.
Read full responseResponse to Revision of the NIS Directive
18 Mar 2021
European Data Centre Association (EUDCA) represents the European data centre (DC) operator community. EUDCA is happy to submit feedback on the revision of EU rules on the security of network and information systems and wants to draw attention to three main remarks that it identified concerning the NIS2 Directive proposal which are the following:
1) Inconsistencies in the implementation of the Directive in Member States
2) Need for clarification on definitions and scope
3) An unbalanced approach
4) Overlap between OES and OIS within the supply chain
Please find further explanation on these points in the attachment.
Read full responseResponse to Modernising the EU’s batteries legislation
1 Mar 2021
The European Data Centre Association (EUDCA) represents the European data centre (DC) operators community which are users of industrial storage batteries and are positioned downstream of both production and manufacturing. EUDCA is pleased to submit a commentary to this consultation, and wants to draw attention to the following key points:
• EUDCA supports this revision - continually moving our sector towards the elimination of waste and the reuse of raw and active resources in a safe, competitive and sustainable economy.
• DC aim to be fully renewable by 2030 and experiment with new technologies - batteries are a key component to decarbonised energy sources. Whilst focusing on the deployment of large-capacity/long-term energy storage, DCs aim to exploit battery types with Lithium-ion storage for large capacity/ short term energy gaining market share.
• In support of a more circular economy - DC’s are heavily dependent upon robust energy storage and batteries. Europe should be a leader in research and development of energy storage technology and have access to a robust and competitive market for sustainable products and solutions.
• DC’s as industrial battery end-users - support full traceability of materials, clear regulation regarding battery & energy storage performance and life cycle, security of supply and the effective use of raw and active materials and their reuse in promoting low carbon economy.
Please find the rest of EUDCA's feedback in the attachment.
Read full responseResponse to EMAS Sectoral Reference Documents for Telecommunications/ICT services
9 Feb 2021
The European Data Centre Association (EUDCA) represents the European data centre operator community. The EUDCA is happy to submit feedback on the Environmental management & performance – sectoral reference document for telecommunications/ICT.
The data centre industry has always been concerned with Efficiency and Sustainability. Over the past 20 years, data centres have delivered a reduction of 60-85% of the energy used by its business to support their customers. Furthermore, many data centre operators have consumed renewable energy sources for over a decade and are continuing to increase the renewable energy factor. The industry has also adopted various international and regional standards on efficiency as well as European Commission (Commission) recommended guidelines as captured in the GPP and EU Code of Conduct of the JRC. Finally, the data centre industry has just launched a binding self-regulatory initiative with the Climate Neutral Data Centre Pact – jointly founded by the EUDCA and CISPE. Already, well over 50% of the data centre industry, in terms of power capacity, has signed up to operate within these guidelines. As such, any further regulation or voluntary recommendation is probably superfluous. Specifically, most of the provisions in this document are covered very clearly in other standards and guidelines.
Thus, EUDCA wants to draw attention to its specific commentary on the recommendations:
• Under WEEE, every data centre operator is required to achieve 100% recycling targets. It is Public Bodies and Private Businesses operating server rooms that are most concerned here.
• Please note that in section 3.1.5 of the Annex, reuse and refurbishment targets are being crafted now based on capability of equipment, and customer data privacy concerns. This will require a whole of economy approach to achieve meaningful improvement.
• Every commercial data centre operator manages all items in sections 3.1 and 3.2 as standard. It is only Public Bodies and Private Companies operating small scall server rooms that usually do not have the capabilities to measure. Hence, EUDCA believes that the Commission’s recommendation is targeted at the wrong ICT group.
• Regarding section 3.2.7.2, reuse of heat is carried out by operators where district heating services make it possible. Without a broad change in district heat policy across Europe, waste heat cannot be delivered and used effectively.
• EUDCA applauds the Commission calling out the benefits of digitisation to green the whole economy. Nevertheless, EUDCA feels the Commission should put more effort into codifying the climate neutral value of digitisation over the further addition of metrics on an industry already replete with standards and metrics.
Read full responseResponse to Legislative framework for the governance of common European data spaces
1 Feb 2021
The European Data Centre Association (EUDCA) represents the European data centre operator community. The EUDCA is happy to submit feedback on the new rules for the common European data spaces and wants to draw attention to the following key points:
• Colocation DCs provide space, power, cooling, and physical security for the server, storage, and networking equipment of other firms. These firms are Enterprises, Public Bodies, Technology Companies, Network Operators, and Cloud Service Providers. Data centres also connect these firms to a variety of telecommunications and network service providers – they are the physical part of data infrastructure. We call this Interconnection.
• Therefore, data centres are not to be considered as data processors nor as data intermediaries or data brokers, as suggested by the point 22 of the proposal for Data Governance Act.
• However, members of EUDCA support data sharing and the creation of common European data spaces as a founding element of the future data economy, but it can only formulate its position on the infrastructure level which underpins the systems of Data Exchanges.
• As an association of data centres which account for physical data infrastructure, EUDCA focuses on issues of providing physical security to data which should be connected through an auditable network. Furthermore, data centres provide a unique environment for firms to house and trade data without being locked in to a single vendor. This is a powerful element of successful Data Exchanges.
• As providers of the infrastructure ecosystem, EUDCA also focuses on the different means of Interconnection besides the Internet. For a large amount of data exchange, direct connection represents a better solution. Interconnection as a form of networking is more secure, faster and more cost effective than the Internet.
EUDCA members host tens of thousands of customers who regularly share and commercialise data. Data sharing and data spaces exist in many industries for decades such that well-known practices for collecting, storing, normalising, exchanging and protecting data exist already.
There are three layers of data spaces: the data market place (data exchange market), the set of governance regulations and the physical infrastructure level. Data centres operate in the physical infrastructure layer where they provide interconnection to multiple clients. The current model of the Internet is not adequate for the exchange of a large amount of data. The means of direct interconnection such as dark fibre, cross-connect and virtual circuits represent better solutions as they provide lower latency.
The data centre infrastructure is facilitating systems of data exchange, providing a most flexible, secure and least costly system. The existing system of private data storage unit using the same dark fibre to access information on the cloud is an example. For instance, banks have their data in data centres, as they are the perfect place to store data, which can still be accessed by the cloud as well as traded and routed securely and effectively using Interconnection.
Read full responseResponse to Climate change mitigation and adaptation taxonomy
18 Dec 2020
Please find attached EUDCA's response to this consultation which was developed in close cooperation with the Cloud Infrastructure Services Providers in Europe (CISPE).
Read full responseResponse to Revision of the Energy and Environmental Aid Guidelines (EEAG)
10 Dec 2020
The European Data Centre Association (EUDCA) represents the European data centre operator (DC) community. The EUDCA is happy to submit feedback on the review of state aid guidelines for environmental protection and energy and wants to draw attention to the following key points:
• EUDCA welcomes the review the Guidelines on State Aid for Environmental Protection and Energy (EEAG) in the light of the twin green and digital transformation of the economy under the European Green Deal (EGD);
• Current EEAG (2014-2020) are obsolete and do not adequately address the EU’s increased environmental ambition and the climate neutrality by 2050 goal stipulated under the EGD;
• The revised EEAG should focus on the energy system holistically (electricity, gas, heating and cooling). Such an approach is in line with both the technology neutrality principle and the process of energy system integration;
• As already stated by the European Commission (EC), the DC industry should become climate neutral by 2030 which means that all DCs should be operating at 100% of renewable energy;
• EUDCA believes that Power Purchase Agreements (PPAs) represent the best alternative for increasing renewable energy consumption and can serve to drive new developments of grid-scale renewable energy sources;
• Thus, DC’s PPAs should be encouraged and supported in the form of reductions in the funding of support for energy from renewable sources.
Read full responseResponse to Sustainable Products Initiative
2 Nov 2020
The European Data Centre Association (EUDCA) represents the European data centre operator community. EEE (Electrical and Electronic Equipment) technologies are critical to energy transition and decarbonisation of EU and global economy. We believe is it crucial to push EU towards:
• Transparent and digital EPD/Environment Product Declarations for products and systems, inclusive of CO2 footprints; EU Initiative called Product Environment Footprint (PEF) is heading towards this very precise direction, with a number of PEF pilots already delivered, such as on UPS/Uninterrupted Power Supply Technologies.
• EU PEF program has selected and recognised PEP ecoPassport and Orgalim as anchors of this PEF experimentation phase. PEP ecoPassport has been WW leading Program Operator to guide and promote production of EPDs in the ICT sector, with today thousands of ICT Product Categories covered by strictly developed.
• A recognition of the specificity of EEE technologies: indeed, whilst they have an embodied CO2 (through the materials contained and upstream supply chain steps), and some of them trigger some energy consumption and CO2 emissions during their lifetime, many of them have an overall beneficial effect onto their users’ own CO2 footprint, such as through their Buildings, Data Centres, Plants, or else. Indeed, Building Management Systems, Smart and connected data centres, can trigger much more CO2 avoidance and savings than they contain embodied CO2. With this in mind, whilst EPDs/PEFs will remain critical to assess CO2 impacts of products, it is critical that simultaneously the science of “CO2 Scope 4” calculations understood as “benefits delivered on Customers’ end”, concurrently emerges. In our sector, the ratio of “Scope 4” divided by “Scopes 1+2+3” can often be superior to 1, ie our technologies and systems help avoid & save more CO2 than they contain or emit.
• We plead for external verification and assurance of any Environmental footprint or impact data. Only external and independent validation, based on agreed upon Product Specific Rules (PSRs), will allow EU to ensure the right technologies are adopted towards fast EU decarbonisation.
• We plead for EU to recognise and leverage existing Industry Sector specific initiatives, and not reinvent a new language, norms, or vocabulary, as our ICT sector has more than 10 years leadership in Environmental data accounting and reporting. In the Circular Economy space for instance, our Industry sector, through CEN/CENELEC, has already been working extensively on defining relevant Metrics, ranging from Recycled Content of course, but for ICT technologies lasting 5, 10, 30 years, metrics such as IoT nature, upgradability, retrofitablity, etc are paramount.
• We believe Public Procurement has a major role to play, moving from one-off initial procurement costs assessment, to more lifecycle costs. Same applies to CO2 and Environmental impacts, where we urge Public and Private players in Europe (and beyond), to look beyond initial “Capex” costs to Lifecycle Costs”.
• We support EU’s vision to aspire to a Product Environment passport, bringing together different dimensions of Climate/CO2, Resources/Circularity, Biodiversity/Substances, meanwhile recognizing the need to strictly prioritise between such priorities.
• We encourage any EU’s effort to help simplify the triangulated challenges known as Chemicals, Products, Waste (CPW).
Read full responseResponse to Review of Directive 2012/27/EU on energy efficiency
21 Sept 2020
The European Data Centre Association (EUDCA) represents the European data centre operator (DC) community. The EUDCA is happy to submit feedback on the review of EU energy efficiency directive (EED) and wants to draw attention to the following key points:
• EUDCA welcomes the review of the EED in the light of a higher EU climate ambition under the European Green Deal;
• EUDCA supports a higher 2030 target for energy efficiency (from at least 32.5%) as they are themselves as highly energy efficient industry;
• Reducing greenhouse gas emissions (GHG) and improving energy efficiency is corelated – for example, 1), DC’s are buying sustainable energy to a large extent as the prime source to operate; 2) DCs are seriously investigating their design future without the use of fossil-fuel back-up generators. Instead of these back-up diesel generators and grid supply, DCs are planning on making use of hydrogen fuel cells (HFCs), coupled as large-scale / long-term energy storage solutions and prime energy source. This technology could significantly lower carbon emissions and improves energy efficiency onsite as energy is no longer wasted as heat. As the by-product of HFC is water, it could be re-used for other purposes. Overall, producing energy onsite contributes to energy efficiency as much less energy is lost in transit when it is produced elsewhere and needs to be carried over lines that may be many km in length. ;
• However, emissions can be solved by sustainability, but efficiency can be solved by other means;
• EUDCA would like to work closely with the European Commission (EC) on adopting best practices and promoting improvements in the EU Code of Conduct (EUCofC) for DCs;
• EUDCA would like to bring to the EC’s attention that any DC legislation or policy should differentiate and promote efficient DC versus inefficient DC including enterprise DC over a certain size. Financial support to public and private users of servers to migrate to efficient DC would help get companies to continue studies and pilot adopt efficient IT solutions.
Read full responseResponse to Revision of the Renewable Energy Directive (EU) 2018/2001
21 Sept 2020
The European Data Centre Association (EUDCA) represents the European data centre operator (DC) community. The EUDCA is happy to submit feedback on the review of EU renewable energy rules and wants to draw attention to the following key points:
• EUDCA welcomes the review of the Renewable Energy Directive (RED) in the light of a higher EU climate ambition under the European Green Deal;
• EUDCA also believes that through a more integrated energy system, better use of waste heat and alternative sustainable hydrogen stored energy, the EU renewable energy target could be raised (from at least 32%) leading to an overall increase of the 2030 target for GHG reduction;
• As already stated by the European Commission (EC), the DC industry should become carbon neutral by 2030 which means that all DCs should be operating at 100% of renewable energy;
• EUDCA would like to point out that a steep increase in the renewable energy target could seriously hinder the progress in other sectors due to the lack of available sustainable energy across the EU. Therefore, this transition has to be supported by large-scale EU investment in green and sustainable energy production.
Please find attached the rest of EUDCA's feedback in the attachement.
Read full responseResponse to Review of EU rules on fluorinated greenhouse gases
7 Sept 2020
The European Data Centre Association (EUDCA) represents the European data centre operator community. The EUDCA is happy to submit feedback on the review of rules on flourinated greenhouse gases consultation and wants to draw attention to the following key points:
• We must ensure via study that any restriction caused by policy results in a net improvement in overall sustainability. Data centre operators which use refrigerants extensively often do this to perserve drinking water for the community and surrounding environment. In many EU states drinking water is a high environmental priority and the preservation of it central to integrating data centres into sustainable communities.
• Replacement refrigerants such as alkenes which are non-toxic and have lower GWP (globall warming potential) and ODP (Ozone Depletion Potential) are in development and being adopted in many member states, but these currently reduce electrical efficiency resulting in higher power consumption for the IBX.
• So for this example of the “dry” IBX we are weighing an emmissions risk which occurs on escape of hydrofluorocarbons (HFC) refrigerants contained during normal operation, against electrical efficiency reduction which (in most member states) causes a direct increase in GGE.
• It is not yet clear what specification sustainable refrigerants will achieve by 2030 and consequently not easy to settle on a policy for this period. To support the path to HFC removal while maintaining an improvement tragectory for overall sustainability, we recommend an evaluation policy which is updated with available technology up to and beyond 2030.
Items for consideration include the following:
1. Incentives for sustainable refrigerant use in data centres
2. Support of industry for research and development of sustainable and efficient refrigerants and cooling plant
3. Association of allowable refrigerant use with
a. year-round energy efficiency / coefficient of performance limits.
b. efficient volumes / quantities of refrigerant gases and secure containment of these.
c. Water use efficiency and preservation of water sources
4. Containment rules for HFC refrigerants / controlled consequence for escape of HFC gases.
Any consideration of tariffs or removal of HFC refrigerants from circulation in the immediate term should be studied and be cogniscant of:
a. Presence of equivalent available alternatives
b. Effect of operating cost in EU states vs outside
c. Carbon leakage in other economic zones
d. Increases in GGE from higher electricity consumption
e. A migration back to extensive water use for IBX cooling.
Read full responseResponse to Revision of the NIS Directive
11 Aug 2020
The European Data Centre Association (EUDCA) represents the European data centre operator community. The EUDCA is happy to submit feedback on the the revison of the Network and Information Security Directive (NIS Directive) and wants to draw attention to the following key points:
• There is embedded ambiguity in the directive in that it addresses Network & Information Services for Operators of Essential Services (OES) and Digital Service Providers (DSPs). In several cases, essential services are digital services (as well as the services of the DSPs ) which requires separate Network & Information Systems to manage these digital services.
• Currently, data centre operators are addressed differently in Member States depending if the data centre (Non-IT infrastructure managed with IT) or Connectivity product (Network Service managed via an IT estate) or combination is deemed essential service.
• For organisations where these multiple domains (the IT services to manage the essential service, the non-digital essential service and the Digital services provided) are managed by different parties, the directive can provide confusion and ambiguity in organising security incident prevention, monitoring and follow up, especially for organisations where the Digital Services provided are managed from a different Member State or outside the EU.
• At this stage, Member States do implement different granularity of regulations for essential services which can lead to misalignment in case of cross boundary management of services.
Therefore, EUDCA would like to propose several changes to the revised NIS Directive:
1. Greater clarity/guidance on the definitions of DSP and OES to enable organisations to self-report more effectively on whether they are subject to the NIS Directive. The Member States have different criteria for being deemed a DSP or OES and this leads to uncertainty and inconsistency in an organisation’s approach per Member State.
2. There is a lack of consistency in the approach adopted by different Member States and the relevant Supervising Authorities in those Member States. Whilst EUDCA appreciate the implementation of a Directive which is subject to variation on a Member State basis, this variation in approach means that organisations that operate in more than one Member State will potentially need to adopt different operational solutions/processes to ensure compliance and this can lead to added complexity and ultimately, cost.
3. Linked to point (2) above, as a pan-EU organisation, EUDCA’s member companies have had varied contact from the Supervising Authorities in the Member States with their different approaches and again, there is a lack of consistency in the Supervising Authorities’ actions.
Read full responseResponse to Legislative framework for the governance of common European data spaces
31 Jul 2020
The European Data Centre Association (EUDCA) represents the European data centre (DC) operator community. The EUDCA is happy to submit feedback on the new rules for the common European data spaces and wants to draw attention to the following key points:
• Colocation DCs provide space, power, cooling, and physical security for the server, storage, and networking equipment of other firms. They also connect these other firms to a variety of telecommunications and network service providers – they are a physical part of data infrastructure.
• EUDCA supports data sharing and the creation of common European data spaces as a founding element of the future data economy.
• Cross-sectoral data sharing should be in compliance with the GDPR where users keep personal ownership of their data despite it being shared.
• The EU should create a regulatory environment which would enable data sharing but also ensure that ownership of data is codified in a standardised set of rules on data ownership on the EU level.
• As an association of DCs which account for physical data infrastructure, EUDCA would like to focus on providing physical security to data which should be connected through an auditable network.
High level – the European Data Centre Association members host tens of thousands of customers who regularly share and commercialise data. Data sharing, and data spaces exist in many industries for decades such that well known practices for collecting, storing, normalising, exchanging and protecting data exist already.
However, the European Commission is right to look at data sharing as the economy digitises and the value of data becomes more important. Furthermore, the ability to truly digitise economies rests in open standards that allow broad access across individuals, enterprises and public bodies.
• The use of public data for the common good will require adopting current best practices and building open systems using APIs and data normalisation standards. However, these practices will have a cost to taxpayers to maintain public data. These public assets have value and should be protected both physically and legally such that private benefits are shared with the public. These will require very secure physical infrastructure and connectivity underpinning governance systems. A method for publishing available data sets on a public data marketplace would be a valuable resource.
• Individuals should be informed about the data they create directly and indirectly and be able to differentiate data that they want private and that which could help a digital economy. Citizens should have clear rights to data they create, with trust that public bodies will uphold and defend these rights. However, public bodies and private enterprises need easy access to personal data sets to provide improved and new digital services. This suggests that policy in data spaces should be concerned with cost effectiveness and efficiency as well as regulation. Highly complex systems will drive users to take up services elsewhere that are easier but may not have the citizen or public good in mind.
• Structures to enable sharing of data should be defined both simply and at a low logical level – ie: public bodies should ensure that fibre-optic backbone networks, mobile and fixed line access networks, datacentres, managed and cloud services can all invest in and develop the necessary physical infrastructure they need as cost effectively as possible. This digital infrastructure underpins efficient data sharing. Governance should focus on defining data ownership and rights and transferance of these much what exists in the physical world.
Read full responseResponse to Revision of the EU Emission Trading System Accreditation and Verification Regulation (AVR)
24 Jul 2020
The European Data Centre Association (EUDCA) represents the European data centre (DC) operator community. The EUDCA is happy to submit feedback on the implementation of Phase IV of the EUETS and wants to draw attention to the following key points:
• The EUDCA wholeheartedly supports policy that will drive down Greenhouse Gas (GHG) emissions and recognises that EUETS is a key component of this. However, the application of such policy measures should be targeted effectively to ensure that undue burden is not placed on unintended sectors, whilst still achieving the policy objectives.
• A strong DC sector is a vital element in leveraging the European economy towards a lower carbon future and should be supported, rather than hindered in this mission.
• The EUETS is targeted at large Scope 1 emitters. DCs are ultra-low emitters. They are included in the scheme solely by virtue of having large on-site emergency back-up power generation plant. DC generator plant is typically only ever operated for emergency back-up power and testing purposes, normally operating for less than 50 hours per year.
• ‘Article 27 a’, a policy tool designed to exempt ultra-low emitters from Phase IV of the EUETS and its associated bureaucratic burden, does not meet its objective. DCs should be automatically excluded from EUETS.
The EUETS is a legislative instrument targeted at large Scope 1 emitters (i.e. sites combusting significant volumes of fuel, such as power stations). The policy objective is not reflected in the criteria for participation in the scheme, which are focussed on combustion capacity rather than emissions.
The data centre sector is characterised, perhaps uniquely, by having both large installed generating capacity and minimal activity. Despite negligible Scope 1 emissions, many DCs are therefore obliged under EUETS.
The sector is clearly not the intended target of the regulation and the current approach to implementation and enforcement is burdensome and delivers no beneficial outcomes. Compliance costs dwarf allowance costs, sometimes by as much as a factor of 100:1.
Other EU nation states have explicitly, or implicitly, placed such DC installations out of scope of EUETS and we believe that the EU should make sector specific concessions to address those instances where enforcement of EUETS delivers no policy outcome. Also, a disparate implementation regime across the EU is at best unfair and at worst, creates market distortion.
Under the current proposed rules for EUETS Phase IV (2021 to 2030), ‘Article 27 a’ is the mechanism intended to facilitate ultra-low emitter ‘exemption’ from the full EUETS compliance burden. However, there is a very significant caveat: Article 27 a does not exempt operators from the EUETS itself and has its own compliance requirements. Utilisation of Article 27 a requires an operator to provide three years of verified data [from historic EUETS compliance]. The requirement to provide three years of verified data in order to be exempt is illogical. Further, installations that reach have reached the threshold for EUETS compliance within the last three years will not have three years of verified data, despite being some of the smallest emitters in the scheme. Similarly, new sites reaching the threshold during Phase IV will have to participate in the full scheme until its end, or at least the mid-point review point if applicable.
In conclusion, the EUDCA supports policy instruments that will drive genuine reductions in GHG emissions. However, the application of EUETS to the DC sector does not meet this policy objective and DCs should be automatically excluded from the scheme. In addition, the existing inclusion of the DC sector within EUETS is inconsistently applied within member states and the policy tool, Article 27 a, designed to exempt ultra-low emitters from EUETS will not meet its intended purpose.
Read full responseResponse to Modernising the EU’s batteries legislation
9 Jul 2020
The European Data Centre Association (EUDCA) represents the European data centre (DC) operators community which are users of industrial storage batteries and are positioned downstream of both production and manufacturing. EUDCA is pleased to submit commentary to this consultation, and wants to draw attention to the following key points:
• EUDCA supports this revision - continually moving our sector towards the elimination of waste and the reuse of raw and active resources in a safe, competitive and sustainable economy.
• DC aim to be fully renewable by 2030 - experiment with new technologies, batteries are a key component to decarbonised energy sources. Whilst focusing on the deployment of large-scale / long-term energy storage. DCs aim to exploit ‘other’ battery types as defined in the 2019 Battery Directive with lithium-ion storage gaining market share.
• In support of a more circular economy - DC’s are heavily dependent upon robust energy storage and batteries. Europe should be a leader in research and development of energy storage technology and have access to a robust and competitive market for sustainable products and solutions.
• DC’s as industrial battery end users - support full traceability of materials, clear regulation regarding battery & energy storage performance and life cycle, security of supply and the effective use of raw and active materials and their reuse in promoting low carbon economy.
Please find enclosed the rest of EUDCA's feedback in the attachment.
Read full response30 Jun 2020
The European Data Centre Association (EUDCA) represents the European data centre (DC) operators community. EUDCA is pleased to submit commentary to this consultation, along the following lines:
• EUDCA welcomes the initiative to create regulations across the 27 member states in lieu of leaving decisions to individual states, which would lead to a fragmented regulatory landscape.
• EUDCA agrees with the Context as defined in the document. There is an increasing concentration of market power in the hands of a few global online platforms, due to the network effects of the platform consumption model.
• EUDCA supports the overarching policy objective to ensure a fair trading environment and to increase the innovation potential and capacity across the online platform ecosystem.
• EUDCA partially agrees with the problem defined in terms of these online platforms acting as gate-keepers. While it is accurate that the nature of these platforms favours aggregation of demand, the network effects create value for the users and allow the emergence of business ecosystems.
• It is our opinion that regulations should be aimed at improving the ability of European businesses to leverage the scale of the global online platforms and innovate on top of them. This appears a more viable business model than competing directly against global platforms or attempting to substitute them, because the global economies of scale make such propositions unrealistic.
• Any regulation aimed at containing the network effects would damage the ecosystem, would put European consumers at a disadvantage vis-à-vis other areas of the world, would slow down the roll out of digital infrastructure in Europe, and would ultimately diminish the ability of European businesses to compete effectively and innovate. Consequently, the EUDCA recommends to focus the regulations on diminishing the power of the platforms to integrate the upstream and downstream value chains, where the room for innovation lies.
Please find the rest of EUDCA's feedback in the attachment.
Read full responseResponse to Strategy for smart sector integration
8 Jun 2020
The European Data Centre Association (EUDCA) represents the European data centre (DC) operators community. EUDCA is pleased to submit commentary to this consultation, and wants to focus on the following key points:
• EUDCA supports this Strategy - as a fully electrified industry, we believe that only through creating a smarter, more integrated and optimised energy system can all sectors fully contribute to decarbonisation.
• DC aim to be fully renewable by 2030, as well as experiment with new technologies and decarbonised energy sources such as hydrogen, whilst focusing on the deployment of large-scale / long-term energy storage. DCs aim to explore geo-thermal energy sources as part of a circular energy system;
• To become more circular and energy efficient, the industry is also investigating options like the use of waste heat from DCs to heat buildings, which could take place via a district heating network.
EUDCA supports the Commission in creating an enabling framework across sectors which can fully contribute to decarbonisation. Although DCs consume a large amount of electricity, due to their energy efficiency and use of sustainable resources they have a relatively small carbon footprint, determined by the increasing demand for data storage. The European DCs envision themselves as central to the EU’s energy transition and are already contributing to smart sector integration through:
1. Promotion of renewable and decarbonised gases such as hydrogen
EUDCA sees hydrogen as an important element of this Strategy. The DC industry is working towards the replacing of fossil-fuel back-up generators with hydrogen fuel cells (HFCs), coupled with large-scale / long-term energy storage solutions (see attachment). HFC technology and large energy storage, supported by smart computing power, would optimise the energy consumption of DCs based on the actual supply and demand on the wholesale electricity market. Hydrogen technology would enable the DCs to go off the grid when necessary and even let them deliver energy, thus stabilising the energy supply. To run sustainably there must be a competitive market for green hydrogen - the generation of hydrogen from renewable energy sources.
This technology significantly lower carbon emissions and improves energy efficiency onsite as energy is no longer wasted as heat. As the by-product of HFC is water, this can also be used to cool the DCs.
DCs want to explore different green friendly energy alternatives such as geo-thermal and geo-thermic sources, which contribute to the circularity of an energy system.
2. Building a more circular energy system, making use of various waste resources for energy purposes, and implementing the energy-efficiency-first principle
Almost all electricity of DCs is converted into heat. Using low caloric residual heat of maximum 30 C water temperature, made from green electricity, has great potential. If we accelerate the use of the DC residual heat for households, offices and pools, we can achieve a CO2-emission reduction and provide heat sources free of emission of nitrogen and fine particles. This means we can help accelerate the energy transition and reach the climate goals within the given timeframes. These projects require strong private-public cooperation.
The path towards a digital and circular economy requires flexibility in existing legislation to look ahead and create several scenarios when it comes to the demand and investment for heat networks. Combined European efforts can upscale the use of this already available long-term green energy source.
Alongside relevant legislation, investing in research can help to make the heat more usable. For instance, conducting more research on low temperature heat networks and new cooling techniques as liquid cooling raises the temperature of the residual heat. In this way, the heat can be used for more purposes. If all energy of DC can be re-used for heating, this might be a future proof for circular solution.
Read full responseResponse to Revision of the guidelines for trans-European Energy infrastructure
8 Jun 2020
The European Data Centre Association (EUDCA) represents the European data centre (DC) operators community. EUDCA is pleased to submit commentary to this consultation, and wants to draw attention to the following key points:
• EUDCA supports the revision of the Trans-European Networks for Energy (TEN-E) infrastructure framework as a key enabler towards the Union’s decarbonisation objectives for 2030 and 2050;
• In order to enable smart sector integration, EUDCA believes that the revised TEN-E framework should foster the deployment of innovative technologies and infrastructure such as smart grids, networks for hydrogen and other carbon-neutral/renewable sources and energy storage. This would increase the efficiency of the energy networks with positive impacts on overall costs for energy consumers.
• EUDCA envisions that the smart grid would be based on a European super grid, where all well- founded sustainable energy sources will inject their capacity into this super grid.
In line with the European Green Deal and the accelerated take-up of renewable energy sources and smart sector integration, EUDCA believes that regulatory framework for energy infrastructure, including the guidelines for TEN-E Regulation, needs to be reviewed to ensure consistency with the 2050 climate neutrality objective. The revised TEN-E framework would offer better conditions for the rollout and scaling up of hydrogen across sectors, which would in turn help in developing a sizeable, well-functioning clean hydrogen market and a cost-effective infrastructure.
The European DCs are already replacing diesel-fueled backup generators with environmentally friendly alternatives such as hydrogen fuel cells and larger energy storage solutions. As a result, the European DCs can stabilise energy supply by generating energy onsite, which results in the increased reliability of power grids. Furthermore, supported by smart computing power, hydrogen technology would enable the DCs to go off the grid when necessary and even allow them to deliver energy to this grid. (see the Future of Energy Vision in the attachment)
The smart grid would be based on a European super grid, where all well-founded sustainable energy sources will inject their capacity into this super grid. For instance, the super grid would encompass tidal energy from the North Sea, solar energy from the Southern countries, wind energy form the various areas, geo-thermal and geo-thermic from more isolated areas to better investigate the impact around the various concerns on ground pollution and earthquakes.
EUDCA would like to point out that projects such as generation of green hydrogen and geothermal and geothermic which are not commercially viable, despite important socio-economic benefits, need financial assistance for their implementation.
Read full responseResponse to A EU hydrogen strategy
8 Jun 2020
The European Data Centre Association (EUDCA) represents the European data center (DC) operators community. EUDCA is pleased to submit commentary to this consultation, and wants to draw attention to the following key points:
• EUDCA welcomes an EU hydrogen strategy launched alongside the Strategy for energy system integration which outlines a framework enabling scaling-up of hydrogen.
• EUDCA supports all initiatives to replace all fossil fuel energies by carbon neutral energies. This will go through a deep swing in the primary energy from fossil to electrical. Thus, all sources of carbon free electrical energy sources will be the prime choice for all responsible industry and policy.
• DC operators are already testing hydrogen fuel cells (HFCs) technology with local storage of green H2 in order to replace diesel fueled back-up generators and get rid of any possible electrical usage coming from fossil energy.
• DC operators are also testing on site power generation using fuel cells operated in natural gas, replacing natural gas by H2 would be the next step.
• EUDCA sees green hydrogen as one of the vectors playing a strategic role in achieving the objectives of climate neutrality by 2050, which includes the target of 2030 for the DC industry;
• EUDCA supports the EU hydrogen strategy launched in synergy with the Strategy for energy system integration, offering a vision to smarter, more integrated and more optimised energy system, in which all sectors can fully contribute to decarbonisation.
To make a positive impact on the European energy market by reducing carbon emissions through a massive scale-up of hydrogen, EUDCA believes that it is essential for the EU to:
• Create dedicated funding instruments to facilitate this large-scale deployment;
• Invest in large / long-term energy storage solutions;
• Create relevant legal frameworks allowing Innovative business models with European industries, developers and municipalities giving the required flexibility to implement local optimal distributed solutions (Hybrid power plants for example);
• Promotes European local industries to develop the related social & employment matrix to accompany this Transformation;
• Involve the Transmission System Operators in the architectures of all the solutions as they will be main stakeholders in the success of this initiative. The energy flow will be multidirectional, consumers become also producers.
The DC industry is a unique component of the digital ecosystem which needs now to be an integral part of every future smart city planning along with the urban architects and municipalities. It requires special enabling legislation and funding, as it is the interconnector between the digital and climate ambitions of the EU.
Read full responseResponse to Climate Law
1 May 2020
The European Data Centre Association (EUDCA) represents the European data centre operators community. EUDCA is pleased to submit commentary to this consultation and to endorse the EU for enshrining carbon neutrality by 2050 into the law, especially for paving the way for carbon neutral energy. EUDCA believes the data centre industry can contribute both directly and indirectly to its objectives. To realise this vision, the EU can play a constructive role through appropriate regulatory approaches and investments in enabling technologies.
Examples of the environmental benefits of the digitalisation of our economy and society are myriad. The relocation of increasingly powerful ICT from on premises "server rooms" to professionally managed data centres has significantly improved energy efficiency and led to a substantial reduction in energy losses.
Beyond that, the data centre industry has made a large amount of investments in energy efficiency and adopted renewable energy sources to drastically reduce its carbon footprint while allowing their customers to share in environmentally and corporately responsible energy policies:
• The data centre industry measures its design efficiency with a metric called Power Usage Effectiveness (PUE). In the past 20 years, annual PUE has been reduced from 2.5 to 1.2, which represents over 80% reduction in energy consumed to support a customer.
• Thanks to the environment awareness, most of the industry is moving to 100% renewable energy purchases and carbon offsets.
• Where possible, the industry now designs data centres to capture excess heat to be reused in office or residential heating.
• The industry also invests in technologies that reduce their wastewater from cooling.
Looking ahead, there are multiple avenues for the data centre industry to make even more meaningful contributions to the objectives of the proposed regulation:
• As the industry moves toward full power by renewable energy (thereby eliminating the related carbon emissions), the heat that is still produced by the operations of servers and other equipment in the data centres can be recovered and re-purposed within an integrated community energy scheme.
• As the data centre industry demands and deploys more renewable energy, and as new technologies like grid batteries emerge to store green energy and supply it when required, the industry will be in a position to further decarbonise the economy by participating in grid balancing efforts. Deployment of demand management models and how they are controlled, for example, holds great promise, but is currently hindered by insufficient investment.
• Data centre operators are already testing clean generation alternatives to diesel-based back-up generator systems. These include off-grid energy supply based on hydrogen fuel cells, gas turbines, large energy storage solutions and renewables. Once these projects prove successful, the use of wind turbines will be explored in a move to fully renewable energy-driven data centres. Data centre design adaptations are necessary to incorporate these changes and to allow for additional production of energy (150% of current capacity). This would enable going off the grid whenever necessary and to allow data centres to deliver energy to the grid.
EUDCA supports the European climate law binding the European society to carbon neutrality in its entirety. As a forerunner in the green energy transition, we are happy to engage with the EU to help it fully realise climate neutrality by 2050.
Read full responseResponse to Climate change mitigation and adaptation taxonomy
27 Apr 2020
The European Data Centre Association (EUDCA) represents the European data centre (DC) operators community. EUDCA is pleased to submit commentary to this consultation, and wants to draw attention to the following key points:
• EUDCA supports the Taxonomy and efforts to steer investment in sustainable actions to reach climate neutrality by 2030, as required from the DC industry;
• However, to achieve this ambitious target, EUDCA believes that further investment in green energy production is needed, especially in developing green hydrogen and large-hydrogen fuel cells (HFCs) capabilites and large-scale energy storage solutions;
• HFCs are an environmentally friendly alternative for on-site gas turbines and back-up diesel generators;
• HFC in DCs and large energy storage systems will enhance the efficiency of European energy infrastructure by providing an off-grid energy supply, to be combined with new demand management solutions. The HFC’s byproducts of water and heat can be used to cool DCs and used in a district heating system respectively;
• EUDCA would like to include HFC and large-scale energy storage technology in the context of the EU taxonomy on Sustianable Finance.
EUDCA appreciates the Commission’s support for research on development of next generation technologies and is willing to help facilitate tests on DC assets under the right financial considerations. DCs provide an ideal environment for these tests as they have a stable electricity supply and 24/7 in-house maintenance staff available. This can increase the speed of rollout of the tested technologies.
DCs consume a large amount of electricity with a relatively small footprint, determined by the increasing demand for data storage. Moving the entire ICT industry to electricity obtained from renewables will be difficult at the current rate of growth of renewables in markets and cities where ICT is used most intensively. Moreover, renewable energy is highly dependent on weather conditions causing volatility in prices due to an imbalance between supply and demand of energy in the grid. The potential unreliability of grid based renewable energy forces DCs to plan for on-site generation and larger battery deployments. The long-term solution, which EUDCA proposes, is HFC technology to solve these unreliability issues and the deployment of large-scale energy storage.
HFC would enable the DCs to go off the grid when necessary and instead allow them to deliver energy to it, stabilising energy supply. To run sustainably, there needs to be a competitive market for green hydrogen - the generation of hydrogen from renewable energy sources. Furthermore, fuel cells also perform the task of regulating voltage and frequency and thus some of the traditional electrical infrastructure such as Uninterruptible Power Supplies and Batteries are no longer needed.
Not only does this technology significantly lower carbon emissions, but it allows for energy efficiency on site because energy is no longer wasted as heat. In addition, since the byproduct of HFC is water, it can be used to cool the DCs. HFC technology and large energy storage, supported by smart computing power, would be able to optimise the energy consumption of DCs based on the actual supply and demand on the wholesale electricity market.
Since some utility providers are running out of capacity to sell power to DCs, EUDCA would like to emphasise the vital potential importance of installing on-site generation plants so that DCs do not need to rely on the stretched utility supply. EUDCA hopes that it has effectively illustrated the huge potential benefits of HFC technology, which needs more finance and investment support.
EUDCA is glad to see ‘Hydrogen storage’ listed as an environmentally sustainable economic activity on the Technical Annex of the Final report of the Technical Expert Group. Nevertheless, we would like the Commission to include HFCs as part of the recognised sustainable economic activities.
Read full responseResponse to 2030 Climate Target Plan
15 Apr 2020
The European Data Centre Association (EUDCA) represents the European data centre (DC) operator community. EUDCA is happy to submit to the feedback period on the 2030 Climate Target Plan and wants to draw your attention to the following key points:
• EUDCA welcomes the Commission proposal for an increase of the 2030 target for EU greenhouse gases (GHG) reduction in order to gradually achieve climate neutrality by 2050;
• However, EUDCA is concerned that the current green energy production and technologies cannot possibly respond to the rapid increase in demand for sustainable energy which is driven by the higher GHG reduction targets;
• According to 'Shaping Europe's digital future,' DCs should be climate neutral by 2030 which might not be feasible for all DCs. This transition to climate neutrality could hinder progress in other sectors due to DCs high demands for green energy;
• EUDCA would like to point out the need for a fair transition with equally disturbed efforts among different industries. This transition needs to be supported by large-scale EU investment in green energy production.
Read full responseResponse to Revision of the Energy Tax Directive
1 Apr 2020
The European Data Centre Association (EUDCA) represents the European data centre (DC) operator community. EUDCA is happy to submit to the feedback period on the EU Green Deal - Revision of the ETD, and wants to draw your attention to the following key points:
• DCs are key to the digital economy and enable the movement, storage and computation of the world’s digital data resources. Thus, we are the cardiovascular system of the global digital economy;
• The ETD is outdated and incapable of addressing the needs of today’s society which is undergoing a major digital transformation;
• DCs should be recognised as an energy intensive industry (EII);
• The criterion for energy taxation reductions should take into account energy efficiency commitments and use of renewable sources. These should account for and include the downstream carbon emissions benefits of the use of digital technology and business processes to reduce the use of physical resources in industries such as transportation.
DCs are the backbone of the digital industry and enablers of the digital economy: 80% of servers in Europe are currently located in data centres, as the Commission recently recognised in the EU Strategy for Data. They play an essential role as facilitators of the data storage and processing infrastructure, helping Europe to achieve the twin objectives of ecological and digital transition. Current tax burdens hamper data centre development and the digitisation of the economy. Therefore, the current ETD needs to be revised in light of the Green Deal, keeping in mind the data centre industry and energy reduction targets. The ETD is outdated and incapable of addressing the needs of today’s society, which heavily relies on data industry. Indeed, the amount of data and consequently the need for data storage has multiplied since the adoption of ETD in 2003. The 2007-2017 data volume shows an increase of 220%. Moreover, according to the EU Data Strategy, the volume of data produced is expected to increase by 530%. Today, it has been estimated that DCs consume about 2% of electricity worldwide. Taken into consideration the growth of the industry and the constant need for its services, it is essential that DCs join the group of recognised EII in the revised ETD.
The current ETD does not adequately promote greenhouse gas emission reductions, energy efficiency, or alternative fuels, nor does it provide sufficient incentive for investments in clean technologies. According to the EU’s Industrial Strategy, the modernising and de-carbonising of EII must be a top priority. DCs are actively working towards the greening of the sector to achieve carbon neutrality by 2030 as stipulated in the Commission’s ‘Shaping Europe’s digital future.’ To facilitate this transition the DC industry needs support through being recognised as an EII. Applying high energy taxes will paralyse data centres rather than reduce the data economy’s environmental footprint. Energy taxation reductions for DCs in exchange for energy efficiency commitments will further reduce the environmental impact of the data industry whilst keeping operational costs affordable. Thus, new ETD should look into net energy utilisation instead of gross.
Continuous efforts from DCs to improve energy efficiency have already led to an efficiency gain of over 80% in the past twenty years. DCs already run 50-100% on renewable energy. Furthermore, the industry reduces waste heat energy through export of waste heat, free-air cooling and higher operating temperatures. As demand for data storage grows, the focus should not be on hampering DC operations but rather on stimulating energy efficiency.
EUDCA supports the common EU goal to achieve carbon neutrality by 2030 for DCs. However, to achieve this, DCs require support from the EU and the revision of the ETD will play a crucial role. Energy taxation reductions and more alignment between ETD and other policies would enable the data economy to grow more efficiently.
Read full responseResponse to Digital Operational Resilience of Financial Services (DORFS) Act
16 Jan 2020
The European Data Centre Association (EUDCA) represents the European data centre operator community in its dealings with the European Union as well as National governments.
The European Commission is to be commended for focusing on the residual and growing challenges associated with the “Digital Operational Resilience for the Financial Sectors.” As the Inception Impact Assessment states in its opening, “The financial sector is the largest user of Information and Communication Technology (ICT) infrastructure in the world, accounting for about a fifth of all IT expenditure.” Indeed, as new technologies emerge and are adopted by the financial sectors and as the sectors migrate more of their ICT infrastructure and functionality from on-premises to third party providers, a clearer understanding of how this evolution is impacting operational resilience is paramount.
Simultaneous with this evolution in the financial sectors, the modern data centre industry has emerged as a key, foundational component for this ecosystem. While a great deal of attention is justifiably paid to cyber threats as they impact the financial institutions either directly or through third party partners such as cloud service providers, a better understanding is needed of the role that data centres provide and their contribution to stronger cyber- and physical security, as well as their role in enabling the new technologies that are shaping the future of the financial sectors.
The EUDCA recommends that the Commission should take the data centre industry into account when amending the existing Network and Information Security Directive (NIS) or drafting new legislation on digital operational resilience. Not just as a third-party ICT provider, but in particular as the digital backbone of the financial sector. Therefore, the EUDCA, as representative of the European data centres, welcomes the opportunity to provide its expertise and is available for cooperation.
Read full responseResponse to Commission Delegated Regulation establishing the Innovation Fund
11 Jan 2019
The European Data Centre Association (EUDCA) welcomes the efforts of the European Union to financially support innovation in low-carbon technologies by initiatives such as the ETS Innovation Fund. This matches the ambition of the EUDCA, as the sector has made a great effort in improving its overall energy efficiency, while increasingly enabling digitisation and serving its role as the backbone to the digital economy in Europe. Nevertheless, we believe that the scope of the Innovation Fund should be widened so that a greater number of actors beyond those currently listed could be eligible for funding support.
The EUDCA would recommend that these grants include the adoption of new technology into practical commercial use, rather than just the development of new methods. That would help to practically reduce energy consumption. Beyond encouraging innovation itself, innovative and early application of carbon emission reducing technology is also crucial. There are many innovative technologies that may offer benefits that have not been commercially proven: examples include pilot fuel-cell installations at data centres and energy storage. For example, fuel-cell installations at data centres have been trialled in the USA but have not taken off in Europe yet. Such technologies produce either significantly fewer carbon emissions than traditional gas-fuelled power plants, or allow more efficient use of energy infrastructure.
The most commonly cited drawback of fuel-cells is their high upfront cost.
The positive impact of thousands of data centres across Europe on reducing carbon emissions by applying the latest advances in technology related to their operations could be potentially transformative. We would, therefore, recommend to reconsider the scope of the proposal and expand the number of sectors eligible for the ETS Innovation Fund.
Read full responseResponse to Environmental impact of enterprise servers and data storage products
31 Jul 2018
The European Data Centre Association (EUDCA) welcomes the Commission’s proposal for a revision of the Ecodesign Directive for enterprise servers and data storage products. With the following comments, it intends to constructively further improve the proposal.
Please consult the Postion Paper attached. Of course, we remain at the Commission's disposal to address any questions or further explain our views.
Read full responseMeeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis) and Association of Credit Card Issuers in Europe and International Card Services BV
27 Jun 2018 · Fintech Action Plan and Transparency in currency convension
Meeting with Alexander Italianer (Secretary-General Secretariat-General)
31 May 2017 · EnergyClimate - Infrastructure
Meeting with Sarah Nelen (Cabinet of First Vice-President Frans Timmermans)
8 Dec 2015 · Circular Economy