Zahl Limbuwala, chairman of the Data Center Specialist Group of the British Computer Society warned data center owners and operators attending the DatacenterDynamics San Francisco conference on Friday about the threat looming in the form of a carbon-reduction law making its way through the U.S. legislature.
His warning came after witnessing firsthand the impact of similar legislation being drawn up in the UK in the form of the carbon-trading scheme, which is part of the Carbon Reduction Commitment Act. The scheme has yet to become law but is scheduled to begin from April 2010.
Referring to the Climate Change Act, which was passed in 2008 Limbuwala said: "For some reason, the UK decided to be the first country in the world to set (legally-bound carbon budgets) in law."

Political pressure - fueled by nervousness about energy security, inspired partly by the Russian government's periodic use of its power to cut natural gas supply to European countries as leverage in geo-political negotiations - made the Climate Change Act legislation slide effortlessly through the UK government and into law. Unfortunately for businesses, the bill did not consider their needs as seriously as they would like to have seen, he said.

Limbuwala warned his American colleagues to keep a watchful eye on any similar bill that is currently making its way through the U.S. legislation and to do what is in their power to make sure its authors make decisions that are informed by industry realities.

On the proposed Carbon Reduction Commitment and the carbon credit scheme, Limbuwala said some of the very basics of business were largely ignored. For example, it evaluates emission reductions against one baseline year - the first year of compliance. This approach discounts businesses' inherent need to grow.

"The way that CRC measures carbon is your net increase, preferably your net decrease of carbon against the baseline year. And it's always against the baseline year...You acquire your business;you grow your business (and) then measure your carbon footprint against your baseline year," Limbuwala said. "We really hope (it) was a big year for you, in terms of (consuming carbon) because you're measured from that year forward."

BCS believes evaluation should instead be based on how efficiently a business uses energy and not the total amount of energy it consumes or CO2 it emits.

The proposal is especially ignorant on the subject of data centers.

For example, the legislation's authors did not take into account the ease with which companies can outsource their data centers to other companies. Since responsibility for a company's emissions falls on whoever's name is on the electricity bill, shifting data center ownership to others creates a gaping loophole.

"If I move all of the data centers, give them (for example) to a third party. His name is on the energy bill. We've just laundered the carbon."

It also did not consider how easy a data center can be moved to a different country.

After they realized the bill's implications for data centers, industry leaders in the UK wrote numerous reports for members of the government, explaining the carbon laundering and carbon off-shoring issues, as well as the consequences of losing high-tech jobs overseas.

"So far, the response has been: 'Nice, but no. We've decided this is the way it's going forward.'"
Limbuwala also gave updates on efforts to create a free, open-source simulator that assesses a data center's energy efficiency and presented a demonstration of the program.

BCS's Data Center Energy and Cost Simulator can measure how efficient a data center is going to be before it is built, expanded or changed.

The beta version came out in May and is at this point only accessible to BCS members.
Using a Web-based interface, the simulator works as a wizard on the input side, where the user inputs various specifications of their future data center, including the general layout and types of IT, as well as power and cooling gear (manufacturer specified).

The simulator outputs a 3D graph where it correlates IT electrical load, air temperature, and DCiE. The other output is total cost (beta version in pounds sterling only) and energy in kWh.
Correction: This is a corrected version of the original story which said that the Carbon Reduction Commitment (CRC) had come into law in 2008. This is incorrect. The Climate Change Act came into law in the UK in 2008. The CRC and the carbon credit scheme that is part of it have yet to be enacted. A final round of consultation ends in early August 2009. Apologies.