Round Table for Delegated Act on Data Centres in Brüssel 

On May 29th, a round table discussion on the implementation of the EU Energy Efficiency Directive (EED) took place in Brussels. The invitation was extended by CISPE, the European Association of Cloud Infrastructure Providers and EUDCA, the European Data Centre Association. 

A total of over a dozen representatives from the relevant ministries and authorities of the member states, as well as around thirty representatives from the industry and professional associations, participated. 

Gernot Frauscher was present as a representative of the ADCA, the Austrian Data Center Association. 

The EU was represented by Nikolaos Kontinakis, Policy Officer, Energy Efficiency Unit, Directorate-General for Energy (DG ENER). 

In a brief presentation followed by a Q&A session, the current status of the implementation of the EED and the Delegated Acts was discussed. 

From the Union’s perspective, the data to be reported is fixed with the publication of the Delegated Acts. Uncertainties arising from additions or changes to the original text in the national legislation must be resolved at the national level. In Brussels, the focus is now on the implementation of the central database. 

If individual countries do not establish a national database, operators in those countries will be able to report directly. However, the creation and verification of accounts must be done by the countries themselves. This mainly affects small member states with very few data centres that are subject to reporting requirements. 

In countries where a national database is established (such as in Austria by the e-control), operators must report into the national database. User account creation is managed by the national authority (in our case, by the e-control). However, operators will still be able to query their own data in the central European database to verify whether the transmision by the national authority was error-free or not. 

Each data centre will have its own account in the database. If an operator has multiple locations, they will also have a corresponding number of user accounts in the (national) database. While this increases the initial effort in setting up accounts, it makes it easier if, for example, the operator of a location changes. There will also be a mechanism to correct data that has already been submitted. It is expected that there will be errors, especially in the initial phase. 

As of September 15, 2024, the first reporting from all data centres with an installed IT capacity of over 500 kW must be made. If national requirements are more detailed or extensive than those in the Delegated Act, national authorities must process and filter this data accordingly before transmission. For example, in Germany, data centres are already required to report if their intalled IT capacity exceeds 300 kW. 

Especially for colocation providers, collecting values for C_SERV and C_STOR will be difficult because they will need to gather this information from their customers. Some customers may be reluctant to support this, and many may simply not have this data at the moment. Aware of this situation, estimates for C_SERV and C_STOR from colocation operators can be used for 2024 and partially for 2025. With continuous hardware upgrades, all IT operators should build a complete database of C_SERV and C_STOR values for all devices over the next five years. 

In the concluding discussion, it became clear that work on a new version of the Delegated Act, incorporating previous experiences, is set to begin in the fall. A major topic will be the reduction of the 500 kW threshold to, for example, 100 kW. Estimates suggest that there are approximately 16,000 data centres in the EU with capacities between 100 kW and 500 kW, which have a savings potential of about 5TWh.