Issue link: https://cp.revolio.com/i/488587
THE DATA CENTER JOURNAL | 17 www.datacenterjournal.com consumers money and protect the envi- ronment. ose, of course, are laudable goals, but if some regulation is good, then more is better. Energy use could be easily contained by making it almost impossible to comply with regulations, but the effect on the economy would be devastating. Unfortunately, however, measuring those negative effects isn't as easy as tallying the watts saved by converting from incandes- cent light bulbs to the ghoulish compact fluorescent lights (CFLs) that have been all but mandated by national energy-efficien- cy standards. us, the only data typically proffered is in defense of regulations. In addition, regulations may price consumers out of certain markets, lower- ing the standard of living. For instance, the California Energy Commission said in its publication, "Keeping inefficient and wasteful appliances out of the Califor- nia market saves California consumers money through reduced energy bills and reduces statewide electricity demand by an estimated 18,000 gigawatt-hours annually." Ignoring whether that savings estimate is trustworthy, the problem is that higher- efficiency appliances typically cost more, and the return on investment may be less compelling for some consumers than others. Again, this isn't to say greater ef- ficiency lacks value, but efficiency at all costs imposes an inflexibility that makes life and business more difficult. In evaluat- ing any regulation, this consideration should be kept clearly in mind. imPact on the Data center In July 2014, Title 24 was explicitly extended to cover data centers operating in California. According to a publication by the California Utilities Statewide Codes and Standards Team, the regulations will yield all the usual benefits that data center operators would like to see in their facili- ties: lower energy costs, fewer hot spots, less noise, a more hospitable temperature in the computer room and so on. e publication lists a number of "new prescriptive requirements that are specific to computer rooms." One of the main items is a requirement for the use of economizers in small data centers, with the exception of those in buildings that lack economizers, certain expansion projects and certain new data centers in existing buildings. Another major require- ment is the use of containment "in large, high density data centers with air-cooled computers." Other regulations include pro- hibition of reheat as well as non-adiabatic humidification (i.e., humidification that involves the use of thermal energy, such as through creation of steam). Unsurprisingly, companies that man- ufacture data center equipment have trum- peted the new rules and even hinted that they're coming to a state near you. ese companies, naturally, have listed all the reasons why Title 24 is wonderful owing to the many benefits of higher efficiency, but they invariably overlook the costs. Large data center operators in California (and elsewhere) likely implement many if not all of these requirements already, so the regulations may impose little additional cost on them. (Some aspects of compli- ance may increase administrative costs, however.) For these operators, regulations can actually be a tremendous advantage: they may impose crippling capital costs on smaller competitors, and they may simply drive others to outsource, expanding the potential clientele. toDay california, tomorroW the nation? A chief danger of regulations is that they pave the way for further regulations, ultimately leading to the ruin of industries. In the health-care industry, for instance, what at first probably sounded like "common-sense" patient protections has turned into a nightmarish maze of bizarre rules and limitations that have yielded exorbitant prices and supply shortages. e danger in the data center industry is that energy-efficiency regulations may eventually involve some quantitative met- ric—power usage effectiveness (PUE), for instance. To implement such a standard and avoid gaming of the system—to say nothing about setting a standard that applies meaningfully and fairly across geographies, industries and so on—the regulations would have to become increas- ingly complex. Although Title 24 may not take this route presently, it may in the future, or some local regulator may add such requirements, since Title 24 has offi- cially opened the door to energy-efficiency regulation of data centers. Given that building codes, particu- larly if they apply to data centers, are a rather obscure part of the law for most people, proposed Title 24–style data center regulations in other states are unlikely to face any broad opposition. ey would likely be touted as a sensible means of reducing data center energy consumption in a way that benefits both companies and consumers. Of course, if that were the en- tire story, one might wonder why compa- nies don't implement these improvements voluntarily. e answer is the seldom mentioned costs of regulatory compliance. Furthermore, proponents of regulation are unlikely to mention the Jevons paradox, or the fact that even though average per- capita energy consumption in the U.S. has declined since the 1970s, consumption in California has remained steady despite its ballyhooed regulatory scheme. Economic headwinds, however, may thwart the spread of Title 24. Although the word recovery is regularly bandied about, the recent crash in oil prices—not to mention the continuing low per-capita energy consumption in an ostensibly growing energy-based economy—sug- gests that something is amiss, regardless of what stock prices might indicate. Regula- tions may face less opposition in times of abundance, but dubious conditions tend to create resistance, especially since economic growth is such a universally hallowed goal. On the other hand, the data center industry's reputation has taken a beating in recent years owing to its energy appetite, so state and local governments and regulators are already primed for the glowing (and exclusively positive) argu- ments for Title 24–style regulation. Such rules have been on the horizon for years; their arrival may be imminent. n