ASHRAE

Technology for a Better Environment

1791 Tullie Circle, NE

Atlanta, GA 30329-2305 USA

Tel 404.636.8400

Fax 404.321.5478

http://www.ashrae.org

Terry E. Townsend, P. E.
President

Reply to:

TOWNSEND ENGINEERING, INC. P. O. Box 23526 Chattanooga, TN 37422-3526 423-855-1184 Fax 423-855-1185 E-mail terry@townsend-engineering.com

May 7, 2007 Andrew Fanara EPA EnergyStar Program 1310 L Street, NW Washington, DC 20005 RE: Comments on Draft Report to Congress on Server and Datacenter Energy Efficiency Dear Mr. Fanara, We applaud EPA and EnergyStars consideration of datacenters as a significant area of opportunity for increasing energy efficiency. As the report notes, ASHRAE has provided considerable guidance on and continues to examine cooling needs related to datacenters. Based on these activities and our considerable expertise, we are pleased to provide the following input to the draft report. Koomey states datacenters account for 1.2% of total U.S. Consumption excluding storage and network devices. Page 6, line 11. Reference should be made to ASHRAEs Thermal Guidelines for Data Processing Equipment, 2004. "High relative humidity levels have been shown to affect failure rates of electronic components. Examples of failure modes exacerbated by high relative humidity include conductive anodic failures, hygroscopic dust failures, tape media errors and excessive wear, and corrosion. The recommended upper relative humidity limit is set to limit this effect. Electronic devices are susceptible to damage by electrostatic discharge, while tape products and media may have excessive errors in rooms that have low relative humidity. The recommended low relative humidity limit is set to limit this effect. Page 9, line 8. Table 5.1 (page 62, line 13), should reference ASHRAEs report Thermal Guidelines for Data Processing Equipment, 2004 where it initially appeared. See ASHRAE publication Thermal Guidelines for Data Processing Equipment, 2004 which describes the various class environments for data centers. Page 59, line 6. Beyond the ASHRAE guidance publications already referenced, ASHRAE TC9.9 is publishing two upcoming books highlighting energy efficiency and best practices. They are: Improving Energy Efficiency of Datacom Equipment Centers and High Density Data CentersCase Studies and Best Practices. Page 97, line 12. Figure 1-3 is really not showing a best practice layout for a data center and should be corrected. Attached is a more appropriate diagram. Page 10, line 1.
American Society of Heating, Refrigerating and Air-Conditioning Engineers, Inc. A N I N T E R N A T I O N A L O R G A N I Z A T I O N

EnergyStar ASHRAE Datacenter Report Comments Page 2 of 3

Figure 2-3 is from ASHRAEs Datacom Equipment Power Trends and Cooling Applications, 2005. Please reference as such and not a paper that is a secondary reference. Page 19, line 4.

ASHRAE Technical Committee 9.9, Mission Critical Facilities, Technology Spaces, and Electronic Equipment, consists of a diverse group of stakeholders (roster attached) working to produce guidance necessary to reduce datacenter energy use. As the report indicates (page 97, line 21), guidance addressing the design and operation of datacenters has been developed and is being utilized within the industry. As a surrogate for utilization of ASHRAE guidance within the design community, the following table reflects the sales of special publications developed by TC9.9. Title Thermal Guidelines for Data Processing Environments Data Equipment Power Trends and Cooling Applications Design Considerations for Datacom Equipment Centers Liquid Cooling Guidelines for Datacom Equipment Centers Published Print Sales Downloads

Jan 04

2,402

834

Feb 05

1,785

349

Jan 06

1,269

292

Dec 06

325

88

ASHRAE Technical Committee 8.3, Absorption and Heat Operated Machines, also is developing guidance and sponsoring research on thermally activated cooling (particularly relevant to page 79, line 39) (see the attached summary of research projects). Many active and completed ASHRAE research projects may help further illuminate opportunities for increased efficiency and provide the IT industry with the necessary data to support operational changes. Attached is a summary of relevant projects. On at least two occasions (page 86, line 22 and page 96 line 12), the report mentions the inapplicability of ASHRAE Standard 90.1-2004 to cooling in datacenters. In light of this concern, ASHRAE Standing Standard Project Committee 90.1 (SSPC90.1) will evaluate whether datacenters could be included within Standard 90.1 as such cooling requirements could be within the purview of the design professional and could be well characterized. Regarding the discussion of metrics for datacenter energy efficiency (page 89, line 28), we would strongly recommend the use of Data Center Efficiency (DCE) rather than Power Usage Effectiveness (PUE). This reflects the traditional engineering practice of expressing efficiency as useful energy divided by total energyIT energy or useful work divided by total energy to the datacenter. Use of this measurement will allow non-engineers (including datacenter operators, building owners, business owners, and equipment purchasers) to simply determine the efficiency of one process relative to another. Finally, the report seems to devote a significant amount of discussion to combined heat and power. However, other holistic designs for datacenters should be equally considered. ASHRAE would be

EnergyStar ASHRAE Datacenter Report Comments Page 3 of 3

pleased to assist EnergyStar with outlining all the holistic designs for datacenters that employ green practices. Thank you in advance for consideration of our comments. If you require any additional feedback or would like ASHRAE participation in any of your future efforts related to datacenter energy efficiency, please contact ASHRAE Government Affairs Representative Ryan Colker (202-833-1830, rcolker@ashrae.org) or TC9.9 chair Roger Schmidt (845-433-5259, c28rrs@us.ibm.com). Sincerely,

Terry E. Townsend President

TET/rmc cc: Roger Schmidt, TC9.9 Chair Drake Erbe, SSPC90.1 Mechanical Subcommittee Chair

ASHRAE
Technology for a Better Environment

1791 Tullie Circle, NE

Atlanta, GA 30329-2305 USA

Tel 404.636.8400

Fax 404.321.5478

http://www.ashrae.org

Summary of ASHRAE Research Projects Relevant to Datacenter Energy Efficiency Active projects 1281-RP, Identification, Classification, and Correlation of Ultrafine Indoor Airborne Particulate Matter with Outdoor Values and1302-RP, Comparison of Gas Phase Air Filtration Equipment (GPAFE) Lab Tests to Field Experience may provide information on the use of filtration to allow for the greater use of outside air. Active research project 1373-RP, Air Distribution Effectiveness with Stratified Air Distribution Systems may help to expand our understanding of air movement with under-floor air distribution systems. Active research project 1340-RP, Intelligent Control of Combined Heat and Power Systems will assist in the development of guidelines to integrate intelligent controls with available onsite generation capability. ASHRAE Technical Committee 8.3, Absorption and Heat Operated Machines, can serve as a resource for information on thermally activated cooling. Completed research projects include 1200-RP, Optimized Operation of Heat and Electrically Activated Chiller Equipment in Hybrid Machinery Rooms and Associated Design and Control Strategies; 773-RP, Development of an ASHRAE Design Guide for Optimum Use of Sorption Equipment and Other Waste Heat Generating Facilities; and 919-RP, Secondary Properties of Aqueous Lithium Bromide Solutions. Active project 1270-RP, Characterization of Selected Refrigerants in Flat Plate Micro-scale Condensers, could provide information on emerging technology potentially useful in datacenters.

Other ASHRAE research that could possibly either directly or indirectly support reductions in the use of energy use for data centers is as follows: Active project 1326-RP, Application Manual for Non-Residential Load Calculations 1387-WS, Thermal Energy Storage Design for Emergency Cooling 1465-RTAR, The Development of a Computational Fluid Dynamic Model to Represent the Performance of a Round Floor (Swirl or Induction type) Outlet Used in Under-floor Air Distribution If you would like additional information on any of these research activities, please contact Ryan Colker in ASHRAEs Washington office (202-833-1830, rcolker@ashrae.org).

American Society of Heating, Refrigerating and Air-Conditioning Engineers, Inc. A N I N T E R N A T I O N A L O R G A N I Z A T I O N

ASHRAE
Technology for a Better Environment

1791 Tullie Circle, NE

Atlanta, GA 30329-2305 USA

Tel 404.636.8400

Fax 404.321.5478

http://www.ashrae.org

Technical Committee 9.9, Mission Critical Facilities, Technology Spaces, and Electronic Equipment
Name Roger R Schmidt Jeffrey P Rutt Thomas A Davidson Christopher W Kurkjian Mark M Hydeman Adrian Altenburger Kevin Fletcher David Copeland John V Glass John C Groenewold Christopher G Malone Timothy S McCann David L Moss Michael K Patterson Herbert V Sorell J F Stack Donald L Beaty Joseph Lombardo Richard F Pressley Sr Robin Steinbrecher John J Adelsberger Deepak Agarwal Dereje Agonafer Terral L Altom Paul T Artman K M Asawa Frank Atkinson Daniel B Baer William P Bahnfleth Committee Position Chairman/Mbr Vice Chairman/Mbr Program Subcom Chm/Mbr Handbook Subcom Chm/Mbr Ali Coordinator/Mbr International Member International Member Member Member Member Member Member Member Member Member Member Alliance/International Activities/Cm TC Webmaster/Corresp Mbr Secretary/Cm Research Subcom Chm/Cm Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Company Affiliation IBM NSA/DOD DLB Associates Consulting Eyp Mission Critical Facilities Taylor Engineering LLC Amstein Walthert AG The Hermitage Sun Microsystems Citigroup Technology Infrastructure J P Morgan Chase Hewlett Packard Company Silicon Graphics Inc Dell Computer Intel Digital Enterprise Group Syska Hennessy Group Liebert Corporation DLB Associates Consulting Mallory & Evans Intel Corporation AG Edwards Indian Oil Corporation Ltd. U. Texas at Arlington Electronic Data Systems Dell Computer Bank of Baroda GMAC Residential Funding Liebert Corporation Pennsylvania State Univ Country

Switzerland United Kingdom

India

India

Kenneth R Baker Christian L Belady Ng Kai Beng Michael R Bishop Byron P Blackmore Neil Chauhan Victor A Chiriac Herman Chu Alan Claassen Howard M Cooper Bob Culver Philip G Cutino Steve David Robert Doherty John Duffin Gregory K Fennewald Philip Flinn Alan Robert Fraser F William French Stephen Fry Joseph D Gangemi Arthur L Giesler Kenneth E Gill Gregory R Guard Stephen C Halsted Kevan John Harrison Dennis G Hellmer Magnus K Herrlin Ted Hight Elly Hiu Akio Idei Maged Iskander Charles E Johnson Er Toh Siam Hui Joseph Ashraf K Kailash C Karki Kishor K Khankari Mukesh K Khattar

Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member

Hewlett Packard Company Hewlett Packard Company Housing Development Board - Singapore Nortel Networks Flometrics Inc. DLB Associates Consulting Freescale Semiconductor Cisco Systems IBM Corp Qwest Communications International Wells Fargo Stanford Linear Acelerator Center American Power Conversion Beth Israel Deaconess Medical Center M Moser Associates Ltd. eBay GMAC EMC Corporation PTS Consulting Ltd. Data Aire PermAlert ESP JJA Inc. J P Morgan Sebesta Blomberg Associates Johnson Controls Tier IV Consulting Group ANCIS Inc. Target Corporation BP Singapore Pte Lts Hitachi Ltd. KAZ CEJ Consulting Engineers Maunsell Consultants Self employed Innovative Research, Inc. Fluent Inc. Oracle Corp.

Singapore

Hong Kong

Hong Kong

United Kingdom

Singapore Japan Singapore Singapore United Arab Emirates

Scott Killian Mark E Kiselow Erhard Klotz Peter A Koch Rajesh G Korde David A Landsberg Matt Lawrence Christian Le Bret W Lehman Hsing-Sheng Liang Michael J Linde Wei Ling Lu Luna William Maltz Lawrence C Markel Renee Marzitelli James P McAleer Shadab Mehboob Godwyn Mendes Stephen Montgomery John Murgida John Musilli Sanjeev Nangia Budy D Notohardjono Shlomo Novotny Rodney R Oehlers Sanjay Panchbhaya Steven Parris Suhas V Patankar Chandrakant D Patel Gregory W Pautsch Richard L Pavlak Patrick E Phelan Bon Pipkin Geoff Ploskitt Andrew P Prandoni Joe Prisco Peter Quek

Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member

America Online Engineered Data Environment Fujitsu Siemens Computers Williams Furnance KPIT Cummins Infosystems Ltd. Landry Gauthier ET Associes Bellsouth Telecommunications Intel Corporation IBM Cisco Systems Philadelphia Stock Exchange Lucent University of Kansas Electric Cooling Solutions Inc Sentech Inc Northwest Airlines Morgan Stanley J&K Bank Larsen & Toubro Ltd. Intel Corporation Lehman Brothers Japan Inc. Intel Corporation Kris Infrastructure (P) Ltd. IBM Corp Aavid Thermalloy Donnelly Simpson Cleary & Oehlers Larsen & Toubro Ltd. Kajima Innovative Research, Inc. Hewlett Packard Company Cray Research Inc. Heapy Engineering Arizona State University Fujitsu Siemens Computers National Institute of Health IBM Corp Trammell Crow Company

India

India India Japan India

Singapore India

Germany

Singapore

Reinhard Radermacher Gamal Refai-Ahmed Charles W Rego William Reynolds Terry Rodgers Steven Rosenstock Michael Salvatore Daniel Santalucia Walter R Schwarz Michael CA Schwedler Mike Scofield Anthony C Sharp Timothy A Shedd PhD Kevin Shinpaugh Mark J Simpson Shelby L Sims Grant Smith Benjamin L Steinberg Robert F Sullivan Abhishek Sundaram Jeff Tepler Nelson Terk Ronald R Thomas Chad D Tramonte Jeff P Trower William Tschudi James W VanGilder Marlin R Vogel Aleksandar M Vukovic David Wang Ralph L Webb Katherine Whitenack Nick Wold Jackson Wong Larry Wong Tony S F Wong Lang Yuan

Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member Corresponding Member

University of Maryland ATIO Technologies Inc. Intel Corporation Tate Access Floors Inc. Syska Hennessy Group Edison Electric Institute Childrens Hospital Airflow Company Fluent Inc. Trane Company Conservation Mechanical Systems Sanmina-SCI University of Wisconsin-Madison VA Polytechnic Institute & State University DSCO Rice University UNISYS American Power Conversion The Uptime Institute Atelier d-arts & Architecture Pvt Ltd Qualcomm Incorporated Ryder Ronald R. Thomas P.E. SunTrust Banks Inc Data Aire Inc Lawrence Berkeley National Laboratory American Power Conversion Sun Microsystems Communications Research Centre NCR Corporation Pennsylvania State Univ Lytron Cisco Systems Ove ARUP & Partners Hong Kong Ltd SBC Services Inc. J P Morgan Fujitsu Network Communications

Canada

Canada

Singapore

India Singapore

Canada

Hong Kong Hong Kong