Comments on the Task A document dated 28/11/2022 supplied by Viegand Maagøe and COWI on behalf of the EU Commission regarding the Energy Efficiency Directive

As part of the European Green Deal, the ‘Fit for 55’ package comprises a set of proposals to revise and update EU legislation and implement new initiatives to ensure that EU policies are in place to achieve the EU’s climate goals. The European Commission is in the process of revising the Energy Efficiency Directive (EED), including setting new obligations and reporting requirements on the energy performance and sustainability of data centers.

To provide technical assistance in support of the introduction of the EED provisions (Commission proposal for the EED recast) the Sustainable Digital Infrastructure Alliance e.V. and the co-authors cited have prepared aggregated comments on the Task A document dated 28/11/2022 supplied by Viegand Maagøe and COWI on behalf of EU Commission regarding the Energy Efficiency Directive.

Our combined commentary offers guidance on the definition and classification of data centers, energy consumption, ways to ensure consistency and quality of reporting, metrics and key indicators, our views, and assessment of the proposal.

We believe the motivation of the initiative is sound. However, to reach the objectives defined and achieve a significant reduction in the EU’s data center energy footprint of the industry, it is imperative to think out-of-the-box. - To create real transparency on total power consumption and create the connecting tissue between data centers and software applications to achieve definitive change.

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