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ESC is an alliance of European organisations that strives to reduce the
impact of modern communications and electricity use on health and the environment. We are not against technology, but we are pro safe technology and safe connections.

    Have your say - Datacentres

    Have your say – Data centres

    You can also get involved in forming EU laws. The European Commission offers a platform “Have your say” with the list of all new EU initiatives open for public consultation. You need to register to write your feedback: ec.europa.eu/info/law/better-regulation/have-your-say

    Data centres in Europe – reporting scheme

    About this initiative: This act sets out a reporting scheme to rate the sustainability of data centres in the EU. More broadly, it is part of the EU’s ‘Fit for 55’ ambition to ensure energy efficiency in all areas of the energy system and in all relevant sectors.

    Feedback period: for stage 4 it is 11 December 2023 – 15 January 2024

    Link: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13818-Data-centres-in-Europe-reporting-scheme_en

    Feedback from Europeans for Safe Connections

    The Europeans for Safe Connections (ESC) welcomes the European Commission’s efforts to develop better regulation for environmental issues related to energy effiency of datacentres. ESC have already highlighted the enormous electricity consumption and energy waste associated with digitalisation in its European citizens’ initiative Registration number: ECI(2021)000009 in Proposal 12.

    The rise of digitalisation brings familiar benefits, but also underreported risks. The number of Internet users is growing every year. During this decade, global data has increased more than tenfold, while global data centre capacity has grown 25-fold. The facts presented on the first page of the draft Regulation confirm the statements of researchers and the industry that the high energy consumption and large environmental footprint associated with information processing and storing will continue, in the form of linear growth in energy consumption and further increases in greenhouse gases or water consumption.

    We are seeing a steep rise in data volume, mainly in digital entertainment such as streaming, social networking, cloud gaming, virtual reality. The quest for ever-higher video resolution results in significantly higher power consumption. Ericsson predicts that 2025 5G users will consume 200 GB/month which would be 10-14 times more than 4G. The average household around 20 connected devices that are expected to supply the data centres with a steady flow of data or to consume data from it.

    Approximately 66% of the world’s electronic devices use the Internet of Things, with an estimated 15 billion for 2023. By 2030, the number of IoT devices is expected to grow to 30 billion, with 8 billion in all industries, 1 billion in IT infrastructure monitoring, asset tracking and monitoring, traffic management through artificial intelligence, and 17 billion consumer IoT and media devices like smartphones and connected devices.

    Artificial intelligence is seen as a giant energy hog, with huge water footprint. As well as cryptocurrency mining. Data centres with artificial intelligence hardware consume 20 times more energy than traditional server-based data centres. A single query to a GPT chatbot can consume up to 100 times more energy than a regular Google search query. In its Environmental Sustainability Report, Microsoft quantified a 34% increase in water consumption between 2021 and 2022. In the 2023 study researchers highlighted a serious environmental and social issue that a large AI model can evaporate a staggering one million litres of fresh water per training session. This information has been kept secret. A training session also could consume 1,287 MWhof energy and release up to 550 tonnes of CO2 to the envinroment.

    Emerging connected (autonomous) AI-based vehicles are gathering vast amounts of information from their sensors and cameras in real time. A connected car can have 150 control units and produce around 25 Gigabytes of data per hour. Data centres, the brains of autonomous vehicles, require massive computing power, equal to 25 personal computers per vehicle, to process and analyse such a huge amount of data, either from the vehicles or from traffic monitoring systems, so that the vehicles can make the right decision in a fraction of a second. If self-driving cars become widespread, they will be a significant source of unaccounted carbon emissions that could exceed the global emissions of existing data centres, a recent study warns. One million connected vehicles generate as much data as the entire internet-connected population of the world. The level of autonomy determines the vehicle’s dependency on surrounding infrastructure.

    The European Commission continues to push for blanket coverage of all urban areas with 5G technology through a massive number of base stations. Whether the aim of 5G rollout is seamless mobile connectivity for the aforementioned connected vehicle industry, smart cities, business companies or the general population, 5G is far from being a solution to climate change and the environmental footprint of the digital economy would reach its peak with 5G traffic feeding datacentres.

    Industry reports that energy consumption from wireless devices and networks will grow exponentially, by 160% until 2030 and 5G Radio Access Network will increase global CO2 emissions by approximately 250 megatonnes. A 2019 German study, funded by E.ON, found that 5G will significantly increase energy consumption in data centres and boost data demand, resulting in increased energy consumption of ~3.8 TWh per year by 2025 (the electricity used by 2.5 million German residents). Chinese 2023 study reveals carbon trap and significant energy increase associated with 5G rollout.

    ‘…Whereas 5G infrastructure can be 90% more energy efficient than 4G on a per bit basis, a typical 5G base station also requires three times more energy to provide the same coverage as a 4G network,… ’. ’And more 5G base stations are needed to cover the same area’, says experts. ‘Going from 2G to 4G, it has dropped from 60% to 20%. A twenty percent efficiency means that for every watt of useful signal, four watts of energy will just end up as heat. ‘For 5G, the efficiency will be only 10%, meaning that nine watts will be turned into heat,’ says McCune.

    With real growth in data traffic, it is clear that energy efficiency cannot prevent a significant increase in 5G power consumption. Especially if the Commission follows its action plan to deploy up to 800 base stations per square kilometre, serving up to one million connected 5G and IoT devices per square kilometre. As indicated above, 5G base stations consume more power than 4G, despite their better efficiency, so the transition of existing 4G infrastructure to 5G is unlikely to reduce consumption on the antenna and wireless infrastructure side.

    Compared to previous generations of mobile connectivity, base stations operating over software-defined 5G networks are entirely dependent on software algorithms controlled from data centres. The blanket rollout of 5G will lead to a huge increase in energy consumption to power the huge number of base stations, but the massive additional energy consumption will fall on the data centres that control all these stations. With the increased burden on the environment, there will also be a huge rise in widespread and local exposure to wireless radiation, which has not been adequately tested for health risks.

    Our recommendation:

    • We welcome activities that reduce environmental impact, but we believe that the problem at the data centre level is only a consequence, not a cause. The cause lies in the huge amount of data generated by technology, which will have a significant impact on the environment and the management of natural resources.
    • Companies operating data centres or telecommunications infrastructure with an environmental impact should provide transparent data to the public on their management of energy, water and natural resources.
    • If companies with data centre or telecommunications infrastructure harm the environment or human health, promote the polluter pays principle.
    • The Commission should more carefully assess all technologies before they are deployed to ensure that they do not cause massive damage to the environment and natural resources in the future.The EU in the Green Deal there is based on the idea that ICT technologies will solve the situation. Existing evidence suggests that ICTs are contributing to further burden on the environment or human health rather than solving it. We also believe that many of the European Commission’s actions on technology issues are counterproductive to the implementation of the Green Deal.
    • The pursuit of economic growth and profit by telecom operators, industrial companies or other entities should not override the primary need to protect the environment, the sustainable management of natural resources and the right to health. We refer, for example, to what we consider to be a neglected analysis of the environmental, energy and health impacts of 5G wireless technology under the Gigabit Infrastructure Act Impact Assessment part 1 (p 51, footnote 150).
    • The Commission should prioritise the the communications technologies based on wired, cabled connections (to homes, businesses, data centres) as the most sustainable communications technology solution in terms of energy, maintenance and cost efficiency – in terms of data centres and the infrastructure that connects the path from the data centre to the end user. This also supports the objectives of the Ecodesign Directive, which we have also commented on.
    • Therefore, according to the previous point, wireless technology including e.g. 5G base stations, short-range wireless base stations, fixed wireless access points should be classified as a secondary solution in terms of poorer energy efficiency and adverse radio frequency emissions to the population.
    • Concurrently we have the following suggestion: Into the Annex I, point 1d add also a type of data centre, whether it uses wireless communication technology or cables.
    • Avoid blanket rollout of the next phase of 5G, as the form of high densification wireless base stations will have a significant negative impact on the environment. Alternatively, the development of 5G should only be allowed within industrial enterprises.
    • Artificial intelligence, as an energy hog, should be used selectively for research and work that ensures certain and significant scientific progress, rather than being deployed globally and encouraging the waste of natural resources through AI for minor everyday tasks.
    • As with AI, we have the same recommendation not to deploy connected autonomous vehicles on a wide scale because of the adverse environmental impact.
    • Implement a strategy for the protection of the environment from the environmentally harmful effects of cryptocurrency mining to the public and businesses.
    • Reduce the pursuit of higher resolution multimedia and entertainment content, especially in mobile communications.
    • Support an approach based on energy-efficient and less costly technologies that combine well with renewable energy generation and are resilient to interruptions, even in conditions where access to energy is more limited On the contrary, high-end communication technologies increase the cost and energy consumption of the Internet and mostly expose humans and environment to wireless radiation.
    • Sustainability can also be promoted through consumer attitudes towards sober digital practices and the use of sustainable communication technology solutions. According to The Shift Project: The energy consumption of Information and Communication Technologies (ICT) is increasing by 9% every year. It is possible to limit this growth to 1.5% per year by moving to sober digital practices. The digital transition as it is currently implemented participates to global warming more than it helps preventing it. The need for action is therefore urgent.
    • Many commercial party activities require the connection of people and equipment. However, in order to limit energy consumption, a fine-tuning in terms of connectivity is required, as the processing of information locally requires less energy. In addition, processing of non-connected information is less vulnerable than processing of information that requires connectivity.
    • European Commission should also offer a strategy to reduce obsolescence by extending the lifetime of consumer devices (including mobile phones) communicating with datacentres. Promote the reduction of e-waste to avoid unnecessary damage to the environment through the extraction of minerals, the plundering of natural resources or the creation of unequal human working conditions.

    Best regards
    Kamil Bartošák, Giorgio Cinciripini, Petra Bertová
    Europeans for Safe Connections
    This feedback was sent from a wired internet connection
    No use of harmful radiation
    Less electricity consumption
    Increased data security

    Link to our feedback: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13818-Data-centres-in-Europe-reporting-scheme/F3450932_en

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    Have your say - Datacentres

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