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To: Irish Government, EU

No new fossil fueled data centres

No new fossil fueled data centres

Moratorium on new data centres until they can meet the following conditions:
* No new fossil fuel burning infrastructure should be installed to power data centres, either on or off site, either owned and operated by the data centre owner/operator or otherwise
* Data centres should be required to invest in renewable energy generation either on-site, or close by, on the grid it is connected to, and locate in places where it is feasible to generate sufficient energy from renewables.
* Data centres should be required to consume grid electricity at times when there is plentiful wind or other renewable energy on the grid relative to demand.
* Data centres should not be allowed to run “mining” of bitcoin or other cryptocurrencies, which consume huge energy resources and have been banned in some jurisdictions already.

Why is this important?

Eirgrid and the Commission for Regulation of Utilities have stated that if new data centres are built without new electricity generation and "demand side flexibility", we will have blackouts. The new generation being proposed is primarily fossil gas based. The flexibility being discussed is primarily through the data centres installing private fossil fuel generation (rather than batteries/other energy storage/ real time demand flexibility). We need to pause all new data centre development until we can guarantee that it will not cause new fossil fuel generation, either on the grid or data-centre-owned generation. We also need to call at EU level for all data centres to be located in places where it is feasible for the centres to be 100% renewable powered in real time (not through "guarantees of origin").

Data centres consume a lot of energy, and there are a large number of new data centre proposals being made for Ireland. For example, the proposed data centre in Ennis would have a 200 MW load - equivalent to the electricity consumption of approximately 210,000 homes, which is the number of homes in Clare, Limerick and Kerry combined. The Commission for Regulation of Utilities (CRU) recently issued a consultation paper recommending that data centres be obliged to adhere to “connection measures” (i.e. to be flexible in their timing of use of grid electricity), in order to prevent black outs. However, the paper fails to adequately address climate change, and fails to clearly distinguish between a) flexibility through storage, b) flexibility through matching real time electricity usage to the timing of the wind and sun, and c) flexibility through private data-centre operated fossil fuel generation. The first two are compatible with decarbonisation, the last is not.

There are two big issues in electricity decarbonisation: increasing the quantity of renewables, and managing intermittency (e.g. energy storage and demand response).

Quantity of renewable supply: We need a lot more renewable generation on the grid to replace existing fossil fuels and to enable transfer of heating and transport from fossil fuel to decarbonised electricity.

Grid stability, storage and timing: Many renewables, such as wind and solar, cannot be timed or turned up and down at will. To avoid using fossil fuels as backup when there is low wind and sun, and to avoid wasting renewable energy when there is surplus supply from wind and sun, we need to use more when it is available and use less when it is not (i.e. real-time demand response), and we need to store renewable energy when it is available, for use when it is not.

Just transition: We need to manage the transition to more renewables, better storage and timing of electricity use, in a way which prioritises essential needs and the most vulnerable, and uses the electricity we have more efficiently.

Current data centre plans = more fossil fuel generation. Many current data centre plans, including the Ennis plan, involve either the data centre installing it’s own large-scale fossil fuel generation, or the grid being forced to procure fossil fuel generation to keep up with the data centre’s demand whenever it wants it. The Commission for Regulation of Utilities (CRU) recently issued a consultation paper recommending that data centres be obliged to adhere to “connection measures” to be flexible in their timing of use of grid electricity, but the paper fails to clearly distinguish between a) flexibility through storage, b) flexibility through matching real time electricity usage to the timing of the wind and sun, and c) flexibility through private data-centre operated fossil fuel generation. The first two can be compatible with decarbonisation, the last is not.

The greenwash trap. We need to be careful of data centres (and other businesses) claiming they are 100% renewable because they have purchased “guarantees of origin”. These are credits from renewable suppliers which are not even connected to the electricity grid the data centre is connected to, and which are not producing electricity at the time it is being used by the data centre. This is smoke-and-mirrors greenwash and doesn't do anything to prevent the Irish grid using fossil fuels. Instead, we need to focus on the "carbon intensity" of the grid they are using (the Irish grid), at the time they are using it. Carbon intensity means grams of CO2 equivalent emitted per kWh of electricity produced, and it can vary substantially according to the wind. Data centres should be required to use or store electricity when the carbon intensity is low, and minimise their use of the grid when there is a shortage of renewables like wind or solar. The true carbon intensity of electricity imports over inter-connectors should also be accounted for.

Demands to data centres: Pre-conditions which can be set out for new data centre proposals include:

* No new fossil fuel burning infrastructure should be installed to power the data centre, either on or off site, either owned and operated by the data centre owner/operator or otherwise
* The data centre should be required to invest in renewable energy generation either on-site, or close by, on the grid it is connected to (ie the Irish grid), and locate in places where it is feasible to generate sufficient energy from renewables
* The data centre should be required to consume grid electricity at times when there is plentiful wind or other renewable energy on the grid relative to demand. To facilitate this, they may turn off servers and delay low priority computing tasks, and install batteries or other energy storage infrastructure.
* Data centres should not be allowed to run “mining” of bitcoin or other cryptocurrencies, which consume huge energy resources and have been banned in some jurisdictions already.

Ennis, Co. Clare, Ireland

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Updates

2021-09-01 21:32:49 +0100

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