WIREDGOV

The Environment Agency has published their Combustion Sector report, which provides a useful point of reference for data centre operators with standby plant.

techUK welcomes the Environment Agency’s Outlook For the Combustion Sector.  This useful overview explains the Agency’s role and the importance of environmental compliance for industries engaged in combustion activities.  It summarises the progress that has been made over recent years, outlines recent developments and set out the Agency’s future priorities.

A publication focused on combustion industries may seem at first glance to be a strange place to find the digital technology sector, but combustion plant plays a crucial role in ensuring resilience and business continuity within the UK’s data centre estate. 

Data centres are part of our core national infrastructure.  They process, store and transact digital data, enabling the ICT functions that underpin every aspect of our modern economy, and they have a long association with combustion plant in the form of diesel generators. 

However, this plant is not used to power our facilities:  data centres run almost exclusively on mains electricity.  The generating plant is in place as emergency standby, to be deployed in the unlikely event of grid power failure, or in some cases when the quality of supply is inadequate (e.g. the frequency varies or drops below the required threshold).  ICT functions are compromised by power interruptions longer than a few milliseconds, so uninterruptible power supplies are absolutely critical for data centres.   Most use a combination of batteries and diesel generators to ensure continuity of supply: the batteries provide instantaneous but short term power whilst the generators start up, a process that takes around 30 seconds.   The generators can then run indefinitely provided that they can be refuelled regularly.

We estimate that the total embedded generating capacity currently installed within the UK data centre sector is somewhere between 1GW and 3GW.  The standby capacity for the sector is relatively high because sufficient emergency back up provision is needed to cover the maximum possible load at each site, plus spare capacity in the event that any units should fail.  In reality, because of the reliability of the grid supply, data centre generators are used rarely in anger and many have never been deployed in this way.  They are of course run regularly for short periods as part of testing and maintenance routines. 

The sector complies with a range of regulations and controls relating to its combustion plant.  These controls include EU ETS, which deals with scope 1 carbon emissions.   Air quality and other pollutant emissions are currently addressed by the Industrial Emissions Directive which applies to a few of our very largest sites and is implemented through EPR (Environmental Permitting Regulations).  From next year the Medium Combustion Plant Directive and additional domestic generator controls will introduce air quality control measures for smaller installations.

We work closely with the Environment Agency to raise awareness of new legislation, we explain regulatory requirements to our operators and we explain our members’ operations to the regulator, we develop guidance materials and act as a conduit for discussion and information exchange.   This new publication will help to inform those discussions and will act as a useful reference source both for those working within the sector and external observers.

Explanatory and contextual notes: 

techUK represents the UK’s data centre industry, for whom the Environment Agency regulates emergency backup combustion plant. This sector is relatively new to regulation by the EA.  The data centre sector also works with the EA on climate change adaptation along with other infrastructure operators and reported on sector readiness at the end of the second round. The UK data centre sector is globally significant, dominating the European market.  Data centres are unusual in that the sector is characterised by significant generating capacity but negligible generating function.  With some of the largest facilities in EMEA, UK operators are often the first in the region to tackle EU combustion compliance requirements.

Challenges for the sector in a combustion context are:

• Ensuring awareness of, and compliance with, regulations that are targeted at large scope one emitters.  
• Security of supply during the transition to renewable provision and also following our exit from the EU.  While existing operators generally have power provisioning   contracts in place, constraints on supply could limit future growth.
• Establishing ways to make better use of embedded generating capacity for load balancing / peak demand without impacting air quality or human health.

In the longer term,

• Contributing to the development of a more proportionate regulatory regime for  combustion plant operators with very low emissions.
• Identifying and implementing alternative solutions for the provision of emergency standby power for data centres, so that diesel power can be phased out.

EA ENVIRONMENTAL OUTLOOK FOR THE COMBUSTION SECTOR, 2016 (PDF)