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DIGITALEUROPE appreciates DG GROW’s continuing due diligence to refine the ErP Lot 9 server energy efficiency requirements and the opportunity to provide additional input as part of the Public Consultation Forum. DIGITALEUROPE, with technical support from the Green Grid (TGG) SERT Analysis Working Group (SERT WG), has made significant progress doing further analysis and developing recommendations on:
 
(1) The analysis of the SERT dataset to develop and evaluate options for establishing server efficiency thresholds to identify more energy efficient servers; 
(2) Assessment of the impacts of SERT V2.0.0 release and modified SERT score calculations based on the measured active efficiency and new proposed thresholds;
(3)  Assessment of the idle power and active efficiency of the new x86 servers; 
(4) Refinement of the system performance idle adder, an alternative to idle approach proposed in our March 31, 2017 comments. The above work and recommendations have taken   into account changes in the SERT V2.0.0 normalized performance scores and the higher idle power values associated with higher performance servers - particularly those using the recently announced next generation x86 processors with more than 16 cores and;
(5)  Proposing an additional category and idle adder for I/O ports with transfer speeds of ≥ 50Gbit and ≤100 Gbit. 
(6) Providing an updated definition for Auxiliary Processor Accelerators (APAs) that distinguishes between expansion APA cards and embedded APAs.   
 
DIGITALEUROPE and the SERT WG intend to continue to work with DG GROW and its consultants to further discuss Industry’s assessment and recommendation on server energy efficiency metric and thresholds.  
 
Finally we reiterate that eco-design measures for this product group should understand and ensure that the overall energy consumption impact within the data centre is taken into account. Energy efficiency at the product level must also translate into optimized energy savings potential at the data centre level.    
 
These comments are provided as an addendum to the comments provided to DG GROW on 17 March 2017 and 31 March 2017 as part of the Consultation Forum.  The comments and supporting data have been developed as the SERT WG and DIGITALEUROPE have continued our work to refine our Lot 9 recommendations to improve server energy efficiency while ensuring that overall data center energy consumption is reduced and innovation in server and storage technologies and products is not hindered.