A Comprehensive ICT Energy Sustainability Policy

The governance of digital information and communication technologies (ICTs) must prioritize, rather than undermine, the public interest. This requires that ICTs be open, interoperable, and environmentally sustainable. Given the climate crisis and the fact that ICTs contribute significantly to global carbon emissions and electricity consumption, it is imperative to ensure that ICTs are developed and used in a responsible and resource-efficient manner. This is in line with the overarching goal of sustainable and non-exploitative resource management, which is a key component of the Digital Commons.

Despite the urgent need, the European Union (EU) lacks a coherent policy to address the energy and, more generally, environmental sustainability issues raised by digital technologies. The current approach to addressing these issues is fragmented and lacks a comprehensive strategy.

For example, software, which drives the energy needs of ICT infrastructure, is largely unregulated from an environmental perspective. The forthcoming EU Ecodesign Regulation has been described as a “cornerstone of the Commission’s approach to more environmentally sustainable and circular products.” However, because “products” are defined as “physical goods,” software is not treated as a separate product group. As a result, software products remain outside the scope of the proposal and fall through the cracks of the ecodesign requirements.

This is a significant gap, especially given the rapid proliferation of AI systems that consume significant amounts of energy. While there is growing concern about the high energy consumption of AI, when it comes to regulatory requirements, those proposed in the upcoming AI Act are limited to certain types of AI systems only and constrained to monitoring energy consumption.

Similarly, the updated Energy Efficiency Directive includes a requirement to monitor the energy performance of data centers. However, this monitoring requirement does not require efforts to reduce energy consumption and ensure their more sustainable use. In particular, the energy performance of data centers is affected by many factors, such as the type of software applications and the efficiency of the software code. As a result, initiatives to improve data center energy efficiency will be ineffective unless they address both the hardware and software layers.

What needs to be done?

The EU needs to make a concerted effort to formulate a unified and comprehensive ICT energy sustainability policy. Although existing initiatives and legislation  — including the forthcoming EU Ecodesign Regulation, the Energy Efficiency Directive, and the AI Act — individually aim to improve the environmental sustainability of digital technologies and infrastructures, the lack of an overarching framework specifically tailored to the multifaceted dimensions of ICT is a potential barrier to the effectiveness of these efforts.

The close relationship between the energy consumption of hardware and the software products they host, including AI systems, underscores the importance of developing a comprehensive policy that addresses both layers. Efforts to improve the energy efficiency of ICT must go beyond hardware considerations and include software optimization. The call to establish requirements for software-driven energy efficiency, energy consumption reduction, and digital sustainability is not new, but it has gained momentum with the rise of AI products and services.

The energy consumption of AI systems and the energy sustainability of software are both intertwined aspects of the larger effort to make digital technologies more environmentally friendly. A comprehensive ICT sustainability policy would help address the climate crisis by incentivizing lower overall energy consumption, while benefiting society through more sustainable and responsible resource use. Such a unified policy would provide clarity for researchers and businesses and foster a collaborative effort to advance sustainability goals in the digital realm.

Europe’s opportunity

The proposed action includes the establishment of a comprehensive EU policy on the energy sustainability of ICTs (a “Digital Technologies Energy Sustainability Act”), focusing on both hardware and software components.

Key elements of this regulation should include energy efficiency standards for both hardware and software, guidelines for responsible energy use, and incentives for the development and adoption of technologies that use less energy. The regulation should also include monitoring and reporting mechanisms to track progress and enforce compliance.

Such a regulation, focused on enforcing sustainable practices across the ICT sector, would provide a missing link between the digital and green transitions. This approach would contribute to the creation of a greener and more sustainable digital landscape in the European Union, reinforcing efforts toward a more resilient and sustainable future.


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