Product Accounting & Reporting Standard ICT Sector Guidance Document

Transcription

1 Product Accounting & Reporting Standard ICT Sector Guidance Document Summary of Stakeholder Advisory Group Comments on the Telecom Network Services (TNS) and Desktop Managed Services (DMS) Chapters January

2 Introduction The first chapters to be released to the Stakeholder Advisory Group of the Greenhouse Gas Protocol Product Standard ICT Sector Guidance document were the TNS and DMS chapters. They were released for initial comment in November 2011 and the following pages summarise the comments received. Comments were received from 10 organisations/individuals in total, making a combined number of over 300 comments ranging from formatting and structural, to very detailed technical feedback. These comments have now all been reviewed and resolved by the chapter lead authors and they will be reflected in the subsequent draft versions of these chapters. Telecom Network Services (TNS) Chapter General Comments Energy efficiency Need to emphasise who the chapter is for Terminology: o Use the term equipment instead of products, as product can also refers to services o use of the word infrastructure could be replaced with support equipment o Consistency when talking about human / people / organizational activities. Select one. Structure of chapter difficult to navigate headers to be reformatted in subsequent draft Cumulative effects and thresholds of omissions due to insignificance need to be considered Inclusion of embodied emissions of hardware could be clearer or at least refer to Hardware chapter Clarification of when this simplified methodology is applicable and when a full LCA or ETSI are more appropriate - Introduction Guidance on interpretation of results needed (e.g. sensitivity analysis) 1. Introduction Need for a glossary to be included at the end of the complete document Could do with reference to ETSI document number and up-to-date status (published) 2. Goal of the telecommunications network services guidance document Consistency with DMS chapter, goal or rationale? Data quality requirements is an important factor ISO, ETSI and ITU_T could be referred to strengthen the message 3. Business goals Guidance may also be used by companies to appraise internal procedures (e.g teleconferences vs. face-to-face meetings) covered in Transport Substitution chapter 2

3 Some business goals are mixed up and are actually assessment targets Some goals relate to a network and not a network service, could be clarified in title- telecommunication network and network services? 4. Establishing the scope of a product inventory Discussion of functional units and reference flows Service Deployment & Build concept is useful and could be extended to other chapters Terminology use of activities preferred to events Discussion of appropriate examples and their use of functional units ETSI defines one year of (defined) service use as the basic functional unit which should always be used but could be complemented by other more specific functional units 5. Boundary setting Approach to embodied emissions in vehicles differs from that in DMS guidance Transport: ETSI standard expressly states that transport emissions should be calculated at each stage of the life cycle Vehicles used by engineers producing the service platform, are these included/excluded? Description of the life cycle stages inconsistent with the DMS approach needs clarification Definition needed for non-ict infrastructure, is the intention to capture full life cycle impact of those or use only? Treatment of consumables Terminology: running network to operating network Developing a process map, not specific to TNS - Introduction 6. Allocation It would be useful to explain why physical and economic allocation methods may not be useful 7. Calculating inventory results assessing GHG emissions of a telecommunications network service Embodied stage covered by the separate hardware/infrastructure chapter For the embodied stage, the list of approaches listed in decreasing order of accuracy should be complemented by documentation requirements: e.g. only if primary data from equipment manufacturers are not available can an LCA estimation approach be acceptable and this should be clearly documented. Customer domain use stage: Detailed measurements long term averages are most representative Reference to detailed LCA missing. Service platform use stage: It is likely that the top-down and bottom-up approaches are combined. Operational activities, there are several preferred data quality levels for secondary data to be considered before EIO 3

4 8. Customer domain Different approach being taken here to DMS. No allowance for the impact of software, and how that can affect power consumption. 9. Customer domain embodied stage Isn t the embodied stage covered by the separate hardware/infrastructure chapter? Treatment of embodied stage in general is far too loose, needs to be more prescriptive. Given the Industry now has 2 official standards this should be the basis of any calculation of the embodied energy and carbon emissions Reference for table showing the ratios of embodied emissions needed Double counting needs further clarification, only relevant if the results will be used in an aggregation context Terminology: Energy supply preferred to energy source as sources are beyond ICT sphere of influence maximum or typical power consumption rephrase as typical power consumption Trend shifts due to smartphones Concept LCIA primary data unclear. Is the intention to capture the calculation methods or the data quality? Should also be clarified that ISO and others can be referred for general guidance while ETSI (now published) provides ICT specific guidance to further guide the reader. GHGP product standard should be mentioned for consistency ITU will be published 2012 LCA according to ISO does not specifically require primary data; ETSI in many cases asks for primary or ICT specific (secondary) data i.e. although secondary data is used ISO is still applicable transparency required regarding data Comparability is also beyond the intention of the GHGP Product standards. The equipment may consist of many parts which are produced in various countries, and the mix of countries may also change over time. This approach will not capture improvements made in handling of low power modes which could have as large effects on the results as hardware improvements 10. Service platform Potentially consider economic allocation techniques here Unclear what is excluded: Electricity supply has considerable impact on the results Physical parameters should take precedence over economical Seems like the text refers to different kinds of allocations rather than to different approaches, also are the additional approaches better described as sub-approaches? Transaction-based approach description unclear Assessment approach proposed to move to Introduction/appendices. End of Life Treatment? 11. Operational activities 4

5 Operational activities embodied stage unclear what is included/excluded (e.g. embodied emissions of operational activities during use phase, construction of buildings and vehicles) Definition of non-ict facility unclear, examples needed Operational activities use stage unclear is this operational activities during use stage? 12. Detailed Assessment GHG emissions from distribution and transport of ICT equipment Need to include diesel as well as petrol/gasoline. Need guidance for the source of emission factors outside the UK. GWP needs to be mentioned Litres approach is more accurate than distance based approach 13. Detailed Assessment GHG emissions from end-of-life treatment of ICT equipment Excluding life cycle stages for historical reasons leads to lack of visibility of trend shifts 14. Appendix 1 Energy efficiency is a concept much broader than the mere consumption. Energy efficiency = F (consumption, intensity indices, and others, etc...) Source, method and assumptions behind the table to be stated. The values for mobile does not seem to imply fair assumptions for the different lines. What is a transaction-based power model? 15. Appendix 2 Energy efficiency depends on many factors thus no estimates are made that increase the degree of uncertainty." Very useful case study The structure and format of the document Structure of the document is a little unclear, not easy to discriminate between major and minor headings. Care needed to prevent repetition of issues that are generally applicable for each assessment better to describe them generally and refer back to that description to give the reader support in understanding what is general method and what is specific consideration for this specific part of the product. Any other general comments or feedback Energy balance equations, may be useful Consistency needed between chapters in respect of embodied emissions and emissions from end of life. Assessment approach for equipment, if this is generic guidance for ICT equipment, should potentially be in an Appendix Terminology needs to be consistent with GHG Product Standard Good guidance document 5

6 Desktop Managed Services (DMS) Chapter General Comments Good Document, needs more work to bring in line with the TNS which was easier to follow Many subjective statements proposed that subjective language statements are avoided in this kind of text GHGP product standard should be referenced and not quoted heavily References also to other standards (e.g. the ICT specific standards ETSI TS , and the ongoing ITU-T L.1410 as well as general ISO 14040/14044 would be appropriate or could be handled in Introduction Chapter appears UK/European centric, suggest making more global especially when citing examples 1. Introduction Take care to not limit to services sold as desktop managed services but also organisations who may want to assess internally provided services Overall a well written document. Clear, one-sentence definition of Desktop Managed Services needed (in addition to the more comprehensive definition outlined in the scope chapter (2.2.)) Clarify on alignment with other standard methodologies or guides being developed Outline specific business goals for assessing DMS in addition to the general rationale Some text in this section seems more relevant for the general Introduction chapter 2. Establishing the scope of the product inventory Functional Unit ( ONE supported user per year??) 1. Needs degree of uncertainty or reliability. 2. Reference flows helping to define this 3. Examples would be useful Wider design of the service can affect the environmental aspects, not just service level objectives (e.g. using remote assistance rather than desk-side engineer support) End user device service, does this refer to a service or to the hardware? Service Level Agreement (SLA) definition needs to be added (earlier) 3. Boundary setting Important to consider the software in the process map Need consistent boundary setting approach with TNS Consider accumulation of insignificant emissions A good service management definition needed. Recycling is important, definition of different processes involved would be useful Exclusion of embodied emissions for engineers cars/transport unjustified 6

7 Discussion of life cycle stages Reference or data or scenario to support training of users being insignificant Provide reference or data or scenario for insignificant activities Color-code (highlight) of the DMS components and life cycle stages boxes for greater usability and usefulness Example of a process map (preferably related to the reference flow and inventory calculation examples, for continuity) would be useful Expand list of non-attributable processes and explain why they are non-attributable End user infrastructure definition needed Use life cycle stages/names instead of stage 1, 2 Consistency with GHG Protocol life cycle stages required Avoid statements that are biased with respect to the expected outcome reduces credibility. 4. Allocation Physical allocation and when it is appropriate Terminology: client devices are elsewhere called End User Devices? 5. Collecting data and assessing data quality Practically, it may not be possible to calculate a PUE for smaller server rooms because the measurement infrastructure may not be in place. Need to be wary of double counting keep definitions of primary, secondary, activity, emission factors, direct emissions, and financial data for clarity and refresher. A decision tree for filling data gaps customised for DMS would be useful. Define, explain and exemplify what type of data can be used to fill data gaps 1. extrapolated, proxy 2. estimated. Add emissions from manufacture, maintenance and decommissioning of other capital equipment, such as buildings and machinery Rationale for exclusion, especially consumables would be appropriate 6. Calculating inventory results Laptops and battery use and double counting of stored energy Not clear whether , print, internet access are services within scope; could be deemed to be a hosted service, so an issue would be drawing the boundary. Use of emission factors in the document confusing, currently very UK centric More general advice re: emission factors could be provided (e.g. latest IPCC emission factors) Handling of GWP is very confusing, in some countries emission factors for grid electricity of for fuels are given by constituent GHG so one needs the GWP for the individual gases to convert to CO2e. 7

8 Are idle, off and sleep states considered to when arriving at the total wattage? Need to consider the cooling PUE co-efficient here as all end user equipment is housed in server rooms or communication rooms in the office buildings. Attributability of employees already employed Rationale for only considering part of the transport distance not clear Business travel The energy bill can be used as an alternative, should be further clarified. Rationale for allocation of servers The structure and format of the document How much will be included from the Product Standard in the Introduction. Any other general comments or feedback Less complete than the TNS guidance Need closer alignment in terms of style and content Needs to be consistency in the scope of the chapters in respect of embodied emissions and emissions from end of life Perhaps these are considered in the Hardware chapter The TNS chapter uses the concept of customer domain, service platform and operational activities and suggests these are generic but they are not used in the DMS guidance, could they be? 8