/ EU Artificial Intelligence Act – recommendations on ecological transparency

Ensure minimum transparency on the ecologicalsustainability parameters for all AI systems inthe AI Act
April 2022

Context
The draft Artificial Intelligence Act (AI Act) will profoundly shape AI regulation in the next
decades in the European Union (EU) and beyond. As it currently stands, the AI Act misses acrucial opportunity to ensure that the development and use of AI systems can be donein a sustainable, resource-friendly way which respects our planetary boundaries. Thisshortcoming of the AI Act is not only detrimental in the light of our collective endeavour tocombat climate change but is also at odds with the objectives of other environmental EUpolicies.

The AI Act must address the environmental impact of AI systems•AI has a “multi-faceted relationship with climate change”: it can be deployed to help withclimate change mitigation and adaptation; can also be used in ways that contravene
such efforts, therefore potentially increasing greenhouse gas emission; and AI
systems themselves can directly emit greenhouse gases through computationalenergy consumption1. Moreover, as the European Consumer Organization (BEUC)
stresses, “empirical findings have shown that digital technologies contribute to 4% ofoverall greenhouse gas emission, a number expected to double by 2025” 2.

•The White Paper on Artificial Intelligence - A European Approach to excellence andtrust3 [White Paper] which laid the ground for the draft AI Act, stressed that “AI canhelp with finding solutions to climate change and environmental degradation”, but “it isimportant that it happens in an environmentally friendly manner”. It set out that the“environmental impact of AI systems needs to be duly considered throughout their lifecycle

1 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12527-Artificial-intelligence-ethical-and-legal-

requirements/details/F2665623_en
2 https://www.beuc.eu/publications/beuc-x-2021-088_regulating_ai_to_protect_the_consumer.pdf
3 https://ec.europa.eu/info/sites/default/files/commission-white-paper-artificial-intelligence-feb2020_en.pdf

and across the entire supply chain, e.g. as regards resource usage for the training ofalgorithms and the storage data.” This consideration got translated into the voluntary
application of codes of conduct for the AI Act, whereby providers may create andimplement commitments related to environmental sustainability themselves. In ourview, this does not go far enough to ensure that the development and use of AI
systems are done in a sustainable, resource-friendly way.
•Both in order to contribute to the endeavour of combating climate change and toensure the coherence among EU policies, we demand the introduction ofhorizontal, public-facing transparency requirements on the resource
consumption and greenhouse gas emission impacts of AI systems – irrespectiveof risk level – in relation to design, data management and training and underlying
infrastructures (hardware, data centres, etc.).

•Transparency indicators would have a twofold purpose: On the one hand, they could
inform users and the general public about the ecological impact of AI systems, on theother hand we could gain invaluable insights in the potential issues for sustainability
regarding AI that could lead to further political measurements.

•Moreover, impact on the environment shall be considered as a factor whenassessing the risk an AI system may pose and therefore as a criterion shall be
included in Article 7.

This paper was drafted by AlgorithmWatch with the support of Access Now. It is supportedby the following organizations:

The paper follows the Joint Civil Society Statement 'An EU Artificial Intelligence Act for
Fundamental Rights’ signed by 123 organisations in November 2021.