UNITED STATES ENVIRONMENTAL PROTECTION AGENCYWASHINGTON, D.C. 20460
OFFICE OF
AIR AND RADIATION

October 6, 2011
Dear Data Center Storage Manufacturer or Other Interested Party:
The U.S. Environmental Production Agency (EPA) welcomes your input on the attached Draft 2 Version
1.0 ENERGY STAR® Data Center Storage specification. Comments on Draft 2 are due to EPA no later
than November 4, 2011.
Since the release of Draft 1, EPA has worked with a wide range of stakeholders to revise and clarify theapproach associated with this new ENERGY STAR product category. The attached Draft 2 presents a
proposed scope and package of efficiency requirements that enable the program to highlight the topperformers in the market in the near-term and contains provisions to support more robust efficiency
criteria going forward. EPA’s rationale for proposals and important discussion topics are highlighted innote boxes located throughout the document. The following key changes were made in this draft:

1•General Formatting and Partner Commitments: The structure and sections of the specification are
now aligned with ENERGY STAR formatting requirements. Stakeholders are encouraged toreview, in particular, the revised proposal for use of the ENERGY STAR mark in association withStorage Equipment.

•Definitions: EPA reviewed existing and new definitions in the specification and compared them tothe 2011 Storage Networking Industry Association’s (SNIA) dictionary to identify potentialconflicts. Definitions are aligned with the 2011 SNIA dictionary where they were found to be
sufficiently descriptive for use in the specification. Product classification definitions originallydrawn from the SNIA Storage Taxonomy are revised to align with updates presented in the SNIA
1Emerald™ Power Efficiency Measurement Specification .

•Product Families: The family structure is revised to reflect EPA’s proposal to pursue“bookending.” This approach provides a representative testing structure by evaluating maximumand minimum points in a group of configurations, representing the maximum and minimum
configurations intended for sale as ENERGY STAR qualified (not necessarily the limits ofavailable configuration options).

•Program Scope: The Version 1.0 scope of the program is solidified to cover Online-2, Online-3,and Online-4, as defined in the in SNIA Emerald™ Power Efficiency Measurement Specification,
Version 1.0 (23 August 2011). EPA will consider other sectors of the market in future revisions tothe program.

•Power Supplies: Efficiency and power factor requirements for all primary power supplies are set
at levels that align with those of Climate Savers/80Plus Silver. This proposal will be revisited if
industry-gathered data on storage power supplies justifies modification. Additionally, stakeholders
have raised concerns about power supplies associated with “embedded” hardware manufacturedby third parties (e.g., network switches). Placeholder language is added under Table 3 inreference to this topic and EPA encourages stakeholder comments and proposals on this issue.

http://www.snia.org/tech_activities/standards/curr_standards/emerald•Efficiency Criteria: In support of a future active mode efficiency requirement, EPA intends toinitially require the reporting of certain key data for the first version of the Storage specification.
This would require that a Data Center Storage product be evaluated using a predetermined activemode testing methodology, with results to be publically disclosed via the ENERGY STAR
program as part of the Power and Performance Datasheet. EPA proposes the use of the SNIA
Emerald™ Power Efficiency Measurement Specification, Version 1.0 (23 August 2011) as thebasis of Active State evaluation and data disclosure.

•Ready Idle: A framework for Ready Idle power limits is also included. EPA proposes that products
be required to meet the power limits ultimately set for this requirement in addition to disclosing
active mode efficiency.

•Energy Efficient Features: To ensure ENERGY STAR Data Center Storage products offer a toptier energy-efficient platform, EPA proposes a list of core features required of all productsqualified in the program. EPA has added a new section to capture these features and welcomesstakeholder input and comments on this feature list.

EPA will host a stakeholder meeting at the Storage Networking World (SNW) Fall 2011 conferencein Orlando, FL on Thursday, October 13, 2011. A Webinar will be offered for those who cannot
attend in person. The agenda will be focused on elements from Draft 2, Product Families, and other key
topics. Please RSVP to storage@energystar.gov no later than Tuesday, October 11, 2011 with thesubject "RSVP – Storage SNW October 13 Meeting," and indicate in-person or remote attendance.
Stakeholders are encouraged to review the Draft 2 specification and send comments tostorage@energystar.gov no later than November 4, 2011. For further information on specification
development activities to date, visit the ENERGY STAR Product Development website atwww.energystar.gov/NewSpecs and follow the link for “Data Center Storage.”Thank you for your continued support of the ENERGY STAR program. Please direct any specificquestions to RJ Meyers, EPA, at Meyers.Robert@epa.gov, or 202-343-9923; or Evan Haines, ICF
International, at ehaines@icfi.com, or 202-572-9456.
Sincerely,

Robert Meyers
U.S. Environmental Protection Agency, Climate Protection Partnerships Division
ENERGY STAR Program