Index

1

Topic

Definitions

Subtopic

Stakeholder Comment

EPA Response

Product Types

A stakeholder suggested changes to add clarity to the product types definition. It wasrecommended that the term "storage media" be defined or replaced with "storage
device" and that a more detailed description of "other devices" be used. Anotherstakeholder questioned the use of the term storage device in certain definitions (ex: NAS
and SAN) and suggested referring to the 2012 SNIA Dictionary.

EPA will maintain the current definition using the term storage device
as the term provides sufficient clarity. Also, the definition will remain
open to "other devices" to prevent an unnecessary constraint ontechnologies.
There is currently no test to detect auto-tiering in the SNIA V2.0
EmeraldTM specification, so EPA is not able to recognize this as a COM
at this time. EPA hopes that auto-tiering can be included in a futureversion of the Emerald specification, and notes that nothing prohibits
manufacturers from enabling it in their systems.

2

Definitions

COMs

A stakeholder requested that the list of COMs be increased to include Automatic Tieringand other similar functions since product documentation can verify their availability.
They suggested that an appropriate requirement would be that the documentation ofthese products be under some form of engineering control.

3

Definitions

Thin Provisioning

A stakeholder suggested that the term "reallocating" be changed to "allocating" in thethin provisioning definition.

EPA has incorporated this change into Draft 4 of the specification.

Storage Taxonomy

A stakeholder suggested that the term "moderate response time" and "moderate andlong term" be further defined. They also suggested removing the optical disk referencein the removable media library and virtual media library definitions because this is a
specific product. Also, they requested that "SAN" be deleted from the interconnect
element definition because there are many types of switches.

The terms "Moderate response time" and "moderate to long responsetime" are defined in the definitions where the terms are used. The
optical disk and SAN references are meant as examples to provide
further clarity for the definition and are not intended to distinguish any
product.

4

Definitions

5

Definitions

Capacity

6

Definitions

Operational States

A stakeholder recommended adding the base + exponent to capacity examples (i.e. 1 MiB MB and MiB are defined in the Capacity definition. Raw capacity isdefined in Section F.5 of the definitions. The storage specification ties
= 220 = 1,048,576 Bytes, 1 MB = 106 = 1,000,000 Bytes).
its requirements to storage device count and does not need to
A stakeholder requested that references to raw capacity be used as is the standard in the reference specific capacity amounts. The raw capacity definition is
included for reference only.
SNIA EmeraldTM Power Efficiency Specification.
The definition of Max TTFD is defined in the specification under
One stakeholder suggested the addition of a definition of MaxTTFD and also a reference Section J.6 in the definitions.
to avoid confusion. Another stakeholder recommended adding "user settable" to themention of deep idle in the online storage definition.
The Deep Idle definition states that this capability must be a userselected, optional feature of the storage product.
Several stakeholders had questions on the SSD storage device limit for cache andrecommended that the manufacturers state cache size for each tested configuration
within a product family. Stakeholders stated that the quantity of cache is somewhat
dependent on the number of storage devices in a system.

7

Definitions

Product Family Cache

EPA will maintain the current approach that a storage product may bequalified with any amount of cache (DRAM, SSD, etc.) that the
manufacturer chooses to use in the qualified optimal configuration andthat the qualified family of storage products may contain that amountA different stakeholder agreed that a range of cache be allowed but suggested that it be aof cache or larger without retesting. This enables manufacturers to
configuration variable instead of a qualification criterion because it is defined by thedefine a floor for their products' cache performance, letting them scale
performance envelope and configuration. Two additional commenters stated that thecache upward from a minimum level of their choosing. This approachallowable cache should be greater than or equal to the qualifying configuration.
removes a possible confounding variable in understanding systembehavior--namely, the possibility of system performance decreasing
Another stakeholder supported the product family approach but believed that the amountdue to a smaller cache size.
of cache should be limited to the amount of the corresponding qualified configuration toprevent certain configurations from consuming more than the registered product.

IndexTopic

Subtopic

Stakeholder Comment
Stakeholders agreed with the definition of optimal configuration but pointed out that
there is no requirement for homogeneous configurations. Another commentersuggested that vendors derive optimal configurations to show the best power
performance ratio.
A stakeholder believed that optimal configuration should be renamed Optimal
Performance/Power Configuration (OPPC) because "optimal configuration" is used inregards to performance when communicating with customers.

8

Definitions

Product Family Configurations

Several stakeholders stated that the terms maximum and minimum configuration were
confusing because products could be configured outside of these terms. One
stakeholder pointed out that these terms refer to a system with the minimum/maximum
number of storage media to deliver an acceptable workload capability. A recommended
change for these configuration terms was 'Maximum/Minimum Qualified Configuration'.
Two commenters suggested that the -20% to +5% range for qualified systems is
restrictive. One recommended that it be expanded to -40% to +15% or it should beallowed as a sliding bar.

9

Definitions

Several stakeholders offered cooperation and urged EPA to consider qualifications forheterogeneous configurations for several reasons:• Optimum systems could result in configurations that would never be sold; which
would be potentially confusing for customers• Test burden could be significant for qualifying a new product since it would requireapproximately 2 days to test each configuration for each device type
Product Family Mixed Configurations • Predicted performance of heterogeneous systems would not be representative of realworld situations
Another stakeholder suggested that limiting the optimal configuration to only
homogeneous drives might be best for consistency. One stakeholder questioned how amixed configuration would go through the qualification process.

EPA Response

EPA has provided additional clarification in Sections 1.I.2 and 1.I.7 that
only single storage device configurations may be tested in the Draft 4
specification.
EPA has maintained the Optimal Configuration definition, but hasrevised and renamed the Minimum and Maximum Qualified
Configuration definitions to clarify that they are not the same as theminimum and maximum configurations offered by the manufacturer.
EPA will maintain the current range for qualified storage products, but
has added an Expanded Maximum Qualified Configuration in addition
to the existing Expanded Minimum Qualified Configuration to provide
more flexibility for products whose performance/watt remains within
15% of the Optimal Configuration outside the default qualified range.

While EPA agrees that heterogeneous testing would be ideal for
reducing test burden, EPA maintains its concern that the current V2.0
SNIA Emerald specification does not provide sufficient insight into
heterogeneous configuration performance and that applying it to such
systems will not produce consistent results. The current
homogeneous device testing proposal provides purchasers withtargeted information that highlights how a given system will handle
particular workloads and allows for estimation of how a heterogeneous
system would behave, even if it does not directly test a heterogeneous
device system.

Index

10

11

Topic

Definitions

Definitions

Subtopic

Product Family Drawer Boundary

Product Family Expanded
Configuration

Stakeholder Comment

EPA Response

Another point of concern for stakeholders was drawer rounding. Two stakeholders
recommended that the requirement to round to the nearest shelf for minimum andmaximum configurations be optional. Another stakeholder proposed that drawer
rounding be applied to systems of any device count because a drawer that is not full, is
not fully amortized. Another stakeholder pointed out that the quanta of less than one
shelf reduces energy efficiency and all systems should be rounded to the nearest nonzero shelf boundary, independent of number of drives.

EPA thanks stakeholders for their comments on this issue.

A suggested strategy for drawer rounding from a stakeholder is as follows:• Allow rounding of drawers for Online 3 and 4 systems• Allow maximum qualified configurations to be a full drawer above the optimal in order
to simplify the maximum configuration designation• Allow the minimum configuration to be set at the nearest full drawer multiple below the
20% optimal drive count• Require workload metrics to be reported for the minimum/maximum systems after therounding has been completed

While only size increases may appear to be favored, EPA believes thatrounding up to a larger drawer count (rather than down) in a Minimum
Configuration will result in a smaller range of qualified product, as thespace between Minimum and Maximum Configurations will be smaller.
Many stakeholders have argued that scale-up systems are sold small
and built up over time. EPA believes that rounding down allows
smaller systems to qualify and provides purchasers with more relevant
information for the systems they will likely be buying.

A stakeholder requested expansion of the percentage differences required forcomparison to the optimal configuration. The commenter also suggested that thecomparisons be performed between each individual workload test score instead ofcreating a single score.

The Expanded Maximum and Minimum Qualified Configuration's
performance difference requirement has been expanded to within 15%of the Optimal Configuration performance (performance/watt) based on
stakeholder feedback. EPA agrees that this expansion will allow amore representative range of product sizes to qualify while maintaining
the rigor of ENERGY STAR requirements for storage products.

If indeed drawer boundaries are the most efficient operational point,
EPA would expect venders to center submissions around those points.
The current Draft 4 specification has included language stating that
manufacturers may choose to round up (in Maximum Configuration) or
down (in Minimum Configuration) to the nearest drawer boundary, andexcludes Online 2 systems. In this way, EPA feels venders whose
A stakeholder stated that a 1-drawer allowance is not useful and it doesn't make sense to systems are most optimal around drawer boundaries have the ability totest and submit results showcasing that, while at the same time not
be liberal about size decreases and size increases because size increases are favored
imposing architectural restrictions for developments which might besince they amortize the power used by the controller. A commenter recommended
allowing product variance in either direction because testing a product at several levels able to deliver energy efficiency at configuration points not alignedwith full drawers.
can be expensive.

Index

12

Topic

Definitions

Subtopic

Product Family Combinations of
OptimalConfigurations

Stakeholder Comment

EPA Response

A commenter stated that the description for creating combined storage media systems
from transaction and streaming systems is confusing and offered some additional
clarifications and suggestions:• Allow validated storage replacement options to be included in the combined systems• "lines 366 to 367: Reword this section to read: “The combined system does not containany storage device, or its validated replacement storage device, at a greater percentage
of total devices than that found in the OPPC (Optimal Performance/Power Configuration),
Minimum Qualified, or Extended Minimum Qualified configurations."
EPA has revised Section 1.I.7 to provide more clarity on the• "lines 374 to 375: This sub-section should be reworded to read: “When rounding to a
replacement of storage devices as well as providing drawer rounding
drawer, Storage Devices should be added or removed (as appropriate) to maintain disk
guidance when multiple Optimal Configurations are combined. EPA
percentages in roughly the same proportion as the proportion used in the configuration welcomes stakeholder feedback on these changes.
before drawer rounding is initiated.” "• Sub-section 1.I.iv should be removed because it restricts the percentages of storage
EPA is open to discussions on the algorithm for combining optimal
configurations.
devices in smaller configurations to the maximum percentage of the optimal or tested
configurations.
Another stakeholder appreciated the idea of qualifying combinations of optimal
configurations but stated that the algorithm would need to be rethought if optimal
configurations were allowed to be heterogeneous. Another suggestion was to eliminate
the complex criteria and state that all devices are required to be from one or more of theaccepted configurations.

13

Definitions

14

Definitions

15

Definitions

Product Family A stakeholder supported the position that a capacity optimization configuration should
Capacity Optimization be submitted in conjunction with a transaction or streaming optimized system.
A stakeholder stated that the definition for "Scale-Out Storage Product" doesn't reflect
what is available on the market because there are products with controllers that have theability to work in tandem and to add additional storage devices. For "Scale-Up Storage
Products", they suggested the definition exclude products that have the ability to scaleout. The suggested definitions are:• "Scale-Out Storage Product: A storage product in which independent functional nodes
have the ability to work in tandem with additional nodes."• "Scale-Up Storage Product: A storage product in which additional storage devices canbe added to the original controller(s) configuration as capacity needs increase, and inwhich all functional nodes operate independently from other functional nodes."EPA thanks this stakeholder for their feedback.

The definitions for scale-out and scale-up storage products have been
removed and new definitions have been added to provide clarity. The
new terms, "centralized controller storage" and "distributed controller
storage", were added to Section J of the definitions. The Draft 4
Scale-Out/Scale-Up
specification contains requirements for both centralized controller
storage as well as distributed controller storage. EPA looks forward to
Another commenter noted that differences in scale-up and scale-out systems are blurring
discussing these new definitions with stakeholders.
as technology advances. For example, most large systems can scale up to some defined
number of storage devices and then scale out with additional controllers. They stressed
the importance of not precluding recognition of either type in the definitions and thatfurther discussion would be beneficial. A stakeholder recommended that the definitionof scale-out products account for a node that contains a variable number of storage
devices.
EPA has removed the Maximum Sustainable Performance definition as
Maximum Sustainable A stakeholder requested a reference to the EmeraldTM specification stability criteria for
it is not used in the most recent drafts of the V1.0 Storage specification
Performancesustainable performance.
or test method.

IndexTopic

Subtopic

16

Definitions

Physical/Modeled
Data

Stakeholder Comment
A stakeholder agreed with the physical and modeled data definitions.
A stakeholder questioned the inclusion of only online data storage products andrecommended that more products are considered because of their role in efficient tiered
storage concepts and can provide options for efficient storage management (e.g.
MAIDS). However, excluding adjunct storage products, interconnect elements, and tapebase long term storage products is appropriate.

17

EPA Response
EPA thanks this stakeholder for their feedback.

While the addition of Near Online may be considered in future versionsof the storage specification, it is too large of an alteration to the
Version 1.0 specification at this time. Additional data or supporting
information on Near Online systems is welcomed to support future
development.

Another stakeholder expressed their need to evaluate the risk of having a small range of
qualified systems compared to what is required to be tested although they understandwhy EPA has chosen a smaller range for qualified systems. This commenter expressed a
The Online category definitions have been altered to clarify that aneed for industry to find a balance between testing systems and minimizing risk tostorage product should only exist in one category.
ENERGY STAR.

Qualifying Products

A stakeholder suggested that a product should only be in one online category for
qualification purposes to ensure compatibility between Version 1.0 and 2.0.

18

Qualifying Products

RAID

A stakeholder requested that the requirement for a RAID capable storage controller bechanged to "contains a controller with advanced data recovery capability such as RAID, Based on stakeholder feedback, EPA has clarified that all products
submitted for qualification must include a controller with advanced
mirroring/grid technology, or other comparable advanced error detection and recovery
data recovery capability, including but not limited to RAID. Based on
system." Some systems use mirroring/grid technology that is comparable to thefunctionality of RAID and can even improve performance. Another commenter suggested stakeholder feedback, EPA believes the RAID requirement in Draft 3'parity' as a better term than RAID and JBOD be used instead of Direct Attached Storage was too restrictive for newer storage architectures.
products.
There were some concerns regarding scale-out and scale-up systems. One stakeholder
encouraged communication regarding the exclusion of scale-out products that support a
block interface. Another stakeholder expressed the need for "node" to be defined anddata obtained to show the impacts of additional nodes. A different stakeholder
recommended that scale-out products be excluded until a definition is agreed upon.

19

Qualifying Products

Scale-Out/Scale-Up

One stakeholder suggested that only scale-out storage products beyond the firstcontroller node where the system consists of more than 200 drives be excluded because
See Index #14. EPA looks forward to discussing scale-up and scalethe total scale-out system is greater than the sum of individual parts. Though theseout systems with stakeholders when reviewing Draft 4.
products are excluded, the stakeholder recommended that EPA allow companies tosubmit data for larger scale-out systems to determine if it should be included in Version
2.0.
Another stakeholder agreed that scale-out systems be excluded only if the definition ischanged to state that it is a storage product with independent functional nodes that havethe ability to work in tandem with additional nodes. This commenter noted that productsthat scale-out but do not scale-up can compete with products that scale-out and scale-up
so these products need to be on a level playing field to avoid a competitive advantage.

Index20

Topic

Power Supply
Requirements

Subtopic

Efficiency
Requirements

Stakeholder Comment

EPA Response

Several stakeholders supported a consistency with CSCI Silver requirements andencouraged the removal of the 10% load point and the increase for efficiency
requirements unless data can support. Commenters said that it would be confusing if
the target efficiencies did not correlate with CSCI Silver and selecting levels between two
Based on stakeholder feedback and additional research, EPA has
recognized PSU performance categories makes comparison difficult when comparing
removed the 10% load point from the power supply efficiency andqualified and non-qualified products.
power factor requirements in storage products.
One stakeholder stated that correct sizing of power supplies is crucial to high overall
EPA will display the presence of power supply resizing functionality on
efficiency which can lead to a larger saving potential than by striving to strengthen thethe ENERGY STAR website, and will add the topic for consideration in
power supply efficiency. Thus, the commenter suggested that this be referenced andfuture specification revisions.
requirements be established to provide online power calculation tools to help buyers
choose the right power supply. Also, the supplier should offer several power supply
EPA has updated Section 3.2.1 to reference Rev 6.6 of the EPRI Internal
models to serve different loads and configuration levels. The products equipped with
Power Supply Efficiency Test Protocol to harmonize with theredundant power supplies should include the option to switch this power supply into
requirements in the V2.0 Computer Servers Program Requirements.
standby when not used.
Another stakeholder requested that the power supply units section reference Rev 6.6 of
EPRI Internal Power Supply Efficiency Test Protocol to be consistent with the Computer
Server Requirement Version 2.0 and to include the most current version of the protocol.

21

Power Supply
Requirements

Embedded
Equipment

A stakeholder supported requirements for efficiency of embedded PSUs that power
primary components of a DC storage product but believed it necessary to include arequirement that all equipment in a storage system that falls under another ENERGYSTAR specification (ex: servers, computers) also be qualified. The reason for thisrequirement being that a customer would expect all equipment in a labeled storage
system be compliant. A stakeholder believed that it was not appropriate to require
individual qualification of embedded products that are used as components in a storage
system. A storage controller, for instance, will fit the definition of a server but isdesigned specifically to operate a storage system and will likely not perform well under
ENERGY STAR server criteria.
Several stakeholders agreed with the embedded equipment requirements because it
keeps the focus on elements that require the most power in online storage products.
One stakeholder stated that the amount of embedded power supplies and regulators canvary from product to product and testing and validating the efficiency of thesecomponents will be difficult. It is suggested that the efficiency should be assessed
through performance of the product on the performance/power metrics.

EPA thanks the stakeholders for their comments and will maintain thecurrent requirements of Section 3.2.1.iii that only embedded power
supplies that power primary components of the storage product mustmeet the power supplies requirements in Table 1 and Table 2 of the
Draft 4 specification. This issue has been discussed in the past andwas deemed to introduce a high level of complexity with respect tocomponent sourcing and coordination between unconnected andshifting updates of other ENERGY STAR specifications.

IndexTopic

Subtopic

Stakeholder Comment

One stakeholder agreed with the active and idle state disclosure but requested a readyidle and deep sleep requirement for the specification. The commenter stated thatremoving the idle requirements will create difficulty in identifying the most efficient
products.

22

Active/Idle State
Criteria

23

Power Management
Requirements

EPA Response
EPA will provide Ready Idle information for all configurations on the
ENERGY STAR website in Version 1.0. Creating requirements for
Ready Idle in Version 1.0 would lead to systems being optimized for
Ready Idle, which produces non-representative data for transaction
and streaming optimized systems. EPA cannot require a deep idle
option as there is currently no test method to validate it.

EPA will publish all active and idle data at the effective date of the
Two stakeholders supported the proposal for collecting active metric data for
Version 1.0 Storage specification.
transaction, streaming, and capacity optimized systems before setting qualifying criteria
because there is insufficient data currently. One commenter stated that the lack of SNIA
Based on stakeholder feedback, EPA has removed the 24 hour idle test
metric results, cost of obtaining systems and performing testing has created difficulty inrequirement from the test method and now requires that testers follow
providing the EPA with a broad data set. This commenter recommended that EPA
the idle testing criteria presented in the V2.0 SNIA EmeraldTM
publish the data received without references for two years to give manufacturers a better
specification. The 24 hour period was suggested to help capture
understanding of the test data for a range of system configurations.
system behaviors that occur infrequently but which could have asignificant impact on long-run power consumption. However, it is not
Another stakeholder stated that the 24-hour idle test is excessive but gave support forclear at this time that 24 hours would capture all of these, so the gains
EPA's position on user-settable deep idle. This commenter requested the opportunity tofrom lengthier testing would not outweigh the additional burden. EPA
work with the EPA to define a test for COM technology.
will pursue the topic of idle power activities in future revisions of theStorage specification to better understand what an ideal idle test time
would be.
Several stakeholders appreciated the removal of the requirement for a power modelingpresale tools warranty. One of these stakeholders requested clarification on the interestin power-performance modeling tools, validation of model data, and the process forusing these models for qualification. A commenter encouraged using modeling data as
an optional requirement because this information is confidential and not as well
EPA would like to clarify that for Online 4 systems that use modeled
developed as it is for server products.
performance/watt data for qualification, EPA expects that a powermodeling tool characterizing the storage product will be madeThree stakeholders questioned whether this requirement regarded power calculators
available to manufacturer qualified purchasers of the product. EPA has(customer tool to determine power required for a potential configuration) or a powermade minor revisions to Section 3.3.1 to provide additional clarity on
performance modeling tool that would predict performance/Watt for a configuration andwhat this requirement is asking. Online 4 systems that do not use
workload. The power-performance modeling tool is viewed as experimental andmodeled data to qualify will not be subject to this requirement.
additional information would need to be provided regarding the expected accuracy andcalibration. One stakeholder proposed to ask for modeled data between three measured
points and allow a vendor to chose a range for testing.
Another stakeholder supported the availability of power modeling presale tools for online
4 systems and believed that performance per Watt is an easy metric for customers tounderstand.

24

Energy Efficiency
FeatureRequirements

Adaptive Cooling

One stakeholder pointed out that some devices or units in a storage product do not
EPA has revised Section 3.5.1 to state that adaptive coolingrequire active cooling and requested that this requirement clarify that adaptive cooling is requirements are not applicable to devices that employ passive
not necessary for these devices.
cooling.

IndexTopic

Subtopic

Stakeholder Comment

EPA Response

A stakeholder requested that the COMs in Table 4 be defined. They stated it was
regrettable that the list of energy efficiency features was reduced from the previous draft
and additional features could be added. Exceptional cases where COMs would not be
required should be defined rather than reducing the overall requirement.

25

Energy Efficiency
FeatureRequirements

26

Energy Efficiency
FeatureRequirements

27

Information
Reporting
Requirements

COMs

Other stakeholders wanted to further reduce the minimum number of required COMs.
Several commenters suggested one COM be required for Online 3 and 4 systems
because these systems may not have COMs initially designed into the system to meet acustomer's needs. Two stakeholders requested 1 COM for Online 3 and 2 COMs forOnline 4 be the requirement because Online 4 products demand performance rather thancapacity optimization.
Stakeholders gave the following reasons to not require that a number of COM functions
be available for all qualified systems but the COMs available should only be listed on a
PPDS:
• Many COMs require a higher level of power consumption and can degrade system
performance (customers may choose to improve system utilization and accept
performance degradation in some applications due to COM use)
• A growing trend of COMs being managed by hardware appliance added to the system
as opposed to being on system hardware• COMs functionality can be embedded into a product where that functionality brings
benefits to a specific workload type and it is not possible to turn the COMs off

Proposed COMs

EPA will not add additional COMs to the energy efficiency feature listthat can not be validated by an existing test. EPA encourages
stakeholders to develop additional validation tools for COMs theywould like to be considered in future revisions.
Based on stakeholder feedback and a survey of products available on
the market, EPA has revised the COMs requirements for Online 3 andOnline 4 products in Table 4 of the Draft 4 specification.
EPA would like to clarify that all COMs that are offered for a qualified
product will be listed on the ENERGY STAR website.

Stakeholders requested an expansion of the list of available COMs. One requested that
MAID, a feature that stops a spinning disk and enables power saving, and auto-tiering,which is a feature that allocates hot data to SSD and cold data to HDD, be included in the
See Index #25
recognized COMs. Another stakeholder supported an opportunity to declare additionalenergy saving software and use these or SNIA defined COMs for the requirements ofTable 4 (ex: Data Migration).
A stakeholder expressed concern with publishing data and how it will be displayed. The
data collected by EPA will never have been reviewed by industry for consistency,
configuration errors, or interpretation discrepancies. They requested that this dataremain anonymous for at least 2 years to allow stakeholders to understand its
implications.
EPA has revised Section 3.5.7 to clarify that all active and idle test
results will be made available on the ENERGY STAR website as part ofA stakeholder was opposed to disclosing active performance and efficiency because
the qualification process.
active performance can be obtained from multiplying power by active state efficiency.
Since storage systems are tailored to specific needs, each system would have its own
performance parameters which could cause confusion for customers. If the data ispublished, they asked that it be anonymous.

Index

28

29

Topic

Information
Reporting
Requirements

Information
Reporting
Requirements

Subtopic

Active/Idle State
Disclosure

Stakeholder Comment

One stakeholder suggested changing the "Optional" requirement for transaction,
streaming, and capacity optimization in Table 5 (Public Disclosure Requirements for
Active and Idle State Efficiency) to "Not required".
SNIA's "Hotband Workload" test should be finalized in October 2012 and two
stakeholders believed that it should be incorporated into the Version 1.0 metrics
collection process.

Several stakeholders expressed confusion regarding the requirements listed in Table 6(Workload Weighting Requirements) and some suggested its removal from thespecification. Reasons for removing this requirement include:• Flexibility is needed to develop storage systems for different markets• SNIA is working to improve the test methodology to show performance power
improvement of cache and ENERGY STAR should wait to include this method to collectcorrect data for storage systems that utilize cache and caching algorithms• The requirements represent a blended score for transactional, streaming and capacity
optimized workloads and there is little data on typical workloads to determine anWorkload Weighting
appropriate proxy• Requirement improperly weighs metrics that have higher ranges over metrics withlower ranges• The results for "Mixed Workload 2" are not used for any purpose and should be
removed.
One stakeholder supported the inclusion of Table 6 to ensure a level of commonality indifferent manufacturer's approach to defining Optimal Configuration but believed thetable needed to be simplified as appropriate.

EPA Response
EPA will maintain the current use of "optional" in Table 5. EPA would
like to clarify that all testing data shall be submitted via Certification
Bodies, but only the required workloads in Table 5 will be shown on
the ENERGY STAR website.
EPA has incorporated the V2.0 SNIA EmeraldTM specification into theDraft 4 specification and Draft 2 test method, with the hopes that theV2.0 Emerald specification will be finalized and fully functional prior
the release of the Final Draft of the ENERGY STAR Storage
specification. If the V2.0 Emerald specification does not meet thisexpectation, EPA will revert to referencing the V1.0 Emerald
specification for the Final Draft of the specification and test method.

EPA has simplified the approach in Table 6 of the Draft 4 specification,
while maintaining the goal of ensuring a level of commonality indifferent manufacturer's approach to defining optimal configurations.
EPA welcomes stakeholder feedback on these revisions.

Index30

Topic

Information
Reporting
Requirements

Subtopic

Stakeholder Comment

Two stakeholders offered an alternative approach to require comparison between
individual workload test scores for a workload type, with the majority of the scores (3 fortransaction, 2 scores for streaming and 1 for capacity optimization workload). The
requirement would be that these majority scores have to be within 15% of the scores for
the OPPC (Optimal Performance/Power Configuration) and the remaining scores within
20% of the OPPC scores (2 for transaction workload and 1 for the streaming workload).
Also, they believed that 10% is too narrow of a band for comparison, and this range
should be expanded to enable qualification of systems with a lower number of storage
media. If this approach is adopted, it is also recommended that Table 6 be removed and
See Index #29. EPA looks forward to discussing this issue with
Workload Weighting a section for Extended Minimum Configurations be added to account for this method.
stakeholder when reviewing Draft 4.
Proposals
A stakeholder also suggested that EPA collect metric results for different systems toassess their relative values and determine overall criteria for the different workloads. If
there are significant differences in the data, then additional investigation will be required
to create specific weighting criteria. Another stakeholder recommendation was tosimplify the table with the following criteria:• Transaction Optimization: 80/10/10 of the transaction workloads and eliminate theMixed Workload 2 since it does not count in the weighting, or add it in as a 10% factor• Streaming Optimization: 50/50 of the sequential workloads• Capacity Optimization: 100: Ready Idle
The request for data at +15% and -40% of optimal configuration, while the qualification
range is from -25% and +5%, will require interpolation so one commenter suggested thatthe required data submission bounds be the same as the maximum and minimum
configurations. Also, one stakeholder stated that expansion in either direction for
product size should be optional because some manufacturers have configuration limits.
Another stakeholder requested that these requirement point to Table 5 instead of Table 6(Workload Weighting Requirements).

31

Information
Reporting
Requirements

EPA Response

Online 2/3 Storage
Products

EPA will maintain the current default ranges of system size for both
qualification and testing, and would like to clarify that the range of
qualification is a subset within the range of testing in most cases. The
two ranges may be equal depending on how the system fits into theoptional Expanded Minimum and Maximum Qualified Configuration
provisions in Sections 1.I.3 and 1.I.4.

A commenter wanted clarification on why class 2 or 3 systems have more stringent
EPA agrees that rounding to the nearest drawer boundary when testing
testing requirements than class 4 products and believed that they should have the samelarger systems can provide more energy efficient systems, and has
treatment. They also stated that the 3-configuration test is onerous and a sliding bar
revised Section 3.5.3 to allow rounding to the nearest drawer.
percentage range should be used instead. This commenter pointed out that 15% of a 288disk system is only 43.2 drives and rounding that is 0 shelves thus having the same as
EPA is allowing modeled data for O-4 systems only because of their
the optimal configuration. They recommended rounding up would be more appropriate
large size, and the associated testing burden that comes with thesein addition to not setting a limit on the size of the larger configuration, except to specify
systems.
that it has more drawers than the optimal configuration. A stakeholder also suggested
that Online 2 and 3 be allowed to provide modeled data.

Index

32

33

34

Topic

Information
Reporting
Requirements

Information
Reporting
Requirements

Storage Device
Replacement
Requirements

Subtopic

Stakeholder Comment

Online 4 Storage
Products

A stakeholder was confused by the fact that data is required to be submitted for the
optimal configuration and for configurations at least 40% smaller and at least 15% larger,
while the standard qualification range is only -20% and +5%. They assumed that there
was an implication to calculate this envelope assuming linearity. This commenter
recommended that the minimum and maximum configurations be measured directly and See Index #31
allowing manufacturers the option of submitting additional data for configurations
outside of this range. Another suggestion was to set the minimum configuration at -25%
to reflect typical configurations of purchasers. A commenter requested that the EPA
state the allowable % difference between the model and actual measured data.

PPDS

One stakeholder supported the development of the PPDS to better inform buyers.
Another stakeholder recommended that the PPDS only include performance per Wattdata without any raw performance numbers or raw power consumption data because thisSee Index #27
would contradict long-standing operating norms of the industry and will not add value
for consumers. One additional commenter stated that the data should be anonymous oronly the performance/power ratio be published. They also noted that the ASHRAE chartreference was not necessary.

EPA Response

Several stakeholders appreciated the attempt to reduce test burden with allowing
substitutions outlined in the storage device replacement requirements. However,stakeholders had the following comments and suggestions regarding the requirements:• Rotational media requirements are too narrow for significant testing reduction because
there will be variance greater than 5% (alternative: use the requirements for nonrotational storage devices for rotating media while specifying that the rotational speed beequal)• Rotational speed should be removed from the "no change" requirements because
rotational storage devices with optimized motor speed don't have rotational speed
values in manufacturer's specification sheets
Based on stakeholder feedback, EPA has simplified Section 3.6 and• Cache size requirement for rotational speed be changed from "no change" to "equal or revised several of the requirements within the section. EPA welcomes
greater" because successor devices often have larger cache memory
stakeholder feedback on these changes.
• Performance requirements for rotational devices be changed from "within +/- 5%" to"equal or improved" performance• Testing is not reduced by including the requirement that performance be impacted byless than 20% (some stakeholders suggested the removal of this section because there
are limited means to assess if this is the case and current modelers have accuracies of +/15% to +/-20%)• A stakeholder suggested reversing net performance impacts for qualification ranges
and device substitution (device substitution should have no greater than 10% impact on
performance/Watt and qualified configuration range should be expanded to -20%)• Another stakeholder recommended changes in parameters is permitted within thelimits stated for each item, where "equal" has a +/- 5% toleranceIndex

Topic

35

Standard
Performance Data
Measurement and
Output Requirements

Subtopic

Stakeholder Comment

Three stakeholders recommended that Online 2 storage products be exempt from theStandard Performance Data Measurement and Reporting requirement because of their
EPA agrees with these statements and has revised Section 3.7 to apply
limited capacity and non-expandable nature. Their proliferation in a data center is limited only to Online 3 and Online 4 storage products.
and the cost of the product is disproportional to the cost of the required infrastructure.

A stakeholder supported the inclusion of the air inlet temperature measurement but
suggested that since there are many unknowns related to this measurement, the vendor
should define the main inlet point, recording where it is and how it is measure and thenreporting this information on the PPDS.

36

Standard
Performance Data
Measurement and
Output Requirements

EPA Response

Data Elements

EPA will maintain the current optional air inlet requirements proposed
in Draft 3, but welcomes additional feedback from stakeholders on
which temperature data is important for collection during qualification.
EPA does not currently specify where these measurements take place,allowing manufacturers to choose as needed.

Three stakeholders agreed with the proposal to make this requirement optional. One
stated that in terms of operational management, collecting temperature data via wireless
LAN from multiple thermal sensors distributed in a data center is more suitable for
EPA thanks stakeholders for their support and is open to further
unified management in a data center. They also stated that there is little demand for
discussions on appropriate forms of mandatory temperature data
embedded thermal sensors in a storage product and the placement of the sensors iscollection in Storage Products for future specification revisions.
spatially challenging because the air inlet is usually where drives are densely packed.
Another stakeholder stated that temperature is a facilities-side concern and would prefer
to allow the market to decide whether external or embedded devices is the best solution.

37

Standard
Performance Data
Measurement and
Output Requirements

Reporting
Implementation

A stakeholder believed that limiting the implementation of data reporting stifles
innovation of storage products and requested that add-in devices be allowed in Version
2.0.

See Index #36

A stakeholder requested allowing a 30 second frequency where the data is provided witha time stamp, in addition to reporting on a 10 second frequency. The time stamp willallow the collection system to match up multiple readings to get a constant view of thedata center power profile while enabling the collection system to poll less frequently.

38

Standard
Performance Data
Measurement and
Output Requirements

Sampling
Requirement

In terms of input power sampling, one stakeholder believed it would be appropriate tostate that the data be provided only via a pull mechanism by external software. This
commenter requested further discussion on the value of providing a rolling average of 3
samples rather than the software that is using the data provide its own rolling average.
However, a new trend in data center management software, provides its own informationthat is likely to use actual rather than averaged data. Also, they believed that the
sampling accuracy should have a range of +/- 5% because this is the capability of theavailable parts to perform this work. An alternative approach to the sampling
requirement would be to require that the supplied data be less than 30 seconds old,allowing implementation to be up to each manufacturer.

EPA has revised Section 3.7.3 to harmonize with the V2.0 Computer
Servers Program Requirements, which includes provisions for timestamping and updated language on data sampling requirements. EPA
welcomes stakeholder feedback on these changes.

Index

39

40

41

Topic

Timeline

Proof of Concept

Considerations for
Future Revisions

Subtopic

Stakeholder Comment

EPA Response

EPA understands stakeholder concerns regarding the size andcomplexity of these products. The CBs and labs that EPA has worked
A stakeholder indicated that there is an inadequate amount of time to allow certification
with on other complex products such as servers have shown that theybodies and labs to implement the specification. These bodies usually have not dealt withare capable of learning quickly and handling complexity. EPA
products of this size and complexity. One stakeholder referenced the UPS specification
acknowledges that storage is even more complex than servers, and isas support of their argument and stated that at least six months would be necessary after
therefore proposing a three month window between publication of thethe publication of the final draft.
final specification and the effective date (where typically for new
products there would be no window). EPA is also coordinating with
One stakeholder supported the effective date and stated that the specification will
SNIA to ensure adequate hands-on training for CBs and labs and will
become active in the European Union three to six months after the January 2013 date.
monitor the situation to ensure that everyone is ready by the effective
date.

Another stakeholder offered support by performing an assessment of the potential
complexities associated with product family and replacement storage device processes
by testing the qualification process on two or more actual products.

A stakeholder suggested several considerations for future specification revisions:• Addition of energy efficiency requirements (ex: step-wise reduction of disk speed,
parking of disk heads, batching requests and intelliseek)• Widening qualifying products to include more than online storage products because
other types can play a role in efficient tiered storage concepts (ex: MAIDS)• Criteria for active and idle state efficiency by possibly categorizing data storage
technologies and defining more than one set of requirements (ex: SSD technology may
have higher efficiency)
It is also recommended that work on version 2 will begin soon after the effective date to
make the lifetime of version 1 short.

EPA thanks the stakeholder for this offer and has been working withstakeholders during the development of the Draft 4 specification toevaluate any complexities with the specification methodology, as wellas test methodology (V2.0 SNIA Emerald specification). EPA isappreciative of the considerable stakeholder resources that have been
provided during this effort and sees this as an excellent indicator of
the future success of this specification.

EPA will consider these and any other suggestions for future revisionconsiderations and will finalize the list in the Final Draft specification.
EPA welcomes additional feedback on potential future considerationsfor Storage Products in the Version 2.0 Storage specification. Clearlyhighlighting future concerns now will help EPA and stakeholders tomake preparations to address them prior to future Storage Version 2.0
development.