Ref.
#12Topic

Definition

Definition

Subtopic

Stakeholder Comment

EPA Response
EPA has updated the Computer Server definition in the Final
Specification to harmonize with the V2.0 Computer Servers Final
Program Requirements definition.

Computer Server

A stakeholder requested that the Version 2.0 Computer Server specification bereferenced in this definitions.

Product Family

Several stakeholders agreed with the use of flexible as well as fixed bounds for
qualifying product families. One stakeholder specifically mentioned their support for
EPA thanks stakeholders for their support on the changes to productallowing a percentage difference of 15% in the performance per watt metric tofamily in the Final Draft Specification. EPA is not making any additional
qualify minimum and maximum configurations. Other stakeholders encouraged EPAchanges to the qualification range language in the Final Specification.
to consider flexible limits at ‐25% or less and +10% or higher for a configuration
because some products may not meet the 15% performance threshold at ‐40% or
EPA has included additional guidance in the Mixed Qualification+15%. They stated that manufacturers should be able to expand the qualificationCriteria definition which provides clarity on when a fixed testing point
range beyond the ‐20% and +5% stated in the requirements where they cannot meet
may used in place of a flexible testing point to extend the range ofthe requirement broader testing range.
qualification of a product family. EPA provided examples of productfamily creation through a slide deck distributed to industry in May
A stakeholder suggested that it be clarified that the flexible maximum and minimum
2013, as well as examples presented in person during the SNIA Emerald
qualification configuration data may be rounded up to the nearest drawer boundary.
training session in Colorado Springs, CO in late June 2013.
Another commenter requested a methodology with supporting calculations and rules
to derive the qualifying product ranges to submit optimized data.
A stakeholder stated their support for the drawer rounding approach because it willallow companies to have the option of selecting an approach that provides the mostefficient system for their products.
Two stakeholders proposed that the language pertaining to maintaining device
percentages when rounding be clarified to state that the ratios be maintained as
closely as possible rather than precisely (as it is in 1.I.7.ii).

3

Definition

4

Definition

5

Definition

6

Definition

Single Device
Combinations

EPA thanks stakeholders for their comments on drawer rounding.
EPA has clarified language in the Final Specification regarding
maintaining device percentage ratios in automated storage tieringsolutions.

Another stakeholder requested examples of how the single device concept would be
used to manage a multi‐storage device product. They asked if their understanding
See Index #2
was correct: The relationship of device counts between groups of storage devices canbe represented by a ratio of 1:x:y:z, where the 1 is set against the smallest number ofdevices in the multi‐device system and x, y, and z represent the ratio of the otherdevices to the device type that is represented in the smallest quantity.

A stakeholder stated that it is not clear how to determine the optimal point for aMixed Qualification system with multiple device types that employs automated storage tiering.
Range
A stakeholder supported the use of the terms "scale‐up" and "scale‐out" as opposedScale‐Up/Scale‐Out to centralized and distributed.
Advanced Data
Two stakeholders supported the expansion of the definition of Data Recovery toRecovery Capability include technologies other than RAID.

It is up to the manufacturer to identify the optimal point in a mixed
storage device solution with automated storage tiering, as thisconfiguration will be dependent on proprietary variables including
hardware and software implementation.
EPA thanks stakeholders for this comment.
EPA thanks stakeholders for this comment.

7891011A stakeholder pointed out that there is no definitions for Object Based Storage.

EPA feels it is too late in the development process for new definitions
to be added that are not essential for the function of the specification.
The current Version 1.0 specification works fine without this definition,
though future scope expansions in Version 2.0 and beyond may
eventually require developing such a definition. EPA looks forward toworking with stakeholders on this issue in the future.

Power Modeling Presale Tool

A stakeholder requested that the power modeling presale tool would be stated as arequirement as opposed to an expectation. If this is difficult to comply with, theysuggested it be included as a consideration for future revisions.

EPA thanks the stakeholder for this comment, but will retain thecurrent language on the power modeling presale tool as it may bedifficult to comply with.

Information
Reporting
Requirements

A stakeholder supported the clarifications made to Tables 5 and 6 which delineate
what metric data need to be reported to EPA and what will be published on theENERGY STAR website. This commenter also agreed with the addition of the Hot
Band workload to the data reported to EPA and published on the website because itis critical to properly assess storage system performance per watt characteristics.

EPA thanks the stakeholder for this comment.

Definition

Information
ReportingRequirements
TestingRequirements

Object BasedStorage

A stakeholder expressed concern that the SNIA Emerald test results are not yet
understood and it would be premature to attempt to modify or weight the sequential
read and write scores. They recommended that EPA gather substantially more datato assess the best use of the SNIA metrics to measure product energy efficiency. At aminimum, this commenter requested the sequential read and write scores beAfter additional discussion with industry, EPA has revised thereported unweighted and weighted on the ENERGY STAR webpage so that the results
streaming optimization section to require 50%/50% split for sequentialare clear. One stakeholder noted that it is appropriate that EPA require reporting ofreads and writes when optimizing for a streaming workload. EPA has
SNIA Emerald metrics, including Hot Band data in Version 1.0 rather than trying to set
discussed the methodology for incorporating the weighting into
specific performance/power thresholds.
published scores with industry in a series of recent meetings, and has
been informed that any questions on the methodology have been
Several stakeholders asked for further clarification on the methodology toanswered adequately. For any additional clarifications, please contact
incorporate the weighting for the 70%/30% split on the sequential reads and writes
EPA at Meyers.Robert@epa.gov or John.Clinger@icfi.com.
into published scores. One of these stakeholders asked if EPA intends to apply thissequential I/O weighting to the spindle counts that result for the optimal andboundary configuration points. They requested that the device count for the optimal
Workload Weighting configuration be set by the sequential read configuration because writing will playsuch a small part in the actual workload.
Requirements
One stakeholder recognized the benefits of the restructuring of the testing
requirements section.

EPA thanks the stakeholder for this comment.

1213

1415

Information
Reporting
Requirements
Information
Reporting
Requirements

PublicInformation

PublicInformation

EPA has revised this language to state that the manufacturer shallA stakeholder asked if they should first choose the biggest seller device type for achoose the representative highest predicted deployed volume of agiven workload and test for the Optimal Point qualification range. At that point, it isstorage device. This allows manufacturers to focus on the storage
possible to select other device types to do more qualification range testing. One
device they anticipate will be the largest seller during the life ofstakeholder stated that it would be more appropriate to say that a manufacturer may
product certification, rather than potentially on a device which has solddetermine to submit rather than test a Fixed, Flexible and Mixed Qualification Range.
significantly in the past, but is no longer a focal point of the productfamily.
Another stakeholder recommended that EPA add specific language to state the intent
that SSDs can be included in a qualified mixed drive configuration built without
EPA has clarified that SSDs must be tested when used as part of an
testing the SSD drive.
automated storage tiered mixed storage device solution.

Modeled Data

Two stakeholders supported the decision to allow the use of validated performanceand power models to generate qualification data.

EPA thanks stakeholders for this comment.

Several stakeholders suggested that EPA consider a process of reviewing initialsubmissions with an industry body to ensure the data to be published is consistentand well‐vetted. They requested that the review period could cover the first monthsof submissions, during which the data could be made anonymous.

EPA agrees that a review period would be desirable for the collected
data and is currently exploring ways to make the data available
anonymously for a limited period of time. Since the effective date iscurrently listed at the beginning of December and testing andcertification will take some time, EPA will look to hold a review
meeting in late Q1 2014.

A stakeholder stated that the product characteristics may vary with the actual
configuration under test, as different device types may require different drawer
types. They stated it will be difficult to match the components of a single dataset.

EPA is collecting product characteristics on all configurations tested for
ENERGY STAR certification, collecting the data through Qualified
Product Exchange (QPX) XML system.

GeneralProductCharacteristics

16PublicInformation

Qualified SystemConfigurations

17

PublicInformation

ASHRAE

Two stakeholders pointed out that these requirements should state
performance/power scores and not absolute power or performance scores. One ofSee Index #15
these commenters stated that it was unclear what information is being requested in
3.5.7.iii.
Several stakeholders asked which selected data from the ASHRAE Thermal Report isbeing requested to be displayed on the ENERGY STAR website. They also stated that EPA has simplified and clarified the thermal reporting requirements in
the Final Specification.
since temperature and humidity readings are already recorded for each test, thisrequirement should be removed.

Energy Efficiency
Performance

One stakeholder requested a definition for energy efficiency performance data beprovided. They stated that the appropriate meaning of this term is confused by the EPA has clarified that the energy efficiency performance data in Table 7
separate reference to performance/watt data in 3.3.1. This commenter asked if EPA refers to the performance/watt data appropriate for each optimization
could specify units for active and idle state efficiency test results in Table 7 as well,type.
assuming they are IOPS per watt for active and GB per watt for capacity.

18

PublicInformation

19

PublicInformation

A stakeholder asked for further clarification on the methodology to incorporate theweighting for the 70%/30% split on the sequential reads and writes into publishedscores.

See Index #2

One stakeholder noted that the revised product family requirement that allow forreplacement drives make testing more efficient and reduce the quantity of testing
while still providing EPA with data needed to evaluate representative metrics.

202122

Product Family
Variation

EPA has clarified to manufacturers that CBs may review whichever
A stakeholder noted that the CBs will need to review proprietary vendor drive data
storage device data sheets they feel is necessary to certify asheets under a NDA to evaluate all the criteria listed in 3.6.2. As a result,replacement device. All storage device replacement criteria will be
stakeholders suggested that EPA should require that the CB certify the replacement
certified by the CB and the resulting storage device data sheets will not
drive criteria are met and agree that only the generic drive specification sheets frombe passed along to the EPA.
the device vendor’s website be supplied to EPA to support identification ofreplacement drive types.
Systems that surpass the 20% limit on increased performance/watt of
the storage product as a whole will require a retest for a new
Another stakeholder asked if system retesting will be required if a set of productsubmission for that product family.
changes are made that are suspected of leading to a greater than 20% shift in theoverall system performance/watt.

Product Family
Variation

Two stakeholders noted that the transfer speed is listed as a variable that must notchange even though the Sustained Transfer Rate has been given flexibility. Thesecommenters stated that this is a contradiction because a change to transfer speed
from the disk to its interface may make no difference to the actual data transfer rate
as it is likely to be capped by device and bus interfaces.

EPA has clarified that a Replacement Storage Device may contain newtransfer speeds providing the new speeds are not able to be utilized in
the storage system due to architectural / design limitations (e.g., newtransfer speeds not supported by the host bus adapter).

A stakeholder requested clarification on what the phrase "discretion of the user"
meant during a discussion regarding data elements.

The language referenced in this comment was part of a note box
explaining the changes to the data elements section of the Final Draft
Specification, specifically explaining how different implementations
may be chosen to measure power and temperature at a system level.
All note boxes from the Final Draft Specification have been removed inthe Final Specification.

Transfer Speed

Data Elements

23

Sampling
Requirements

24

Sampling
Requirements

25

Sampling
Requirements

26

EPA thanks the stakeholder for this comment.

Documentation
Requirements

Inlet Air
Temperature

A stakeholder proposed that the inlet air temperature requirements be optional in
EPA cannot determine inlet air temperature requirements for theVersion 2.0 because products with high scalability require a specific placement ofthermal sensors and also how to report data to end users. These factors largely affect Version 2.0 Storage Specification at this time.
product development.

Rolling Average

A stakeholder stated that the simplification resulting from the removal of the rolling
EPA thanks the stakeholder for this comment.
average requirement for input power will eliminate a potential source of confusion.

One stakeholder noted that timestamping should be optional.

The timestamping requirements are only required for storage products
which implement timestamping. The capability itself is not required.

Timestamping
Several stakeholders noted that temperature reporting should be optional to provide
manufacturers time to incorporate temperature measurement capabilities into theirsystems. One of these stakeholders suggested providing the time period andEPA has clarified Section 3.7.4 that air inlet temperatures are optional.
sampling rate used along with language that specifies the rolling average is not
required as the noteboxes will be removed for the final version.

A stakeholder recommended the requirements of sales, delivery and support bymanufacturers be optional in order for customers to have the flexibility to purchase
iPDUs from other vendors. As an example, they stated a customer could havepreviously purchased an iPDU from another vendor and then purchase an ENERGYSTAR certified storage product that can use this iPDU.
27iPDUs

EPA would like to clarify that storage products which cannot provide
the input power reporting requirement internally must have the option
to be purchased with an iPDU in the same place that the purchaser ispurchasing the storage product. The purchaser is not required toacquire the iPDU from the same vendor as the storage product, but it
must be an available option in this scenario.

One stakeholder requested that the rolling average calculation be included inconsiderations for future revisions because it is beneficial for users and they may beable to find a solution to the issue of varying time scales for averages.
Another stakeholder suggested the following for the Version 2.0 specification:• Usage of market data with respect to the number of options that exist in the market
and the overall volume of sales. The emphasis should be on those segments of themarket that would generate notable savings when aggregated and where theEPA has added potential rolling average calculation requirements in theincremental costs of improved efficiencies are outweighed by the incremental savings
Version 2.0 Storage Specification. EPA has also added inlet airwithin the useful life of the product.
temperature sensing as a potential requirement in Version 2.0.
• Avoid considering specific technology solutions, but instead identify areas thatmight yield effective savings will not hindering the functional end‐user requirements
of products in respect to their performance, RAS, useable scalability, or other aspects
important to data center operations.

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Considerations
for Future
Revisions30

DeviceQualification

32

Data Submission

A stakeholder also stated that the right sizing and system management offerings
involve tradeoffs between energy efficiency, expandability, and system flexibility
which has energy and material use implications.
A stakeholder expressed concern regarding appropriately communicating which
storage device types and combinations of those devices are ENERGY STAR certified
EPA has held additional discussions with industry on this topic, anddue to the large number of permutations of devices and combinations. They
welcomes any additional questions on the creation of product families
requested that EPA be flexible in accepting approaches for defining qualifies systems and qualification range of particular storage products.
and be open to discussions with manufacturers.
One stakeholder supported the EPA in ensuring that non‐anonymized data ispublished from the point the specification comes into effect because the Final Draft isSee Index #14.
less stringent in terms of tolerances and the main goal of the specification seems tobe to provide a data foundation for future revisions.

34

Verification
Testing

Two stakeholders agreed with EPA that Verification testing for Data Center Storage
products would have added a significant complexity and not provide benefits.

EPA thanks stakeholders for these comments.