Public comment from The Information Technology Industry Council

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December 21, 2018
Ms. Suzette Kent
U.S. Federal Chief Information Officer
Office of Management and Budget
725 17th Street NW
Washington, DC 2050

Re: Federal Register Notice 2018–25573, Request for Comments on Update to Data Center Optimization Initiative (DCOI)

The Information Technology Industry Council (ITI)[^1] is pleased to provide comments in response
to the Office of Management and Budget’s (OMB) request for public input on a draft
memorandum titled ‘‘Update to Data Center Optimization Initiative (DCOI).’’ Our members
represent the entire spectrum of technology: from internet companies, to hardware and
networking equipment manufacturers, to software developers, and have long been leaders in
sustainability. Many exceed environmental design and energy efficiency requirements and lead
the way in product stewardship efforts. As a result, the Dow Jones Sustainability Index, the
Financial Times Sustainability Index, and the Global 100 have consistently recognized several ITI
member companies for their significant environmental and sustainability achievements.

We commend the Agency for seeking to optimize Federal data centers in accordance with Federal
Information Technology Acquisition Reform Act (FITARA). We urge the Agency, however, to
evaluate the following IT modernization and energy efficiency considerations.

IT Modernization

While we are encouraged by the extension of the FITARA requirements, our member companies
are concerned that the revised DCOI policy deviates from the policies and goals outlined in the
Report to the President on IT Modernization,[^2] as well as the President’s Management Agenda.[^3]
As your office looks to revise policy, we would encourage you to provide agencies with the tools
and guidance to move away from legacy IT and to enable the modernization of systems, whether
it be “low-hanging fruit” or larger scale projects.

Specifically, we would recommend the policy provide more guidance with regards to determining
the cost-effectiveness of potential solutions, as well as the outyear total operating costs of the
system(s) currently fulfilling the same or similar requirements. As recognized by the National
Defense Industrial Association (NDIA) in its 2014 study, “Pathway to Transformation,”[^4] faced
with the responsibility to manage processes and increasingly complex IT programs, the
government’s use of Big Data and other analytic tools with comprehensive metrics would
enhance program performance and management. These metrics would allow the government
to assess the Total Cost of Acquisition (TCA), i.e., all direct and indirect costs of acquisition,
including the monetized cost of time, associated with differing approaches to acquisition,
security, scalability, resiliency, and overall efficiency. In addition to defining optimal acquisition
solutions up front in the process, managers would be able to identify performance issues before
they undermine a program, manage any needed implementation changes, and identify
opportunities for success that can be shared. Focusing on the TCA recognizes that processes are
tools to an end, not an end in themselves; thus, it allows the government to assess whether the
benefit of any process is worth the cost. Any process not mandated by law that increases the
TCA should be avoided.

We would also note that the revised policy relies heavily on the inclusion of the Cloud Smart
guidance. Because Cloud Smart, which is not yet finalized and is still in coordination, and DCOI
include decision points for agencies and must work in concert, it difficult for industry to
accurately assess and comment on the revisions to DCOI. Cloud Smart includes guidance around
Cloud First and the use of hybrid cloud, both of which would affect the DCOI efforts. We would
therefore recommend that your office postpone finalization of DCOI until such time that industry
can review the final Cloud Smart policy and assess and understand any implications it will have
on the DCOI revisions currently under consideration.

Additionally, the revised memorandum should align federal government policies with
commercial practices. In order to achieve the cost-effectiveness of vendor-provider services, the
government should utilize commercial terms and conditions, not government-unique
regulations. Increasingly, the commercial market is the main driver of information technology
(IT) research and innovation. Absent an appropriate statutory, programmatic, or policy driver, it
is not in the federal government’s interest to consume scarce resources undertaking unique
activities and/or innovations that could be procured from the commercial market. Indeed, by
utilizing streamlined commercial processes and purchasing commercial products and services,
the federal government can leverage the research and innovation expenditures made by the
private sector and thereby free scarce budget dollars for mission-critical needs.

By leveraging competitive commercial procedures to fulfill its requirements, the government can
maximize its access to cutting-edge technology, while also increasing downward price pressure
and incentives for vendors to innovate. Current laws and regulations provide excellent guidance
on the use of commercial processes and products. Specifically, they require agencies to utilize
commercial products, terms, and conditions “to the maximum extent practicable.”[^5] By
articulating this standard, these policies recognize that, although government and commercial
entities may have similar operational processes, the two sectors are not identical. Legal and
policy drivers, as well as the mission of the government itself, may militate against its wholesale
adoption of all commercial practices. What is left for consideration, then, is a strong preference
for commercial processes and products, with a recognition that appropriate government
interests must be balanced.

The policy can also be improved by providing additional guidance as to what is included in the
justification for new data centers on key areas such as better defining strategy for modernization,
providing a road map on how to get to a particular service, as well as detailing what platforms
will be used. The DCOI should also consider the role of interconnection as a means to achieve
objectives as well as access to cloud to achieve data center optimization. Industry would also
recommend more definitive timelines for when migrations are to occur.
Industry also recognizes that virtualization technologies continue to evolve to support changing
application needs and a variety of cloud platforms. As such, it’s important that the policy
recognizes that portability, scalability, and elasticity are the proper measures of long-term
optimization.

Energy Efficiency and Cost Optimization

ENERGY STAR®, EPEAT® and ASHRAE

Industry supports inclusion of a reference to the most recent ENERGY STAR® specification for
servers as a recognized driver of best in class energy performance. Additionally, agencies should
seek to operate facilities at the widest ASHRAE range that can be economically achieved by
supporting ASHRAE A2 or ASHRAE A1A, as doing so will improve the energy efficiency of the
datacenter.

With respect to the multi-attribute eco-label, EPEAT®, we recommend adherence to stated OMB
policy to avoid creating government-mandated monopolies by specifying conformance to either
the underlying ANSI-accredited consensus standard, NSF-426, or registration with the privately
managed “EPEAT registry”. Market options should be permitted that allow manufacturers to
demonstrate conformity with approved consensus-based standards.

Power Usage Effectiveness (PUE)

We do not support complete removal of the PUE metric. While it is true that geographic
considerations impact PUE values, it remains a valid tool for measuring system efficiency.
Further, it can be used for easy comparison of facilities within a geographic region, e.g. Austin
Texas, the pacific northwest, etc. Reducing PUE will enable Agencies to meet operational
effectiveness mission goals.

Ultimately, PUE is improved through higher utilization of the IT equipment and better matching
of the heat load to the cooling delivery. New server equipment currently coming onto the market
has 1.5x to 2.5x the work per watt capability of previous generation equipment. The DCOI should
encourage federal data center operators to make full use of that capacity, increasing server
utilization, consolidating existing workload into a smaller IT footprint and putting new workloads
into the existing IT infrastructure, thereby minimizing equipment inventory and energy
consumption. On the cooling side, it is recommended that automated, real-time temperature,
humidity, and airflow measurement systems should be installed in all data centers of 500 ft2 or
more. Minimizing the data center IT power demand through optimized utilization of the
equipment and matching the cooling delivery to that reduced heat load will minimize the PUE
and the energy use in the data center. Appropriate technical expertise must be applied to
monitor the system results and respond to changes. As these systems are all IT based, they can
be monitored and managed from a central control room/facility to ensure that systems are
performing as expected.

Discarding PUE entirely would be contrary to the intent of improving energy efficiency.

Underutilized Servers

With respect to accounting for underutilized servers in DC, we recommend use of automated
software that analyzes component utilization and serviceability to optimize both workload
placement and server utilization.

Thank you again for the opportunity to share our perspectives regarding this draft. Should you
have any questions, please feel free to contact us.

[^1] About ITI. ITI is the global voice of the tech sector. We advocate for public policies that advance innovation, open
markets, and enable the transformational economic, societal, and commercial opportunities that our companies are
creating. Our members represent the entire spectrum of technology: from internet companies, to hardware and
networking equipment manufacturers, to software developers. ITI’s diverse membership and expert staff provide a
broad perspective and intelligent insight in confronting the implications and opportunities of policy activities around
the world. Visit http://www.itic.org/ to learn more. Follow us on Twitter for the latest ITI news @ITITechTweets.

[^2] https://itmodernization.cio.gov/assets/report/Report%20to%20the%20President%20on%20IT%20Modernization%20-%20Final.pdf.

[^3] https://www.whitehouse.gov/wp-content/uploads/2018/04/ThePresidentsManagementAgenda.pdf.

[^4] National Defense Industry Association, Pathway to Transformation: NDIA Acquisition Reform Recommendations (Nov. 14, 2014).

[^5] Cf. 41 USC 3077; see FAR 12.301(a) and FAR 12.302(c).