techUK Climate Change Agreement (CCA) Briefing for Data Center Members on DESNZ's Performance Account Template (PAT) and Savings Assessment Template (SAT)

Some operators have expressed concerns over commercial/security confidentiality of the information being asked for by DESNZ in the current Performance Account Template (PAT) and Savings Assessment Template (SAT).

Concerns include reluctance to disclose plans for future technology adoptions and investment plans along with disclosure of utilisation levels to account for decreasing energy efficiency.

Regarding confidentiality concerns, DESNZ have responded as below regarding the SAT. It would be expected that the same would apply to information provided in the PAT:

Q: What guarantees can DESNZ provide that commercially sensitive data, particularly relating to costs and investment plans, are not put in the public domain?

A: Previous iterations of the SAT included requesting data on Capital Expenditure (Capex). DESNZ has taken on board feedback from the January workshops and will no longer be requesting that information. Instead, DESNZ will only be requesting estimates on payback periods for relevant demand-side and supply-side measures.

We recognise the sensitivity around the data being submitted for target setting and assessing performance. Subject to compliance with the Freedom of Information Act 2000 (FOIA) and the Environmental Information Regulations 2004 (EIRs), DESNZ will treat commercially sensitive data on a confidential basis subject to disclosure to the EA and our technical consultants. When dealing with any relevant FOIA/EIR request DESNZ will consider and apply any relevant exemptions under FOIA/EIR on a case-by-case basis. Where appropriate, we will consider all options to amalgamate data or redact information to protect commercial confidentiality.

techUK and SLR Consulting will be holding a briefing to hear feedback from data center operator members, as well as to gather industry consensus on next steps in engagement with DESNZ and to test some potential positions, including whether the classification of Critical National Infrastructure could exempt the sector from these requirements as non-disclosure is not guaranteed. This doesn’t just relate to commercially sensitive information but to information that could pose a threat to national security. E.g. although the sector should be exempted under section 24(1) of FOIA, is ‘consider and apply’ sufficient safeguard to ensure non-disclosure?

Please find below the following documents on PAT and SAT example templates and associated guidance to help guide the conversation - The SAT ‘with examples’ is an example completed template (not specific to this sector) however gives an indication of the type of information being requested:

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Luisa C. Cardani

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Programme Assistant, Data Centres, Climate, Environment and Sustainability, Market Access, techUK

techUK Climate Change Agreement (CCA) Briefing for Data Center Members on DESNZ's Performance Account Template (PAT) and Savings Assessment Template (SAT)

Data Centres Programme activities