CSC statement to the working group on energy taxation reform

CSC has left its comments to the energy taxation reform working group. The reform of energy taxation is related to the entries in the government program, according to which emission control of energy production will be increased by abolishing the industrial energy tax rebate system and lowering the electricity tax category II towards the minimum level allowed by the EU. It is important for CSC to state the reform of energy taxation, as one of the purposes of the reform is to transfer heat-generating heat pumps and data centers to the district heating network in the electricity tax class II. 

The reduction of the electricity tax category II should be implemented in full from the beginning of 2021. The reduction of the electricity tax category II electricity tax to the EU minimum should be implemented in such a way that the competitiveness of Finnish companies is guaranteed. CSC is in favor of moving data centers to electricity tax category II if the data center is able to utilize more than 50% of the energy it uses in the recovery of waste heat. Therefore, the reform also takes into account data centers with less than 5MW that utilize waste heat. A clear delimitation of the waste heat to be recovered will reduce the potential for abuse of the tax relief. 

CSC also stated that the criteria for tax relief must take into account the eco-efficiency, cost-effectiveness and environmental friendliness of the data center alongside consumption. The tax reduction should be accompanied by a requirement to use zero-emission energy in data centers. In CSC's view, the current system does not take the above issues into account. 

In addition to the electricity tax category, CSC also comments more widely on waste heat. CSC's view is that the utilization of waste heat is supported by Finland's extensive district heating network, the innovative energy sector and the growth of knowledge on the subject. More efficient utilization of waste heat requires more support from the Ministry Economic Affairs and Employment of Finland. By mapping waste heat utilization sites and cooperating with potential companies, many more uses can be found alongside district heating. 

CSC's data center in Kajaani operates on the principle of sustainable development: ecologically, reducing the global carbon footprint. The electricity used in the data center is produced with 100% renewable energy. Thanks to the cold climate (annual average temperature less than 3 degrees), free cooling can be used in the data center, i.e. no extra energy is needed for cooling. 

High-performance computing and data management services will be needed even more in the future, and at the same time the electricity consumption of data centers will increase. CSC has a model for how data centers can be implemented in a carbon neutral, or even carbon negative way. Finland is an ideal location for data centers due to its cool climate, affordable and clean electricity and stable conditions. It is important to take this message forward in the international arenas as well. 

Read all the comments in Finnish (pdf).