Fuse capacity planning, telemetry, and sustainability into one operating model
Zeph Tech’s field notes combine Uptime Institute outage economics, ASHRAE TC 9.9 thermal envelopes, NERC CIP reliability controls, and CISA’s Cross-Sector Cyber Performance Goals to help operators prove resilience.
Updated with expanded regulatory mapping, detailed tooling architectures, and comparative case studies spanning North America, EMEA, and APAC hyperscale operators.
Reference internal research: Uptime outage cost escalation briefing, EU data center efficiency rule summary, CHIPS Act fabrication award analysis.
Executive overview
Global data-center operators are dealing with outage costs that continue to trend upward and regulators that expect auditable telemetry pipelines. Uptime Institute’s 2024 Global Data Center Survey reports that 55% of operators suffered an outage within the last three years, with 10% quantifying their most severe incident above US$1 million.Uptime Institute Global Data Center Survey 2024 Hyperscaler best practices—codified in the AWS Well-Architected Reliability Pillar and Google’s Site Reliability Engineering (SRE) workbook—show that instrumentation must be designed alongside capacity planning, not bolted on afterwards.AWS Well-Architected Reliability PillarGoogle CRE Site Reliability Workbook
Resilience now requires coordination across four disciplines: (1) capacity planning grounded in power, space, and network runway; (2) observability that captures workload health and thermal envelopes; (3) automation and runbooks that align with CISA’s Cross-Sector Cyber Performance Goals (CPG) and NERC Critical Infrastructure Protection (CIP) evidentiary requirements; and (4) sustainability programs that surface energy, carbon, and water metrics. ASHRAE TC 9.9’s 5th edition thermal guidelines emphasise that mechanical and electrical telemetry must stay within defined envelopes to avoid catastrophic load shedding when workloads surge.ASHRAE TC 9.9 Thermal Guidelines 5th Edition
This guide maps those disciplines to a repeatable operating rhythm. Each phase ships with implementation checklists, telemetry baselines that leverage OpenTelemetry and Kepler power monitoring, automation patterns using Terraform and GitOps controllers, and compliance evidence packages that satisfy CPG, NERC CIP-007/009, and regional sustainability disclosures.
Capacity planning anchored in outage economics
Capacity planning must quantify both business demand and infrastructure constraints. Uptime Institute notes that supply-chain lead times for high-density equipment still exceed twelve months for many operators, prompting a focus on stranded capacity avoidance and scenario modelling.Uptime Institute Global Data Center Survey 2024 Combine macro trends with Zeph Tech’s CHIPS Act coverage to forecast silicon availability: recent U.S. awards to Texas Instruments and GlobalFoundries indicate expanded 300 mm capacity coming online between 2027 and 2028.Zeph Tech CHIPS Act fabrication award analysisZeph Tech GlobalFoundries expansion briefing
Integrate ASHRAE TC 9.9 thermal envelopes with hyperscaler reference architectures when sizing mechanical and electrical systems. The AWS Reliability Pillar recommends holding 20–30% buffer capacity for critical workloads; align that with ASHRAE recommended inlet temperature ranges (18–27 °C for Class A1 hardware) to prevent cascading incidents during failover.AWS Well-Architected Reliability Pillar — Sustain ResiliencyASHRAE TC 9.9 Thermal Guidelines
Capacity reviews should maintain three horizons:
- Quarterly silicon refresh: Pull manufacturer roadmaps (AMD MI325X, NVIDIA Blackwell, Intel Gaudi 3) and update rack density assumptions; Zeph Tech’s silicon briefings flag HBM availability and lead times.Zeph Tech NVIDIA Blackwell roadmapZeph Tech AMD MI325X planning noteZeph Tech Intel Gaudi 3 integration briefing
- Annual resilience scenario: Stress test capacity for concurrent failure scenarios (loss of utility feed plus cluster upgrade) to meet NERC CIP-009 recovery plan expectations.NERC CIP-009
- Multi-year sustainability horizon: Align with EU data-center efficiency proposals that mandate 1.3 PUE or lower for high-density halls and require water usage reporting.Zeph Tech EU data center efficiency rule summary
Observability instrumentation tied to thermal and workload envelopes
Modern observability stacks must ingest infrastructure, application, and environmental telemetry. Adopt OpenTelemetry for traces, metrics, and logs so workloads remain portable across hyperscaler landing zones and regulated on-premises estates.OpenTelemetry documentation Pair it with the Kepler exporter to track real-time power consumption per pod or virtual machine; this enables correlation between workload performance and ASHRAE thermal envelope excursions.Kepler projectASHRAE TC 9.9
Google CRE recommends defining service-level objectives (SLOs) before instrumenting pipelines to avoid metric sprawl. Establish golden signals (latency, traffic, errors, saturation) for each platform and map alert thresholds to the same severity scale that CISA CPG prescribes for incident response.Google Site Reliability WorkbookCISA Cross-Sector CPG
In regulated environments, maintain distinct telemetry paths for NERC CIP high, medium, and low impact zones. Encrypt all streaming data, enforce role-based access, and store retention logs for at least 15 months to support CIP-007 patch monitoring evidence. For public cloud workloads, follow hyperscaler guidance: AWS recommends centralising account-level telemetry through multi-account observability accelerators; Microsoft and Google provide similar blueprints via Azure Monitor workbooks and Cloud Monitoring metrics scopes.AWS Observability AcceleratorGoogle Cloud Monitoring overview
Automation, runbooks, and compliance evidence
Automation should codify infrastructure, observability pipelines, and compliance attestations. Use Terraform or Pulumi to declare landing zones, telemetry collectors, and data retention policies. Layer GitOps controllers (Argo CD, Flux) to reconcile drift and provide immutable audit trails; this aligns with CISA CPG Outcome 5.1 on configuration management.Terraform documentationArgo CD documentationCISA Cross-Sector CPG
Codify NERC CIP evidence within pipelines. CIP-010 requires change management proof; capture Terraform plan outputs, GitOps sync events, and peer approvals. CIP-008 and CIP-009 require incident and recovery documentation—instrument runbooks in tools like Rundeck or AWS Systems Manager Automation so actions, timestamps, and personnel are logged automatically.NERC CIP Standards
Automation must also orchestrate sustainability data. Integrate Kepler or hyperscaler carbon APIs with infrastructure as code so every deployment updates carbon budgets. Use policy-as-code (Open Policy Agent, HashiCorp Sentinel) to block deployments that exceed energy thresholds or violate ASHRAE temperature bands. Tie these controls to Zeph Tech’s sustainability briefings, which track EU efficiency proposals and DOE transmission incentives.Zeph Tech EU data center efficiency rule summaryZeph Tech infrastructure weekly briefing
Sustainability instrumentation and reporting
Regulators increasingly mandate transparency into energy, carbon, and water consumption. The European Commission’s energy efficiency proposal for data centers will require operators to publish PUE, WUE, and renewable energy ratios annually starting in 2026.Zeph Tech EU data center efficiency rule summary The U.S. Department of Energy’s Better Climate Challenge similarly encourages 50% emissions reductions over ten years. Observability pipelines must therefore correlate workload telemetry with sustainability metrics.
Implement the following telemetry extensions:
- Energy baselines: Use Kepler or hyperscaler sustainability APIs (AWS Customer Carbon Footprint Tool, Google Carbon Footprint) to track emissions intensity per workload.Kepler projectAWS Customer Carbon Footprint Tool
- Thermal compliance: Ingest ASHRAE TC 9.9 allowable and recommended ranges into alerting so deviations trigger automated airflow adjustments.
- Grid interaction: Track local utility carbon intensity and demand response commitments; Uptime Institute notes that grid events now account for 24% of major outages.Uptime Institute Global Data Center Survey 2024
Publish quarterly sustainability scorecards that tie to Zeph Tech’s CHIPS Act and DOE transmission coverage. These reports become evidence for ESG disclosures (CSRD, SEC climate rule) and demonstrate proactive compliance during audits.
Implementation checklists and quarterly refresh cadence
Each phase is tied to telemetry baselines, automation stacks, compliance artefacts, and quarterly update triggers. Use the checklist to assign owners and to document evidence for regulators and auditors.
| Phase | Telemetry baselines | Automation & tooling | Compliance evidence | Quarterly updates |
|---|---|---|---|---|
| Capacity planning | Consolidate OpenTelemetry resource metrics, Kepler power per rack, hyperscaler quota dashboards. | Terraform capacity modules, AWS/Azure quota APIs, GitOps drift reports. | NERC CIP-009 recovery scenarios, Uptime outage impact reports, ASHRAE thermal trending. | Refresh silicon roadmap (NVIDIA Blackwell, AMD MI300 series), update supply lead times from CHIPS Act awards. |
| Observability instrumentation | Trace sampling baselines, golden signal SLOs, thermal sensor calibration. | OpenTelemetry Collector pipelines, Prometheus federation, managed log analytics exports. | CISA CPG detection controls, NERC CIP-007 patch audit logs, hyperscaler shared-responsibility matrices. | Review runbook metrics vs. Google CRE error budgets; update tracing schemas for new services. |
| Automation & response | Incident Mean Time to Detect/Resolve, playbook execution timestamps, carbon-aware scheduler data. | GitOps controllers, Terraform Cloud run tasks, workflow automation (Rundeck, AWS Systems Manager). | CIP-010 change logs, CPG incident response outcomes, SOC 2 evidence packs. | Validate failover exercises and test chaos engineering scenarios using AWS Fault Injection Simulator or GCP DiRT practices. |
| Sustainability reporting | PUE/WUE telemetry, renewable energy certificates, utility carbon intensity feeds. | Carbon data pipelines, policy-as-code guardrails, sustainability ledger integrations. | EU efficiency disclosure drafts, SEC climate attestation workpapers, corporate ESG dashboards. | Reconcile energy baselines with DOE incentives; adjust targets based on regional water stress indices. |
Document checklist completion in your configuration management database (CMDB) and attach machine-generated evidence (Terraform plans, GitOps sync reports, Kepler exports). This ensures auditors can verify compliance without ad-hoc queries.
Governance cadence and communication
Establish a governance board that meets monthly to review observability health, outage retrospectives, and sustainability trends. Align agendas with CISA CPG maturity tiers so leadership can track progress toward target posture levels. Quarterly, publish an executive-ready dashboard summarising capacity runway, SLO adherence, automation coverage, and emissions trajectory. Tie findings back to Zeph Tech briefings on grid stress, silicon supply, and regulatory shifts to maintain situational awareness.Zeph Tech Uptime outage cost briefingZeph Tech AWS global infrastructure roadmap note
Finally, maintain a living architecture repository with references to the figures and configurations in this guide. Update diagrams whenever hyperscaler reference architectures evolve or regulators revise reporting templates. Doing so keeps frontline engineers, auditors, and sustainability officers aligned on a single source of truth.
Regulatory landscape and evidence expectations
High-availability estates now face overlapping resiliency, cybersecurity, and sustainability mandates that explicitly call out observability evidence. The European Union’s recast Energy Efficiency Directive requires every data centre with installed IT power above 500 kW to submit annual reports covering energy consumption, cooling efficiency, PUE, renewable sourcing, and waste heat reuse metrics to the European database from 15 May 2024 onward, forcing operators to maintain auditable telemetry across energy and mechanical systems.Directive (EU) 2023/1791, Article 12 Australia’s prudential supervisor set similar expectations through CPS 230, which obliges regulated financial institutions to test operational resilience scenarios, monitor critical operations continuously, and provide post-incident data to the Australian Prudential Regulation Authority (APRA).APRA CPS 230 Operational Risk Management In the United States, the Securities and Exchange Commission’s 2023 cybersecurity disclosure rule compels registrants to disclose material cyber incidents within four business days, making timestamped telemetry and capacity insights essential for verifying materiality assessments.SEC Cybersecurity Disclosure Rule
Regulators are also explicit about instrumentation depth. The European Banking Authority’s Guidelines on ICT and security risk management require financial institutions to maintain end-to-end logging, tamper-resistant storage, and monitoring that correlates infrastructure capacity with business service impacts.EBA/GL/2019/04 Singapore’s Guidelines on Technology Risk Management instruct banks to capture telemetry from data centres, networks, and applications in near real time, integrate with anomaly detection, and retain evidence for supervisory inspections.Monetary Authority of Singapore TRM Guidelines 2021 For critical infrastructure operators, NERC CIP standards continue to dictate recovery plan validation (CIP-009), configuration monitoring (CIP-010), and cyber incident reporting (CIP-008), each requiring correlated observability records that prove when control systems deviated from their approved states.NERC CIP Standards
Cybersecurity regulators additionally demand rapid remediation proof. CISA’s Binding Operational Directive 23-01 orders U.S. federal agencies to log vulnerabilities enumerated in the Known Exploited Vulnerabilities (KEV) catalogue and to produce remediation evidence within set due dates, meaning observability pipelines must stitch vulnerability telemetry, configuration baselines, and change management records for auditors.CISA BOD 23-01 Canada’s Office of the Superintendent of Financial Institutions codified similar telemetry expectations in its Technology and Cyber Risk Management guideline, emphasising the need for continuous monitoring of capacity, resilience, and incident response performance.OSFI Guideline B-13 These mandates reinforce why observability, capacity planning, and sustainability programs cannot operate in silos.
Boards also expect proof that the telemetry platform itself is governed. The Basel Committee on Banking Supervision requires board-level reporting on service resilience metrics, including indicators that track early warning signs before tolerances are breached.BCBS Principles for Operational Resilience Combine those governance expectations with the European Commission’s requirement to disclose data-centre-level sustainability metrics to end users under the EU Data Act when sharing industrial data, and the stakes for traceable observability only increase.Regulation (EU) 2023/2854 (Data Act)
Case studies from regulated operators
DBS Bank’s March 2023 service disruption in Singapore shows how observability gaps cascade into regulatory consequences. The Monetary Authority of Singapore imposed an additional capital requirement amounting to 1.8 times the bank’s risk-weighted assets for operational risk because investigations identified monitoring blind spots and recovery runbooks that failed to restore digital banking channels promptly.MAS supervisory actions on DBS Bank MAS subsequently directed DBS to implement enhanced observability coverage across infrastructure tiers, expand synthetic monitoring of customer journeys, and furnish periodic reports demonstrating telemetry coverage improvements—illustrating the direct link between instrumented capacity, customer impact metrics, and prudential oversight.
The 2021 OVHcloud Strasbourg fire also highlights the business value of structured observability data. OVHcloud’s official incident report details how delayed smoke detection telemetry and missing automated shutdown signals allowed flames to propagate from SBG2 to adjacent halls, leading to extended downtime for European customers.OVHcloud Strasbourg incident update Post-incident remediation included deploying additional thermal sensors, integrating fire system telemetry into their central operations platform, and publishing a resilience improvement roadmap—steps that align squarely with this guide’s recommendation to merge mechanical, electrical, and IT observability into one evidence stream.
TSB Bank’s 2018 migration failure, which culminated in a £48.65 million fine from the UK Prudential Regulation Authority and Financial Conduct Authority, demonstrates how insufficient observability can exacerbate transformation risks. The regulators’ joint findings emphasised that TSB lacked effective monitoring of the new platform’s capacity and could not detect issues affecting customer-facing channels before widespread impact occurred.PRA enforcement action against TSB Post-enforcement remediation required TSB to overhaul its telemetry, implement more rigorous load testing, and embed real-time dashboards into crisis decision-making. Using these lessons, Zeph Tech recommends integrating observability acceptance criteria into every migration or major release gate, ensuring that telemetry coverage, synthetic monitoring, and rollback controls are validated before go-live.
Infrastructure operators outside finance face similar expectations. The U.S. Federal Aviation Administration’s review of the January 2023 NOTAM outage concluded that legacy architecture without redundant observability pipelines delayed recovery, prompting a multiyear modernization roadmap that includes data replication, real-time telemetry, and enhanced cyber monitoring.FAA NOTAM modernization plan The roadmap commits to segmented infrastructure, automated failover, and deeper monitoring integration to prevent a repeat disruption that grounded thousands of flights.
Tooling blueprint for multi-cloud and hybrid estates
Implementing the observability and capacity disciplines described above requires a layered tooling strategy. At the telemetry collection tier, standardise on OpenTelemetry collectors for infrastructure and application signals to preserve portability across hyperscaler, colocation, and sovereign hosting regions.OpenTelemetry documentation Pair collectors with the Cloud Native Computing Foundation’s Kepler exporter to capture per-workload power consumption and feed sustainability models.Kepler project Use Prometheus or managed metric services (Amazon Managed Service for Prometheus, Google Cloud Managed Service for Prometheus) as the long-term metrics store, enabling the same queries to underpin alerting, dashboards, and regulatory evidence packages.
Control-plane automation must keep tooling consistent. Terraform modules should declare observability infrastructure—collector fleets, message queues, log retention policies—and integrate with GitOps controllers so every change yields a signed audit log.Terraform documentationArgo CD documentation Policy-as-code guardrails using Open Policy Agent can block deployments that do not register Golden Signals, thermal sensor coverage, or KEV remediation states, satisfying the enforcement expectations highlighted in APRA CPS 230 and CISA BOD 23-01.Open Policy Agent documentation
Analytics and reporting layers should cross-correlate observability data with business context. Adopt service catalogues (Backstage, Atlassian Compass) that tie telemetry streams to service-level objectives, owners, and regulatory impact assessments. Build executive dashboards that surface capacity runway, carbon metrics, outage severities, and remediation latency in one pane of glass; these dashboards feed directly into board reporting for Basel Committee and OSFI expectations. For sustainability assurance, integrate with hyperscaler sustainability APIs (AWS Customer Carbon Footprint Tool, Google Cloud Carbon Footprint) so every service displays real-time emissions intensity and compliance with EU reporting thresholds.AWS Customer Carbon Footprint ToolGoogle Cloud Carbon Footprint
Finally, document runbooks for every tooling component. Capture how observability collectors are patched, how dashboards are validated before regulator submissions, and how evidence is exported in machine-readable formats (CSV, JSON) to satisfy supervisory examinations. Embed role-based access control and tamper detection on all telemetry stores to comply with EBA/GL/2019/04 and NERC CIP-010 requirements for configuration monitoring and log integrity.
Operating metrics and review cadence
Translate observability into quantitative outcomes that executives and regulators can audit. Google CRE recommends service-level objectives with explicit error budgets; align SLOs to customer journeys (authentication, payment processing, telemetry ingestion) and tie each to a recovery time objective that matches board-approved impact tolerances.Google Site Reliability Workbook For each critical service, maintain the following metrics:
- Capacity runway: Forecast power, space, cooling, and network headroom for 6, 12, and 24 months using demand projections, silicon supply updates, and mechanical efficiency baselines. Reconcile forecasts with EU and Singapore reporting thresholds quarterly.Directive (EU) 2023/1791MAS TRM Guidelines
- Telemetry coverage: Percentage of infrastructure assets, workloads, and environmental sensors enrolled in OpenTelemetry or equivalent pipelines. Gap analyses should highlight assets lacking trace, metric, or log coverage.
- Alert fidelity: Ratio of true-positive alerts to total alerts for each severity band, ensuring analysts can respond within the thresholds outlined in CISA CPG detection and response outcomes.CISA Cross-Sector CPG
- Remediation latency: Median time to resolve KEV vulnerabilities, thermal excursions, and sustainability threshold breaches. Present trends to board risk committees alongside BOD 23-01 deadlines.
- Evidence freshness: Age of last exported compliance evidence package (NERC CIP, APRA CPS 230, MAS TRM, EU energy reporting). Automate exports so documentation never exceeds the oldest reporting obligation.
Layer in quarterly and annual reviews that blend telemetry with human oversight. Conduct quarterly resilience councils with operations, cybersecurity, sustainability, procurement, and finance leaders to review incidents, supply risks, and carbon performance. Annually, execute board-sponsored scenario tests that follow Basel Committee principles: simulate concurrent outages (utility feed loss plus application surge), record telemetry-driven decisions, and track post-test remediation to completion.BCBS Principles for Operational Resilience
Controls mapping quick reference
Use the controls matrix below to demonstrate how observability artefacts satisfy cross-regional mandates. The mapping helps internal audit trace requirements to dashboards, evidence repositories, and automation triggers.
| Requirement | Telemetry artefact | Evidence owner | Automation hook |
|---|---|---|---|
| Directive (EU) 2023/1791 Article 12 | PUE and WUE dashboards exported monthly, Kepler workload energy logs, sustainability API extracts. | Sustainability program manager | Terraform task scheduling CSV uploads to national database; GitOps validation of telemetry schemas. |
| APRA CPS 230 | Scenario test telemetry archive, incident timeline, board reporting pack with capacity runway graphs. | Operational resilience lead | Runbook automation to snapshot dashboards pre/post scenario test and store in immutable object storage. |
| NERC CIP-009 / CIP-010 | Change detection logs, configuration baselines, recovery plan execution traces, asset inventory exports. | NERC compliance officer | OPA policies blocking drifts; SOAR playbooks collecting incident artefacts into compliance vaults. |
| CISA BOD 23-01 | KEV remediation dashboards, patch deployment telemetry, exception approvals with expiration dates. | Vulnerability management lead | Ticketing system automation to escalate overdue KEV entries; CI pipelines enforcing remediation evidence. |
| SEC Cybersecurity Disclosure Rule | Materiality assessment templates referencing SLO impact, incident timeline with annotated telemetry, investor communication log. | Chief information security officer | Workflow automation triggering legal reviews once alert severity crosses pre-defined thresholds. |
Keep this matrix synchronized with internal control libraries so audit teams can trace every regulatory expectation to live telemetry. Update the matrix whenever new mandates emerge, such as the European Data Centre Energy Labelling scheme or sector-specific resilience rules.