Digital Resources
Digital Resources
Digital Resources
Opaque Market
Opaque Market
Opaque Market
Shared Factory Model
Shared Factory Model
Shared Factory Model
Planetary Boundaries
Planetary Boundaries
Planetary Boundaries
Lock -in
Lock -in
Lock -in
Credit Schemes
Credit Schemes
Credit Schemes
Reservation Practices
Reservation Practices
Reservation Practices
Our submission supports the European Commission in developing an AI and Cloud Development Act to establish Europe's own digital infrastructure path.
Our key recommendations include improving market design through a European Digital Resource Exchange, addressing anti-competitive practices in data centers, and ensuring development operates within planetary boundaries while prioritizing the well-being of European citizens.
We advocate for better policymaking assumptions, targeted market support, and a rigorous impact assessment of environmental effects related to data center expansion.
Our submission supports the European Commission in developing an AI and Cloud Development Act to establish Europe's own digital infrastructure path.
Our key recommendations include improving market design through a European Digital Resource Exchange, addressing anti-competitive practices in data centers, and ensuring development operates within planetary boundaries while prioritizing the well-being of European citizens.
We advocate for better policymaking assumptions, targeted market support, and a rigorous impact assessment of environmental effects related to data center expansion.
Our submission supports the European Commission in developing an AI and Cloud Development Act to establish Europe's own digital infrastructure path.
Our key recommendations include improving market design through a European Digital Resource Exchange, addressing anti-competitive practices in data centers, and ensuring development operates within planetary boundaries while prioritizing the well-being of European citizens.
We advocate for better policymaking assumptions, targeted market support, and a rigorous impact assessment of environmental effects related to data center expansion.
Introduction & Outline
Our submission seeks to support the European Commission in developing a comprehensive AI and Cloud Development Act. We strongly believe that Europe must define its own path forward on digital infrastructure. Europe’s digital future is only possible and sustainable, however, if it promotes fair and effective competition, commits to operating within planetary boundaries and promotes the fundamental values and well-being of the people of Europe.
In this document, we first outline our thoughts on the assumptions underlying the Cloud and AI Development Act and the policy documents on which it rests (Part 1). We then introduce a set of workable policy interventions that would enable fair and robust competition on the digital infrastructure markets in Europe (Part 2).
Finally, we argue how the updated assumptions in Part 1 together with the policy interventions for fair and robust competition on European markets for digital infrastructure in Part 2 would be meaningless if the EU does not also consider the wider context in which these markets operate and stays close to the very foundations on which the Union is built.
As a Leitmotiv for the future of European digital infrastructures, the EU should commit to making sure digital infrastructure markets operate within planetary boundaries, including but not limited to its climate goals, and respect and promote the fundamental values and well-being of the people of Europe (Part 3).
Introduction & Outline
Our submission seeks to support the European Commission in developing a comprehensive AI and Cloud Development Act. We strongly believe that Europe must define its own path forward on digital infrastructure. Europe’s digital future is only possible and sustainable, however, if it promotes fair and effective competition, commits to operating within planetary boundaries and promotes the fundamental values and well-being of the people of Europe.
In this document, we first outline our thoughts on the assumptions underlying the Cloud and AI Development Act and the policy documents on which it rests (Part 1). We then introduce a set of workable policy interventions that would enable fair and robust competition on the digital infrastructure markets in Europe (Part 2).
Finally, we argue how the updated assumptions in Part 1 together with the policy interventions for fair and robust competition on European markets for digital infrastructure in Part 2 would be meaningless if the EU does not also consider the wider context in which these markets operate and stays close to the very foundations on which the Union is built.
As a Leitmotiv for the future of European digital infrastructures, the EU should commit to making sure digital infrastructure markets operate within planetary boundaries, including but not limited to its climate goals, and respect and promote the fundamental values and well-being of the people of Europe (Part 3).
Introduction & Outline
Our submission seeks to support the European Commission in developing a comprehensive AI and Cloud Development Act. We strongly believe that Europe must define its own path forward on digital infrastructure. Europe’s digital future is only possible and sustainable, however, if it promotes fair and effective competition, commits to operating within planetary boundaries and promotes the fundamental values and well-being of the people of Europe.
In this document, we first outline our thoughts on the assumptions underlying the Cloud and AI Development Act and the policy documents on which it rests (Part 1). We then introduce a set of workable policy interventions that would enable fair and robust competition on the digital infrastructure markets in Europe (Part 2).
Finally, we argue how the updated assumptions in Part 1 together with the policy interventions for fair and robust competition on European markets for digital infrastructure in Part 2 would be meaningless if the EU does not also consider the wider context in which these markets operate and stays close to the very foundations on which the Union is built.
As a Leitmotiv for the future of European digital infrastructures, the EU should commit to making sure digital infrastructure markets operate within planetary boundaries, including but not limited to its climate goals, and respect and promote the fundamental values and well-being of the people of Europe (Part 3).
Key Takeaways & Recommendations
1. Better Assumptions for Better Policymaking
Europe does not lack computational infrastructure at present.
More AI development and deployment does not necessarily equal prosperity.
More American-style digital infrastructure development in Europe does not necessarily equal a more competitive Europe.
More AI development and deployment does not necessarily solve all of humanity’s problems – and may pose some new ones.
2. Improve Market Design
Establish a European Digital Resource Exchange — Create a marketplace for digital resources that enables price discovery, transparency, and competition in the digital infrastructure markets.
Integrate EuroHPC super computing capacity into the Digital Resource Exchange for public access to AI training infrastructure.
Enforce interoperability standards for digital resources offered on the exchange.
Require all digital services offered within the EU Single Market to procure digital resources from a European exchange.
Verify that public sector purchases of digital and AI services use digital resources procured through a European exchange.
Establish a regulatory oversight body at the European level to monitor and enforce rules for the Digital Resource Exchange.
3. Address Anti-Competitive Practices
Address anti-competitive reservation practices in data centers by:
Requiring transparency on reserved vs. utilized space.
Conduct assessment of existing data center capacity utilization before implementing policies to expand facilities.
Regulate IT Service Providers (ITSPs) by:
Offering EU-funded alternative training/certification for European platform and infrastructure services.
Creating transparency on incentives offered by cloud platforms.
Addressing anti-competitive free training and certification offerings.
4. Implement Targeted Support for Market Development
Create a migration financing facility to help European providers finance the migration of services and customers to European infrastructure or a European exchange.
Provide targeted financial support for European cloud platforms focused on:
Low-interest loans for IT equipment with payment structures aligned to business models.
Incentives for purchasing refurbished equipment or equipment produced in Europe in line with the EU Green Deal.
Provide an alternative financing mechanism for cloud platform credits: Reduce dependence of European startups on cloud platform subsidies. Level the playing field by either banning credits or providing equal credits through the Exchange.
5. Operating Within Planetary Boundaries While Serving the Well-Being of People
Undertake a rigorous impact assessment of the climate and broader environmental impacts of expanding Europe’s data center footprint as proposed in the Cloud and AI Development Act to enable a rational and evidence-based public debate about the future of digital infrastructure markets in the EU.
Commit and ensure that current and future development of data center capacity in Europe operates within planetary boundaries.
Pledge that promoting peace, its values and the well-being of its peoples is the first and foremost priority in policies regarding cloud and AI.
Base policies in this area on the precautionary principle given severe negative social externalities and human rights impacts of AI.
Any further investment in, or enabling of, AI development and deployment in Europe must be accompanied by a strengthening and broadening of regulatory frameworks.
Key Takeaways & Recommendations
1. Better Assumptions for Better Policymaking
Europe does not lack computational infrastructure at present.
More AI development and deployment does not necessarily equal prosperity.
More American-style digital infrastructure development in Europe does not necessarily equal a more competitive Europe.
More AI development and deployment does not necessarily solve all of humanity’s problems – and may pose some new ones.
2. Improve Market Design
Establish a European Digital Resource Exchange — Create a marketplace for digital resources that enables price discovery, transparency, and competition in the digital infrastructure markets.
Integrate EuroHPC super computing capacity into the Digital Resource Exchange for public access to AI training infrastructure.
Enforce interoperability standards for digital resources offered on the exchange.
Require all digital services offered within the EU Single Market to procure digital resources from a European exchange.
Verify that public sector purchases of digital and AI services use digital resources procured through a European exchange.
Establish a regulatory oversight body at the European level to monitor and enforce rules for the Digital Resource Exchange.
3. Address Anti-Competitive Practices
Address anti-competitive reservation practices in data centers by:
Requiring transparency on reserved vs. utilized space.
Conduct assessment of existing data center capacity utilization before implementing policies to expand facilities.
Regulate IT Service Providers (ITSPs) by:
Offering EU-funded alternative training/certification for European platform and infrastructure services.
Creating transparency on incentives offered by cloud platforms.
Addressing anti-competitive free training and certification offerings.
4. Implement Targeted Support for Market Development
Create a migration financing facility to help European providers finance the migration of services and customers to European infrastructure or a European exchange.
Provide targeted financial support for European cloud platforms focused on:
Low-interest loans for IT equipment with payment structures aligned to business models.
Incentives for purchasing refurbished equipment or equipment produced in Europe in line with the EU Green Deal.
Provide an alternative financing mechanism for cloud platform credits: Reduce dependence of European startups on cloud platform subsidies. Level the playing field by either banning credits or providing equal credits through the Exchange.
5. Operating Within Planetary Boundaries While Serving the Well-Being of People
Undertake a rigorous impact assessment of the climate and broader environmental impacts of expanding Europe’s data center footprint as proposed in the Cloud and AI Development Act to enable a rational and evidence-based public debate about the future of digital infrastructure markets in the EU.
Commit and ensure that current and future development of data center capacity in Europe operates within planetary boundaries.
Pledge that promoting peace, its values and the well-being of its peoples is the first and foremost priority in policies regarding cloud and AI.
Base policies in this area on the precautionary principle given severe negative social externalities and human rights impacts of AI.
Any further investment in, or enabling of, AI development and deployment in Europe must be accompanied by a strengthening and broadening of regulatory frameworks.
Key Takeaways & Recommendations
1. Better Assumptions for Better Policymaking
Europe does not lack computational infrastructure at present.
More AI development and deployment does not necessarily equal prosperity.
More American-style digital infrastructure development in Europe does not necessarily equal a more competitive Europe.
More AI development and deployment does not necessarily solve all of humanity’s problems – and may pose some new ones.
2. Improve Market Design
Establish a European Digital Resource Exchange — Create a marketplace for digital resources that enables price discovery, transparency, and competition in the digital infrastructure markets.
Integrate EuroHPC super computing capacity into the Digital Resource Exchange for public access to AI training infrastructure.
Enforce interoperability standards for digital resources offered on the exchange.
Require all digital services offered within the EU Single Market to procure digital resources from a European exchange.
Verify that public sector purchases of digital and AI services use digital resources procured through a European exchange.
Establish a regulatory oversight body at the European level to monitor and enforce rules for the Digital Resource Exchange.
3. Address Anti-Competitive Practices
Address anti-competitive reservation practices in data centers by:
Requiring transparency on reserved vs. utilized space.
Conduct assessment of existing data center capacity utilization before implementing policies to expand facilities.
Regulate IT Service Providers (ITSPs) by:
Offering EU-funded alternative training/certification for European platform and infrastructure services.
Creating transparency on incentives offered by cloud platforms.
Addressing anti-competitive free training and certification offerings.
4. Implement Targeted Support for Market Development
Create a migration financing facility to help European providers finance the migration of services and customers to European infrastructure or a European exchange.
Provide targeted financial support for European cloud platforms focused on:
Low-interest loans for IT equipment with payment structures aligned to business models.
Incentives for purchasing refurbished equipment or equipment produced in Europe in line with the EU Green Deal.
Provide an alternative financing mechanism for cloud platform credits: Reduce dependence of European startups on cloud platform subsidies. Level the playing field by either banning credits or providing equal credits through the Exchange.
5. Operating Within Planetary Boundaries While Serving the Well-Being of People
Undertake a rigorous impact assessment of the climate and broader environmental impacts of expanding Europe’s data center footprint as proposed in the Cloud and AI Development Act to enable a rational and evidence-based public debate about the future of digital infrastructure markets in the EU.
Commit and ensure that current and future development of data center capacity in Europe operates within planetary boundaries.
Pledge that promoting peace, its values and the well-being of its peoples is the first and foremost priority in policies regarding cloud and AI.
Base policies in this area on the precautionary principle given severe negative social externalities and human rights impacts of AI.
Any further investment in, or enabling of, AI development and deployment in Europe must be accompanied by a strengthening and broadening of regulatory frameworks.
Download the full version of our response to the EU AI & Cloud Development Act here.
Download the full version of our response to the EU AI & Cloud Development Act here.
Download the full version of our response to the EU AI & Cloud Development Act here.