Nasscom’s Feedback on the Consultation Paper for creation of Dedicated Building Code for Data Centers

February 23, 2024

Shri Sanjay Koul

Ministry of Electronics and Information Technology
Copy to:
Shri Sanket S Bhondve
Joint Secretary
Ministry of Electronics and Information Technology

We welcome the opportunity to provide feedback on the Consultation Paper for creation of Dedicated Building Code for Data Centers.

In the past, nasscom has highlighted the need for creating a dedicated building code for data centers (DCs), so we sincerely appreciate
this multi-stakeholder initiative of the government to create a dedicated building code for DCs.

To further strengthen the Proposed Building Code (PBC), we have provided below our comments, suggestions along with reasoning for
kind consideration of the Working Group. For industry input, please refer to Annexure I. We have given additional input based on industry
feedback, currently not part of the PBC, for your kind consideration. Please refer to Annexure II.

Given the inputs on the PBC are technical in nature, we request an opportunity to meet you in person to discuss our inputs in detail, so
they could be appropriately considered in the final draft of the building code for DCs.

Sincerely

Ashish Aggarwal

Vice President & Head Public Policy

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 Annexure I

Current Status Proposed Building Code Industry Recommendation

1. Floor to ceiling height for 1. Floor to ceiling height shall be in the 1. Floor to ceiling height shall be
commercial buildings is in a range of 4.5meter to 7 meters. This allowed up to 9.5 meters (This
range from 4 to 4.5 meter. shall include raised floor height, and additional height should not be
2. Most of the Data Centre false ceiling height as illustrated in counted as additional floor). This
developers follow the same Figure 1. shall include raised floor height, and
norms specified for commercial (Finished floor surface to the finished ceiling false ceiling height as illustrated in
buildings. surface) Figure 1 of the MEITY consultation
(Finished floor surface to the finished paper.
ceiling surface)-Ref: NBC-2016- part-3 2. Any access platform, fully meant for
(2.70) maintenance, shall not be considered
as Floor and to be not counted
Issue: currently in most of the cases, towards FSI and height restriction.
Data centres follow the norms of 3. Additional Floor Area Ratio (FAR)
commercial buildings, whereas Data should not be considered for
centres have a different requirement accommodating the increased floor
because technical infrastructure / to ceiling height.
equipment of varied sizes has to be
placed inside.
Floor Space Index (FSI) or Floor Area Ratio
Current Status Proposed Building Code Industry Recommendation
1. FAR/FSI varies from city to city 1. FSI/FAR should be as per Master Plan FSI/FAR should be allowed up to "3" for DC.
and lies in the range of 2 to 5 for prepared by competent authorities of
the commercial buildings. concerned city/town. Reasoning: Since DCs do not have much
2. Developers may choose to locate their occupancy, they do not burden the physical
Issue: Currently in most of the cases, projects in re-development sites, infrastructure of cities like sewage, water
Data centres follow the norms of identified by the Planning Authorities, network, public roads, Hence, increasing the
commercial buildings while as Data where generally twice the existing FSI FSI/FAR would allow DC industry to build
centres have a different requirement is assigned for development. more capacity in lesser site area. In a Master

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because technical infrastructure / 3. Developers may also seek locations in Plan, this would allow to provide land for
equipment of varied sizes has to be Transit Oriented Development (TOD) other use e.g. green buffer or social
placed inside. Policy Transferable Development infrastructure.
Rights (TDR) receiving zones where
FSI assigned are much higher (around
4-5 but may vary by State/location)
than the regular FSI in any other
development zones.
Ground Coverage and Open Space and Setbacks
Current Status Proposed Building Code Industry Recommendation
1. Ground Coverage lies in the 1. Ground coverage shall be in the range No change is required.
range of 30%-40% for large of 40-50%for plots sizes less than
plots. 10000sqm.
2. Open space is designed, 2. For plot sizes more than 10000 sqm,
developed, and maintained as ground coverage shall be in the range
per the requirement of type of of 40- 60% of total plot area.
building. 3. Setbacks are to be provided
3. Most of the DC developers considering provisions for fire tender
follow the same setbacks norms movement, vehicular movement,
specified for commercial pedestrian movement and other site
buildings which is very high for level utilities as may have been
Data-Centres. provided by the Architect/Designer.
Such setbacks shall be valid subject to
Issue: Limited ground area is available NOCs from Fire and other relevant
for construction of Data Centre, and departments / agencies. (Suggested
area required for public movement in setbacks for this use case is mentioned
Data Centres is limited. Therefore, more in Figure 2)
area can be used for construction to 4. Relaxation in setbacks may be
occupy higher capacity / number for requested unless there are proposals
racks. of road widening/ urban design/FBCs
applicable. Building permit authorities
may consider requests for relaxation
of setbacks in consultation with Fire
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 and Emergency Services departments
w.r.t norms of Fire / Disaster safety.
Relaxation in Green Belt
Current Status Proposed Building Code Industry Recommendation
1. Green Belt requirement for 1. “Green Belt” is an entity of urban It should be permissible to plant shortfall
most of the establishments is planning and is not a site level trees in a separate land parcel within
around 33%. regulation. city/jurisdiction limit of respective AHJ
2. Green cover and plantation within (Authority having Jurisdiction).
premises may be provided in
accordance with provisions of: Reasoning: The tree requirement is 1 tree
- Model BBL-2016 at clause 10.2.1- per 80 sqm of site area. This corresponds to
Provision for site level greens, or 16% of areas dedicated to trees, whereas
- As per the prevailing local Bye-laws. most of Byelaw does not allow green areas in
setback. Apart from these parking areas, road
area, equipment area, assembly area,
separation between buildings for fire tender
movement and set-back requirements takes
lot of open space at site. DC site cannot have
trees on periphery due to security concerns.
Thus, for DC exception should be allowed to
plant shortfall of trees in a separate land
parcel within city/jurisdiction limit of
respective AHJ (Authority having
Jurisdiction).
Car Parking for Data Centres
Current Status Proposed Building Code Industry Recommendation
1. In commercial establishments, 1. Requirement of parking spaces shall No change is required.
equivalent car space (ECS) be from 0.50 to 1.5 ECS/100 sqm. for
varies from 0.25 to 2.5 per 100 Administrative & staff holding area
sqm. of floor area. (including staff utilities) or any other
human occupancy, if so provided.

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 2. The number of such parking may be
accommodated in a multi-level
mechanized parking facility provided
within the basement, or on open
ground within the premises, if so
required.
3. In case basement parking is proposed,
clear height of basements shall be
provided accordingly, and appropriate
ramps shall be provided with clear
margins as specified in the bye-laws.
(If such ramps are required for
basement entry)

Loading-Unloading space: Apart from the car

parking space provision for light personal and
commercial vehicles, a heavy vehicle (truck)
parking space and loading-unloading space
shall have to be provided for handling/ loading
/ unloading of heavy equipments – minimum
8m x 4m near the service entrance.
Lifts/Elevators
Current Status Proposed Building Code Industry Recommendation
1. Elevators are installed in the 1. As of now no statutory regulations in Mandatory lift provisions shall be limited to
Data Centre buildings as per the country specifies the number of the fire lobby and firefighting lift
commercial building norms lifts required in a building for any use requirements. 1 lift for office area and 1
which is very high for Data occupancy. The provision of lifts is goods lift for DC.
Centre as there are very limited decided by the designers/architects
personnel working / human based on the overall occupancy load
movement in the Data Centres and ‘response time’ / ‘service level’
for using the lifts. desired, after methodical calculations.
2. However, certain provisions of Model
BBL-2016 recommends relevant
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 regulations for design and safe
operation of lifts in following paras:
- 5.4.4- Building component Lift,
- 8.6- Lifts for differently-abled,
- 11.9- Provision of Lifts, relevant
items of Annexure D (Bye-laws
11.2.3),
- Appendix –D (Bye-laws 4.31.2).
3. Any provision of lifts shall conform to
such given regulations, where
adopted.
4. 3. If multiple floors are to be built for
operational Data storage area, freight
elevator/goods lift (to carry heavy
equipments) shall also be added as
mandatory provision according to
applicable norms, beyond the
provision of the passenger lifts.
Installation of Chillers on Rooftop
Current Status Proposed Building Code Industry Recommendation
1. Installation of chillers on 1. Chiller installation on roof may be 1. Point # a: Developers should be
rooftop is allowed, however a allowed subject to: allowed to submit a third-party
lot of material, construction and a. Structural stability certificate report (From IIT/NIT or suitably
spacing restriction apply on (including weight of all installations empaneled agencies) for structural
chillers installation. within and on roof of the building) Stability Certification.
from the Engineer on Record (EoR). 2. Point # b to be modified so "Relevant
b. Clearances as per Authorities can give clearance
Fire/Disaster/PESO/BIS or any other subject to compliance to point a”.
relevant department/authority.
Reasoning: The DC developers themselves
(Note: Unless specified otherwise in the restrict the number of chillers on roof due to
relevant bye-laws, the height of chillers short cycle of air. Thus, the number of chillers

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 including any other installations shall not be shall be subject to structural stability of
added to the building height) building. No other condition is required.
Stacking of DG Sets
Current Status Proposed Building Code Industry Recommendation
1. The power requirement of a 1. “Stacking of DG sets” is specific 1. Point # 1: The minimum DG flue
commercial complex varies technical/safety issue that is evaluated stack height required is 30 mtr (above
from size to size and depends on for structural/operational risks. 1000 kVA DG) and if building height
the number of personnel 2. This aspect shall be governed by the is more than 30 mtr, then 6 mtr extra
working at that facility. regulations laid down by BIS / Fire/ height is required as per the current
However, Data Centre are Explosive or any other relevant building code.
power guzzlers and need department.
uninterrupted, high quality and We request not to keep 30 mtr
quantity of power while building height as the minimum
comparing to commercial criteria because a single floor DC
buildings height comes around 12 mtr.
Therefore, for 12 mtr height DC
requires 30 mtr flue stack.

Rather it should be linked to building

height and 6 mtr can still be retained
and in that case the DG flue stack
height would become 18 mtr instead
of 30 mtr.

This would save 12 mtr steel and

concrete foundations per DC. This
could amount to approximately 40%
net saving of natural resources.

Reasoning: It is understood that 30m height

is required to discharge SO2/NO2 /CO/ etc.
gases up in the atmosphere. However, height
can be reduced because of the advanced DG
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 sets which has reduced the volume of
emission values of these gases. Reduction in
height could result in significant saving of
steel and concrete in laying foundation,
which in turn would reduce carbon footprint.

2. Point # 2 – The clearance from local

urban bodies and regulatory bodies
would defeat the purpose of a
Uniform Building Code. Thus, the
number of DGs shall be subject to
structural stability of building only.
No regulatory framework should be
added.

Reasoning: DC operators exercise

due diligence on account of safety
like, roof top installations of chillers
and DG stack on multi-stack. The
design is reviewed through an
Engineer on Record (EOR) and
vetted through an independent third
party e.g., IIT/NIT.

The Structural Stability Certificate

from EOR and/or from IIT/NIT shall
be provided to the authority.

As per industry feedback, further,

regulatory framework like, seeking
approval from local or any other
authority like,
Fire/Disaster/PESO/BIS or any other

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 relevant department/authority may
result in additional documentation or
compliance based on their subject of
expertise.

These additional asks from other

local authorities (for e.g., municipal
authorities follow their respective
system and procedures to sanction
a building layout based on
Structural Stability Certification)
would involve more time and can vary
from one authority to the other based
on their regional experiences and
capacity. Thus, these would add
multiple layers of approval and thus
defeat the purpose of Proposed
Building Code, as a uniform code
across the country.

Therefore, such local authorities

should provide NOC/approvals, etc.,
once “The Structural Stability
Certification” from EOR is provided.

3. Fire egress norms to follow provision

of staircase for safe egress in case
connection to DG stack from DC
building should be provided. DG
stacks to be counted free of FSI.
4. Since DG are stacked to save ground
coverage and reduce urban heat
island effect (sustainability

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 requirement) and there is no
occupancy in the DG stack, thus it
should not be accounted for in FSI.
Fire Safety
Current Status Proposed Building Code Industry Recommendation
1. The fire safety equipment such 1. Active components of any fire 1. At Present the, Part 4 of NBC 2016
as warning system/alarm, protection/suppression systems are (Fire and Life Safety) is the only
sprinklers etc. should be not within the purview of building bye- governing document for Fire
commissioned laws. Proposal shall comply with the Protection. NBC does not have any
relevant state/city fire safety norms provision for DCs where occupancy is
with NOC obtained from local fire minimal. This should be updated in
department for building permit. line with NFPA. If the DC developers
2. Appropriate fire suppression systems are complying with their design with
(of approved make/quality) to be NFPA and do a self – certification
adopted with compliance to relevant (through a third party if required), the
Fire norms and BIS specifications. local authority should provide NOC.
2. Increase the floor plate size from
3000 sqm to 6000 sqm (due to very
low occupancy presence) for a single
fire zone. This will make the DC work
with a reduced carbon footprint and
less energy with same capacity.
3. The data halls shall be considered as
Industrial Occupancy Group for Fire
Egress Travel Distance.
Reasoning: As per NBC, the fire egress
distance is 45m for certain industrial
occupancy group, though at present data
halls are considered as business group and
30m distance is applicable. As the data hall
have no permanent occupancy, they should
be under industrial occupancy group.

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 4. At present the local authority
(Authority having Jurisdiction) takes
a very long time in approval and
imposes rudimentary requirements
as per her discretion. This should be
standardised.
5. Occupancy load for DC buildings
should be kept at 50 sqm/ person or
higher, which is at par with global
standards.

Load Bearing
Current Status Proposed Building Code Industry Recommendation
1. Load bearing capacity limit 1. Load bearing capacity of structure 1. PBC Point #1- No change required.
varies from building size and w.r.t its occupancy shall be certified by
occupancy load, servers, the Structural Engineer on record for 2. PBC Point #2- Not required, subject
storage load, rack load etc. all purposes of permits/occupancy. to compliance to point 1.
2. In case the bye-laws define Risk based
Building classification, such provisions Also, please refer page 8 for “Reasoning”
shall have to be conformed to. given under Point # 2; Heading - Stacking of
DG sets.
Physical Security
Current Status Proposed Building Code Industry Recommendation
1. Physical security measures vary 1. The height of boundary wall shall not PBC Point #2 - Other sophisticated security
from facility to facility and be less than 3m, with other parameters system e.g., PIDS (Perimeter Intrusion
should be standardized. and installations felt necessary for Detections System) shall be left to the
securing the premises. discretion of DC developers.
2. Security installations and systems may
be used as per the relevant
specifications of BIS.
3. Data Centre shall have to comply with
the norms specified for high rise

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 structure such as fire regulations, risk
compliance, etc. wherever applicable.
4. No Restrictions on Building height
subject to clearance from Airport
Authority of India (AAI).

Other Regulations

S. Aspect Sub-Aspect Recommended Regulations Industry Recommendation

No.
1. Basements Shall be permitted up to 2-storeys
underground, the maximum extent of
which shall not be more than 50% of
plot area.
2. Parking Standards Parking space only for Administrative & There should be a space for visitor
staff holding/other human occupancy parking as vendors and customers
area (including staff utilities) often visit DCs for various
requirements.
3(a) Basement Setbacks Front Concerned City authority may decide
(b) Rear basement setbacks with reference to
(c) Side 1 stipulations made in Master
(d) Side 1 Plans/Building Bye-laws of other states
(e.g., Jammu Master Plan 2032)
4. Staircases General General staircase shall follow all 1. The minimum flight width
regulations as per clause 12.18 of NBC- of the staircase is
2016 with minimum flight width of acceptable. As per the
1500mm. National Building Code,
width of staircase should
not be governed by height
of building but by
occupancy.

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 2. Occupancy load for DC
buildings should be kept at
50 sqm/ person or higher.
Fire Stair Unless the main staircase is designed as NBC 2016 is more relevant and
a fire escape, a separate Fire escape/ acceptable.
External staircase shall be necessary for
the Administrative/Office bldg. - clause
11.8 of MBBL-2016.
5. Permissible Human Safety Building block for Administrative/staff This criterion should not be
Occupancy(ies) above holding/other related occupancies may applicable and must be at the
occupancy(ies) be provided above Data Storage units discretion of DC operator. Safe exit
on subsequent upper floors. of all occupants/ staff should be the
point of concern irrespective of
However, the vice-versa should not be office location within building.
permitted. Data storage occupancy
shall not be provided over human
occupied spaces in lower floors.
6. Other building Other building components like
components corridors, vent shafts, rooms, etc. shall
conform to the local BBL regulations, or
as per the NBC-2016, MBBL 2016 (in
case such components are not covered
in the prevailing local building bye-
laws)
7. FAR exemptions Following may be exempted from being While we appreciate the exemption
accounted in FAR/FSI: recommendation in the PBC,
covered area used for vehicle parking / following are the industry inputs so
other building utilities e.g., Plant room, exemptions are clearly spelled out
pump room, equipment storeroom etc. in the PBC to avoid conflicting
interpretation by the local
authorities which would defeat the
purpose of having a unified building
code.
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 Exception required –
1. Elements like DG stacks,
electrical, mechanical
rooms which are utility
driven spaces should be
fully exempted from FSI.

2. Server room floor area FSI

shall be counted only once
irrespective of the floor
height if no mezzanine floor
is cast in between.

3. Ancillary buildings like

chillers on ground, DGs on
ground, STP, fire tank,
water tanks, waste storage
etc. should be excluded
from FSI.

Reasoning: The floor height

requirement is due to equipment
heights, and this is a technical
requirement for efficient working
of DC buildings.

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 Annexure II

Additional recommendations on the PBC

1. Petroleum and Explosives Safety Organization

Permit use of belly tanks with capacity of 20000L sitting below the DG instead of centralised bulk storage tanks without the requirement
of NoC from the PESO. This will eliminate a separate HSD yard along with its pumps and accessories which in turn will save space and
energy, carbon footprint will reduce running of pipes will be eliminated with these belly tanks. Also, this would be aligned with
international best practices followed in DCs.

2. Fire & Life Safety Features of DG Stack

• The DG sets are acceptable to be stacked in an adjoining steel structure.

• DG Mounting: Deck slab (Metal deck with reinforced concrete topping) shall be used as flooring system around pathways for DG
platform, DG shall be mounted on concrete deck-slab. The deck-slab system shall be supported with framing of UB & WPB beams.
• Each DG set, placed on stack, shall be housed in separate & dedicated 2-hour fire rated MS enclosure along with day oil tank of
capacity 990 Liters. This is to confine the fire / smoke within enclosure at initial stages and to do safe evacuation from DG area
as well as adjoining DC buildings.
• The DG stack steel structure including open stairs shall be designed for 2 hours fire-rating.
• Fire brigade access to DG stack shall be provided from the main roads, at least 2 sides.
• Standalone water mist system shall be provided for each DG enclosure.
• Each DG gantry floor shall be protected with an automatic sprinkler system.
• Automatic fire detection and alarm systems shall be provided inside each DG set and in the gantry. The fire alarm system for DG
stack shall be integrated with adjoining building fire alarm system. In addition to the automatic fire detection and alarm system,
manual call points shall be provided at each level of DG gantry.

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 • Fire hydrants shall be provided at each level of DG stack at landing of staircase, leading to top of structure. An external hydrant
system on ring-main with a maximum spacing of 30 meters between two stand posts shall be provided to cover the steel structure.
Portable fire extinguishers and sand buckets shall be distributed all over the DG stack.

3. Lithium-ion battery

The server racks with in-built lithium-ion battery inside the DC should be allowed. We are happy to provide detailed feedback on fire
safety for further deliberation.

4. Green building

PBC should incorporate green building or environment sustainability requirements.

5. Flexibility on use of DC building

There should be no restriction in the use of a part of the DC building as office space for the staff of the DC provider and technical staff
of customers who need to be stationed close to the IT equipment for any urgent issue and for 24x7 monitoring.

For any queries related to this submission, please contact:

Ashish Aggarwal ([email protected]) or Sudipto Banerjee ([email protected]) with a copy to [email protected].

About nasscom
Nasscom is the premier trade body and chamber of commerce of the Tech industry in India and comprises over 3000 member companies
including both Indian and multinational organisations that have a presence in India. Established in 1988, nasscom helps the technology
products and services industry in India to be trustworthy and innovative across the globe. Our membership spans across the entire
spectrum of the industry from start-ups to multinationals and from products to services, Global Service Centres to Engineering firms.
Guided by India’s vision to become a leading digital economy globally, nasscom focuses on accelerating the pace of transformation of the
industry to emerge as the preferred enablers for global digital transformation. For more details, kindly visit www.nasscom.in

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