- Rack power density, not floor area, decides which cooling approaches remain viable.
- Uptime Institute’s 2025 survey puts average modal rack density near 9 kW, with 82 percent of facilities below 30 kW per rack and 9 percent above 50 kW.
- ASHRAE Technical Committee 9.9 frames the air cooling ceiling as airflow: at 40 to 50 kW per rack the supply air requirement reaches about 5,000 cubic feet per minute.
- Direct-to-chip removes heat only from cold plated components. Immersion removes almost all of it.
- PUE flatters liquid cooled halls because pump energy migrates inside the IT boundary. Report Water Usage Effectiveness alongside it.
- Title 24 Part 6 treats computer rooms as a covered process, and the containment threshold fell from 175 kW per room to 10 kW in the 2022 code.
- What Data Center Cooling Is, and Why It Became the Constraint
- How Data Center Cooling Works, From Die to Atmosphere
- The Four Cooling Families
- Which Approach Applies at Which Rack Density
- What Cooling Asks of Each Building System
- Standards and Metrics: ASHRAE, PUE and WUE
- California, Healthcare, Laboratories and Retrofit Halls
- How to Choose a Cooling Approach
- Commissioning, Redundancy and Concurrent Maintainability
- Where Budlong Works
- Related Reading
- Frequently Asked Questions
For twenty years the hard question in a data center was electrical: how many megawatts could reach the site, and how they would be backed up. Cooling was answered with more air handlers and a bigger chiller. Accelerated computing has ended that. Rack density has passed the point where moving air can carry the heat away, and the thermal design now sets the shape of the building, the floor structure, the water strategy and the electrical layout rather than following them.
This article compares air cooling, the close coupled technologies that extend it, direct-to-chip liquid, immersion and hybrid halls, with the metrics that judge them and the California code layer that catches owners out. Budlong’s mission critical practice works on both sides of this problem, and our MEP engineering services cover the coordination a density change sets off, as our expertise overview shows.
1. What Data Center Cooling Is, and Why It Became the Constraint
Data center cooling moves waste heat from a semiconductor die to the outside air, continuously and within a temperature envelope the equipment manufacturer will warrant. Every watt delivered to a server leaves as heat, so a 10 MW IT load is a 10 MW heat load rejected without interruption.
What changed is density. The U.S. Department of Energy reported that data centers consumed about 176 TWh in 2023, roughly 4.4 percent of U.S. electricity, up from 58 TWh in 2014, with a projected 325 to 580 TWh by 2028. That growth arrived not as more racks but as far more power in the same cabinet footprint.
The Uptime Institute global survey for 2025 puts average modal rack density near 9 kW, up from 8.3 kW a year earlier. The spread matters more: around 82 percent of facilities report a maximum below 30 kW per rack, 9 percent sit between 30 and 49 kW and 9 percent exceed 50 kW. Mainstream racks have barely moved; the top of the distribution has moved a very long way.
Density is the only input that matters at concept stage. A 5 MW hall at 8 kW per rack and a 5 MW hall at 80 kW per rack share an electrical service and almost nothing else. The second needs roughly a tenth of the floor area, a different heat rejection path, structural capacity for filled liquid equipment, and piping the first does not have.
2. How Data Center Cooling Works, From Die to Atmosphere
Every approach performs the same four steps, and the differences are about where the medium changes from air to liquid. Heat capture happens through server fans drawing room air across heat sinks, through a cold plate, or through submersion in a dielectric fluid. Density decides that step, because air carries roughly one four thousandth of the heat per unit volume that water does. Transport moves heat out of the space, through the room or through pipe. Heat exchange passes it to the plant loop at the coolant distribution unit. Rejection pushes it into outside air.
Economisation and free cooling
Economisation rejects heat without running compressors whenever ambient conditions allow. An airside economiser brings filtered outside air directly into the hall when it is cooler than the return air. It is the most efficient option, but it exposes the white space to outdoor particulate and humidity swings, so filtration to at least MERV 13 and careful changeover control are essential.
A waterside economiser makes chilled water using a cooling tower or dry cooler without running the chiller, keeping the air loop closed. Lawrence Berkeley National Laboratory guidance puts its home in climates with wet bulb temperatures below 55 degrees Fahrenheit for 3,000 or more hours a year: met along the California coast and in the Bay Area, less so in the Central Valley, barely at all in the desert.
Adiabatic and evaporative assistance sits between the two, wetting media upstream of a dry cooler to depress entering air temperature toward the wet bulb. It extends free cooling substantially in hot dry climates, which is exactly where California water is most contested.
Ask for free cooling hours as a number, not as a claim. A credible team will produce annual bin hours for the site’s own weather file at the proposed supply water temperature, and show how that moves if the IT vendor later demands colder water.
📖 Also Read: Chilled Water System Design for High Rise Buildings for how plant sizing, pumping and distribution play out on a large continuous load.
3. The Four Cooling Families
Air cooling
CRAC versus CRAH. A computer room air conditioner is a packaged direct expansion unit with its own compressor, rejecting heat to an outdoor condenser. A computer room air handler has no compressor: it is a fan and a chilled water coil fed from a central plant. CRAC units deploy quickly and need no chilled water, but each is an independent refrigeration machine with its own maintenance burden. CRAH units need a central plant, which then carries economisation, variable speed pumping and thermal storage across the whole load. Above a few hundred kilowatts, CRAH almost always wins.
Raised floor versus overhead. A raised access floor used as a supply plenum stays flexible for cabling, but capacity falls as underfloor obstructions accumulate and unsealed cutouts bleed supply air where it does no work. Overhead distribution avoids the plenum and delivers directly above the cold aisle, so it suits new build halls with a known rack layout. Retrofits with limited height often have no choice.
Containment. This is the highest value air side measure available: racks face front to front and back to back, blanking panels close every vacant rack unit, cutouts are sealed, and a barrier stops hot exhaust mixing with cold supply. LBNL notes that a sealed arrangement can return air at 85 degrees Fahrenheit or higher, which is what makes economisation worth having. Without it, supply temperature must be depressed to protect the worst rack in the room.
In-row units and rear door heat exchangers
These transition technologies shorten the air path rather than eliminating it. An in-row unit sits in the rack line rather than at the room perimeter, drawing hot aisle air across a coil and discharging into the cold aisle a few feet away, so fan energy falls and capacity lands where the load is. A rear door heat exchanger replaces the rack’s back door with a chilled or condenser water coil, so exhaust leaves at close to room temperature and the rack is thermally neutral. Rear doors are the least invasive route into liquid: only water at the rack.
Direct-to-chip liquid cooling
Direct-to-chip puts a cold plate in contact with the processor or accelerator and circulates coolant through it. Two loops are involved, and the boundary between them is the commercial fault line of the design. The technology cooling system loop is the clean, chemically controlled secondary loop running to the servers. It belongs to the IT vendor’s reference design and carries strict limits on temperature, pressure, flow, water quality and materials. The facility water system loop is the building’s chilled or condenser water. A coolant distribution unit sits between them: liquid-to-liquid CDUs exchange to facility water, while liquid-to-air CDUs push the load back onto the air system.
Single phase keeps the coolant liquid, typically an inhibited water and glycol mixture, and dominates in practice. Two phase lets it boil at the cold plate and condense in the CDU, carrying far more heat per unit of flow at near constant temperature, at the cost of pressure control and a fluid inventory with real handling implications.
ASHRAE Technical Committee 9.9 defines the temperature envelope you must design to. The fifth edition of the Thermal Guidelines renamed the liquid classes so the number states the upper supply temperature: W17, W27, W32, W40, W45 and W+ mean maximum facility supply water temperatures of 17, 27, 32, 40 and 45 degrees Celsius and above. Ask which class the IT equipment is certified to before sizing plant. A W45 machine and a W17 machine imply completely different chiller strategies and free cooling hours.
Immersion cooling
Immersion submerges entire servers in a dielectric fluid, so almost all heat leaves as liquid and the hall needs very little air conditioning. Single phase immersion circulates a dielectric oil or synthetic fluid through a tank to a liquid-to-liquid heat exchanger, usually in horizontal tanks with servers mounted vertically. Two phase immersion uses a fluid with a low boiling point: server heat boils it, vapour rises to a condenser in the tank lid, and condensate falls back. Two phase achieves the highest heat flux available, but its fluids sit under regulatory pressure as part of the PFAS phase out.
The implications are structural and operational. A filled tank concentrates a large mass over a small footprint, so slab capacity is checked first. Serviceability changes completely: a technician hoists a wet server out, lets it drain and works on a drip tray. Fluid inventory, filtration, spill containment and disposal become facility responsibilities that did not previously exist.
Hybrid halls
Most new high density projects are hybrid. A direct-to-chip rack still rejects roughly 20 to 30 percent of its heat to air through memory, drives, network cards and power supplies, so the hall needs both a liquid loop and a working air system. The failure to avoid is undersizing that residual air system so badly that the liquid rows cannot be commissioned.
4. Which Approach Applies at Which Rack Density
Density bands are the cleanest way to frame the decision.
| Rack Density | What It Typically Houses | Approaches That Remain Viable | What Starts to Fail |
|---|---|---|---|
| Under 5 kW | Legacy enterprise, storage, network, telecom rooms | CRAC or CRAH, raised floor or overhead, basic aisle discipline | Nothing. Most rooms here are overcooled, not undercooled. |
| 5 to 10 kW | Mainstream enterprise and general colocation | CRAH with full containment and variable speed fans | Uncontained layouts show hot spots at the top of racks. |
| 10 to 20 kW | Dense virtualisation, entry level GPU, HPC storage | CRAH with containment, in-row units for the hottest rows | Raised floor plenum capacity and perforated tile throughput. |
| 20 to 40 kW | GPU inference, mid range HPC, dense blade | In-row cooling, rear door heat exchangers, tightly controlled contained air | Room level distribution. Supply temperature falls, which kills economiser hours. |
| 40 to 80 kW | AI training partial racks, high end HPC | Direct-to-chip for the accelerators plus air or rear door for the balance | Air alone. ASHRAE puts the airflow requirement here near 5,000 cfm per rack. |
| Above 80 kW | Full AI training racks and accelerated compute pods | Direct-to-chip with liquid-to-liquid CDUs, or immersion | Every air based option. The question becomes which liquid approach, not whether. |
The triggers that force the conversation
Four events should prompt a cooling review regardless of headline density: a change of IT vendor or platform, because reference designs carry non negotiable coolant requirements; a rise in electrical service, because load calculations that rise land as heat; a tenant fit out in a shell built to a lower density; and any structural alteration, because filled liquid equipment changes floor loading.
📖 Also Read: Power Distribution System Design for Data Centers for how the electrical topology has to move in step with a density change.
5. What Cooling Asks of Each Building System
A density decision is never confined to the mechanical scope. It propagates.
Mechanical
Chiller selection and staging, supply water temperature strategy, economiser type, pumping topology, CDU placement and redundancy, secondary loop pipe sizing, filtration, and the residual air system a hybrid hall needs. Accurate load calculation methods matter more here than in almost any other building type, because the load runs continuously and oversizing carries a permanent penalty. Trade offs belong in HVAC system selection, not after procurement.
Electrical
Pump and CDU loads must sit on the right level of backup. An air cooled hall has minutes of thermal mass after a utility failure; a liquid cooled rack has almost none, so coolant pumps belong on uninterruptible power. That is an electrical engineering decision driven entirely by the cooling choice.
Plumbing, structural and fire
Make up water, treatment, filtration, tank and CDU drainage, spill containment for dielectric fluids and, where evaporative equipment is used, blowdown handling form a genuine plumbing engineering scope, not a mechanical subset. Filled immersion tanks impose concentrated loads well beyond a general purpose slab, and on retrofits that constraint most often kills an immersion proposal. Pipe and non conductive fluids also change the fire risk model, so leak detection and fluid compatibility with the suppression strategy need resolving with the authority having jurisdiction.
Controls and coordination
Supply water temperature reset, CDU sequencing, differential pressure control across the secondary loop, leak alarm integration and the interface between vendor monitoring and the building management system all have to be specified. MEP BIM coordination and clash detection is not optional at these pipe densities.
Is Your Hall Sized for the Density You Will Actually Deploy?
The gap between the density a shell was designed for and the density a tenant now wants is the most common problem we are asked to solve. A short feasibility review is far cheaper than finding the limit during fit out.
6. Standards and Metrics: ASHRAE, PUE and WUE
ASHRAE Technical Committee 9.9
ASHRAE Technical Committee 9.9 publishes the Thermal Guidelines for Data Processing Environments, the reference the industry designs to. It defines air classes A1 through A4 for inlet conditions and liquid classes W17 through W+ for facility supply water temperature. It is not a code, but IT warranties are written against it, so commercially it behaves like one.
Power Usage Effectiveness and its limits
PUE is total facility energy divided by IT equipment energy. It measures infrastructure overhead, not efficiency: replacing servers with better ones cuts IT energy and makes PUE look worse while the building uses less power. Industry PUE has stagnated, with Uptime Institute reporting a weighted average of 1.54 for 2025, a sixth consecutive year around 1.54 to 1.58, though sites above 20 MW average near 1.44. A liquid cooled hall also breaks the boundary: pumps and fans that were facility equipment move inside the IT enclosure and are metered as IT load, so PUE improves without a watt being saved.
Water Usage Effectiveness
WUE is annual site water use divided by IT equipment energy, in litres per kilowatt hour. It exists because PUE can be driven down by trading water for energy, so a hall with aggressive evaporative rejection can post an excellent PUE and a poor WUE at once. Any serious California comparison carries both, plus whether the water is potable, recycled or reclaimed.
Ask for PUE at partial load, not only at design load. Halls routinely run at 40 to 60 percent of design IT load for years after commissioning, and a plant optimised only for full load performs badly there. A design PUE with no part load curve behind it is marketing.
7. California, Healthcare, Laboratories and Retrofit Halls
Title 24 Part 6 and computer rooms
Part 6 of Title 24, the California Energy Code, treats computer rooms as a covered process, and the definition catches more than owners expect: any space with an IT equipment power density above 20 watts per square foot qualifies, which routinely captures equipment rooms in buildings nobody calls a data center.
Section 120.6 carries the mandatory requirements: controls must prevent simultaneous heating and cooling and prohibit reheat, humidification must be adiabatic, and fan motor demand must not exceed 50 percent of design wattage at 66 percent of design fan speed for units above 60,000 Btu per hour. Section 140.9 carries the prescriptive requirements: economisers, a total fan power limit of 27 watts per kBtu per hour of net sensible cooling capacity, air containment and minimum UPS efficiencies.
The containment threshold changed dramatically and many owners have not noticed. Under the 2019 code, air containment was required only for computer rooms above 175 kW of IT design load. The 2022 code cut that to 10 kW per room and removed the healthcare exception. A modest telecom room inside a hospital or office building can now trigger a containment requirement that was never in the budget.
The gap between the code and high density reality
Title 24 was written around air cooled computer rooms and has no separate provisions for liquid cooled IT equipment. Its economiser thresholds, fan power limits and containment language all assume heat leaves the rack as air. The California Energy Commission is examining this for the 2028 cycle, acknowledging the absence of liquid cooling requirements. In the meantime these projects end up on the performance path, so open the conversation with the authority having jurisdiction during schematic design rather than at plan check. A well built energy model is the instrument for it.
Water availability and drought policy
California adds a constraint most markets do not. Evaporative rejection is attractive in hot dry inland climates, which is precisely where supply is most contested and agencies are least willing to commit to a new industrial demand. Projects increasingly find that the will serve letter, not the energy model, decides the heat rejection strategy. Recycled water can resolve it where a purple pipe network exists, but that belongs to site selection. Our work on water conservation in MEP design covers the reuse strategies involved.
📖 Also Read: The Title 24 Compliance Guide for how covered process requirements sit inside the wider compliance package.
Healthcare, laboratories and retrofit halls
Hospitals and research buildings carry a surprising amount of computer room load, and both now sit inside the Title 24 definition. In healthcare facilities, imaging, server and communications rooms compete for capacity against infection control ventilation that cannot be compromised. In laboratories, high performance computing sits alongside process exhaust, and the 2025 code removed the laboratory exemption. Converting air cooled space to liquid is rarely wholesale: the realistic scope is a few rows, and the binding constraints are electrical capacity, floor loading and routing space, which is where mechanical engineering in complex existing buildings earns its keep.
8. How to Choose a Cooling Approach
The comparison below sets the four families against the factors that decide procurement. Capital cost is relative to contained air cooling for the same IT load.
| Factor | Air (CRAC or CRAH with Containment) | In-Row and Rear Door | Direct-to-Chip Liquid | Immersion |
|---|---|---|---|---|
| Viable rack density | Up to roughly 20 kW, marginal beyond | Roughly 20 to 40 kW | 40 kW to well above 100 kW | Highest available, 100 kW and beyond |
| Capital cost | Baseline | Modest premium, mostly pipework and units | Significant premium: CDUs, secondary loop, leak detection | Highest: tanks, fluid inventory, structure, handling equipment |
| Retrofit feasibility | Straightforward | Good. No server change for rear door units | Moderate. Needs pipe routes, CDU space and electrical headroom | Poor. Structural loading and service access usually govern |
| Water use | Set by heat rejection. Zero if dry cooled | Same as air. The tower decides, not the door | Same as air, but warmer water widens dry cooling options | Lowest per unit of heat if paired with dry rejection |
| Maintenance burden | Familiar. Filters, belts, coils, controls | Familiar plus water at the rack and leak detection | New skills: fluid quality, filtration, quick disconnects, CDU service | Substantially new: fluid handling, hoists, drainage, spill response |
| Air system still required | Yes, it is the system | Yes, at reduced duty | Yes, for the 20 to 30 percent rejected to air | Minimal. Room air conditioning largely disappears |
| Typical application | Enterprise, colocation, telecom and equipment rooms | Dense enterprise rows and staged density upgrades | AI training and inference, HPC, new build high density halls | Edge, specialist HPC, extreme density pods |
The selection factors in order of weight
Rack density comes first: today’s number and the number the client will want in five years. IT vendor requirements come second, since reference designs specify coolant chemistry, temperature class, flow and materials as warranty conditions. Retrofit versus new build decides how much of the field is open, and retrofit narrows it to rear door and targeted direct-to-chip. Water availability is a permitting item for the supplying agency, not an engineering assumption. Maintenance skills are a real line item, because a team that has never handled dielectric fluid needs training. Redundancy expectations come last but reshape everything.
📖 Also Read: Why Data Center Power Systems Fail for how single points of failure hide inside topologies that look redundant on paper.
9. Commissioning, Redundancy and Concurrent Maintainability
Redundancy in the thermal path
Redundancy language written for chillers does not extend automatically to a liquid cooled hall. A facility can have N+1 chillers and still be single threaded at the coolant distribution unit, the secondary loop pumps, the isolation valves serving a row, or the quick disconnects on a server. Each needs a stated position in the redundancy scheme.
Thermal ride through
An air cooled hall has minutes of thermal mass in the room air and chilled water volume. A direct-to-chip rack has almost none, so if coolant flow stops, junction temperatures rise within seconds and equipment throttles or shuts down. Secondary loop pumps and CDU controls belong on uninterruptible power, and the sequences must restore flow first.
Commissioning and resilience
Liquid systems add activities air systems never required: flushing and pressure testing the secondary loop, coolant fill and chemistry verification, leak alarm testing at every zone, CDU failover under load, and integrated testing that proves the residual air system carries its share while the liquid loop is deliberately failed. The building commissioning process must be scoped for this from the start, and our commissioning services treat integrated testing as the point of the exercise. California sites also face heat waves, smoke events and grid stress at once, which is the subject of resilient MEP systems for climate adaptation.
Key Takeaways
- Establish the target density and the five year density before any other decision.
- Air cooling with proper containment remains correct below roughly 20 kW per rack.
- In-row units and rear door heat exchangers cover the 20 to 40 kW band and are the least disruptive retrofit route into liquid.
- Direct-to-chip removes heat only from cold plated components. Plan for the 20 to 30 percent that still leaves as air.
- Immersion is governed by structural loading, fluid handling and serviceability, not thermal performance.
- PUE flatters liquid cooled halls. Report WUE alongside it.
- Title 24 Part 6 catches any room above 20 watts per square foot of IT load, and the containment threshold is now 10 kW.
- Thermal ride through in a liquid cooled rack is seconds. Coolant pumps belong on uninterruptible power.
10. Where Budlong Works
Cooling strategy is site specific in a way few other MEP decisions are. Climate zone sets the free cooling hours, the water agency sets whether evaporative rejection is available at all, and local plan check culture sets how a covered process on the performance path is received. Budlong maintains teams across California so local knowledge sits behind each judgement, as our company story explains.
Sectors where cooling decisions carry the most weight
Mission critical facilities face the density question directly. Healthcare buildings carry computer rooms that now trigger containment alongside infection control ventilation. Laboratories combine high performance computing with process exhaust. Commercial buildings absorb tenant equipment rooms that quietly cross the covered process threshold.
11. Related Reading
12. Frequently Asked Questions
At what rack density does air cooling stop working?
There is no single cliff, but air becomes difficult above roughly 20 kW per rack and impractical between 40 and 50 kW. ASHRAE Technical Committee 9.9 frames it as airflow: a rack at that density needs around 5,000 cubic feet per minute of supply air, beyond what a floor tile or conventional diffuser delivers. Between 20 and 40 kW, in-row units and rear door heat exchangers extend an air based hall. Above that, liquid at the chip is the answer.
What is the difference between a CRAC and a CRAH?
A CRAC is a computer room air conditioner with its own refrigeration circuit, a packaged direct expansion machine rejecting heat to an outdoor condenser. A CRAH has no compressor, simply a fan and a chilled water coil fed from a central plant. CRAC units suit small rooms and retrofits with no chilled water. CRAH units suit anything large enough to justify a central plant, because economising and variable speed pumping then apply to the whole load.
What is direct-to-chip liquid cooling?
Direct-to-chip puts a metal cold plate in contact with the processor or accelerator and circulates coolant through it, so heat from those components never enters the room air. A coolant distribution unit separates the clean technology cooling system loop that touches the servers from the facility water loop running to the plant. Single phase designs keep the coolant liquid; two phase designs let it boil at the cold plate and condense in the CDU.
How does immersion cooling differ from direct-to-chip cooling?
Direct-to-chip cools only the components that carry a cold plate, so the rest of the server heat still leaves as warm air and the hall needs air handling. Immersion submerges the whole server in dielectric fluid, so almost all heat leaves as liquid and room air conditioning largely disappears. The trade is structural: a filled tank concentrates a load far above a standard rack, and service means lifting a wet unit out to drain.
What is PUE and why is it a poor measure for a liquid cooled hall?
Power Usage Effectiveness is total facility energy divided by IT equipment energy, so it measures infrastructure overhead rather than useful computing work. In a liquid cooled hall the boundary blurs, because coolant pumps and fans that were facility equipment move inside the IT enclosure and are metered as IT load. PUE improves without a watt being saved. It also says nothing about water, so WUE must be reported alongside it. The Lawrence Berkeley National Laboratory Center of Expertise publishes definitions for both.
Does Title 24 cover data center cooling in California?
Yes. Part 6 treats computer rooms as a covered process, defined as any space with an IT equipment power density above 20 watts per square foot. Section 120.6 carries mandatory requirements on simultaneous heating and cooling, adiabatic humidification and fan control. Section 140.9 carries the prescriptive requirements: economisers, fan power limits and air containment. The containment threshold fell from 175 kW per room in 2019 to 10 kW in the 2022 code.
Can an existing air cooled data hall be retrofitted for liquid cooling?
Often yes, but rarely across the whole hall. The realistic scope is a targeted conversion of a few rows. Rear door heat exchangers are least invasive because they need only water at the rack and no change to the server. Direct-to-chip also needs space for coolant distribution units, rack manifolds, leak detection and a clear pipe route. The constraints that bite first are electrical capacity, floor loading and routing space.
How much water does data center cooling actually use?
It depends almost entirely on whether heat is rejected evaporatively. A dry cooled plant uses effectively no water but consumes more energy in hot weather. A cooling tower or adiabatically assisted dry cooler trades water for energy, and in a hot inland California climate that can amount to millions of gallons a year. Water Usage Effectiveness, in litres per kilowatt hour of IT energy, makes the comparison visible.
Do liquid cooled halls still need concurrent maintainability?
Yes, and it is harder to achieve. Every element of the new heat path is a failure point candidate: the CDU, the secondary loop pumps, the isolation valves at each rack and the quick disconnects at each server. Concurrent maintainability means redundant CDUs, valved bypasses that isolate a unit without dropping a row, and a fluid quality regime serviceable live. A liquid cooled rack has little thermal mass, so the gap between power loss and pump restart is seconds. Guidance from the U.S. Department of Energy Building Energy Codes Program treats integrated testing as the point at which such assumptions are proven.

