California Air Resources Board

As someone responsible for managing large-scale infrastructure projects in California, I urge CARB to approve this variance. While the state has taken commendable steps in adopting new refrigerant standards, a variance would provide much-needed flexibility to ensure a stable transition toward low-GWP refrigerant products ahead of the 2027 federal mandate. This approval would allow continued deployment of Stulz equipment that not only meets current project timelines but also fully adheres to California’s stringent Title 24 and Title 20 regulations—something many alternative systems do not. Importantly, this action would help prevent delays for critical facilities such as data centers, universities, and research institutions that rely on compliant CRAC systems to move forward with new builds or essential retrofits.