Vantage Data Centers cooling posture: liquid-to-the-RACK today, liquid-to-the-chip only as a build-to-suit engagement

No published pricing. Build-to-suit liquid-to-chip deployments are quote-only engagements with their own construction timeline, and that construction timeline is the real cost - see notes.

lead_time_weeks is null because the quantity is structurally not applicable: on-demand cloud capacity starts on request, so there is no order-to-delivery lead time. The constraint is the price per GPU-hour and the availability snapshot, not an interval. The one caveat worth keeping: scarce tiers gate capacity behind a reservation or Capacity Block commitment (AWS caps the booking horizon at 8 weeks, source spl-aws-capacity-block-booking-horizon), and that is a commitment window, not a lead time.

EAR 742.6(a)(6)(iii)(A) + EAR 744.23/744.6 (Entity, Unverified, MEU list screening of the end user) + the advanced-computing IaaS obligations of 91 FR 1684 (consignee KYC, and management/limitation of IaaS access to the hardware)

LAYER 1, EXPORT LICENCE: under the Jan 2026 BIS rule 91 FR 1684 (effective 2026-01-15) the license review policy for advanced-computing commodities with TPP < 21,000 AND total DRAM bandwidth < 6,500 GB/s - the NVIDIA H200 and AMD MI325X are the rule's named examples - moved from PRESUMPTION OF DENIAL to CASE-BY-CASE REVIEW, but only for exports FROM THE UNITED STATES to end users located in China or Macau, and only against six exporter certifications filed via SNAP-R before shipment: (1) items below the thresholds with the count of units shipped in the US; (2) sufficient US supply, judged 'taking into account normal lead times'; (3) no diversion of global foundry capacity away from US end users; (4) aggregate China+Macau shipments <= 50% of total US end-use shipments of that product; (5) no end-user or use prohibition; (6) the consignee runs rigorous KYC. Every shipment must then pass a qualified third-party testing lab - US-headquartered, not controlled by a D:5/Macau entity, no ownership stake in any party, qualification revocable by BIS at any time - verifying TPP, total DRAM bandwidth, interconnect bandwidth and copackaged DRAM capacity. Reexports and in-country transfers of the same chips to China/Macau REMAIN PRESUMPTION OF DENIAL. LAYER 2, END-USER AND PARENT SCREENING: per BIS guidance of 2026-05-31 a licence is required where the consignee is HEADQUARTERED in Country Group D:5 (15 CFR part 740 supplement no. 1) or Macau OR whose ULTIMATE PARENT COMPANY is so headquartered - even when the consignee itself sits outside D:5/Macau. The requirement sits at EAR 742.6(a)(6)(iii)(A) for destinations outside the US, with an exception available only under the license exception at 740.2(a)(9)(ii). The destination country alone therefore never answers the question; screen the parent. LAYER 3, REMAINING LIMITS: exports to D:5/Macau-headquartered OR -parented entities stay PRESUMPTION OF DENIAL wherever the buyer sits, and the AI Diffusion Rule that would have set a country-tier structure on who could lawfully buy what was RESCINDED on 2025-05-13 and is not being enforced, so any recorded status rests on the instruments named here rather than on tiering.

THE MOST IMPORTANT COLO RECORD IN THIS SLICE, BECAUSE IT DISTINGUISHES TWO COOLING TECHNOLOGIES THAT ARE ROUTINELY CONFLATED AND THAT DECIDE DEPLOYABILITY. Vantage's own words: 'Vantage has utilized various cooling technologies since our inception, including air-cooled chillers, water-cooled chillers, indirect heat exchange and liquid to the rack. We are committed to an air-cooled chiller model as our preferred design moving forward.' And on going further: 'Vantage is also partnering with customers to bring liquid to the rack in large scale applications. We're making advances toward pushing the medium for heat exchange closer and closer to the source-i.e., the chip-with a goal of an even more efficient, and just as reliable, cooling approach based on our customers' unique needs. This application is ideal for a build-to-suit data center.' READ THAT CAREFULLY. Their 50 kW+ tier is LIQUID TO THE RACK - a coolant loop delivered to the rack enclosure, typically serving in-rack heat exchangers or rear-door heat exchangers. It is NOT liquid-to-the-chip, i.e. not a direct-on-die cold plate fed by a CDU. NVIDIA's GB200 NVL72 needs the latter: the DGX GB guide specifies liquid running up and down the rack through manifolds and then through cold plates attached to the CPUs and GPUs inside each sealed 1RU compute tray. Different plumbing, different failure domains (their guide devotes a section to leak detection), different water temperatures, different maintenance contracts. A facility that can do liquid-to-rack may still not be able to accept an NVIDIA rack-scale system without construction. Their Highlights point the same way: 'Pre-tapped headers to provide liquid to the FLOOR' and 'Forging a liquid-to-the-chip future' - present-tense aspiration, not a shipped standard. THE COMMERCIAL CONSEQUENCE: liquid-to-chip at this density is a BUILD-TO-SUIT project, not a product you order. The lead time to deploy a GB200 NVL72 into an existing colo building is therefore dominated by construction, not by GPU supply, which inverts the usual assumption that lead time is set by the accelerator. Facilities engineering, not procurement, becomes the critical path. EXPORT CONTROL (2026-10-04, mechanism-level; sources spl-bis-2026-05-d5-guidance, spl-bis-2026-01-advanced-computing-case-by-case): renting capacity does NOT remove the export-control question, it relocates it. Providing remote access to controlled computing capability can constitute a transfer under the EAR, so the provider must screen the end user; and separately, under the 91 FR 1684 licence regime the consignee must run KYC procedures to prevent unauthorized remote access and must manage and limit IaaS access to the hardware - obligations pushed onto the customer, who must be told to implement them. For a customer headquartered or parented in Country Group D:5 or Macau the 742.6(a)(6)(iii)(A) end-user/parent test can bite even when the capacity is consumed in a permitted region. Recorded true because the underlying hardware is controlled and the provider carries the screening duty, not because access to a US region is itself restricted. LEAD TIME: null - and for this record that is the WRONG QUESTION, which is the point worth recording. This record measures a build constraint that is not the accelerator supply chain: the lead time for a 120 kW liquid-cooled rack is set by construction, electrical service, and CDU/manifold plumbing, not by GPU allocation. Its own notes already make this argument for the colo case, so this entry only fixes the boundary: do not read a GPU lead time into a facility lead time, and do not read a facility lead time into a GPU lead time. No vendor publishes a weeks figure for either, so both stay null - probe log in source spl-negative-no-oem-publishes-lead-time. Where a real published horizon exists for the supply side it is on the accelerator record (NVIDIA's $95.2bn purchase and supply/capacity obligations substantially payable through FY2027, source spl-nvda-10k-fy2026-supply-commitments).