Rinnai America Corp. v. South Coast Air Quality Management District
2:24-cv-10482
| C.D. Cal. | Jul 18, 2025Background
- Plaintiffs (manufacturers, builders, hospitality, and restaurant groups) challenged SCAQMD Rule 1146.2, which imposes a zero nitrogen oxide (NOx) emission standard on certain natural gas-fired appliances in Southern California.
- Plaintiffs sought declaratory and injunctive relief, claiming that the rule acts as a de facto ban on covered gas appliances and is preempted by the federal Energy Policy and Conservation Act (EPCA).
- SCAQMD is a regional air quality agency tasked with reducing air pollution for compliance with federal standards, especially regarding NOx emissions from large water heaters and small boilers.
- Both sides moved for summary judgment on the core issue of EPCA preemption.
- Intervening environmental groups supported SCAQMD and opposed plaintiffs' motion.
- The court reviewed the legal standards for summary judgment and federal preemption, referencing recent Ninth Circuit precedent (California Restaurant Association v. City of Berkeley).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether EPCA preempts SCAQMD's zero-NOx emission rule for appliances | Rule is a de facto ban on gas appliances and preempted by EPCA | Rule concerns pollution (NOx emissions), not energy use, thus not preempted | Not preempted. Rule concerns emissions, not energy use |
| Scope of CRA v. Berkeley regarding preemption | CRA should control; Rule sets gas appliance use at zero, so is preempted | CRA is narrowly limited to building codes regulating energy use, not emission rules | CRA does not apply; rule regulates emissions only |
| Congressional intent of EPCA preemption | EPCA intended to block state-level barriers to energy-efficient appliances | EPCA intended to set energy efficiency standards, not preempt historic state pollution control | EPCA does not reach air pollution regulations |
| Conflict with historic state police powers | State emission regulations that ban gas appliances are preempted | Preemption would undermine long-held state power over health and air safety | No preemption of emissions limits under police powers |
Key Cases Cited
- Medtronic, Inc. v. Lohr, 518 U.S. 470 (1996) (preemption is a matter of statutory interpretation focusing on congressional purpose)
- Cipollone v. Liggett Group, Inc., 505 U.S. 504 (1992) (statutory preemption clauses must be interpreted based on their text)
- CSX Transp., Inc. v. Easterwood, 507 U.S. 658 (1993) (plain wording of express preemption clauses governs analysis)
- Union Electric Co. v. Environmental Protection Agency, 427 U.S. 246 (1976) (states have primary responsibility but must meet federal minimum standards under Clean Air Act)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (summary judgment standard)
- Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (summary judgment burden of proof)