Case Explained: RINNAI AMERICA CORPORATION, ET AL. V. SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT, ET AL.

Court: United States Court of Appeals for the Ninth Circuit

Filed: 2026-07-02

Docket: 2:24-cv-10482-

The Ninth Circuit affirmed the district court’s grant of summary judgment to the South Coast Air Quality Management District (SCAQMD), holding that the Energy Policy and Conservation Act (EPCA) does not preempt SCAQMD’s amended Rule 1146.2, which phases in zero nitrous oxide (NOx) emissions standards for certain gas-fired appliances. The court applied a de novo standard of review to the preemption claim, analyzing the text, structure, and legislative history of EPCA to determine congressional intent. The panel concluded that EPCA was enacted to establish uniform national energy efficiency standards and prevent a patchwork of state regulations regarding “energy use” and “energy efficiency,” not to interfere with states’ ability to regulate emissions under the Clean Air Act (CAA) to achieve federal air quality standards. The court found no evidence in EPCA’s text or history indicating Congress intended to preempt CAA-based emissions regulations, noting that the EPA has routinely approved such state rules as part of State Implementation Plans. The court distinguished its prior decision in *California Restaurant Ass’n v. City of Berkeley*, clarifying that *CRA* was a “very narrow” ruling concerning building codes that physically blocked gas infrastructure, rather than a broad prohibition on all regulations affecting appliance use. The panel further held that the plaintiffs’ facial challenge failed because Rule 1146.2 regulates “process heaters,” which are not “covered products” under EPCA and for which the Department of Energy has not issued federal energy conservation standards; therefore, the rule is not unconstitutional in every application. As a practical consequence, SCAQMD’s zero-NOx emissions rule remains enforceable, allowing the District to continue its efforts to bring the South Coast Air Basin into compliance with federal ozone standards under the CAA without interference from EPCA preemption claims.

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