Air Conditioning, Heating and Refrigeration Institute v. City of Albuquerque

2008 WL 5586316 (2008)

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Air Conditioning, Heating and Refrigeration Institute v. City of Albuquerque

United States District Court for the District of New Mexico
2008 WL 5586316 (2008)

Facts

The Energy Policy and Conservation Act (EPCA), as amended by the National Appliance Energy Conservation Act (NAECA) and the Energy Policy Act of 1992 (EPACT), was a federal statute that established nationwide energy-efficiency standards for commercial appliances, water heaters, and other products, including heating, ventilating, and air-conditioning (HVAC) equipment. EPCA contained a preemption provision that prohibited states and localities from enacting laws, regulations, or other requirements “concerning” the energy efficiency, energy usage, or water usage of products covered under EPCA. EPCA’s preemption provision included exceptions to preemption for building codes relating to new construction if certain requirements were met. EPACT incorporated EPCA’s preemption provision. In 2007, the mayor of Albuquerque, New Mexico (the city) (defendant), formed a task force to examine the city’s building regulations and propose changes to reduce carbon-dioxide and greenhouse-gas emissions. The city’s green building manager took the task force’s recommendations and drafted the Albuquerque Energy Conservation Code (the code). Volume I of the code applied to new construction of, alterations of, and additions to commercial and multifamily residential buildings. Paths to compliance included (1) achieving a silver-level Leadership in Energy and Environmental Design (LEED) certification, (2) meeting performance-based requirements, or (3) improving energy efficiency by 30 percent. Volume II of the code applied to new construction and renovation of one- and two-family detached dwellings and townhouses. Paths to compliance included (1) silver-level LEED certification, (2) 30-percent energy-efficiency improvement, (3) performance-based options that required building owners to meet certain construction-quality requirements even if federally compliant products were used, and (4) a prescriptive option that required meeting energy-efficiency standards for HVAC equipment and water heaters that exceeded federal standards. The city also adopted a High-Performance Buildings Ordinance (the ordinance), which required compliance with the code. The Air Conditioning, Heating, and Refrigeration Institute, HVAC distributors, and others (collectively, the institute) (plaintiffs) sued the city, seeking injunctive relief to prevent enforcement of the code. The institute asserted that certain sections of the code were preempted by EPCA and EPACT. The evidence before the court suggested that the requirements for a preemption exemption were not satisfied. In considering whether the institute was entitled to a preliminary injunction, the court considered the likelihood of success on the merits of the preemption claim.

Rule of Law

Issue

Holding and Reasoning (Vázquez, C.J.)

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