National Association of Home Builders of the United States v. District of Columbia

CourtDistrict Court, District of Columbia
DecidedMarch 26, 2026
DocketCivil Action No. 2024-2942
StatusPublished

This text of National Association of Home Builders of the United States v. District of Columbia (National Association of Home Builders of the United States v. District of Columbia) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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National Association of Home Builders of the United States v. District of Columbia, (D.D.C. 2026).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

NATIONAL ASSOCIATION OF HOME BUILDERS OF THE UNITED STATES, et al.,

Plaintiffs, Case No. 24-cv-02942 (ACR)

v.

DISTRICT OF COLUMBIA,

Defendant.

MEMORANDUM OPINION AND ORDER

The Energy Policy and Conservation Act of 1975 (EPCA) prohibits state and local

regulations “concerning the energy efficiency [or] energy use” of certain products, including gas

appliances. See 42 U.S.C. § 6297(c). The Clean Energy D.C. Building Code Amendment Act of

2022 (Clean Buildings Act) requires that by 2027, certain newly constructed or improved

buildings in Washington, D.C., operate as zero-energy—essentially, they must produce as much

energy as they consume. To achieve this, it bans the use of gas appliances in those buildings.

The question: does the former preempt the latter? Plaintiffs—an assortment of trade

associations, companies, and unions—say yes. The ban, they argue, de facto sets gas appliances’

energy efficiency or use standard to zero, which conflicts with EPCA’s preemption provision.

The District of Columbia responds that the ban does not address such standards at all. Yes, it

mandates that gas appliances cannot be used in certain buildings. But it says nothing about the

performance standards the appliances must meet when used elsewhere.

1 The District has the better interpretation. The Court therefore GRANTS the District’s

Cross-Motion for Summary Judgment, Dkt. 30, and DENIES Plaintiffs’ Motion for Summary

Judgment, Declaratory Relief, and Permanent Injunction, Dkt. 26.

I. BACKGROUND

A. The Oil Embargo of 19731

While it is difficult to pinpoint the origin story of any litigation, we might as well start

ours on October 17, 1973. That day, President Richard M. Nixon expressed concern that the

Arab–Israeli War might cause gas prices to rise. Given our country’s dependence on foreign oil

then, he feared this would cause economic upheaval at home.2 And he was right to worry. On

that same day, halfway across the world, Arab oil ministers decided to impose a total oil embargo

on the United States and other countries aiding Israel.3 As intended, this ban “sent shock

radiating through the social fabric of . . . industrial nations.”4 In the United States, gas prices

skyrocketed, supplies plummeted, unemployment increased, and the economy teetered.5

Oil was not the President’s only problem. Throughout 1973, the Watergate scandal was

splashed daily in newspaper headlines across the Nation.6 And it seemed that “the President was

1 For those interested in a “panoramic history of the world’s most important resource: oil,” including the 1973 oil crisis, the Court commends Daniel Yergin, The Prize: The Epic Quest for Oil, Money & Power (1990). 2 Id. at 588–91. 3 Id. 4 Id. at 597. Coincidentally, as the Court publishes this Memorandum Opinion, the world economy is facing potentially its largest oil shock. Due to a conflict in the Middle East. See Emmett Lindner, Echoes of the ’70s in What’s Now the Largest Oil Shock Ever, N.Y. Times (Mar. 13, 2026). 5 H.R. Rep. No. 94-340, at 20–22 (1975). 6 Yergin at 601. For more on that scandal and recommended readings, see Storch v. Hegseth, 804 F. Supp. 3d 216, 219–21 & n.1 (D.D.C. 2025).

2 always searching for some political ‘spectacular’ involving oil and the Middle East to try to

divert the country from its obsession with Watergate.”7 Because of the embargo, Watergate, or

both, on November 7, 1973, President Nixon announced Project Independence: “in the spirit of

Apollo, with the determination of the Manhattan Project, . . . by the end of this decade we will

have developed the potential to meet our own energy needs without depending on any foreign

energy source.”8 And afterward, his administration continued to announce various energy

actions.

But neither the announcements nor the energy actions succeeded. President Nixon was

forced to resign in August 1974. And our dependence on products that used petroleum increased

from 33 percent in September 1973 to 36 percent in December 1974.9

B. The Energy Policy and Conservation Act of 1975

The oil embargo ended on March 18, 1974. But the crisis had awakened the United

States to the “serious long-term economic and national security problems” of continued

dependence on foreign oil. Nat. Res. Def. Council, Inc. v. Herrington, 768 F.2d 1355, 1364

(D.C. Cir. 1985). So in January 1975, President Gerald R. Ford called for “the strongest and

most far-reaching energy conservation program we have ever had.” Id. Congress answered him

by passing EPCA that same year. See EPCA, Pub. L. No. 94-163, 89 Stat. 871 (1975). Relevant

here, EPCA aimed to “reduce domestic energy consumption through the operation of specific

voluntary and mandatory energy conservation programs.” Herrington, 768 F.2d at 1364 (citing

S. Rep. No. 94–516, at 116–17 (1975)).

7 Yergin at 601. 8 Id. at 599. 9 H.R. Rep. No. 94-340, at 20.

3 At enactment, EPCA required the Department of Energy “to mandate energy efficiency

labeling of major residential appliances and to prescribe voluntary industry appliance efficiency

improvements.” S. Rep. No. 100-6, at 3 (1987); see EPCA §§ 324–326. It also “authorized, but

did not require, DOE to establish mandatory efficiency standards if necessary.” S. Rep. No. 100-

6, at 3.

But DOE was slow on the uptake. It did not set standards expeditiously or, in some

cases, at all. See H.R. Rep. No. 95-496, at 43–46 (1977). So three years later, Congress

amended EPCA to mandate minimum energy efficiency standards for appliances that consume

substantial energy, such as kitchen ranges, ovens, refrigerators, and dishwashers. See National

Energy Conservation Policy Act (NECPA), Pub. L. No. 95-619, § 422, 92 Stat. 3206, 3259–62

(1978); Herrington, 768 F.2d at 1362 & n.1. Congress sought product designs that “achieve the

maximum improvement in energy efficiency which the [DOE] Secretary determines is

technologically feasible and economically justified.” S. Rep. No. 100-6, at 3. It added, however,

a waiver provision that DOE began granting as a matter of course. See infra pp. 9–10.

In 1987, again attempting to ensure uniformity, Congress amended EPCA to clamp down

on the waivers and bolster EPCA’s preemption provision. S. Rep. No. 100-6, at 4–5; National

Appliance Energy Conservation Act of 1987 (NAECA), Pub. L. No. 100-12 § 5, 101 Stat. 103,

107–17 (codified as amended at 42 U.S.C. § 6295). If an energy conservation standard exists for

a covered product,10 EPCA preemption now provides that “no State regulation concerning the

10 The statute identifies specific covered products and provides that the Secretary “may classify” certain other consumer products as covered products if the Secretary makes certain findings. See 42 U.S.C. § 6292(a), (b)(1).

4 energy efficiency [or] energy use . . . of such covered product shall be effective with respect to

such product.” 42 U.S.C. § 6297(c).11

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