What are the implications of the federal federal preemption rule on the exhaustion doctrine?

Indeed the preeminent policies underlying the judicially-created exhaustion doctrine are identical to the policies underlying the federal preemption rule. In Abelleira v. District Court of Appeal (1941) 17 Cal.2d 280, 293, 109 P.2d 942, the court described the purpose of the exhaustion doctrine: "The courts have repeatedly recognized the necessity of placing the numerous and complex problems arising under statutes of the type involved herein in the hands of expert bodies, familiar with the subject matter through long experience. They have pointed out that to permit the initial consideration of these matters by the courts would not only preclude the efficient operation of the acts, but would overwhelm the courts with cases of a technical, specialized character, and seriously impair their capacity to handle their normal work." (17 Cal.2d at p. 306, 109 P.2d 942.)