This requirement is on hold. We have an updated story from November 2021 here.
The Contractor State Licensing Board (CSLB) voted 11-3 on July 28 to restrict and impede the lawful trade of 80% of California’s licensed solar contractors to continue installing solar and energy storage systems. This vote comes despite the board’s 40-year history of extensive testing as well as providing written permission for C-46 solar specialty contractors to install solar and energy storage systems and in the absence of identified incidents involving contractor error.
The CSLB ruled that the C-10 license is the only specialty license eligible to install solar and energy storage systems. Unlike previous votes, this decision bypasses regulatory review and therefore goes into effect after 90 days.
In 90 days, the C-46 license holder will no longer be allowed to install a solar and energy storage system in the state of California. Only 22% of the solar and storage installations in the past five years were done by contractors holding only a C-10 license. The majority are being installed by contractors who hold a C-46, with and without other licenses.
Any contractor who holds a C-10 license must adhere to strict workforce hiring requirements: California rules require C-10 contractors to hire only Certified Electricians and registered electrical trainees on a one-to-one basis to perform all of their installation work. Failing to do so will risk having your license revoked.
Contractors who hold a General A and/or General B license may continue to install solar and storage systems so long as the work falls within the legal classifications of those two licenses. Only an act of the state legislature can modify those two licenses.
This decision goes into effect regardless of system size, customer type or technology. It applies to all energy storage systems, whether paired with solar PV or not.
Contractors holding a C-46 license may continue to install solar PV systems that are not paired with energy storage, but there’s an important wrinkle. The July 28 decision was based on a letter from the CSLB head registrar David Fogt to the UC Berkeley Labor Center on April 21, 2021. In that letter, Fogt states that all work performed by a contractor holding a C-10 license, regardless of the other licenses the contractor might also hold, must be done by Certified Electricians per state law. This determination, if correctly interpreted, could impact all solar PV installations, not just solar and storage projects. It could also impact several other trades such as HVAC. Such a deviation from common practice would greatly impact California’s move toward clean energy and building electrification.
According to the report upon which this decision was made, the CSLB has defined the scope of work of electrical contractors as, “An electrical contractor places, erects or connects any electrical wires, fixtures, appliances, raceways conduits, solar photovoltaic cells or any part thereof, which generate, transmit, transform or utilize electrical energy in any form or for any purpose.”
A question for all contractors who hold a C-10, whether you employ Certified Electricians or not: What percentage of your crew must be a Certified Electrician or registered apprentice on a one-to-one basis for both your solar and your solar and storage projects. How does the state define “place” or “erect” an electrical appliance?
The California Solar & Storage Association (CALSSA) is seeking clarification on the issues listed above as well as exploring legal options for challenging this underground regulation.
News item from CALSSA
Hi. I hired SunPower and they disregarded SCE minimum service requirements for the overhead service installation (200a) in Santa Clarita CA. In Feb. 2022. It turns out that the electrical contractor hired by SunPower did not have one electrical installer with CA general electrician certification. When I asked for the ID of guy who is coming to do the repair work yesterday for original problems SunPower refused to supply info. They are trying to send the guy without certification back and want me to not interfere. It turns out that when I told SunPower they needed to supply ID to do work at my house they refused to comply or give any info and refused repairs indicating I was refusing access? I have an email from SunPower stating that the sub does not have CA general journeyman certifications (they admit it). It is safe to say SunPower electricians have no certification on any residential projects. Their lack of knowledge is still on exhibit at my home. It’s July and this is still going on. My understanding is that someone would have to be hurt before the law is enforced. SunPower is from Texas.
Any updates on this? Will a C46 be able to do any work in the main panel on the Utility side?
The latest: https://www.solarpowerworldonline.com/2021/10/californias-c-10-solar-storage-licensing-requirement-on-hold-for-at-least-a-year/
Thank-you Kelly! Really appreciate the update!
As a potential customer for a PV installation + storage battery what is my responsibility when looking for an installer? Do I need to demand in the contract that C-10 and perhaps C-46 workers be the ones doing any and all electrical work? Will the county building department vet the business during the permit application process? Or will the building inspector cry bloody murder – and threaten to halt or void the work after it’s has already started and I’m in for a pretty penny?
Forgot to mention I’m in California and PG&E is my electrical utility, just for context. Thx
I hold a C-53 license, pool builder, and I am allowed to to electrical work. Before my C-53 license I held a D-35 license and I could do electrical work. This is another example of California sucking up to the unions. How do we fight this? If David R. Fogt is responsible for this dumb decision he/they should be fired.
I strongly suspect that the greedy power companies who want to sell more electricity to make more $$$$ are behind this. It’s not enough that Rule 21 can let the power companies dictate how much power your inverter can put out.
Looks like the only logical thing to do is to fight this someway or another.
Nabcep installer certification was created to insure safe installation of solar modules, 90% of the work is roofing work , the best trading a tech can get. Legislature needs to negate this criminal rule. Union protectionism corrupting the licensing board again . Fed osha needs to step in standardize the safety training and adherence to NEC code . nabcep trying program at Santa Monica City college does this well and grid alternatives does the adequate practical hands on internship , 4 years of pulling romlex does nothing to insure the roof integrity and proper spacing clearance for fire protection.
Awesome. I know a few solar companies that have 0 certified electricians on staff doing electrical work. The state has yet to crack down on them
I’ve been a solar contractor for 42 years – a C-46 for 16 Years. I was one of the early solar pioneers that help build this industry from the very beginning. I obtained a solar engineering degree in 1979 – the first offered in the country. I have over my career installed over 300 off-grid battery based systems and scores of grid-tie systems with battery backup. I’ve also installed over 250 Grid-tied systems and consulted on 5 MW solar plants etc. I was there in Massachusetts when the unions tried to push out the original solar companies – I couldn’t afford to wait the two years it took for the state legislature to fight that one off – so I came back to California. I teach C-10s how to do solar – but now I am faced with being forced out of business – what a slap in the face for my 42 years of service in the industry – I provided input in the early 90’s to the authoring process for NEC 690. I’ve been beta-tester for several inverter and battery companies. I’m recognized by my peers in terms of my contribution to the industry – but now you push me out – what a gross injustice. Along the way I could see the industry was headed this way – so I looked into becoming a C-10 only to find I would have to pull romex through walls for 4 years to prove enough hours to become a C-10. I have worked with many C-10s who have no clue about solar and many C-46s who are leaders. This is a sad day for the solar industry – what a way to thank us founder/pioneers.
“In 90 days, the C-46 license holder will no longer be allowed to install a solar and energy storage system in the state of California. Only 22% of the solar and storage installations in the past five years were done by contractors holding only a C-10 license. The majority are being installed by contractors who hold a C-46, with and without other licenses.”
This smells of the “attempt” to do the same thing about 10 years ago in Massachusetts of requiring all solar PV installations to be done by one licensed electrician “journeyman” and one electrician “apprentice”. This was wholly pushed by the local IBEW Union and was finally NOT allowed to happen by the State Legislature. There is NABCEP 10 years old and growing to maintain technical competence in solar PV installations and SEIA should be involved up to their eyeballs in stopping this from happening.
This guy David R. Fogt has been in the “game” for a while now. I believe he’s pushing and overstepping his boundaries and something smells real bad about this whole thing. Earlier this year “someone” found a Democrat Legislator to back AB1139 that died in committee that would have put the brakes on solar PV and energy storage adoption in California. Now we are getting the CSLB President pushing Union “singularity” in the installation and commissioning of solar PV and energy storage apparently in ‘all’ of California. IF left intact, this would be a good way to step on mandated decarbonization and claims that economies of scale will bring down solar PV costs and allow more installations.
The final fall back is the California AG investigating CSLB under the RICO statutes for impropriety to push this edict through without proper input by solar PV businesses and stakeholders. It seems like there is some large piles of “dark money” finding well placed “allies” in Government and regulatory agencies that have found some “sock puppets” to do the dirty work in front of the “curtain” while the “man behind the curtain” is safely hidden from plain sight. Some folks put their “belief systems on solar PV” in the “deflated costs of solar PV” basket. Sighting ‘wholesale’ energy costs below any solar PV incentives.
All this is, is the attempt to keep the IOU electric utility coddled “regulated monopoly” status with “assured” returns on investments that are stacked on the “backs” of the retail electricity ratepayers in a retail market that would NOT enjoy lower costs even IF the wholesale energy market was pushed down to $1/MWh of wholesale generation. In the retail market, with or without subsidies, folks that pay it forward are getting a pay back on their systems in 10 years or less. Current and proposed rules and regulations are pushing the (retail) electricity market to install solar PV, plus smart energy storage and home EV charging station(s), in those cases, it seems one can pay for their system in 5 years on monthly energy savings alone.
It’s well overdue for the EaaS, a digitized grid with bi-directional energy market and fair and “unbiased” compensation for those who pay it forward and buy their own systems to take care of their daily energy requirements. Basically since the WTO complaints of China’s practices of solar PV panel dumping on the market back in 2007 to around 2010 and the tariffs on “some” foreign goods, has dialed up the cost of solar PV above what it “once” was. Yet one can find unsubsidized solar PV systems for the residential sector at a little less than $3/watt installed today, when back in 2005 retail without subsidies was around $8.45/watt installed. It’s the utility bias of these “studies” one gets to read about, not the other end of the cost pipeline where folks who buy their own systems can pay for their energy and stop rate hikes and commodity cost surges.
So as a C-46 contractor, I am still allowed to install solar PV not storage media. Is that correct?
Hi James, according to CALSSA — “contractors holding a C-46 license may continue to install solar PV systems that are not paired with energy storage, but there’s an important wrinkle. The July 28 decision was based on a letter from the CSLB head registrar David Fogt to the UC Berkeley Labor Center on April 21, 2021. In that letter, Fogt states that all work performed by a contractor holding a C-10 license, regardless of the other licenses the contractor might also hold, must be done by Certified Electricians per state law. This determination, if correctly interpreted, could impact all solar PV installations, not just solar and storage projects.”
Hi Kelsey, Might be a good time to circle back around this. with what is fact and what is fiction..
lots of talk in the environment about electricians needing to have a 1:1 ratio on the jobside with other crew members.
Have there been any significant clarifications and decisions here?