CSLB Vote Threatens California’s Solar Industry
When the Legislative Committee of California’s Contractor State License Board (CSLB) voted to begin the process of restricting the installation of solar+storage and other energy storage systems to C-10 licensed electricians, it put an entire industry and our economic future at risk.
As California manufacturers of clean energy storage technology that has participated in the exponential growth of the renewable energy in our state since 2010, we are stunned by the CSLB vote and fear the negative impact it would have on the renewable energy and storage industry for all Californians.
A Solid Track Record
Currently, state regulations allow solar contractors (who hold C-46 licenses) to install battery energy storage systems when they are installing solar photovoltaic projects. However, only electrical contractors (who hold C-10 licenses) are permitted to install energy storage systems without solar in existing buildings.
This model has worked exceptionally well. With nearly a million PV and energy storage systems installed, C-46 contractors have built California’s solar industry.
We have had the pleasure of working with both C-46 and C-10 contractor partners since our company was founded. C-46 contractors do their work as safely as C-10 contractors and both groups are subject to the same engineering, permitting and inspections. Of course, as a manufacturer, we have never relied exclusively on regulators to ensure our contractor partners know what they are doing — we consider it our responsibility too. We back our batteries with warranties and would never let an incompetent installer deploy them in the field. Both C-46 and C-10 license-holders have consistently and reliability installed our systems safely, efficiently, effectively and in compliance with all codes and standards. We have always found C-46 contractors to be knowledgeable, reliable, skilled and properly trained.
Even then-Governor Jerry Brown trusted a C-46 contractor to install his solar+SimpliPhi storage microgrid at his off-grid home at Rancho Venada — and it works perfectly.
Now, it seems that politics are unnecessarily undermining people’s livelihoods and the California economy.
Representatives of the three investor-owned utilities, the Coalition of Utility Employees and their IBEW union, and a handful of large electrical contractors pressured the CSLB to change existing rules and limit or prevent C-46 solar contractors from continuing to install behind-the-meter solar paired with battery storage. They alleged it was a safety issue. However, they failed to provide any credible evidence that there are problems with solar contractors currently (or historically) doing this work. In fact, based on SimpliPhi’s extensive experience and industry data statewide since 2010, there isn’t any evidence that the public’s health, safety or any other legitimate public interest issue is in jeopardy such that the installation of solar and energy storage needs to be restricted to C-10 license holders.
In fact, as Vote Solar reported, “many solar installers [who spoke at the hearing] pointed out that they have been connecting PV systems to homes and commercial buildings for decades without any problems. In response, an electrical workers’ attorney argued that the CSLB did not need any evidence that there has been a problem with the current practice of installing solar or solar plus storage. Instead, he argued the CSLB could take a ‘precautionary’ action to prohibit solar contractors from installing solar plus storage based on the potential for harm.”
The CSLB should recognize that taking “precautionary” action without evidence of any existing problem is not sufficient grounds for locking out the C-46 contractors who have been crucial to California’s economic growth, innovation and renewable energy goals.
The CSLB and our elected officials should reject this unjustified power grab, which runs counter to the public interest.
California Needs More Energy Storage Installers, Not Fewer
California’s economy is dependent on small businesses, and clean energy has been one of the most vital job creators. This change in policy would destroy thousands of small businesses and in doing so, threaten our economic growth, security and innovation. In fact, it’s already begun to happen.
Since the CSLB vote on August 8, we have spoken with some of the most successful C-46 solar contractors in the state. They are already making plans to leave the renewable energy industry or leave the state and take their businesses elsewhere.
With demand for photovoltaics and energy storage ramping up dramatically, it has never been more important that we maintain or increase the number of qualified installers – not arbitrarily and severely reduce them. We need both C-10 and C-46 contractors to be actively engaged in solar+storage deployment.
If allowed to stand, the CSLB’s vote will leave us with a far smaller pool of installers in the face of growing demand. That would drive up costs and discourage consumers from adopting renewables and generating and storing their own electricity. This will both derail the progress California has made toward clean energy adoption and diminish our global leadership in the fight against climate change.
We’re Not Done Fighting
The CSLB vote does not signal an immediate change to existing laws, but rather the beginning of a two- to three-year process during which new regulations will be defined. The starting point is an intent to limit the ability of C-46 contractors to install any PV system greater than 10kW on a single-family dwelling or duplex and or energy storage systems exceeding a 5kW backup/20kWh energy. More than 70% of commercial PV systems in California are larger than 10kW. This suggested cap is arbitrary and represents protectionist practices that effectively create a monopoly for one class of licence holders over another. That protectionism runs counter to the spirit of innovation that our policy makers and laws aim to foster.
Rather than limit installations to only C-10 solar contractors, why not look more closely at the differences between C-10 and C-46 license requirements and — if anyone provides evidence that either C-10 or C-46 requirements are not sufficient — make amendments to both sets of requirements and build a more robust skill set across both licenses. There is no need to marginalize an entire class of experienced license holders without due cause, particularly since C-46 installers have so successfully driven the distributed energy storage and solar industry.
CSLB staff has been tasked with conducting further investigation to define what requirements or limitations would be appropriate, if any. As a member of the California Solar and Storage Association, SimpliPhi stands with CALSSA, Vote Solar and other organizations bringing sanity, actionable data and expertise to this discussion.
We all want to protect the integrity and stability of our industry and the benefits it has and could continue to bring to our state — if we don’t burden it with unnecessary and protectionist restrictions. Those benefits include economic growth, carbon offset, energy access, power security and safety for every person and business in California.