SBE News

GSBE Weekly Update 03/21/2018

Fight Brewing Between Electrical C-10s and C-46s

At a recent meeting of the CSLB, industry representatives engaged in a fight with C-46 solar contractors over who may be permitted to install the storage systems typically associated with new PV installations. For comparison, there are 1,146 C46 contractors in California and 24,711 C10s.


GSBE Golden State Builders ExchangesCurrent Solar Trends: A Statistical Analysis

CSLB staff conducted an analysis of 792 solar-related complaints received at CSLB between January 1, 2017, and December 31, 2017. Of these complaints, 136 were successfully settled, resulting in over $844,000 in restitution to injured parties, and 24 were recommended for further disciplinary action, including two criminal cases. There was an 83% increase in the number of solar complaints filed with CSLB in 2017 as compared to 2016; 43% of these complaints were filed against 33 contractors. Further analysis revealed that 10 of these 33 contractors held the C-46 (Solar) classification as part of their licensure. The remaining 23 contractors held the following classifications: “B” General Building (11), C-10 Electrical (7), “B”/C-10 (3), and C-39 Roofing (2). The majority (57%) of consumer-filed complaints alleged misrepresentation of contract terms and solar panel system production, poor workmanship or abandonment, and most include a Home Improvement Salesperson registration and home improvement contract violations.


CSLB established a Solar Task Force dedicated to working with the industry to reduce consumer solar complaints referred to CSLB Investigation Centers by 50% by June 2018. From January 2017 to December 2017, CSLB received an average of 66 solar complaints per month. And CSLB staff is working with the Public Utilities Commission (PUC) to implement the provisions of AB 1070 (Gonzalez Fletcher) that amended BCP §7169 so that, by July 1, 2018, solar disclosure language must be included on the face of every solar contract.


Over the last year, CSLB staff has met with representatives of electrical contractors to discuss their concerns about which classifications are authorized to install energy storage systems (ESS) which store electricity obtained when power is not being used, or during “off-peak times.” These systems consist of foundations; battery containers set on helical piers and transformers set on concrete pads. Industry representatives raised concerns about whether or not contractors holding the C-46 license should continue to be able to install when it is paired with a solar system. Their arguments follow:

  • Energy storage systems are an evolving technology and CSLB staff’s interpretation of the C-46 (Solar) regulation is no longer correct. C-46 contractors should not be permitted to contract for or install energy storage systems (when paired with a solar system), because these systems are independent of the solar system itself and the C-46 regulation prohibits C-46 contractors from performing trades or crafts except when required to install a solar system.
  • Energy storage systems pose significant risks and hazards to installers, occupants, utility workers and emergency personnel. A system that is not properly installed could cause serious public safety hazards, including explosion, electrocution, arc flashes, arc blasts, and fires caused by shorting of a thermal runaway of a battery storage system.
  • They further note that because C-46 contractors are not authorized to install energy storage systems when they are not paired with a solar system, they should not be able to install them at all.

In response to various industry inquiries, CSLB staff determined that a C-10 classification is the most appropriate classification authorized to install a stand-alone electrical system. In addition to the C-10 classification, CSLB staff has authorized the following classifications to install an ESS, when it is included as part of the installation of a solar system:

  • An “A” (General Engineering) contractor, if the installation requires specialized engineering;
  • A “B” (General Building) contractor, if the installation is in connection to a structure and it involves two or more unrelated trades; and
  • A C-46 (Solar), if the installation is in connection with the installation of a photovoltaic system.


Existing Classifications

According to the California Code of Regulations, Title 16, division 8, section 832.10, the C-10 contractor places, installs, erects or connects any electrical wires, fixtures, appliances, apparatus, raceways, conduits, solar photovoltaic cells or any part thereof, which generate, transmit, transform, or utilize electrical energy in any form or for any purpose.

According to the California Code of Regulations, Title 16, division 8, section 832.46, the C-46 contractor installs, modifies, maintains, and repairs thermal and photovoltaic solar energy systems. A licensee classified in this section shall not undertake or perform building or construction trades, crafts, or skills, except when required to install a thermal or photovoltaic solar energy system.



The exams for both the C-10 (Electrical) and C-46 (Solar) include questions on energy storage systems. The C-46 exam covers the topic more extensively than does the C-10 exam, and every version of the C-46 exam contains questions on the topic, though not every version of the C-10 exam does.


CSLB’s Testing division conducts an occupational analysis for each classification every five to seven years. The most recent C-46 occupational analysis was completed in 2017; the C-10 occupational analysis is currently in process.


CSLB asked the committee to direct staff to conduct public meeting(s) to determine if the “A” (General Engineering), “B” (General Building), C-4 (Boiler, Hot-Water Heating and Steam Fitting), C-10 (Electrical), C-20 (Warm-Air Heating, Ventilating and Air Conditioning), C-36 (Plumbing), C-46 (Solar), and C-53 (Swimming Pool) classifications should be precluded from installing an energy storage system in a standalone contract or when included in the installation of a solar system. After the public/work group meetings conclude, staff would report any findings to the full Board to determine if policy, regulatory, or statutory changes were needed.


At this point the staff attorney for CSLB pointed out that taking the action of revoking the staff opinion that C46 could install ESS might be controversial and deserve more study. But Schetter and Simpson insisted on moving ahead. NECA testified in favor and several C46 who were at the meeting voiced strong objections. WECA’s representative suggested (inasmuch as the WECA Government Affairs Committee hadn’t taken a position) that the staff recommendation to “study the appropriate qualifications for installing ESS” was probably the prudent course.


The vote ended up 3-4 against with Committee Chair Ed Lang, and members Pastor Herrera, Jr. Marlo Richardson and Nancy Springer voting no.


But in reality–the last word will probably be in August when the Legislature adjourns.