California is the United States' number one market for solar energy production. California alone produces more than 28 million MWh of solar energy annually accounting for 30% of all PV energy produced in the country. With the state’s leading role in the US, new regulations and changes to how installers must operate should be closely monitored as they could have a reverberating impact across the country. The most recent update for California's solar industry is about a regulation implemented by the California State License Board (CSLB). The regulation requires C-46 Solar Contractors to obtain an electrician’s license by November 1, 2021, to continue installing solar panels and storage. This would eliminate the opportunity for the majority of solar installers to complete the work that they are currently doing. In response, the California Solar and Storage Association (CALSSA) felt this regulation was illegitimate and sued the CSLB.
Licensing Regulations
The current regulations support California solar contractors that hold a C-46 license by enabling the installation of solar panels along with battery storage systems. The CSLB interpretations of state Labor Code also adds to the restrictions requiring solar contractors to employ Certified Electricians as well. The ruling passed on July 27, 2021, as the CSLB pushed for C-46 contractors to receive an electrician's license (C-10) by November 1, 2021. However, obtaining a C-10 license takes a significant amount of time.
Additionally, those contractors who already possess a C-46 license would need to receive a certified electricians license from the CSLB. This requires applying to be an electrician trainee and completing a minimum of 720 in-class hours from an accredited trade school or apprenticeship program. You must also receive a minimum of 8,000 hours of on-the-job training, which on average takes 4 years. Once the soon-to-be electrician has completed these requirements, one can apply to take the CSLB test, which includes three parts. Once passed, then an elections license is acquired.
Effects of Regulation:
The CSLB’s ruling makes it nearly impossible to obtain an electrician's license in a few months, and C-46 contractors already underwent intensive training to obtain their C-46 license. For instance, to earn a C-46 license one must undergo four years of journeyman experience and pass a test made up of two parts from the CSLB. CALSSA deemed the ruling as unlawful and sued the CSLB as it impacts nearly all solar contractors causing major disruptions for the solar industry and installers’ businesses.
Lawsuit Status:
CALSSA and the CSLB are working together to resolve the stipulations outside of court; removing the ruling until resolved. Therefore, all enforcement of the policy is being suspended at this current juncture. Allowing C-46 contractors to continue installing solar and storage systems in California now and after November 1, 2021. While these licensing regulations were only affecting California, it is unclear if other states will soon follow suit and require solar contractors to become certified electricians before being able to install solar modules and batteries; or seek to implement the future agreed upon regulations by both CALSSA and the CSLB.
It is a big win to have the CSLB remove the ruling while working with CALSSA. But this is not the end since no final conclusion has been determined. The litigation did, however, put restrictions in place for new license requirements. Looking ahead, the CSLB's regulations must adhere to the Administrative Procedures Act (APA). This process can take up to 18 months before going into effect, must be based on fact, be clear, consistent, and consider economic impacts. CALSSA is a defender against harmful policies for the solar industry. Using its litigation expertise, it can limit the threat for major disruptions in the industry by helping to ensure that all new regulations are beneficial to installers and the solar industry at large. To take part in the important work happening to support the solar industry in California, sign up to become a member of CALSSA today.