California solar contractors must be aware of new licensing, consumer protection rulings
The solar industry is arguably more regulated than any other home improvement industry because it is connected to the grid – and subject to utility processes and pushback. California solar installers should pay close attention to two recent bureaucratic rulings that could affect their ability to operate normally.
New customer paperwork required
In 2019, the California Public Utilities Commission developed a guide that solar installers should give to potential customers in investor-owned territories (IOU) explaining everything they “need to know” before investing in solar, the so-called California Solar Consumer Protection Guide. The California Solar & Storage Association (CALSSA) got involved as soon as possible to revise some of the pamphlet’s initial alarming language, said Josh Buswell-Charkow, CALSSA’s deputy director.
While contractors have been technically required to submit signed consumer guides since 2019, there were no consequences for non-compliance until this year. If the IOUs determine that contractors do not upload completed, signed documents, they will be added to a public list of non-compliant installers for that quarter and a subsequent quarter, Buswell-Charkow said. In addition, the IOUs will manually audit the interconnection applications of non-compliant installers during their semi-annual spot checks. In California, residential interconnection applications are usually assessed by IOUs almost immediately.
“As contractors know, time is of the essence here. It’s not a good thing if the IOUs literally search your interconnection application to make sure you’ve done everything correctly,” said Buswell-Charkow. “The advice we’re giving people with this guide is to make sure you meet all requirements as long as you administer them correctly and have good systems in place so you don’t have to deal with unintended consequences for non-compliance. ”
The guide begins with large text in an orange box with an exclamation mark next to it: “SOLAR FACILITATION ON YOUR HOME IS AN IMPORTANT FINANCIAL DECISION. DO NOT SIGN A CONTRACT BEFORE READING THIS DOCUMENT!”
It continues with sections titled “Beware of False Claims”, “Know Your Rights” and 10 additional chapters.
“I can certainly tell you that if CALSSA had the pen, there are some that we would emphasize less, and there are other things that we would probably emphasize more. The guide frame would definitely be different,” said Buswell-Charkow “On the other hand, we also think that there is useful information in this guide, and in general we think that information is a good thing and we certainly believe that consumers should know what they are getting into before they decide to install solar. .”
Adam Rizzo, partner at Escondido’s Palomar Solar & Roofing, thinks the guide is a good tool for consumers to navigate the crowded solar market, and that it should have been published 10 years ago.
“This is exactly how we’ve built our excellent reputation over the past 11 years — teaching people how to do their research. We’ve been training our potential customers this way since we started,” Rizzo said in an email.
He thinks the guide points out some key factors customers should research with a contractor, including how long a company has been in business, what tasks they outsource, and how they say solar system monitoring will work.
Palomar Solar sellers email the guide to potential customers before they even sit down with them for their first meeting. Sometimes clients have already met a handful of contractors but hadn’t seen the guide until their meeting with Palomar, indicating that some solar companies could be in trouble if they’re audited for filing documents, Rizzo said.
Jeff Parr, CEO of San Ramon-based installer Solar Technologies, agrees it’s good for the industry if consumers are better informed. He believes that some solar companies do not operate ethically, but he sees backdoor efforts at play with the guide.
“I think it’s safe to say that what we saw was the opposition to distributed energy sources and to rooftop solar that those bad actors and an extremely small percentage of installations and solar customers were using as leverage points to try put some obstacles between us and make progress in this industry,” said Parr.
Parr is not against the guide in general, but he has a problem with the tone.
“It was mainly drafted by the interests of the utility companies, which made it sound like anyone going solar was going to be screwed,” he said.
New licensing requirements for solar and storage installers
While the consequences of an unsigned consumer protection guide are a simpler paperwork problem, a new Contractor State Licensing Board (CSLB) ruling could create more complex problems for some California installers.
The board recently ruled that a C-46 permit is no longer eligible to install solar + storage systems in the state. According to Bernadette Del Chiaro, CEO of CALSSA, the ruling ensures that any person involved in a solar + storage installation – even if they are only installing panels and not touching the electrical part – will have a C-10 electrical contractor in the area. must be a state of California, or an electrical intern enrolled in a state-approved internship program on a one-to-one ratio with very few exceptions.
“The C-10 and the General A and General B licenses, operating within their classifications, are the only remaining licenses eligible to install solar + storage systems,” said Del Chiaro.
The California Energy Commission just passed the California Energy Code of 2022, which states that all new commercial buildings contain solar and storage facilities. The number of contractors available to install these systems may be small once the new C-10 licensing requirement comes into effect.
CALSA analysed Self-Generation Incentive Program (SGIP) and CSLB data and found that only 22% of solar and storage installations in the past five years were performed by contractors with only a C-10 license. Most systems are installed by contractors with a C-46 solar license, with and without other licenses.
Obtaining a C-10 license requires employees to complete four years of hands-on experience at a journeyman’s level or above, pass the electrical exam, complete an electrical apprenticeship program in the state, and more. In comparison, the C-46 license requires employees to have a college degree or four years of solar experience and pass a solar-specific test. Del Chiaro said the new ruling sets an unreachable bar for the California contractor community and threatens to hamper solar and storage installations for the rest of the year.
“There is a shortage of not only workers in California, but especially electricians. It is simply impossible to meet this new requirement,” she said in an email.
Del Chiaro believes this decision was pushed by utility companies looking to slow down the burgeoning solar industry.
“This isn’t really a union versus non-union issue. There are more than enough jobs for everyone. This is about the utilities trying to take down their competition,” Del Chiaro said.
Parr of Solar Technologies felt that the utilities involved depended on the same few bad actors in the industry to encourage this ruling as they did for the consumer guide.
“I think it was a pretty smart move on their part because if you fast-forward in five years, every solar system is linked to an energy storage system,” Parr said. “The utilities and electric workers’ unions are trying to use other things to slow down the adoption of solar and energy storage or try to capture that market for themselves.”
CALSSA is now in talks with CSLB to clarify this rule and to explore legal options.
In the meantime, California contractors must ensure that they submit all necessary documentation to the IOUs and are equipped to hire workers to comply with the new CSLB licensing requirements.