The Contractor State Licensing Board (CSLB) voted 11-3 today 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. 

Read Public Comments Below from Bernadette Del Chiaro, Executive Director of CALSSA, before the CSLB on Tuesday, July 27:

My name is Bernadette Del Chiaro. I am the executive director of the California Solar & Storage Association. We are California’s largest clean energy trade group representing over 650 businesses who have installed over one million projects making California a world clean energy leader.

The motion on the table will have hugely negative impacts on California’s solar and storage industry, and we are concerned that given the strong public demand for solar and storage, your actions could knock out our most experienced and tested contractors and cause less experienced ones to enter the market, leading to unintended public safety risk.

CALSSA strongly disagrees with the analysis and recommendations of the UC Berkeley Labor Center. Upon initial review, we find their report to be inaccurate, misleading, and biased. The Labor Center offers no evidence to support its unsubstantiated assertion that regulatory action against California’s existing solar and storage contractors is needed to protect public health and safety. Indeed, the report admits what we have been saying for years: there is ZERO evidence that contractors holding a C-46 solar specialty license have created any safety problems, despite the 60,000 storage projects built in the past few years alone.

The Report relies on an erroneous and unsupported assumption that solar contractors hire only certified electricians to build their projects. No analysis is presented to support this false assumption and it’s wrong. And the Report relies on this to support its equally erroneous conclusion that if CSLB changes the law by prohibiting the C-46 license from installing solar and storage there will be minimal fiscal impact and no labor shortages. CALSSA raised this issue in our conversation with the Labor Center and shared our fiscal analysis yet the Report all but ignores these critical facts.   

A C-46 contractor who holds a C-10 license is not required to maintain a crew of electricians to install solar any more than a C-20 contractor who also holds a C-10 is required to use certified electricians to install an HVAC system. Specialty, multi-craft trades hire and train technicians to do their specific job. This is reflected in the CSLB’s testing curriculum. For over 20 years, CSLB has been testing C-46 contractors on energy storage. The C-10 test was only recently modified to include storage. According to the CSLB’s own Occupational Analysis, storage appears over 120 times in the C-46 analysis and fewer than 15 times in the C-10. Energy storage also receives the highest “Critical Task Importance (CTI)” rating compared to a relative low CTI in the C-10 analysis.

The Labor Center has failed to provide CSLB with a complete, objective, or data driven analysis. Critical data and analysis are omitted to support the Labor Center’s well-documented bias.

We have listed only a few of the most obvious deficiencies in the Labor Center report that we received only 11 days ago. We have not yet had an opportunity to review the Report with outside experts. Given the magnitude of its recommendation, we request that the Board afford us basic due process by providing CALSSA 120 days to conduct a thorough review and provide a detailed written rebuttal before the Board takes any action that would change the status quo. Eleven days is simply not enough time to engage on an issue this complex and consequential.  

In closing, we urge you to not undermine the continued growth of solar and energy storage in California by indiscriminately restricting the livelihoods of hundreds of experienced solar and storage contractors this summer, just as the state is facing wildfires and blackouts, to say nothing of the governor’s priority initiatives to address climate change. And all this is occurring against the backdrop of the Covid-19 pandemic that has led to widespread worker shortages. 

CALSSA has demonstrated our eagerness to support the Board’s efforts to promote public health and safety.  Any changes in the law must be rooted in reality and based on fact. We request an opportunity to help the Board do precisely that.

Thank you.