C10 license and a visit to the CEC [RE-wrenches]

Mon Jun 6 20:36:10 PDT 2005

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Most C10 Electricians are also unfamiliar with DC power, battery sizing and
battery safety..  In the event a PV system owner desires a future upgrade to
include battery backup, in order to have power should the grid drop out, who
will perform this task?  When the day comes to remove and re-install the PV
array to allow for re-roofing, who will perform this task?  It should and
must be a C46 Solar Contractor or a C10 Electrical Contractor with
sufficient documented PV experience and training.

When an air conditioning contractor installs an AC unit, a new breaker is
installed in the main electrical service panel; conduit and wiring must be
done to NEC specifications as well as local codes, and the same holds true
for swimming pool contractors installing pumps.  A number of trades include
incidental electrical work, often more demanding than wiring a PV
inter-connection and these contractors know their trade and do not require a
C10 on site.  Installing PV is not rocket science, and SB1 funding must not
be restricted to union certified installers.  The California State
Contractors License Board must remain the determiner of trade
classifications.

I would recommend to family and friends considering a PV installation to
hire a C46 solar contractor for greater assurance the roof will not leak,
the panels will not blow of in fierce winds, and to have the most
knowledgeable working relationship in the event future service or upgrades
are required.  Besides, C46's have been the flame keepers for decades, and
allowing the torch bearing pioneers to avoid arrows in the back is crucial
for long term healthy solar markets.

Arguments against requiring a C-10 license to complete the "electrical work"
necessary to install a solar energy system:

1)      Class C-46-Solar Contractors are qualified to complete this work.

a)      To date, contractors qualifying with a C-46 license have installed
more PV systems in the CEC Emerging Renewables Buydown Program than
contractors qualifying with a C-10 license (see attached graph).

b)      There is no evidence that C-10 contractors are better prepared than
C-46 contractors to install solar energy systems.  In fact, the test for the
C-46 license, revised in 2003, includes significant content specifically
related to the installation of solar electric systems.  The test for the
C-10 license does not include any such specific content.

2)      Class C-46 contractors are permitted by current licensing law to
perform this work (see attached reference).

a)      Current Contractor's State Licensing Board (CSLB) law authorizes two
specialty license classifications to install photovoltaic systems:  a Class
C-46-Solar Contractor, and a Class C-10-Electrical Contractor.  

b)      The laws, rules, and regulations governing specialty contractors
also include explicit provisions for a licensee to perform work other than
that for which he or she is licensed, if it is essential to accomplish the
work for which the contractor is classified.  Other specialty license
classifications including Class C-4-Boiler, Hot-Water Heating and Steam
Fitting Contractor, Class C-20-Warm-Air Heating, Ventilating and
Air-Conditioning Contractor, Class C-36-Plumbing Contractor, Class
C-38-Refrigeration Contractor, Class C-45-Electrical Sign Contractor, Class
C-53-Swimming Pool Contractor all perform electrical work essential to the
installation of their respective systems without requiring a C-10 Electrical
Contractors license.

3)      Subcontracting (C-46 subcontracting a C-10 to complete electrical
work) would not be possible without convoluted changes to current contractor
licensing law.  With the proposed language, a C-46 contractor would need to
acquire an additional license (a C-10) in order to contract for the
installation of a solar electric system.  The burden of carrying this
additional, unnecessary license would result in an increased cost for the
consumer.

4)      Precluding an entire class of contractors from performing the work
they are qualified and authorized by the CSLB to perform would restrict
competition, reduce the pool of qualified installers in the state, and limit
consumer choice.  

Best proposed resolution:  Leave determination of license requirements to
the Contractors' State Licensing Board, amend language to read:

(7) The work to install the solar energy system shall be performed under
contract by a California contractor with an active

license or licenses, in accordance with rules and regulations adopted by the
Contractors' State License Board.   

Reference to specialty contractors law, rules and regulations:

Requiring a C-10 Electrical Contractors license for completing the
"electrical work" necessary to install a solar energy system is inconsistent
with current law, rules, and regulations governing specialty contractors.
Section 7059 of the Business and Professions Code states:

"Nothing contained in this section shall prohibit a specialty contractor
from taking and executing a contract involving the use of two or more crafts
or trades, if the performance of the work in the crafts or trades, other
than in which he or she is licensed, is incidental and supplemental to the
performance of the work in the craft for which the specialty contractor is
licensed."

Contractors State License Board Rules and Regulations, Article 3, Section
831 further defines "incidental and supplemental" as follows:

"For purposes of Section 7059, work in other classifications is "incidental
and supplemental" to the work for which a specialty contractor is licensed
if that work is essential to accomplish the work in which the contractor is
classified. A specialty contractor may use subcontractors to complete the
incidental and supplemental work, or he may use his own employees to do so.

Other specialty license classifications including Class C-4-Boiler,
Hot-Water Heating and Steam Fitting Contractor, Class C-20-Warm-Air Heating,
Ventilating and Air-Conditioning Contractor, Class C-36-Plumbing Contractor,
Class C-38-Refrigeration Contractor, Class C-45-Electrical Sign Contractor,
Class C-53-Swimming Pool Contractor all perform electrical work essential to
the installation of their respective systems without requiring a C-10
Electrical Contractors license.

[Non-text portions of this message have been removed]

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