Who Should Install Home BESS tied to Solar EV System in California
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| AC Coupled BESS, obviously C-10 could handle, both batteries and solar have their own inverter/controllers, hence solar energy lost going into through two inverter stages to battery. Usually prefered for add-on BESS when there are pre-existing panels and inverter to provide power during blackouts. |
Summary - Who Should Install Home BESS tied to Solar EV System in California
Here is a summary of who should install home battery energy storage systems (BESS) tied to solar PV systems in California:
The California Contractors State License Board (CSLB) has ruled that:
1. C-10 Electrical contractors are authorized to install BESS, whether standalone or paired with solar PV systems.
2. C-46 Solar contractors are now precluded from installing BESS, even when paired with solar PV systems. This reverses previous policy that allowed C-46 contractors to install solar-paired BESS as "incidental and supplemental" work.
3. "A" General Engineering and "B" General Building contractors are still authorized to install BESS.
4. C-10 contractors must use certified electricians for the electrical work on BESS installations, as required by state labor code.
5. There is a 90-day grace period (until November 1, 2021) for C-46 contractors to obtain C-10 licenses if they want to continue installing BESS.
The CSLB made this ruling based on a UC Berkeley study that found:
- - BESS have significant safety risks and hazards that require qualified personnel to mitigate.
- - The C-10 workforce of certified electricians has greater demonstrated knowledge, skills and training for safely installing BESS compared to the C-46 workforce.
- - There is no justifiable size threshold or customer class where BESS risks become insignificant.
- - The vast majority of BESS are already installed by C-10 contractors or dual C-10/C-46 license holders.
In summary, the CSLB has determined that for safety reasons, home BESS tied to solar PV systems in California should be installed by C-10 Electrical contractors using certified electricians, not C-46 Solar contractors. General "A" and "B" contractors may also still install BESS.
Impacts of the CSLB Decision
The economic impact of this decision on homeowners and solar system contractors is expected to be minimal. Here's a summary of the key points:
1. Minimal cost increase for homeowners:
- - The UC Berkeley study found that the cost difference between BESS installations by C-10 and C-46 contractors is very small, around 1-2% of total project costs.
- - For residential projects, the data showed that the lowest average cost BESS installations were actually done by contractors holding both C-10 and C-46 licenses.
- - The study concluded that any potential cost increases due to using certified electricians would be minimal and unlikely to significantly impact consumer demand or undermine government incentives.
2. Limited impact on most solar contractors:
- - The vast majority of BESS installations (over 80%) were already being performed by contractors holding C-10 licenses (either alone or in combination with C-46).
- - Only a small percentage (about 3-6%) of BESS installations were done by C-46 contractors without C-10, A, or B licenses.
- - Many C-46 contractors (about 36%) already hold dual C-10 licenses and won't be affected.
3. Transition costs:
- - The study concluded that transition costs for restricting C-46 contractors would be minimal due to the small number currently installing BESS without other relevant licenses.
- - The CSLB is providing a 90-day grace period and expedited review process for C-46 contractors to obtain C-10 licenses if desired.
4. Potential positive impacts:
- - The decision may support companies that invest in a higher-skilled workforce, potentially improving job quality and safety in the industry.
- - It could lead to more consistent training and skill standards across the industry.
5. Long-term market effects:
- - The decision is not expected to significantly restrict the supply of qualified contractors or workers for BESS installations.
- - The number of C-10 contractors and certified electricians in California far exceeds the number of C-46-only contractors and solar installers.
In conclusion, while there may be some short-term adjustments for a small number of C-46-only contractors, the overall economic impact on homeowners and the broader solar industry is expected to be minimal. The decision appears to prioritize safety and workforce standards over potential minor cost savings.
Misguided Opinion?
Based on the comprehensive analysis provided in the UC Berkeley study and the CSLB's decision, it appears that some of the concerns raised in the opinion piece may be misguided or overstated. Let's examine a few key points:
1. Safety concerns: The opinion piece downplays safety risks, while the UC Berkeley study found significant hazards associated with BESS that require qualified personnel to mitigate.
2. Economic impact: The opinion piece suggests this decision will create "unnecessary barriers and added costs," especially for low-income families. However, the UC Berkeley study found minimal cost differences between C-10 and C-46 installations, suggesting the economic impact on consumers will likely be very small.
3. Workforce development: The opinion piece argues this decision is "a step backward for our state's clean energy and workforce development goals." However, the study suggests it may actually support higher workforce standards and skills development in the industry.
4. Market restriction: The opinion piece implies this will severely limit who can install BESS. In reality, the study shows that the vast majority of BESS installations were already being done by C-10 license holders, so the market impact should be minimal.
5. Equity concerns: While the opinion piece raises valid concerns about equity and inclusion, the study suggests that the higher standards associated with C-10 contractors and certified electricians could potentially lead to better job quality and career pathways in the long run.
6. Data and evidence: The opinion piece makes claims without presenting supporting data, while the UC Berkeley study provides extensive data analysis to support its conclusions.
While the opinion piece raises some important considerations about accessibility and workforce development in the clean energy sector, its arguments appear to be based more on speculation about potential negative impacts rather than on the kind of detailed analysis provided in the UC Berkeley study. The study's findings suggest that the CSLB's decision is likely to have a much smaller impact than the opinion piece implies, and may even have some positive effects on safety and workforce quality.
It's important to note that policy decisions often involve trade-offs, and while the opinion piece highlights valid concerns, the overall evidence seems to support the CSLB's decision as a measured approach to balancing safety, quality, and industry development.
AC/DC Coupling
There is some discussion of AC versus DC coupled battery systems, primarily in the context of cost analysis and installation requirements. Here are the key points mentioned:
1. In the NREL (National Renewable Energy Laboratory) cost data presented in the UC Berkeley study:
- The model shows costs for both AC-coupled and DC-coupled systems.
- AC-coupled systems are noted to require slightly more labor hours than DC-coupled systems to integrate with an existing inverter and monitoring system.
2. Cost comparisons:
- For a 3kW/6kWh storage system, the total installed cost is estimated at $11,823 for DC-coupled and $12,287 for AC-coupled systems.
- For a 5kW/20kWh storage system, the total installed cost is estimated at $21,471 for DC-coupled and $22,041 for AC-coupled systems.
3. Installation labor:
- The study notes that AC systems require more hours of work to integrate with an existing inverter and monitoring system compared to DC systems.
- For example, the model assumes 20 hours more time for DC systems and 32 hours more for AC systems per closed sale, associated with selling a storage system versus selling a PV system alone.
4. Technical considerations:
- The documents mention that PV systems and BESS can be connected in a variety of configurations. They can be connected to the same inverter or independent of each other.
- These various configurations are noted to present technical challenges that require knowledgeable installation.
5. Safety and regulations:
- There is no specific distinction made between AC and DC coupled systems in terms of safety requirements or contractor licensing.
- The focus is more on the overall safety considerations of BESS installation, regardless of coupling type.
While the sources do acknowledge differences between AC and DC coupled systems, particularly in terms of installation complexity and costs, this distinction does not appear to be a major factor in the CSLB's decision regarding contractor licensing for BESS installation. The primary focus is on the overall safety considerations and necessary qualifications for installing BESS, regardless of the specific coupling method used.
Opinion: The Unintended Consequences of Restricting Solar Contractors - Times of San Diego
California is the fifth largest economy in the world with the ambitious goal of transitioning to 100% clean energy while expanding its green economy and workforce in a way that is just and inclusive. That’s a tall order that can be achieved, but only if we work together.
Unfortunately, a recent decision by the Contractors State License Board threatens to undermine these goals by restricting who can install and maintain batteries charged by the sun. This rule change not only creates unnecessary barriers and added costs for those who need rooftop solar and batteries most — low-income families struggling to pay their monthly utility bills — but it is also a step backward for our state’s clean energy and workforce development goals.
About five months ago, the CSLB voted to prohibit licensed solar contractors from adding or maintaining batteries paired with rooftop solar panels. There is no apparent reason for this change. It certainly is not a safety concern. CSLB’s own research found no safety issues with the 100,000 residential batteries already installed in California.
If CSLB is changing the rules to protect their own affiliated labor unions’ interests, which also protects the interests of investor-owned utilities, above our neighbors, it is shocking. It is also allegedly illegal, which is why a coalition of environmental, consumer, and solar business organizations have joined together to seek immediate injunctive relief and, ultimately, justice, right here in San Diego Superior Court.
As we transition to a clean energy future, it is imperative that we do so in a way that is inclusive and equitable. This means creating pathways for all Californians to participate in and benefit from the green economy, from access to affordable clean energy technology to good green jobs. The decision to bar licensed solar contractors from battery systems will make it harder for GRID Alternatives and other nonprofits to bring solar and storage to communities of concern.
GRID Alternatives is the nation’s largest nonprofit solar installer, working to make solar and storage accessible for low-income communities while providing clean energy jobs training. We believe that the transition to a clean energy economy should include everyone, particularly those who might otherwise be left out of the economic benefits of energy innovation.
The pool of qualified professionals who can work on rooftop solar and batteries, a rapidly growing sector in the renewable energy industry, will be severely limited by this rule. By restricting solar contractors from participating in this work, the rule effectively limits job opportunities in a field that is crucial for California’s energy future.
This is particularly detrimental to small businesses and workers from diverse backgrounds who are trying to gain a foothold in the green economy. The rule could force many solar contractors to cut their workforce or close their doors entirely, resulting in a loss of jobs and economic opportunities in communities that can least afford it.
Moreover, CSLB’s decision also poses a threat to California’s clean energy goals. Battery storage is a critical component of a resilient and reliable energy grid, especially as we face increasing threats from wildfires and power shutoffs. By limiting who can install and maintain these systems, the rule, if allowed to go into effect Oct. 1, would slow the expansion of local energy storage capacity, making it harder for California to meet its climate targets and increasing costs for consumers.
California has the opportunity to lead the nation in creating an inclusive green economy that works for everyone. This requires policies that support, not hinder, the growth of renewable energy and the creation of green jobs.
We must ensure that the transition to clean energy is equitable, providing opportunities for all communities to thrive.
Eddie Price is community relations coordinator for GRID Alternatives and president of the San Diego Urban Sustainability Coalition.
Clean Energy, Consumer and Environmental Advocates File Preliminary Injunction to Block Controversial CSLB Ruling that would Slow Battery Installations, Hurt Green Jobs — CA Solar & Storage Association
A coalition of clean energy, consumer protection, and environmental groups filed a motion today seeking a preliminary injunction to halt enforcement of a new California rule that would severely restrict solar contractors from installing and servicing battery storage systems.
The rule, approved by the California Contractors State License Board (CSLB) in April, prohibits licensed solar contractors from adding batteries to existing solar panels or performing maintenance on batteries, including those they previously installed themselves. The rule was approved by the CSLB at the behest of the state’s investor owned utilities and their affiliated labor union despite the board’s own research finding zero safety issues or incidents across all residential batteries installed to date across the country, including 100,000 batteries in California alone.
Clean energy supporters say the rule will severely harm small businesses, result in the loss of even more green jobs, and dramatically slow California's progress in expanding local energy storage capacity at a critical time.
"This misguided decision by the licensing board greatly limits who consumers can turn to for solar storage, without any real evidence of a safety issue," said Jenn Engstrom, state director of CALPIRG, one of the plaintiffs. "This red tape will delay services, increase costs for consumers, and make it harder for California to meet its clean energy goals."
The preliminary injunction motion, filed in San Diego County Superior Court, contends the CSLB violated state law by failing to properly assess the economic and environmental impacts of the new rule. The plaintiffs argue it will cause immediate and irreparable harm by forcing hundreds of solar contractors to cut their workforces or close entirely, while harming consumers and undercutting the growth of renewable energy storage that is vital for grid reliability and meeting climate targets.
Clean energy and environmental advocacy plaintiffs are asking the court to prevent the rule from taking effect on October 1, 2024 while their legal challenge proceeds. The preliminary injunction rests on the fact that plaintiffs are likely to prevail on the merits of the case because the CSLB did not follow the Administrative Procedures Act or the California Environmental Quality Act in several important ways, including failing to consider alternatives or examine the economic impact on small businesses.
If implementation is not put on hold, the rule will cause irreparable harm in the form of loss of business, professional reputation, customer goodwill, employment, and the disruption of contracted warranties, according to the motion.
The motion further argues a preliminary injunction serves the public interest by promoting solar and battery installations which are crucial to expanding renewable energy storage in California to increase energy reliability in the face of wildfires and power shutoffs, and to combat global climate change.
With the rule change in place, there simply are not enough certified electricians available to meet demand for new storage capacity, whereas licensed solar contractors are available and have installed and serviced storage systems for 40 years with a perfect safety record, according to the CSLB’s own research.
“This licensing trick is straight from the utility playbook and will cause electricity rates to skyrocket while worsening the climate emergency,” said Roger Lin, senior attorney at the Center for Biological Diversity. “People are dying from extreme heat and California desperately needs smart, resilient energy solutions. Instead, the board is propping up a brittle electricity grid that devastates critical habitats and promotes environmental injustice.”
The CSLB rule is only the most recent attack on rooftop solar and storage in California.
“California keeps saying one thing but doing another when it comes to the fight against climate change,” said Bernadette Del Chiaro, executive director of CALSSA. “In just the past year, California slashed rooftop solar incentives, prohibited self-generation for schools and farms, and proposed expensive fixed charges that hurt energy conservation and local solar. Now they are undermining California’s emerging battery storage progress through severe workforce limitations. This has to stop if we are to move forward as a state, keep energy prices low, and prevent future blackouts.”
CSLB Agrees to Stay Enforcement of Restrictions on Solar Contractors — CA Solar & Storage Association
Thanks to CALSSA lawsuit and advocacy efforts solar contractors may continue to install solar + storage for now
San Francisco – Yesterday the Attorney General of California filed in San Francisco Superior Court a written stipulation agreeing to voluntarily stay enforcement of the Contractor State License Board (CSLB)’s July 27 decision limiting the ability for California’s solar contractors (C-46) to install solar paired with energy storage projects. As a result, C-46 solar contractors may continue to install solar and storage systems throughout California on and after November 1, 2021.
The decision also means that the work of a C-46 contractor installing stand-alone solar or solar paired storage systems may continue to be done through the contractor’s existing trained and experienced solar workforce, and not be limited to hiring Certified Electricians, as required by the CSLB’s July 27 decision. CALSSA contends that there is a severe shortage of Certified Electricians and that they do not necessarily bring public safety benefits compared to the existing specialized solar workforce. The CSLB upheld the existing practice of allowing General A and General B license holders to continue installing solar and solar paired storage systems without using Certified Electricians as well.
“This is a huge relief, albeit temporary, for hundreds of contractors up and down the state,” said Bernadette Del Chiaro, executive director of the California Solar & Storage Association (CALSSA). “The restrictions suddenly imposed this past summer were devastating and came at a time when consumers and the state as a whole desperately need more reliable clean energy, not less.”
The stay agreed to by the CSLB stands until “this action is finally resolved, and the Petitioner-Plaintiff has agreed to withdraw its motion in exchange,” as stated in the stipulation. In other words, the stay on enforcement is good until the CSLB has promulgated new regulations or CALSSA has dropped its lawsuit. The bottom-line is contractors holding a C-46 solar license can continue to install solar and storage systems for at least 12-18 months, and possibly longer depending on the outcome and timeline of any new regulations.
This decision to stay enforcement was made by a majority vote of the CSLB on Wednesday, September 29, and the written stipulation filed with the Court was negotiated between the Attorney General representing the CSLB and CALSSA’s litigation team at Shute, Mihaly & Weinberger. It represents a major victory in defense of California’s solar and storage industry but not the end of the road.
“Much more work lies ahead to ensure that any new regulations are clear, consistent, and not harmful to our industry,” said Del Chiaro. “We sincerely hope the CSLB will work with CALSSA going forward and not try to cut corners again.”
With this written stipulation, CALSSA has agreed to put a hold on its Preliminary Injunction which would have sought a court-ordered stay on enforcement. The voluntary stay has the same effect and was arrived at sooner than a court would have. CALSSA has not put a hold on its lawsuit claiming that the decision and subsequent bulletins are illegal, underground regulations but is willing to enter settlement negotiations with the CSLB.
“We won’t put a hold on our lawsuit until the Board concludes a legal decision-making process for any future regulations and carefully considers what it means to our industry, especially small businesses which make up the majority of our contractor base,” said Del Chiaro.
CALSSA points out that the threat of future licensing restrictions remains at the CSLB. The difference is, thanks to CALSSA’s litigation, any new restrictions would be arrived at through a rule-making process that adheres to the Administrative Procedures Act (APA). Such a process typically takes 12-18 months and, according to the law, must be based in fact, be clear and consistent, and consider economic impacts especially to small businesses. If the new regulations don’t adhere to the APA, then CALSSA could decide to take CSLB once again to court.
“It is CALSSA’s sincere hope that this will not be necessary,” clarified Del Chiaro. “But the solar and storage industry is here to stay. We might be small compared to our opponents in the fossil fuel industry, but we work together to speak with one voice.”
In addition to the existential fight at the licensing board, CALSSA is also engaged in a consequential battle over the future of Net Energy Metering (NEM) at the California Public Utilities Commission. The same labor union, the International Brotherhood of Electrical Workers (IBEW) that pushed the illegal regulations at the CSLB were also behind AB 1139, a bill that mirrored the NEM fight at the CPUC and would have devastated the rooftop solar industry harming existing and future consumers. The bill was shot down by the legislature in June but only after a grueling battle that required the engagement of thousands of voters, small businesses, and environmental groups.
“This has been quite the year and we are not out of the woods yet,” reflected Del Chiaro. “Our hope is that Governor Newsom exerts some leadership and protects the current and future growth of distributed solar and energy storage in California.”
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