1.     What do C-46 Solar contractors need to do if they want to install battery energy storage systems (BESS) after November 1, 2021?

To place, install, erect, or connect a BESS, the C-46 contractor will need to add the C-10 Electrical contractor classification on their license. To get the C-10 added, go to the CSLB website and complete this application. CSLB will expedite its review of applications received by November 1, 2021.

If you are a solar contractor that has been installing BESS in conjunction with photovoltaic (PV) systems for four or more years, you will meet the requirements to add the C-10 Electrical classification to your license. CSLB also encourages you to start studying early for the trade exam, please refer to CSLB’s study guide. Information regarding obtaining a wavier of the exam can be found here.

Without the C-10, B, or A classification on your license, a C-46 Solar contractor cannot take a contract on a project that includes BESS installation. Beginning November 1, 2021, this applies to all new contracts on projects entered into on and after November 1, 2021, and for work occurring on and after November 1, 2021. You may refer to Business and Professions Code section 7059.

2.     Who needs to have a certified electrician on their team?  

A C-10 Electrical contractor needs a certified electrician on staff to engage in the connection of electrical devices greater than 100-volt amperes. CSLB recommends contractors review California Labor Code sections 108-108.5 and California Department of Industrial Relations regulations and its Electrical Certification FAQ.

The only time a contractor needs a certified electrician on staff is when they hold a C-10 classification and are engaging in the connection of an electrical device pursuant to California Labor Code sections 108-108.5. This includes connecting a BESS or PV system to an existing electrical system or to a utility grid. This also includes placing, installing, erecting or connecting an electrical panel.

If you have questions about a specific project, please email CSLB’s classification at classifications@cslb.ca.gov.

If you have questions about electrician certification or how to obtain it, please visit the Department of Industrial Relations, Electrician Certification Program webpage.

3.     When can a contractor with a C-10 electrical classification use non-certified workers?

A C-10 contractor does not need to use a certified electrician to perform work on a BESS or PV when the work does not involve connecting an electrical device.  Examples include installation, repair, or service of:

·       Racks on a roof (including associated flashing and sealing roof penetrations from rack attachment).

·       Installation of poles and racks for ground mounted solar systems.

·       Installation of BESS racks.

·       Installation of required BESS or PV signage.

·       Seismic Restraints

4.     What about General Contractors (“A” General Engineering, “B” General

Building) and BESS?

Please see the August 12, 2021 CSLB Industry Bulletin about this question. A     General Building contractor may take a prime contract that involves a PV or BESS installation if the multiple trade requirement of Business and Professions Code section 7057 is met. And a General Engineering contractor may take a prime contract that involves a PV or BESS installation if the project is in connection with fixed works requiring general engineering knowledge or skill, as required by Business and Professions Code 7056.

The Labor Code sections 108 – 108.5 referenced above do not require general contractors who do not have a C-10 Electrical license to employ certified electricians.