March 21, 2019 Contractors State License Board 9821 Business Park Drive Sacramento, CA 95827 RE: Clarification of Regulations for Battery Energy Storage System Installation Thank you for your continued efforts to protect California consumers by ensuring the construction industry adheres to policies that promote the health, safety and general welfare of the public. We are appreciative of the thorough review the Board has taken in recent months and are writing to urge the Board to clarify current regulations to require that only specialty contractors holding a C-10 electrical contractors license may install battery energy storage systems. The use of battery energy storage systems is rapidly expanding in hospitals, schools, businesses and homes throughout the state. This technology is key in helping California meet its clean energy and emissions reduction goals and to expand the adoption of solar, wind and other clean energy sources. However, if not installed and maintained correctly by highly-qualified and licensed C-10 electrical contractors, battery energy storage systems pose unique fire, electrical and public safety risks to installers, consumers, utility workers and emergency personnel. Ambiguity in the regulations has allowed C-46 solar contractor licensees to install battery energy storage systems when paired with a solar photovoltaic (PV) system, even though these battery energy storage systems are separate electrical systems and the C-46 solar contractors do not have the electrical training or expertise required. A PV energy system is very different technology than a battery energy storage system. A battery transforms electrical energy to chemical energy and back into electricity. For that reason, CSLB regulations specifically require a C-10 license to “install, erect or connect any electrical wires, fixtures, appliances, raceways, conduits, solar photovoltaic cells or any part thereof, which generate, transmit, transform or utilize electrical energy in any form or for any purpose.” C-10 licensed electrical contractors have an extensive background in electrical theory and, by law, are required to install battery energy storage systems with highly trained electricians who have been certified by the state. In contrast, C-46 licensed solar contractors are not specifically qualified to safely install this complex technology and their installing employees have no training nor certification requirements. We are urging the Board to not compromise safety standards by continuing to allow a C-46 solar contractor to install a battery energy storage system. CSLB regulations specifically prohibit C-46 solar contractors from installing standalone battery energy storage systems. Please adhere to the mission of the CSLB and protect public safety and consumers by ensuring battery energy storage systems are installed by only specialty contractors who hold a valid C-10 electrical contractors license. Sincerely,
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March 21, 2019 Contractors State License Board
9821 Business Park Drive Sacramento, CA 95827 RE: Clarification of Regulations for Battery Energy Storage System Installation Thank you for your continued efforts to protect California consumers by ensuring the construction industry adheres to policies that promote the health, safety and general welfare of the public. We are appreciative of the thorough review the Board has taken in recent months and are writing to urge the Board to clarify current regulations to require that only specialty contractors holding a C-10 electrical contractors license may install battery energy storage systems.
The use of battery energy storage systems is rapidly expanding in hospitals, schools, businesses and homes throughout the state. This technology is key in helping California meet its clean energy and emissions reduction goals and to expand the adoption of solar, wind and other clean energy sources. However, if not installed and maintained correctly by highly-qualified and licensed C-10 electrical contractors, battery energy storage systems pose unique fire, electrical and public safety risks to installers, consumers, utility workers and emergency personnel.
Ambiguity in the regulations has allowed C-46 solar contractor licensees to install battery energy storage systems when paired with a solar photovoltaic (PV) system, even though these battery energy storage systems are separate electrical systems and the C-46 solar contractors do not have the electrical training or expertise required.
A PV energy system is very different technology than a battery energy storage system. A battery transforms electrical energy to chemical energy and back into electricity. For that reason, CSLB regulations specifically require a C-10 license to “install, erect or connect any electrical wires, fixtures, appliances, raceways, conduits, solar photovoltaic cells or any part thereof, which generate, transmit, transform or utilize electrical energy in any form or for any purpose.”
C-10 licensed electrical contractors have an extensive background in electrical theory and, by law, are required to install battery energy storage systems with highly trained electricians who have been certified by the state. In contrast, C-46 licensed solar contractors are not specifically qualified to safely install this complex technology and their installing employees have no training nor certification requirements.
We are urging the Board to not compromise safety standards by continuing to allow a C-46 solar contractor to install a battery energy storage system. CSLB regulations specifically prohibit C-46 solar contractors from installing standalone battery energy storage systems.
Please adhere to the mission of the CSLB and protect public safety and consumers by ensuring battery energy storage systems are installed by only specialty contractors who hold a valid C-10 electrical contractors license. Sincerely,
Brian K. Rice, President California Professional Firefighters Tom Dalzell, Chairman Coalition of California Utility Employees Matthew Hargrove, Senior Vice President, Government Affairs California Business Properties Association William “Bill” Kelly, Liaison County Building Officials Association of California Gary Passmore, President Congress of California Seniors Daniel V. Fross, Executive Director Building Safety Alliance Shawn Lewis, Policy Director NFIB California Bernard M. Kotlier, Executive Director Sustainable Energy Solutions Thomas Coleman, Executive Manager San Francisco Electrical Contractors Association Rudy Gonzalez, Executive Director San Francisco Labor Council Alex Lantsberg, Director of Research and Advocacy
San Francisco Electrical Construction Industry
Eddy Pena, Business Agent International Association of Heat & Frost Insulators and Allied Workers Local 5 Anthony Hernandez, President Electrical Workers Minority Caucus - San Jose Chapter Roxana Tynan, Executive Director Los Angeles Alliance for a New Economy JB Tengco, Western States Director BlueGreen Alliance
Mike Shrout, President California State Firefighters Association Richard Samaniego, Secretary/Treasurer California State Association of Electrical Workers Robbie Hunter, President State Building & Construction Trades Council Dion Abril, Executive Administrator Western States Council of Sheet Metal, Air, Rail and Transportation Workers Matthew Hargrove, Statewide Administrator Building Owners and Managers Association (BOMA) California John M. Bozeman, Director, Government & Industry Affairs BOMA – San Francisco Aaron Taxy, Director of Government & Public Affairs BOMA – Greater Los Angeles Eddie Bernacchi, Legislative and Regulatory Advocate NECA – California James Willson, Executive Director NECA – Los Angeles Chapter Greg Armstrong, Executive Director NECA – Northern California Chapter Andy Berg, Executive Manager NECA – San Diego Chapter Fran McDermott, Executive Director NECA – Great Sacramento Chapter Michael Geller, Manager NECA – Contra Costa Chapter Anisa Thomsen, Manager NECA – Redwood Empire Chapter Jerri Champlin, Executive Manager NECA – Monterey Bay Chapter Cody Brooks, Executive Director NECA – Kern County Chapter
Frank Reardon, Business Agent United Association of Journeymen & Apprentices Local 38 Dan Rodriguez, Business Manager IBEW Local 332 Joel Barton, Business Manager IBEW Local 11 Nicolaj Svoboda, Business Agent IBEW Local 684 Daniel O. Chivello, Business Manager IBEW Local 595 Chris Huston, Business Representative IBEW Local 952 Steve Booker, Business Representative IBEW Local 617 John P. McEntagart, Business Manager IBEW Local 551 Nicholas J. Segura, Jr., Business Manager/ Financial Secretary IBEW Local 569 Richard Samaniego, Business Manager IBEW Local 441 John J. Doherty, Business Manager/ Financial Secretary IBEW Local 6 Dave Clark, Director of Membership Development IBEW Local 100 Marc Flynn, Business Manager/ Financial Secretary IBEW Local 40 James S. Elrod, Business Manager/ Financial Secretary IBEW Local 428 David Iloff, Business Agent IBEW Local 180 Jason Eshelman, Business Manager IBEW Local 477
Doug Lung, Executive Director NECA – Santa Clara Chapter Peggy M. Brown, Chapter Manager NECA – Orange County Chapter Shari J. Brunner, Executive Manager NECA – Central Coast Chapter David Shankle, Executive Vice President NECA – Southern Sierra Chapter Robert Meadows, President Morrow-Meadows Corporation Mike Garner, VP Sales Cupertino Electric, Inc. Jeff Neubauer, Manager Neubauer Electric, Inc. Shelley Keltner, CEO Pacific Data Electric Inc. Robert Hayes, President R.I.S. Electrical Contractors Inc. Jack Paulson, Training Director Solano & Napa Counties Electrical JATC Cliff Thompson, Senior Vice President of Field Operations Rosendin Electric, Inc. Earnest Brown, President International Line Builders SoCal Mikaiil Hussein, President/CEO United Taxi Workers of San Diego Collin Weiner, President CalEnergy Electrical Corporation Jim Marsh, President/CEO Taft Electric Company Earl Restine Jr., President Rod Fuller Electric Corporation
Jon Treder, President/CEO Electricraft, Inc.
Andy Hartmann, Business Manager IBEW Local 234 Tom Hansen, Business Manager IBEW Local 302 Robert Ward, Business Manager IBEW Local 340 Chuck Huddleston, Business Manager/ Financial Secretary IBEW Local 413 Matt Furrer, Vice President, Branch Manager Contra Costa Electric, Inc. Douglas Woodruff, CFO Advanced Cable Systems Craig Gini, Vice President Collins Electrical Company, Inc. Jeff Davis, VP Construction CSI Electrical Contractors Tara Hammond, Director of Community Development
Sullivan Solar Power Diana Limon, Training Director Electrical Training Institute William Delucchi, President Delucchi Electric, Inc. Larry Strohm, Co-Owner Big Sky Electric Inc. Robert Davies, President Davies Electric Co, Inc. Travis Becker, President Becker Electric, Inc. Tim Daniels, President TDN Electric, Inc. Andrew Ferrari, Chairman of the Board A.S.F Electric, Inc. Jasen Smith, President Advanced Cable Solutions, Inc.
James Young, CEO Young Electric Co. Inc William Musgrave, President/CEO McMillan Electric Brad Kirk, President Sac Valley Electric, Inc. Jack Bellows, President Vmax Electric Inc. James Reed, Owner Century Electric Michael Brannon, President Brannon Inc. DBA Smith Electric Service Jim Robinson, President Artkos Incorporated Barry Frain, President Con J. Franke Electric, Inc. Asghar Ghassemy, President Telenet VoIP, Inc. Ernie B. Ulibarri, President Barri Electric Company, Inc. David Studebaker, President Stubebaker Brown Electric, Inc. Manny Ayala, President Solar Motion Green Energy Services LLC Stephen Mussell, President Santa Maria Electric, Inc. Jeffrey Simonides, Owner Triple S Electric, Inc. Charles Nunez, President CN O’Niell Electric Keith Burrows, President Decker Electric Derek Kozacko, CFO Corish Electric Corporation Paul McConville, CEO Ard Mac Electric, Inc.
VMax Electric, Inc.
Ryan Cross, General Partner Cross Price Electric Yuriy Fox, President Absolut Electric, Inc. Robert W. Friar, President Chula Vista Electric Russell Sterner, President Rossi Carr Electrical Inc. Vic Giacalone, CEO Best Electrical Co., Inc. Brian Jacoway, President Valley Pacific Electric, Inc. Shane Cox, President The Mike Cox Electric, Inc. Katrina Kincaid, Owner American Electric Company Michael Outerbridge, President Outerbridge Electric Mark H. Olson, President Mark Olson Electric, Inc. Sean Holland, Owner HS Electric, Inc. Louis Buhler, Owner Buhler Construction Co Pete Spencer, CEO Audio Associates Brian Iwashita, CEO/President Palmer Electric, Inc. Gregory Olson, President Olson Electric Services Greg James, President Direct Digital Controls, Inc. Keith Orum, Owner Halco Testing Services Julio Guillen, President Guillen Electric Company, Inc.
Patrick McMillan, President Victory Electric Ted Kristensen, President Enterprise Electric Timothy McBride, CEO Southern Contracting Company James Hart, President DAB Innovations, LLC Walt Zacharias, President/Owner Elite Power, Inc. Richard Nogleberg, President PEI Placer Electric, Inc. Richard Reed, President Renewable Gateway Scott Kingsmill, President Gilbert & Stearns, Inc. Troy Wilhite, President Wilhite Electric Inc. Kevin Carsey, President David Stone Electrical Contractors, Inc. Louis Angelos, President/Owner Betaray Inc. (dba) Sage Electric John Pegram, President Integrated Security Controls, Inc. Rebecca Anderson, Owner Beci Electric, Inc. Kevin Baxter, President Baxter Electric, Inc. Thomas Ispas, President Daniel's Electrical Construction Richard Beard, Owner Beard Electric, Inc. Michael Espinoza, President Calsouth Electric, Inc. Seamus Canning, President Canning Electric, Inc.
American Electric Company
Jeff Perry, President Briggs Electric, Inc. Jeff Bernandino, President Integrated Power & Lighting, Inc. Patrick Grafton, President Grafton Electric, Inc. Nicholas McDaid, Owner/Manager N2 Electric, Inc. Kevin Miller, Owner Alden Electric Co. Mike Neil, President Allcom Electric, Inc.
Leanne Peterson, President Southland Electric, Inc. Dylan Lecair, CEO Lecair Electric Inc. Matthew Sellars, Owner Matthew Sellars Electrical Services Basri Ismail, Owner Buzz Electric, Inc. James Bolter, Owner Bolter Construction
