CSLB Rejects Wholesale Restrictions on C-46 License The Contractor State Licensing Board (CSLB) met March 2021 with proposed C46 licensing restrictions on the agenda. They unanimously rejected the proposed regulations from last year that would have restricted the C46 from installing any, and all, energy storage systems. Given how far we have come in defending the C46 license, this result is no small feat.
However, the threat to the industry looms. The CSLB did take action yesterday, voting to assign staff to study the issue further. By this, the board has committed itself to considering at a future date some level of restriction on the C46 license based on kWh size of the battery system. CALSSA has offered a 1 MWh system size as well as a 600 kWh system size limit to clearly demarcate the behind-the-meter market from the utility-scale market. IBEW has proposed the limit be set at 20 kWh. CSLB staff threw out 50 kWh within the board packet but state they are not wedded to this number. CALSSA will continue to advocate for a reasonable level of flexibility to meet current and future market demands.
Many thanks to Jeanine Cotter of Luminalt, Luke Miller of SolarHut, Stephen Campbell of GRID Alternatives, Emily Langenbahn of Renova Energy, and Suzanne Leta of SunPower for taking the time to testify. The next board meeting is likely to be held in June 2021. Staff are now tasked with hiring a subject matter expert to help them determine a threshold. They will then return to the Legislative Committee before returning to the full board. Once the board approves language restricting the C46 license, the CSLB will open a formal rulemaking process to ultimately change the regulations. This process can take up to 18 months before the changes go into effect.