Arizona Registrar of Contractors (ROC)
1700 W. Washington Street, Suite 105
Phoenix, AZ 85007
RE: Update to Contractor Licenses Relative to Solar
Dear Ms. Verdugo,
Per our conversation in May, AriSEIA submits the following suggestion for updating the contractor licenses applicable for solar.
Solar installations (both photovoltaic and hot water) require a mixture of electrical, roofing, structural steel, and mechanical skills. The current Arizona contracting license classifications leave certain ambiguous and unambiguous gaps relative to how the solar industry operates across the residential, commercial, and utility-scale segments, and it is understood that certain solar projects are often direct-contracted by a customer for scope outside of a license classification i.e., a commercial solar carport being installed by a C-11, or a residential solar system being installed by an R-11 when including roofing repairs.
To streamline licensure requirements and provide a path to comply with Arizona ROC rules without acquiring multiple licenses, we recommend the creation of a standalone “Solar Contractor” classification. The goal is that the license allows for self-performance of electrical work (and interconnection) of solar systems, installation on rooftops or structures (with requisite limitations on self-performance re: roofing, carpentry, or structural steel), and subcontracting of relevant trades (electrical, underground, roofers, mechanical, structural steel, etc.). In essence, the license would blend K/B-1 subcontracting with C/R-11 self-performance capabilities. The classifications could be further delineated into “Residential Solar Contractor,” “Commercial Solar Contractor,” or “Utility Scale Solar Contractor.”
For example, California is one state that has already taken this step to align contracting classifications with the growing solar industry via the C-46 Solar Contractor classification. This license appears to cover both residential and commercial segments.
We encourage the ROC to consider such an update and would be more than happy to discuss this matter further.
 California Department of Consumer Affairs, Contractors State License Board, C-46 – Solar Contractor, available here https://cslb.ca.gov/About_Us/Library/Licensing_Classifications/C-46_-_Solar.aspx.
 Overview of the subject matter knowledge applicable to this license is available here https://www.cslb.ca.gov/Resources/StudyGuides/C46StudyGuide.pdf.
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