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California’s New CSLB Disclosure & Savings Estimate

Anita-PLR Product Ops avatar
Written by Anita-PLR Product Ops
Updated over 3 weeks ago

Need to Know

Beginning November 1, 2025, California residential solar utility Interconnection Application submissions must include a new Solar Energy System Supporting Information document (English), (Spanish), (LightReach English template), and (LightReach Spanish template)

The 7-page document, also referred to as the CSLB Disclosure Document, requires a 1-year energy savings estimate with standardized inputs and assumptions for solar or solar+storage.

  • Utilities are directed to require it with Interconnection Application submissions by November 1, 2025

  • Required for residential only

  • New construction is exempt

  • Applies to PG&E, SCE, SDG&E, and small IOUs Bear Valley, Liberty, and PacifiCorp - no municipal utilities

  • Also, applies to battery retrofit (new storage with existing PV)

Utility Interconnection Application portals require the new form on submissions starting November 1, 2025

Applicable Utilities

Required in all Investor Owned Utilities in California. It is not required in any municipal utilities.

  • Pacific Gas & Electric (PG&E)

  • Southern California Edison (SCE)

  • San Diego Gas & Electric (SDG&E)

  • Bear Valley Electric Service

  • Liberty Utilities

  • PacifiCorp (CA)

New Milestone 1 Requirement

LightReach will begin requiring a copy of the completed Solar Energy System Supporting Information document at Milestone 1 on submissions beginning November 1, 2025 in the applicable utilities (PG&E, SCE, and SDGE).

Legislative Background

Assembly Bill 1070 (Gonzalez Fletcher, Chapter 662, Statutes of 2017) required the Contractors State License Board (CSLB) and California Public Utilities Commission (CPUC) to develop the document to be provided to residential NEM and NBT customers by solar providers which would include anticipated bill savings, system size, total costs, and financing.

This new CSLB Disclosure is in addition to the existing California Solar Consumer Protection Guide and existing 1-page CSLB’s Solar Energy System Disclosure Document, which are both required to be signed before or with the contract -- the older forms are inside the LightReach contract packet. The existing 1-page CSLB Disclosure went into effect in 2019 as a first step while the inputs and assumptions of the savings estimate were debated. The new 7-page CSLB Disclosure does not replace the old 1-page CSLB Disclosure.

LightReach Process

To get ready for the new California standards, we’re partnering closely with our installation teams and integrated sales platforms to ensure everything is updated and ready to go.

Currently, our system doesn’t require customer energy history, but the new requirements do. Specifically:

  • Hourly energy consumption data will be needed.

  • If actual data isn’t available, an attestation on the form must be provided stating why they are not available

Our integrated sales platforms play a key role in supplying these data inputs and assumptions to keep the process accurate and compliant.

Partners will need to:

  1. Complete the form - Partner must complete the new CSLB Disclosure and provide to customers - LightReach English template, and LightReach Spanish template

  2. Savings Estimate - Perform the 1 year savings estimate using the standard inputs and comply with data retention requirements

  3. M1 Submission - LightReach will begin requiring a copy of the completed Solar Energy System Supporting Information document at Milestone 1 on submissions beginning November 1, 2025. While the CSLB disclosure is a state requirement the utilities are required to enforce, LightReach requires a completed copy for our records.

LightReach Requirement

All Milestone 1 submissions in the applicable utilities (PG&E, SCE, and SDGE) must upload a completed copy of the Solar Energy System Supporting Information as an Incentive Deliverable beginning November 1, 2025.

Completing the Form

Typewritten - Type all fields-handwritten entries will not be accepted.

Data Retention - Data used in the savings estimate calculation shall be retained for at least 12 months after PTO in case audited by utilities

Item

Page #

Background & Tips

Form Screenshots

1-2

Click Here

Installation Information

3

Click Here

Will subcontractors be used to perform this work? Yes or No

Answer this to the best of your ability at point of sale.

Info About the Agreement

3-4

Click Here

For LightReach sales with PV or PV+Storage, we currently only offer a PPA in PG&E, SCE, and SDGE.

Use our LightReach Template with pre-entered page numbers for the warranty information.

Enter the PPA Terms per the LightReach Agreement

  • $/kWh starting rate in Year 1

  • Escalator

  • Upfront payment (typically $0 until we launch pre-paid PPAs in 2026)

  • Monthly payments - Enter the year 1 monthly payment

Annual Electricity Usage

5

Click Here

Electricity usage for the past 12 months

This should be based on hourly interval data (e.g. GreenButton data), which can be downloaded from the customer’s utility account portal, UtilityAPI, Arcadia, etc. It may be based on estimated hourly interval data for the customer’s climate zone if 12-months is not available.

  • If 12-months of actual hourly interval data is not available, there is a separate field on page 6 for the contractor to explain why it could not be obtained and to explain how the estimated hourly consumption estimate was derived. Acceptable reasons could include, but not limited to:

    • No smart meter, moved in less than 12 months ago,

    • Customer declined to download or provide access to interval data,

    • Customer does not have access to their online utility account credentials

    • GreenButton data was not accessible from the utility as downloading failed, etc.

  • On the CSLB form’s estimate, there can be no assumption on alternative scenarios for future usage. It must be based on the last 12-months. Alternative scenarios can be presented separately as long as the CSLB form is based on actual historical usage.

  • If you estimate every time, it’s possible the utilities will eventually reject it. See our Utility Enforcement section

  • Hourly usage can be collected through secure, third-party APIs such as UtilityAPI, Arcadia, and Bayou Energy or directly from the utilities in the customer’s online account.

Annual Solar Electricity Generation

5

Click Here

Estimated annual solar electricity generation:

  1. NREL's PVWatts® tool must be used for estimating annual solar electricity production

  2. For battery retrofit systems with existing PV, CPUC staff stated this field must also be completed. In this situation, contractors should make best efforts to use PVWatts to estimate PV production based on the age and condition of the existing PV system.

Before & After Utility Rate

5

Click Here

Enter the before solar rate plan and the after solar utility rate plan.

After solar rate plans for NEM 3 customers should be:

  • PG&E: E-ELEC

  • SCE: TOU-D-PRIME

  • SDGE: EV-TOU-5

The rate plans should be used in modeling the savings estimate including discounts like CARE, FERA, etc.

Estimated Bill Savings

6-7

Click Here

A solar provider must provide a 1-year electric bill savings estimate to every residential customer they intend to enter into a photovoltaic transaction with (except for new housing construction where a solar system is installed prior to sale) using the standardized inputs and assumptions defined by the CPUC and CSLB. Residential is defined by their electric rate class.

While there are 4 different fields for solar estimates, at least 1 must be completed.

  • If a Solar (no battery) system is planned, then a solar only savings estimate must be performed and provided. [page 7]

  • If a Solar+Storage system is planned, then a savings estimate must be complete with the battery optimized for maximizing billing savings. [page 6]

Solar + Storage estimate:

  • ”Required Estimate: Battery optimized for maximizing bill savings (battery is programmed to optimize bill savings by serving onsite load or exporting to the grid based on price signals).”

  • A self-consumption or backup only estimate is optional to complete in addition to maximizing for bill savings.

Name of Calculator Used

6-7

Click Here

In the Savings Estimate section there is a field called “Name of Calculator Used.”

  • Solar Only projects - Although, PV Watts calculates production, and not savings, the CPUC staff confirmed they are looking for PV Watts on solar only projects.

  • Solar+Storage projects - Resolution E-5364, “It is reasonable that, for calculations where battery energy storage is involved, the solar provider may select a calculator of their choosing, and that the name of the calculator be listed for transparency on the CSLB Disclosure Document.”

  • If a proprietary software tool is used for the savings estimate, CALSSA advises to type the internal name of your software tool and “Name -- proprietary software.” If you don’t have a name yet for your internal calculator, create one.

Alternative Estimates

Other

Click Here

This is a 1-year electric bill savings estimate not a Net or Total Savings. The cost of the solar system (whether monthly payments or an upfront purchase) should not be factored on the form.

Alternative estimates are allowed outside of the form including long-term savings estimates (e.g. 25 years).

Rate Escalations

Other

Click Here

Solar contractors may still present their own multi-year savings estimate (e.g. 25 year savings) in addition to the Solar Energy System Supporting Information document.

By law, any escalator used must be capped at the current average annual escalation rate that is posted in the most recent Solar Consumer Protection Guide (currently 4%).

  • The 1-year savings estimate may not include a rate escalation.

Alternative Consumption Scenarios

Other

Click Here

Solar providers may present alternative savings calculations with different inputs and assumptions, such as, alternative scenarios of future energy consumption (e.g. buying an EV or heat pump) as long as the alternative savings estimate is presented side-by-side with the CSLB savings estimate, and “accompanied by a clear explanation that they are not based on the customer’s historic consumption.”

  • The CSLB form estimate must use actual historical usage for the last 12-months.

Need more tips? Review LightReach's slide deck and ask your Relationship Manager

Utility Enforcement

  • Interconnection portals will require the form to be uploaded beginning Nov 1, 2025

  • Utilities are required to audit 100 interconnection applications semi-annually

  • Key inputs and assumptions are to be posted on utility websites

  • Data Retention - Contractors are to maintain key inputs and assumptions for 12 months after PTO

  • Fines, Penalties, and Citations could be authorized under the Commission’s Consumer Protection Enforcement Division (could be authorized, there are no current penalty standards)

  • The CPUC plans to make much of the data on the form publicly available for reporting purposes in an anonymized, aggregated format.

TBD - We are waiting to see what the exact enforcement from utilities will be. Utilities are required to post the standardized inputs and assumptions on their websites.

Potential Utility Audit Requirements

In Decision 20-08-001, August 6, 2020 and Attachment A & B the following was discussed as required to provide if the project is audited, but ultimately was not listed clearly in the Final Resolution E-5364.

“These key inputs and assumptions should include, at minimum:

  • Panel capacity (kW);

  • inverter capacity (kW);

  • tilt (degrees);

  • azimuth (degrees);

  • assumed inflation rate;

  • assumed discount rate;

  • and other inputs deemed necessary by Commission staff.

Solar providers must retain copies of all inputs and assumptions (i.e., both the standardized inputs and assumptions and any alternative inputs and assumptions used to develop alternative calculations or scenarios) used to calculate and present bill savings estimates to customers for at least 12 months following the permission to operate date.“

“We clarify that the electric utilities need not collect source code, but they must collect all inputs and assumptions used (including, for instance, shading reports), along with the programs used and a spreadsheet of the hourly data for at least 100 interconnection applications.”

A.

Required Project Types

  • Residential only

  • PV or PV+Storage Systems

  • Battery retrofit systems with existing PV

B.

Not Required Project Types

  • New Construction / New Homes without a residential utility account holder yet

  • All Municipal Utilities including LADWP, IID, & SMUD

  • Standalone Storage (no PV on the utility meter)

C.

Resources

D.

Acronyms

  • CALSSA - California Solar & Storage Industry Association

  • CPUC - California Public Utilities Commission

  • CSLB - California Contractor's State License Board

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