The Bid That Crossed Into Line Voltage
Cascade Low Voltage & Data wins a $68,000 contract for a tenant improvement. The plans include 40 Cat 6A data drops, a 24-camera IP system, a 12-zone fire alarm, two 120-volt 20-ampere circuits for a server rack, and a new 100-ampere subpanel to feed those circuits. Cascade holds only a low-voltage license. Its owner says 'we do everything up to the panel' and plans to have a journeyman electrician employee do the 120-volt work under Cascade's license. Cascade also intends to subcontract the fire alarm to a friend who is not licensed but 'has done it for years.' The general contractor asks for Cascade's license and permit plan. The plans are already approved by the city, and the GC wants work to start Monday.
1. Which portions of the scope can Cascade legally perform under its low-voltage license, and which require a different license or contractor? Explain the line.
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Read the scope against the license classification. Cascade's low-voltage license covers low-voltage wiring systems such as data cabling, cameras, access control, and similar signal or control work, subject to permit and code requirements. It does not cover:
- the two 120-volt 20-ampere circuits;
- the 100-ampere subpanel;
- any line-voltage branch-circuit wiring, terminations, or panel work.
Those are electrical contractor scope and require a licensed electrical contractor and electrical permits and inspections. Employing a journeyman electrician does not convert Cascade's license into an electrical contractor license. The license is held by the company, and the qualifier must be qualified for that classification. The fire alarm is a closer call: low-voltage fire alarm work may be within a low-voltage license only if the company meets the applicable fire alarm requirements and uses properly licensed or certified personnel. Subcontracting it to an unlicensed friend is not a workaround. The GC should require a license and permit plan for each scope item.
2. What are the regulatory and discipline consequences if Cascade proceeds as planned, and what should it do instead?
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If Cascade proceeds as planned, it risks:
- Unlicensed contracting for the 120-volt circuits and subpanel, exposed to Board citations, cease-and-desist orders, fines, and possible criminal referral;
- Permit and inspection violations for work done without electrical permits;
- Discipline for the company and its qualifier for exceeding the license classification, aiding unlicensed subcontracting, and failing to supervise;
- Contract problems: the owner may terminate, refuse payment for illegal work, or require removal; insurers may deny claims.
The proper course is to revise the contract or issue a written clarification: Cascade performs the data, cameras, and access control; a licensed electrical contractor performs the 120-volt circuits and subpanel with permits; the fire alarm is subcontracted to a properly licensed and, if required, certified fire alarm contractor. Cascade should obtain copies of the subcontractors' licenses and permits before work starts and notify the GC in writing. If the GC will not accept that split, Cascade should decline the out-of-scope work rather than 'do everything up to the panel.' City approval of the plans does not expand Cascade's license.