The permanent line has a real, answerable gate
This isn't a vague "check with a lawyer" — it's a specific statute with a specific test, and a specific gap in that statute nobody has closed yet. Read this page before committing capital to Phase 2.
Does CCC1330941 + pending CBC cover this work?
Verdict: No — with one narrow exemption that may or may not apply
Florida Statute §489.113(3) requires roofing/building contractors to subcontract "all electrical work" to a licensed electrical contractor — there is no incidental-work carve-out for electrical, confirmed by CILB Declaratory Statement 2015-009 (Johannessen). Team Armored's roofing and pending building licenses do not, by themselves, authorize this work.Why it's in scope at all: §489.505(12) defines an electrical contractor as one who installs "electrical wiring, fixtures, appliances, apparatus… which generates, transmits, transforms, or utilizes electrical energy in any form." A permanently mounted LED channel is a fixture that utilizes electrical energy. It is in scope on the plain text — which is precisely why the Legislature had to write a separate carve-out for plug-in landscape lighting.
That carve-out is Fla. Stat. §489.503(24) — "This part does not apply to… A person who installs low-voltage landscape lighting that contains a factory-installed electrical cord with plug that does not require installation, wiring, or other modification to the electrical wiring of a structure."
Correction: plug-vs-hardwire is NOT the controlling test
An earlier draft of this plan treated "factory cord into an existing outlet" as the test that decides the question. It is not. Cord-and-plug is a necessary condition inside §489.503(24) — but the exemption is also limited by what kind of lighting it is: landscape lighting. Roofline and soffit lighting is not landscape lighting on a plain reading, and plugging it in does not change that. The exemption describes a different product. The permanent line cannot be built on §489.503(24).Seasonal — genuinely exempt
§489.503(5) exempts "the sale or installation of any finished products, materials, or articles of merchandise which are not actually fabricated into, and do not become a permanent fixed part of, the structure." Temporary lights on clips, removed in January, are the textbook case. No electrical licence, no interpretation required.
Permanent — the same exemption fails
A channel screwed to the fascia and left there is a permanent fixed part of the structure — §489.503(5) fails by its own terms. And §489.503(24) fails on "landscape." Neither exemption reaches permanent roofline lighting. It requires a licence.
You do not need an unlimited EC
The Electrical Contractors' Licensing Board issues a specialty category drawn almost exactly around this business.
ES / ET — Lighting Maintenance Specialty Electrical Contractor
F.A.C. 61G6-7.001(1): scope is "limited to the installation, repair, alteration, or replacement of lighting fixtures in or on buildings, signs, billboards, roadways, streets, parking lots and other similar structures. However, the scope… does not include the provision of, or work beyond, the last electrical supplying source, outlet, or disconnecting means."
Read the second sentence: the scope limit is the plug-in-only model. Install fixtures, connect at an existing outlet, never touch the circuit. DBPR lists both a certified (ES, statewide) and registered (ET, county-limited) version.
Correction: Limited Energy is the wrong specialty
An earlier draft named ES-Limited-Energy as the fallback. That category (61G6-7.001(4)) caps at 98 volts, which sounds right for a 12–24V system — but its scope is expressly cross-referenced to §489.505(7), which covers alarm, data, proprietary video, central vacuum, surveillance cameras and electric locks. It is a communications category, not a lighting one. Lighting Maintenance is the correct fit.| Path | What it costs | Available | Exposure |
|---|---|---|---|
| A · Subcontract the electrical Crews mount channel; licensed EC handles the connection | Sub margin per job | Today | None. §489.113(3) already requires this of a CBC |
| B · Qualify the business with an ES holder Primary qualifying agent under §489.505(14) — need not be Ryan | ~$690 + the arrangement | Needs a hire/partner | None once qualified |
| C · Plug-in only, rely on §489.503(24) | $0 | Today | Rests on "landscape" covering roofline — it likely doesn't |
What path C risks — §489.531
Unlicensed contracting is a first-degree misdemeanor. A second offence is a third-degree felony. So is a first offence committed during a Governor-declared state of emergency — and for a Florida roofing company, declared emergencies overlap the busiest windows of the year. Local code enforcement may separately cite up to $2,000. Note also §489.531(1)(b): it is a violation to advertise as available to do electrical work without the licence — the marketing site is exposure before a single install.The franchises don't answer this for you
Trimlight, Gemstone, and JellyFish dealer pages do not require a state license to become a dealer, and no Florida dealer site publishes an EC/ES license number. Only Gemstone directly addresses it, and only to punt: licensing "varies by state... reviewed during onboarding." That is not a green light — it's the franchise pushing the compliance question onto the dealer.
A separate question from state licensing — and Pinellas is the hard case
| County | Low-voltage exterior lighting permit |
|---|---|
| Hillsborough | Explicit exemption — no permit for low-voltage systems on an existing single-family home if labor + materials ≤ $5,000 |
| Pasco | Ambiguous — "Residential Low Voltage" exemption lists cable/internet/security as examples; doesn't clearly include lighting, no dollar cap stated |
| Pinellas (Palm Harbor — home jurisdiction) | No exemption found — only a general "$500-or-requires-inspection" threshold, which this job likely triggers. Most likely of the three to require a permit, and it's home turf. |
What to actually do before Phase 2 capital moves
- Call the ECLB at 850-487-1395 with two specific questions: (1) does permanent low-voltage roofline lighting, cord-and-plug into an existing exterior receptacle, require an ES Lighting Maintenance licence — or does §489.503(24) reach it? (2) Is the ET registered route still available in Pinellas after §163.211? Both are answerable on one call, and (1) decides whether permanent is a $690-plus-a-qualifier problem or a subcontract-forever problem.
- Call Pinellas BDRS (727-464-3888) and Pasco BCS (727-847-8126 opt. 5) to confirm local permit treatment before selling anything.
- Usable today, zero licensing risk: run the seasonal line under §489.503(5), and subcontract the electrical on any permanent job (Path A). Neither requires waiting on a declaratory statement.
Why this doesn't block season one
Seasonal has a clean, cited statutory exemption — §489.503(5), temporary installs that never become a permanent fixed part of the structure. It needs no electrical licence and no interpretation. Season one can run entirely on seasonal while the permanent licensing path gets resolved — see Phasing.One door that is already closed
§163.211 preempts occupational licensing to the state, and grandfathered local licences expired 1 July 2025. There is no "get a Pinellas specialty card instead" workaround to go find. It also raises a real question about whether the ET registered route still functions, since registration requires a local competency card counties may no longer issue — unresolved, and question (2) above.Verification status — read before relying on this page
The statutes and board rules cited here were read directly from primary sources (Online Sunshine, F.A.C., DBPR) and are quoted verbatim. The two declaratory statements below — CILB 2015-009 (Johannessen) and ECLB 2006-023 — carried over from an earlier draft and have NOT been independently verified. Do not rely on them. Nothing on this page is legal advice; confirm with a Florida construction attorney before committing capital.Sources: Fla. Stat. §489.503(5), §489.503(24), §489.505(12), §489.505(19), §489.113(3), §489.531 · Fla. Stat. §163.211 — preemption of local occupational licensing · F.A.C. 61G6-7.001(1) — Lighting Maintenance Specialty scope · DBPR Electrical Contractors FAQ — licence types, fees, experience · UNVERIFIED — CILB Decl. Statement 2015-009; ECLB Decl. Statement 2006-023 · Hillsborough / Pasco / Pinellas county permit pages
Not gating, but not free either
Independent/OEM supply path
Bulk pixel-LED sourcing direct from China (the two vendors named across every installer forum) has documented failure incidents — a 6% (15/250) bulk-order failure rate and a reported pixel-fire. The applicable listing standard for a permanent install is UL 2108/8750, not the UL 588 rating cheap "holiday" strip carries. Independent listing typically runs $3,000–$10,000+ per product family, and skipping it risks a voided liability policy.
"Salt-air resistant" claims don't survive the warranty fine print
Oelo dealer marketing pitches coastal/salt-air suitability, but Oelo's own warranty text explicitly excludes "corrosive environment installations" from coverage. None of the five brands' own copy uses "UL file number" — every UL/ETL claim is a marketing assertion, not a database-checkable certificate. For a Palm Harbor coastal install, verify this directly against the actual dealer agreement before it's a customer-facing claim.
Territory may already be spoken for
Gemstone already runs a location page naming Palm Harbor specifically, with an active Oldsmar dealer (Outdoor Lighting Perspectives, Pinellas County). If a franchise/dealer path is chosen, confirm territory availability before assuming Tampa Bay is open — see Market.
Cash-flow timing
Inventory buy precedes revenue by roughly two months. Sales can and should open before inventory lands — deposits fund the buy — but the sequencing has to be deliberate, not accidental.
No verified "roofer added lighting" case study
No independent trade-press article documents a real roofing company's before/after financials from adding a permanent lighting division. The only data points are vendor testimonials with no dollar figures attached. This plan's projections are a model, not a proven pattern.