Sub panel sizing question - is this code compliant?

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Bloomj

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Background - I am installing solar and need to backfeed it to my service. Plan to do that via 40a 2-pole breaker.

My main service comes into a SquareD 200a CSED. This main panel supplies 4 2-pole breakers, 50,40,30,25a all for my HVAC equipment and has no more spaces. Then feed through lugs supply a panel for the rest of the home on the other side of the building.

In in order to add the 40a breaker for solar my thought was to install a sub panel next to the main service panel. Remove one of the 4 existing breakers and put in a 100A breaker and then install the breaker I removed in the new added sub panel. Then I would have room to add more circuits as needed. I would like to end up with the solar breaker, moved breaker, a single pole 15a, and a 20a 2 pole to allow me to run an energy monitor such as Sense.

Can i do this?

Thanks!
 
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