Stakeholder work group: who's at the table
HB 395 created a formal stakeholder process at the SCC to develop the implementation rules. Here's who's participating, what's been decided, and what's still being worked out heading into the final months before January 2027.
Direct answer
The Virginia SCC convened an HB 395 stakeholder working group under docket PUR-2025-00147 in September 2025. The group includes representatives from major utilities, solar manufacturers, tenant and landlord associations, and consumer advocacy organizations. Its primary deliverables are the official tenant notification form and the manufacturer disclosure label specification, both due January 1, 2027. Public meetings are open to observers; documents are filed on the public docket.
Who's at the table
The SCC constituted the working group with a deliberate mix of perspectives: the utilities that must manage the grid impact of behind-the-meter generation, the manufacturers and retailers who need clear product standards, the property owners and associations subject to the new restrictions, and the consumer advocates and legal-aid organizations representing renters and HOA residents.
| Participant category | Representatives (as of July 2026) | Primary interest |
|---|---|---|
| Investor-owned utilities | Dominion Energy Virginia, Appalachian Power Company | Notification process, meter behavior, backfeed rules |
| Electric cooperatives | NOVEC, Rappahannock Electric, BARC Electric | Co-op-specific implementation, member notification |
| Plug-in solar manufacturers | Three major OEMs (names withheld per SCC practice) | UL 3700 label spec, disclosure label format |
| Landlord associations | Virginia Apartment Management Association (VAMA) | Tenant notice format, reasonable restriction definitions |
| HOA/condo associations | Community Associations Institute — Virginia (CAI-VA) | HOA authority limits, architectural review process |
| Consumer/tenant advocates | Virginia Legal Aid Society, Virginia Poverty Law Center | Tenant rights clarity, waiver prohibition enforcement |
| SCC staff | Division of Public Utility Regulation (DPUR) | Process facilitation, regulatory drafting |
The SCC chair appointed a neutral facilitator from outside state government to run meetings, manage the agenda, and draft working documents. Meeting minutes are filed to the public docket within two weeks of each meeting.
What the group is deciding
The working group's formal mandate covers four implementation questions left open by the statute:
Notification form format and content. What fields the official tenant-to-landlord notification form must include, and how to handle situations where required information (e.g., the landlord's unit count) isn't available to the tenant. The June 2026 draft resolves most of this; the remaining question is whether utility notification confirmation should be mandatory or optional on the form.
Manufacturer disclosure label specification. The exact format, dimensions, required text, and certification number format for the disclosure label that must appear on all HB 395-compliant products sold in Virginia after July 1, 2026. Draft finalized in May 2026; awaiting SCC staff review before publication.
Utility voluntary notification process. The logistics of how each utility wants customers to submit voluntary notifications — online forms, phone, mail — and what happens with that information. Dominion and APCo have both circulated their draft processes; co-ops are still developing theirs.
Incremental insurance risk standard. HB 395 limits HOA insurance requirements to the "incremental risk" of the solar system. The working group is developing guidance on what that means in practice — the draft guidance suggests relying on the UL 3700 certification as establishing the base risk level and requiring any insurance mandate above a modest threshold to be justified by a documented risk assessment.
Meeting history: what's been settled
The working group has met approximately monthly since September 2025. Key decisions from the docket record:
- September 2025: Working group constituted; agenda confirmed; facilitator appointed.
- October 2025: First draft of notification form framework discussed. Decision to not require tenant to verify landlord unit count on the form — tenant represents only that the system is compliant; landlord threshold question is handled by statute, not the form.
- November–December 2025: Manufacturer label specification developed. UL 3700 certification number format confirmed; disclosure statement language agreed.
- January–February 2026: Utility notification process design. Dominion commits to online form; APCo commits to phone and online options; co-ops agree to develop individual processes.
- March–April 2026: Second draft notification form circulated. Utility notification checkbox added; form length reduced from two pages to one.
- May 2026: Manufacturer label specification finalized and submitted to SCC staff for review. Expected to be published as draft regulation by September 2026.
- June 2026: Third draft notification form circulated. Most outstanding issues resolved. Insurance risk guidance framework presented; full draft expected August 2026.
Remaining schedule
Based on the SCC's stated timeline and the working group's progress as of mid-2026, the remaining schedule looks approximately like this:
- August 2026: Insurance risk guidance draft circulated to working group members; public comment period opens for manufacturer label specification.
- September–October 2026: Public comment period on notification form draft. Working group reviews comments and prepares final recommendations.
- November 2026: SCC staff finalizes notification form and label specification based on working group recommendations and public comments.
- December 2026: Final form and label published on SCC website; implementation materials distributed to utilities, property management associations, and legal-aid organizations.
- January 1, 2027: Statutory deadline for publication. Full consumer protections take effect simultaneously.
How to follow the process
The SCC's public docket system at scc.virginia.gov contains every document filed in PUR-2025-00147, including meeting notices, agendas, minutes, draft forms, and public comments. The docket is searchable; filtering by document type makes it manageable.
Public comments can be filed directly with the SCC during designated comment periods. The comment period on the notification form draft is expected to open in fall 2026. Consumer advocates, tenant organizations, and individual renters are all entitled to comment.
Working group meetings are open to public observers but not to public participation during the meeting itself. Observers can attend in person at the SCC's Richmond offices or (for some meetings) via webinar. Meeting notices are posted to the docket at least a week in advance.
Common questions
Can the public comment on the notification form?
Yes — the SCC is required to open a public comment period before finalizing the form and label specification. That period is expected in fall 2026. Comments can be submitted through the SCC's docket system, by mail, or through consumer advocacy organizations that participate in the process.
What if the working group can't reach consensus?
The working group operates by consensus where possible, but the SCC staff has final authority over the form and label specification. If participants can't agree on an issue, SCC staff makes the final call — subject to the statutory limits of HB 395 and the SCC's delegated authority.
Will the working group continue after January 2027?
The working group's formal mandate runs through the publication of the official form and label specification. Whether the SCC reconvenes it — for example, to address implementation questions that arise after January 2027 — is at the SCC's discretion. HB 395 doesn't mandate a permanent advisory body.
Does the working group have any power to change what landlords can do?
No — its authority is limited to implementing guidance and standardized forms. The working group cannot expand or narrow the statutory rights established in HB 395. Those are set by the Virginia General Assembly; only the legislature can modify them.
Sources: Virginia HB 395 (2025 Session); SCC Docket PUR-2025-00147; SCC working group meeting minutes (September 2025–June 2026, publicly filed); Virginia SCC Division of Public Utility Regulation.
This article is for general information and does not constitute legal advice. For guidance on a specific situation, consult a Virginia-licensed attorney or your local legal aid office.
Last updated: July 31, 2026
Related Reading
- Read the full legislative breakdown in our analysis of the statutory HB 395 framework.
- Follow official filing updates on our SCC notification form tracker.
- Review early stakeholder meetings in our coverage of the initial opening of the SCC work group.
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