Virginia Code

Va. Code Ann. § 15.2-2210 (2026)

Creation of local planning commissions; participation in planning district commissions or joint local commissions

✓ current as of May 2026
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Every locality shall by resolution or ordinance create a local planning commission in order to promote the orderly development of the locality and its environs. In accomplishing the objectives of § 15.2-2200 the local planning commissions shall serve primarily in an advisory capacity to the governing bodies.

Any locality may participate in a planning district commission in accordance with Chapter 42 (§ 15.2-4200 et seq.) of this title or a joint local commission in accordance with § 15.2-2219.

1975, c. 641, § 15.1-427.1; 1997, c. 587.

Notes of Decisions
Cited in 8 cases (3 in the last 5 years), 2000–2026 · leading case: James v. City of Falls Church, 694 S.E.2d 568 (Va. 2010).
James v. City of Falls Church, 694 S.E.2d 568 (Va. 2010). · cites it 2× “" Code § 15.2-2210. Thus, the Planning Commission is not an "administrative officer.”
Sinclair v. New Cingular Wireless Pcs, LLC, 727 S.E.2d 40 (Va. 2012). · cites it 2× “" Code § 15.2-2210. While the General Assembly describes planning commissions as "primarily" advisory bodies, id.”
Rowland v. Town Council of Warrenton (Va. 2020). · cites it 2× “The circuit court dismissed counts I and II finding that the relevant ordinance and its authorizing statute, Code § 15.2-2210, permit continued negotiations between a rezoning applicant and the locality following a review by the planning commission, which functions only in an…”
Stafford Cnty. v. D.R. Horton, Inc. (Va. 2021). · cites it 2× “2-2229 (setting forth the process for creating and amending the comprehensive plan).”
KSS One, LLC v. Henrico Cnty., Virginia, Bd. of Supervisors of Henrico Cnty. (Va. Ct. App. 2023). · cites it 2× “” Code § 15.2-2210. But the planning commission serves “primarily in an advisory capacity to the governing bodies.”
James R. Garrett v. Roanoke City Council (Va. Ct. App. 2026). · cites it 2× “By statute, commissions shall “[e]xercise general supervision of, and make regulations for, the administration of its affairs” and “[p]rescribe rules pertaining to its investigations and hearings.”
Sterling Land Corp. v. Plan. Comm'n, 51 Va. Cir. 307 (Loudoun Cir. Ct. 2000). · cites it 5× “It is agreed that the Town of Hamilton is a lawfully chartered locality and as such is required to create a local planning commission, which it has done, pursuant to Virginia Code § 15.2-2210. The Town has also enacted a Land Development and Subdivision Control Ordinance, most…”
In re July 31, 2013, Decision of Bd. of Zoning Appeals, 88 Va. Cir. 235 (Fairfax Cir. Ct. 2014). “See § 15.2-2210. Given this statutory framework, the fact that a Board of Supervisors may overrule the Planning Commission is not surprising, nor does it suggest that the BZA may not come to a different decision than the Planning Commission.”
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