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Planning Commissions

This page provides information about local government planning commissions in Washington State, including relevant statutes and court decisions, examples of planning commission rules and bylaws, and recommended resources.

Overview

The planning commission provides citizen review and recommendations on planning-related matters to the city, town, or county council, or county board of commissioners.

Planning commissions are usually involved in reviewing proposed revisions and updates to local comprehensive plans and land use regulations, such as the zoning or subdivision code. This role is typically advisory to the local governing body, with the planning commission forwarding a recommended plan (or ordinance) to the governing body for consideration.

Planning commissions may occasionally serve as the "citizens advisory committee" for a comprehensive plan update, although such committees more commonly consist of different interest groups within a community.

A third, but increasingly rare, function of a planning commission involves reviewing some types of development proposals, such as conditional use permit applications. Not all planning commissions are involved in the development review function. In Washington State, when planning commissions perform this role, typically the commission recommends a decision that the local governing body can approve, approve with conditions, or deny. In some jurisdictions, the planning commission or hearing examiner may hold the public hearing and make a decision on certain types of land use actions. In these cases, the planning commission's decision would be subject to appeal to the local governing body.

Below is an example of a planning commission that reviews development proposals:

Statutes

Public Meeting Procedures

Planning Commissions will usually hold regularly scheduled public meetings and conduct public hearings as part of their official duties. Below are several MRSC pages discussing public meeting procedures and requirements:

Examples of Planning Commission Codes

Below are examples of planning commission codes for code cities, non-code cities/towns, and counties that are presented separately because of different statutory requirements.

Code Cities

Non-Code Cities

County

Examples of Planning Commission Bylaws and Rules

Cities

Counties

Selected Court Decisions

Below is a selection of court decisions that are relevant to the role of the planning commission.

Brinnon Group v. Jefferson County (2011) – Held that the county’s legislative body can make changes to the comprehensive plan amendment recommended by the county planning commission without referring the proposed change or alteration to the planning commission for further public comment and redrafting before the revised plan amendment may be adopted if the public already has had a full opportunity to comment on the proposed change or alteration.

The court also held that a county planning commission's delay in providing the signatures of its chairperson and secretary on a comprehensive plan map containing revisions recommended to the county's legislative body for its consideration and approval as required by RCW 36.70.400 does not render the legislative body's approval of the plan void if the record shows that the delay did not prevent the legislative body from understanding the planning commission's recommendation.

Citizens v. Mercer Island (2001) – Addresses whether the city council exceeded its authority, as an appellate tribunal, when it interpreted and applied zoning variance criteria regarding visual impacts differently than the commission. The court held that the municipal code did not preclude the council from finding facts, that the council was allowed to modify the decision of the commission, but that the council did not disregard or change the basic facts on which the planning commission relied.

Concerned Coupeville Citizens v. Town of Coupeville (1991), review denied – The court decided:

It is clear that under RCW 35.63.060, a planning commission "may act as the research and fact-finding agency of the municipality." A commission acting in such a capacity, however, does not possess fact-finding powers that are final and unreviewable by the municipality. This is made clear by the terms of RCW 35.63.120, which empowers the council or board to "modify or disaffirm any decision of the commission.

Buchsieb/Danard, Inc. v. Skagit County (1982), affirmed (1983) – Held that the Planning Enabling Act, chapter 36.70 RCW, provides that reports and recommendations of the planning commission relating to plats, subdivisions and other "official controls" are advisory only, the final decision as to such controls resting with the county board.

D.E.B.T., Ltd. v. Board of Clallam County Comm'rs (1979) – Addressed whether the board of county commissioners had authority to reject the recommendation of the planning commission and require that the proposed development comply with the State Environmental Policy Act (SEPA). The court noted that chapter 35.63 RCW, which authorizes the creation of planning commissions and the adoption of comprehensive plans by municipalities within the state, gives to planning commissions only the power to make recommendations to the board of county commissioners (RCW 35.63.060 and RCW 35.63.100). The adoption or rejection of such recommendations is in the sound discretion of the board, and the board may disaffirm any decision of the planning commission (RCW 35.63.120).

Lutz v. Longview (1974) – Addressed the separation of functions and powers of the planning commission and the city council, holding that a city council cannot delegate its legislative authority to adopt zoning modifications (where the city council allowed the planning department to adopt a new public utility district zone that differed from existing zones) to the planning commission.

Chrobuck v. Snohomish County (1971) – Confirmed that the appearance of fairness doctrine applies to planning commissions, requiring that their quasi-judicial proceedings, including their hearings and fact-finding processes, be fair and impartial.

Recommended Resources

In addition to MRSC's extensive resources on Planning, Economic Development, Environment, and Transportation, below are some other organizations and resources for planning commissioners and staff that work with these commissions.

Washington State

National

  • American Planning Association (APA) – Includes publications, trainings, applied research, and more
  • Congress for the New Urbanism – Provides resources, education, and technical assistance to support walkable, mixed-use neighborhoods
  • Planetizen – Public-interest information exchange for the urban planning, design, and development community. It is a one-stop source for urban planning news, commentary, interviews, event coverage, book reviews, announcements, jobs, consultant listings, training, and more.
  • Western Planner – Publication of planners’ networking group that represents 13 state planning associations in the western U.S. and Great Plains.

Last Modified: August 21, 2024