The Fairfax County Board of Supervisors voted to re-adopt the Zoning Ordinance Modernization effort dubbed zMOD, based on recommendations from the Planning Commission. The Zoning Ordinance, which was established in March 2021, was invalidated by the Supreme Court of Virginia after it decided Berry v. Fairfax County Board of Supervisors on March 23, 2023.

For background, see McGuireWoods’ previous alerts on this issue, published March 25, 2021, and March 24, 2023.