41 Valley Associates v. Board of Supervisors of London Grove Township

882 A.2d 5, 2005 Pa. Commw. LEXIS 441
CourtCommonwealth Court of Pennsylvania
DecidedAugust 2, 2005
StatusPublished
Cited by12 cases

This text of 882 A.2d 5 (41 Valley Associates v. Board of Supervisors of London Grove Township) is published on Counsel Stack Legal Research, covering Commonwealth Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
41 Valley Associates v. Board of Supervisors of London Grove Township, 882 A.2d 5, 2005 Pa. Commw. LEXIS 441 (Pa. Ct. App. 2005).

Opinion

OPINION BY

Judge SIMPSON.

In this local agency appeal, we consider whether the Board of Supervisors of London Grove Township (Board) erred in rejecting 41 Valley Associates’ (Applicant) 1 proposal to include its property in an “agricultural security area” (ASA) pursuant to the Agricultural Area Security Law (Law). 2

I. Agricultural Area Security Law

The Law is designed to conserve and protect the Commonwealth’s agricultural lands as valued natural and ecological resources, and to encourage the development and improvement of agricultural lands for the production of food and other agricultural products. Section 2 of the Law, 3 P.S. § 902; Northwestern Lehigh Sch. Dist. v. Agric. Lands Condemnation Approval Bd., 134 Pa.Cmwlth. 291, 578 A.2d 614 (1990). 3

The Law establishes a specific process for the conservation of farmland. See Lenzi v. Agric. Land Preservation Bd., 144 Pa.Cmwlth. 571, 602 A.2d 396 (1992). The process begins when a landowner submits a proposal to the local governing body for creation of an ASA. Section 5 of the Law, 3 P.S. § 905(a). After a proposal is *9 submitted, the local governing body provides public notice of the request. 3 P.S. § 905(b). Comments and modifications are invited from other local government bodies affected, persons whose land is included in the ASA and neighboring landowners. Id.

The local planning commission reviews the proposal and advises the local governing body on the proposal’s potential impact on local planning policies and objectives. 3 P.S. § 905(d)(1), (2). The local governing body then gives notice of a public hearing to consider the creation of the ASA. Id.

At the public hearing, the local governing body must consider five “evaluation criteria” to determine whether inclusion in an ASA is appropriate:

(a) Factors to be considered. — The following factors shall be considered by the planning commission, advisory committee, and at any public hearing:
(1) Land proposed for inclusion in an [ASA] shall have soils which are conducive to agriculture. This factor will have been satisfied without further consideration if at least 50% in the aggregate of the land to be included in an [ASA] falls into one of the following categories: land whose soils are classified in Soil Conservation Service Capability Classes I through IV, excepting IV(e); land which falls within the Soil Conservation Service classification of ‘unique farm land’; or land whose soils do not meet Capability Classes I through IV but which is currently in active farm use and is being maintained in accordance with the soil erosion and sedimentation plan applicable to such land.
(2) Use of land proposed for inclusion in an [ASA] shall be compatible with local government unit comprehensive plans. Any zoning shall permit agricultural use but need not exclude other uses.
(3) The landowner may propose to include all of his land, regardless of zoning, in an [ASA],
(4) The land proposed for inclusion in the [ASA], and any additions which are proposed subsequently, shall be viable agricultural land.
(5) Additional factors to be considered are the extent and nature of farm improvements, anticipated trends in agricultural economic and technological conditions and any other matter which may be relevant.
(b) Resource materials. — In considering the viability factors as set forth in this section, various resource materials shall be used, including, but not limited to, the following:
(1) Soil surveys of the Pennsylvania State University.
(2) Soil surveys and other information provided by the National Cooperative Soil Survey.
(3) Soil survey maps prepared by the United States Soil Conservation Service.
(4) The United States census of agricultural categories of land use classes.
(5) Any other relevant published data, maps, charts, or results of soil or land use surveys made by any county, State or Federal agency.

Section 7 of the Law, 3 P.S. § 907 (emphasis added). See also 7 Pa.Code § 1381.26(a).

Following the public hearing and consideration of the evaluation criteria, the local governing body may adopt a proposal with or without modification. Section 8(a) of the Law, 3 P.S. § 908(a). Within 10 days of its decision to reject or modify a proposal, the governing body must provide the landowner a written decision explaining why the proposal was not adopted or was modified. 3 P.S. § 908(b). The written decision must include findings of fact, a *10 review of the evaluation criteria and a discussion of reasons for rejection or modification of the proposal. Id. Any party aggrieved by a local governing body’s decision concerning the creation of an ASA may appeal to the court of common pleas. Section 10 of the Law, 3 P.S. § 910.

After land is designated as an ASA, a legal description is filed with the recorder of deeds and indexed in a way that is sufficient to give notice to potential purchasers of the designated lands and also adjacent lands. 3 P.S. § 908(d). Every seven years, the local governing body is required to review an ASA and determine whether it will continue the protected status. Section 9(a) of the Law, 3 P.S. § 909(a).

The benefits and protections of having land designated as an ASA include: (i) municipalities must encourage the ASA by not enacting ordinances that would restrict farm structures or farm practices; (ii) a local ordinance defining or prohibiting a public nuisance must exclude from the definition of the nuisance any agricultural activity or operation conducted using normal farming operations within the ASA; (in) Commonwealth agencies with programs that might negatively affect farmers must conduct their programs in a manner that will encourage the continuance of viable agriculture in the ASA; (iv) entities seeking to acquire land in an ASA by eminent domain must obtain approval from the Agricultural Lands Condemnation Approval Board; and (v) the owner of land in an ASA comprised of 500 or more acres may be eligible to apply to sell an agricultural conservation easement to the Commonwealth, the county or a municipality. See Sections 11-13, 14.1 of the Law, 3 P.S. §§ 911-913, 914.1. 4 See also 7 Pa.Code § 1381.4.

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Bluebook (online)
882 A.2d 5, 2005 Pa. Commw. LEXIS 441, Counsel Stack Legal Research, https://law.counselstack.com/opinion/41-valley-associates-v-board-of-supervisors-of-london-grove-township-pacommwct-2005.