Southeastern Chester County Refuse Authority (SECCRA) v. Board of Supervisors of London Grove Township

In Southeastern Chester County Refuse Authority (SECCRA) v. Board of Supervisors of London Grove Township, 954 A.2d 732 (Pa. Cmwlth. 2008), the applicant did not expressly agree to an extension; however, at the initial hearing the applicant requested a continuance and then proceeded to participate in 18 hearings, on the record, spanning more than 16 months. The Court stated, "such active participation, which goes well beyond mere attendance, is inconsistent with an intention to stand on the right to a deemed approval and constitutes an implicit, on-the-record agreement to continue with the hearing process, despite the lateness of the initial hearing." 954 A.2d at 738.