41 Valley Associates v. Board of Supervisors of London Grove Township – Case Brief Summary (Pennsylvania)

In 41 Valley Associates v. Board of Supervisors of London Grove Township, 882 A.2d 5 (Pa. Cmwlth. 2005), the Court considered whether a proposed agricultural security area (ASA) met the requirement of the Agricultural Area Security Law that the use of land proposed for inclusion in an ASA "shall be compatible with local government unit comprehensive plans."

The Court concluded that this language addresses whether the proposed land is viable agricultural land from a legal viewpoint.

Agricultural uses should be consistent with present zoning. In addition, agricultural uses should be consistent with future zoning, as best estimated in the comprehensive plan. 41 Valley Assocs., 882 A.2d at 14.

Applying this interpretation of the statutory language, the Court looked at the map of future uses for the property.

Ultimately, we concluded the governing body erred when it departed from analyzing discrete and objective criteria relating to the current and future zoning for the property and focused instead on the goals of the comprehensive plan. Id.