In Plum Borough v. Zoning Hearing Board of the Borough of Plum, 310 A.3d 815 (Pa. Cmwlth. 2024), the Pennsylvania Commonwealth Court addressed several important issues in the realm of land use law, including the natural expansion doctrine and the need for zoning hearing boards to issue findings of fact in support of their decisions.

In January of this year, the Commonwealth Court reviewed a zoning hearing board’s decision to grant an application for expansion of a preexisting nonconforming use in Plum Borough v. Zoning Hearing Board of the Borough of Plum, 310 A.3d 815 (Pa. Cmwlth. 2024). By way of background, Penneco Environmental Solutions, LLC is the owner of the property located in Plum Borough, where it has operated a gas production well since 1989. In 2016, Penneco sought permission to operate an underground injection control (UIC) well on this property.