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October 10, 2014 I Volume 8 I Issue 19 Zoning Bulletin <br />requirements so that she could build on her property. Her zoning variance application was <br />denied by the Town. In this decision, the Second Circuit noted that even if Holt were to as- <br />sert that she had exhausted administrative remedies after the filing of her suit, that would <br />be immaterial to the court's conclusion. The Second Circuit noted that the Connecticut <br />Supreme Court has "recognized on multiple occasions that an aggrieved party must <br />exhaust its administrative remedies before it may seek judicial relief." <br />Zoning News from Around the Nation <br />PENNSYLVANIA <br />West Goshen Township, in Chester County, recently passed a series of amend- <br />ments to its zoning laws related to natural gas pipelines. Under the amendments, <br />pipelines are restricted to industrial areas, and must be proven to be a "necessary <br />public utility." <br />Source: Statelmpact; http://stateimpact.nvr.org <br />Robinson Township residents have challenged the validity of the township's <br />zoning amendment, passed last month, which opened up more areas to drilling <br />companies. The amendment at issue "replaced the special exception process for <br />considering oil and gas applications with a permitted use or conditional use pro- <br />cess, depending on the zoning district." Under the amendment, oil and gas <br />companies that meet a list of uniform requirements outlined by the township may <br />drill land in certain zoning districts, while in other districts a conditional use <br />permit is required for drilling. The residents challenge reportedly alleges that the <br />amendments: violate the Environmental Rights Amendment in the Pennsylvania <br />Constitution; create entirely new zoning districts; and violate property rights. <br />Source: Observer -Reporter; www.observer-revorter.com <br />12 ©2014 Thomson Reuters <br />