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Zoning Bulletin March 25, 2016 I Volume 10 ( Issue 6 <br />Orlandi was entitled to have the Environmental Division rule on the <br />merits of the application, regardless of whether or not the application <br />was deemed -approved. Since the Supreme Court of Vermont had af- <br />firmed the Environmental Division's decision on the merits of the ap- <br />plication, it determined that it need not address the arguments <br />concerning the deemed -approval remedy because the resolution <br />would not affect the court's decision on the merits of the zoning <br />application. <br />See also: In re Trahan, 184 Vt. 262, 2008 VT 90, 958 A.2d 665 <br />(2008). <br />Zoning News from Around the <br />Nation <br />CALIFORNIA <br />Residents of a low-income southwest Fresno neighborhood and <br />the nonprofit association Familias Addams Por Un Mejor Futuro are <br />reportedly suing the city of Fresno for failing to comply with zoning <br />laws to identify land for low-income multifamily housing. The <br />lawsuit alleges that the city "failed to rezone 700 acres for develop- <br />ment of multifamily affordable housing that was in Fresno's 2009 <br />housing element." The lawsuit also claims that the city failed to meet <br />a deadline on December. 31 to revise the housing element (a require- <br />ment of a city general plan) to include additional land for affordable <br />housing to meet needs through 2023. The lawsuit further alleges that <br />the city's zoning policies are discriminatory, "denying housing op- <br />portunities to people of low incomes, racial and ethnic minorities, <br />families with children and female -headed households in violation of <br />state law." <br />Source: The Fresno Bee; www.fresnobee.coin <br />FLORIDA <br />The state House Transportation & Economic Development Ap- <br />propriations Subcommittee recently approved a proposal—HB <br />1379 that would update the state's Airport Zoning Law of 1945. <br />The bill would "modernize[ ] the rules regulating airspace and land <br />use." Among other things, the bill "provides that existing, planned <br />and proposed facilities at public -use airports contained in the master <br />plan will be protected from airport hazards." Reportedly, the bill now <br />heads to the House Economic Affairs Committee. <br />Source: Florida Politics; http://floridapolitics.com <br />© 2016 Thomson Reuters 11 <br />