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Zoning Bulletin May 25, 2018 I Volume 12 I Issue 10 <br />ing"; and such approved meeting minutes to be made "open to public <br />inspection, but in no case later an immediately following [the board's] <br />next regular meeting." (See O.C.G.A. §§ 50-14-1(e)(2)(A) and 50-14- <br />1-(e)(2)(B)•) <br />Applying Georgia's Open Meeting Act's procedural requirements to <br />the case at hand, the Eleventh Circuit found that the Board had "ple- <br />nary power over the August 5 minutes: it could approve the minutes, <br />revise them, or postpone its approval decision until the next month's <br />meeting in October." As it turned out, at its September 2, 2014 meet- <br />ing, the Board approved the August 5 minutes in full. This, concluded <br />the court, was when the Board's denial of the Verizon's Permit became <br />a "final action," starting the TCA's 30-day statute of limitations period. <br />In other words, it was at the September 2 meeting that the Board ap- <br />proved the August 5 meeting minutes and thus "the Board's `decision - <br />making process' was . . . consummated, and the relevant legal conse- <br />quences under the TCA [flowed]." "Verizon's action, filed on <br />September 24, was therefore timely," concluded the court. Accord- <br />ingly, the District Court erred in dismissing Verizon's case. <br />See also: T-Mobile South, LLC v. City of Roswell, Ga., 135 S. Ct. <br />808, 190 L. Ed. 2d 679 (2015). <br />See also: Bennett v. Spear, 520 U.S. 154, 177-78, 117 S. Ct. 1154, <br />137 L. Ed. 2d 281, 44 Env't. Rep. Cas. (BNA) 1161, 27 Envtl. L. Rep. <br />20824 (1997). <br />Zoning News from Around the <br />Nation <br />CALIFORNIA <br />In early April 2018, amendments were made to the housing transit <br />bill —Senate Bill 827—which would allow for construction of taller <br />residential buildings near public transportation stations. Among the <br />amendments: the "maximum height of buildings that could be built <br />under the bill has been reduced to five stories from eight"; and the ef- <br />fective date of the bill, should it become law, would be 2012 instead of <br />2019. The bill was expected to go before its first committee hearing on <br />April 17. <br />Source: Curbed San Francisco; htws://sf.curbed.com <br />PENNSYLVANIA <br />In early April, the Philadelphia City Council announced a "package <br />of affordable housing bills," which includes new "inclusionary zoning <br />© 2018 Thomson Reuters 11 <br />