In a recently published Law360 article "In Pa., Is Payne A Pain Or Still The Law Of The Land?", John F. Povilaitis and Alan M. Seltzer, shareholders in Buchanan’s energy practice, ponder  the continued viability of the 1973 decision in Payne v. Kassab which for decades provided the legal standard in Pennsylvania for evaluating claimed violations of the Environmental Rights Amendment to the Pa Constitution,  until seemingly limited in the Pa Supreme Court’s controversial 2013 plurality decision in Robinson Township  invalidating substantial portions of Act 13 of 2012 , 58 P.S. § 2301 et seq.  

The full article is available here