Robertson discusses Pennsylvania legislature's Act 13, enacted in February 12, 2012. This Act was an attempt to revamp its oil and gas laws and also to pre-empt local regulation of oil and gas development. Like the Ohio Legislature, Pennsylvania's legislature was very clear about its intent to preempt local regulation of oil and gas operations. But, in July 2012, in Robinson Township v. Commonwealth of Pennsylvania, the Commonwealth Court (an intermediate court) held that the provisions of Act 13 that would override local zoning and environmental laws are unconstitutional, and therefore null and void. Those provisions, the court held, violated environmental rights provision in the Pennsylvania constitution. The court focused on the fact that denying localities the right to impose land use and zoning restrictions designed to protect their local environments violates their constitutional duty to protect the environment.