Last week, a divided Commonwealth Court of Pennsylvania judicial panel struck down the provisions of the recent Pennsylvania Oil and Gas legislation, known as "Act 13," that created statewide uniform zoning for purposes of oil and natural gas development in Pennsylvania as unconstitutional by a vote of 4–3. The entire judicial panel also held that the portions of Act 13, which authorized the DEP to grant a waiver of certain setback requirements from water bodies and wetlands, were null and void. This Reed Smith client alert summarizes and analyzes the July 26 court opinion, and provides guidance related to the future procedural path of the case.