The defendant owned a three-acre property that used to be a quarry but was presently used to convert tree stumps, yard waste and logs into mulch. The plaintiff township notified the defendant that the mulching activity violated a township ordinance for operating non-permitted mill, warehouse and wholesale uses on the property. After notice and a hearing, the zoning board determined that the mulching activity violated the ordinance as a manufacturing use. The trial court affirmed the board's decision on the basis that the raw materials used in making the mulch did not originate on the property and none of the resulting mulch was used on the property. On further appeal, the appellate court affirmed. The court determined that the activity was not protected under state (PA) Municipalities Planning Code (MPC) or the right-to-farm act. The activity failed to meet the definition of "forestry" or "silviculture" under the MPC and did not involve the production of agricultural crops and commodities. Likewise, the appellate court determined that the mulching activity was not protected by the right-to-farm law because it didn't fit within that statute's definition of "agricultural activity." Tinicum Township v. Nowicki, et al., No. 2176 C.D. 2012, 2014 Pa. Commw. LEXIS 440 (Comw. Ct. Pa. Sept. 9, 2014).