The Pennsylvania Supreme Court has held that the Commonwealth of Pennsylvania can take land set aside as a public common and use it to improve a public highway without violating the constitutional duty to conserve and maintain public natural resources for the benefit of all.
Payne v. Kassab, 468 Pa. 226, 361 A.2d 263 (1976).
James R. Walsh,
Environmental Law - Article I, Section 27 of the Pennslyvania Constitution - Acquisition of Public Parkland,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol16/iss1/12