The Pennsylvania Supreme Court, applying the Surrick test, has held that a municipality can meet its fair share obligation by providing for some form or forms of multi-family dwellings, but a municipality need not provide for every conceivable subcategory of such dwellings.
In re Appeal of Elocin, Inc., 501 Pa. 348, 461 A.2d 771 (1983).
John R. Hanlon Jr.,
Municipalities - Exclusionary Zoning - Constitutionality - Ordinances Failing to Provide for Townhouses,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol23/iss1/11