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6-15 PROCEDURES ~ 6.03[1] The standards for granting a variance are often no more specific than the general purpose of variances itself. The language of the cases concerning variances reflect these broad standards: The sole justification for the grant of a variance is that a strict application of the terms of the zoning statute will result in an unnecessary hardship and even then, the variance can be granted only if the spirit of the ordinance may be observed, the public health, the public safety and the general welfare secured and substantial justice done. . . . IT]he "hardship" . . . must be "unnecessary," not a "mere" hardship, as well as unique or peculiar to Ithe property in- volved]. . . .76 A variance is said to be proper only if it poses no substantial detriment to the public or to immediate neighbors77 and the property has hardship characteristics which render it eligible.78 These same standards recur in various forms among state zoning enabling acts79 and local zoning ordinances.8o A distinction has arisen between the requisite standards for an area and use variance. In this regard, proof of practical difficulties is said to be sufficient to justify an area variance; whereas a finding of a presumably more demanding standard, unnecessary hardship, is required to sustain a use variance.81 The particular distinction is absent from the Standard State Zoning Enabling Act, and many state enabling acts and local ordinances allow variances for either "practical difficulties" or "unnecessary hardship. "82 Nevertheless, while these terms may often be used interchangeably there is considerable support for considering them as separate and distinct standards. When statutorily undefined, the standards are open to broad interpretation and application. They are discussed in more detail in 76 Richman v. Zoning Bd. of Adjustment, 391 Pa. 254, 137 A.2d 280,283 (1958). 77 E.g., Board of Zoning Appeals v. Bond, 300 S.E.2d 781 (Va. 1983). 78 Rathkopf, The Law of Zoning and Planning ch. 38. 79 See, e.g., Pa. Stat. Ann. tit. 53, ~ 10912 (Purdon 1972); N.J. Stat. Ann. ~ 40:55D-70 (West Supp. 1980), as amended by L. 1979, ch. 216, ~ 23; L. 1983, ch. 260, ~ 13 (West Supp. 1984). 80 See NIMLO, Model Zoning Ordinance ~ 11-229(b)(3) (1953); San Francisco, Ca\., City Planning Code ~ 302(d) (1964). 81 Alumni Control Bd. v. City of Lincoln, 179 Neb. 194, 137 N.W.2d. 800 (1965); Anderson v. Board of Appeals, 22 Md. App. 28, 322 A.2d 220 (Md. Ct. Sp. App. 1974). 82 See, e.g., Mo. Rev. Stat ~ 89.090 (1971). (Release #5, 2/91)