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6-22.1 PROCEDURES ~ 6.03[5] the homeless.108.2 The zoning board had rejected the variance on the basis of parking problems, undesirable people, the lowering of property values, and drug problems. The board's decision was reversed premised on the state law favoring variances for "inherent- ly beneficial uses." [5] Conditional Grant of Variance As discussed in a later section,109 special exceptions by their very nature are uses permitted only upon designated conditions. In this regard, section 7 of the Standard State Zoning Enabling Act empowers the board of adjustment to make special exceptions to the zoning ordinance "in appropriate cases . .. subject to appropriate conditions. . . ." However, no similar provision regarding the condi- tioning of variances is included in the Standard Act. Thus the question arises whether a variance may be granted only on the condition that certain requirements are met. Some state enabling acts have expressly delegated the power to place conditions on variances,uo Moreover, many municipal ordi- nances expressly grant such power,111 and some courts uphold the right of a board of adjustment to impose conditions as an implied power inherent in the statutes and ordinances which authorize the granting of variances.1l2 This power to condition variances is becoming so universally accepted that challenges to the board's authority are now typically confined to questions of whether there is a legitimate justification for imposing the conditions and the reasonableness of the conditions imposed.1l3 108.2 Homes of Hope, Inc. v. Mount Holly Zoning Bd. of Adjustment, 566 A.2d 575 (N.J. 1989). 109 Infra ~ 6.04. 110 See, e.g., Cal. Gov't Code ~ 65906 (West ] 983); Pa. Stat. Ann. tit. 53, ~ 10912 (West 1972). 111 Rathkopf, The Law of Zoning and Planning ch. 40. 112 Service Realty Corp. v. Planning & Zoning Bd. of Appeals, 141 Conn. 632, 109 A.2d 256 (1954); Everson Elec. Co. v. Zoning Bd. of Adjustment, 395 Pa. 168, 149 A.2d 63 (1959); Young Israel of Scarsdale v. Board of Standards & Appeals, 39 App. Div. 2d 51,331 N.Y.S.2d 105 (1972); Wentworth Hotel, Inc. v. Town of New Castle, 112 N.H. 21, 287 A.2d 615 (1972); Town of Warren v. Frost, 115 R.I. 517, 350 A.2d 608 (1976); Shohola Tp. Bd. of Supervisors v. Bishop, 279 Pa. Super. 313, 421 A.2d 215 (1980). 1135 R. Anderson, American Law of Zoning ~ 18.60 (1977). (Release #5, 2/91)