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municipal decisions to grant variances. Id. at 327-28 & n.2. Compare Minn. Stat. <br />§ 462.357, subd. 6, with Minn. Stat. § 394.27, subd. 7 (2008).8 <br />In Stadsvold, we interpreted Minn. Stat. § 394.27, subd. 7, which sets forth the <br />statutory standard for county variances. This statute contains both the "practical <br />difficulties" standard and a "particular hardship" standard. Specifically, section 394.27 <br />authorizes a county to grant variances from "the terms of any official control" but only <br />when the property owner would face "practical difficulties or particular hardship" in <br />meeting "the strict letter of any official control." Minn. Stat. § 394.27, subd. 7.9 We <br />distinguished the "less rigorous `practical difficulties' " standard that applies to area <br />variance applications from the more rigorous "particular hardship" standard that applies <br />to use variance applications. Stadsvold, 754 N.W.2d at 330-31.10 <br />8 While Minn. Stat. § 462.357, subd. 6, and Minn. Stat. § 394.27, subd. 7, both set <br />forth standards for granting variances, section 462.357, subdivision 6, applies to <br />municipalities and section 394.27, subdivision 7, applies to counties. <br />v The same dichotomy of language at issue in Stadsvold existed in the predecessor <br />to the municipal zoning statute, section 462.357. Until 1965, section 462.22 (enacted in <br />1929, repealed in 1965) granted municipalities the power to vary or modify the <br />application of a zoning regulation where there were "practical difficulties or unnecessary <br />hardship" in complying with the strict letter of the regulation. Minn. Stat. § 462.22 <br />(1961). In 1965, the legislature replaced Minn. Stat. § 462.22 with Minn. Stat. § 462.357. <br />Act of May 22, 1965, c. 670, § 7, 1965 Minn. Laws 995, 1000-03. The new statute <br />replaced the "practical difficulties or unnecessary hardship" standard with the current <br />single "undue hardship" standard. Id. "Undue hardship" was undefined in the statute <br />until 1982, when the legislature, borrowing the definition of "hardship" from the county <br />variance statute, Minn. Stat. § 394.27, added the current definition of "undue hardship" to <br />the statute. Act of Mar. 22, 1982, ch. 507, § 22, 1982 Minn. Laws 592, 593. <br />10 As we discussed in Stadsvold, "[t]here are two types of variances: use variances <br />and area variances. `A use variance permits a use or development of land other than that <br />(Footnote continued on next page.) <br />15 <br />