Nancy R. Stansbury, petitioner, petitions this Court to reverse the decision of the Court of Special Appeals. A zoning administrator in Anne Arundel County had recommended that Ms. Stansbury be granted certain variances in respect to property owned by her in the subdivision of Pleasant Plains in Anne Arundel County, a parcel of property that petitioner had reserved to herself in the re-subdivision of a larger tract. The Anne Arundel County Board of Appeals (hereafter “Board”) had not accepted the recommendation, and had denied the variances, allegedly, on the sole ground that the claimed hardships there alleged had been self-created. Upon petition for judicial review, the circuit court had remanded the matter to the Board, directing that the Board reconsider the application considering all of the variance factors contained in the county zoning code. Randy Q. Jones, and others, respondents, appealed that decision to the Court of Special Appeals. That court reversed the decision of the Circuit Court for Anne Arundel County, holding that the hardship alleged in the case was self-created and that no other factors needed to be considered in the denial of the application.
*176The crux of the controversy at the circuit court level was, whether the Board, during an administrative appeal, should have declined to accept the recommendation of the administrative hearing officer on the sole ground that the need for the variances had been self-created by the petitioner. The Court of Special Appeals, agreeing with the Board that the hardship had been self-created, stated:
“First, it was thought by the circuit court that judicial review of the Board’s decision was governed by the APA. Second, a recent trilogy of Court of Appeals’ decisions involving critical' area variances were read by the circuit court as requiring the Board to address each variance standard. Third, the circuit court failed to recognize the fundamental nature of the principle that self-created hardships cannot justify the grant of a variance, including the concept that a self-created hardship is not merely another variance standard, but is instead an essential part of the unwarranted hardship standard that is the primary determining factor that must be met by a variance applicant.”
In her brief in this Court, petitioner presents four questions:
“1. Is the examination of just one factor alone, specifically the concept of self-created hardship, sufficient basis to deny a critical area variance request for a legally buildable lot, thereby precluding the use of the other factors in determining whether unwarranted hardship1 exists?
“2. Did the Court of Special Appeals and Anne Arundel County Board of Appeals commit reversible error by *177failing to examine all statutory factors in determining whether unwarranted hardship exists when denying a variance in the Chesapeake Bay Critical Area for a legally buildable lot created with Anne Arundel County approval?
“3. Was the Circuit Court correct in remanding the case to the Board of Appeals for further consideration because the Board of Appeals’ administrative decision incorrectly applied the law and lacked adequate findings of fact?
“4. Did the Anne Arundel County Board of Appeals effect a ‘taking’ of Petitioner’s property without just compensation by denying Petitioner the requested variances on a legally buildable lot?”2
*178Because, in the first instance, we shall hold that the facts of this case do not support the intermediate appellate court’s judgment or the Board’s findings that the hardship in this case was self-created, we shall not resolve, although we may discuss, the other issues presented. Accordingly, we shall reverse the decision of the Court of Special Appeals, and direct it to affirm the circuit court’s judgment remanding the case to the Board to reconsider the petitioner’s request for variances utilizing all of the applicable requirements of the statute. The hardship or practical difficulty here, if any, arising out of the re-subdivision, was not self-created within the meaning of the local ordinance. When a property owner does that which is permitted, or required, under a zoning code, that property owner is not necessarily creating an automatic hardship for purposes of the self-created hardship standards of variance provisions.
Facts
In 1927, petitioner’s predecessor in title, by recording a plat in the County land records, created a subdivision known as Plat No. 2 Pleasant Plains. At that time, as far as the record reflects, there was no subdivision ordinance existing in Anne Arundel County. At sometime prior to, and/or in 1986, Anne Arundel County passed an ordinance or ordinances which resulted in the lots in the then Pleasant Plains subdivision, becoming substandard size lots, i.e., non-conforming lots. The County, in 1986, enacted statutory provisions that the parties refer to as the Antiquated Lots Law (now codified in Article 28, Section 2-101 of the Anne Arundel County Code (“Code”)). Charlene Morgan, the zoning analyst for the Anne Arundel County Department of Planning and Code Enforcement, testified before the Board as to the effect of the 1986 statutory provisions on the property here at issue:
*179“I’m going to go briefly through the history the way the county has reviewed it.
“In 1924 Pleasant Plains was platted. The lots were required to [be] create[d], by recorded plat prior to the county code. The lots were considered legally created antiquated lots.
“In 1986 the Antiquated Lots Law was passed which was bill 86-86, and is now codified into article 28, section 2-101C. This required antiquated lots that are in ownership to be combined to meet lot area requirement.
“In 1986 planning and rezoning — dated March 6th, 1986, explained to the owner of this property that they needed to be combined in regard to bill 86-86.
“In 1991 an Administrative plat was signed on July 31st and the plat combined legal Pleasant Plains lots into larger building sites.
“On these particular sites a reserved parcel label was assigned to the subject lot until it could pass a perk test. To my definition, and my understanding a reserved parcel means that this lot is on hold until it can meet that criteria.
“At this time the subject site does not lose it’s underlying legal status. And as a — indicates that there are many legal lots that are not filling it, and that in the county view the words ‘parcel and lot’ are used interchangeably and don’t indicate whether the lot is legal or buildable.
“In 1997 waiver 5867 was signed on September 11th and that waiver deems a lot buildable because the lot perked at that time.
“The waiver is the subdivision approval that is needed that is referenced on the plat that waives the need to rerecord the administrative plat. Typically an administrative plat is not recorded unless there’s a change in the lot lines. In this case all that was deemed done [by] removing the term ‘reserved parcel’ and making it a lot.
“This site has always been, and is now a subject of permit review of critical area criteria and Health Department requirements, as is any legal lot. And any legal lot has the *180right to apply for a variance during the building permit review.”
The 1986 Antiquated Lots Law, as now codified as aforesaid, provides in relevant part that:
“(a) In this section ‘properly recorded lot’ means a lot:
(1) of record and created in compliance with the zoning and subdivision regulations in effect when the lot was created; or
(2) recorded on or before June 30,1952.
“(b) Notwithstanding the minimum lot area and width requirements of this title, a residential dwelling may be constructed on a properly recorded lot if:
(1) the lot was. not in the same ownership as an adjacent unimproved lot on January 1,1987; and
(2) the other requirements of this article are met.
“(c) ... [A] residential dwelling may not be constructed on a properly recorded lot that was in the same ownership as one or more adjacent unimproved lots on January 1, 1987 ... unless the adjacent lots are combined to meet or come as close as possible to meeting the area requirements for the residential district in which the lot is located.”3
*181Anne Arundel County Variance Standards
Sections 11-102.1(c) of the Anne Arundel County Code, applicable to the granting of variances, provides as to the general consideration of variances that:
“(c) A variance may not be granted unless it is found:
(1) that the variance is the minimum variance necessary to afford relief;
(2) that the granting of the variance will not:
(i) alter the essential character of the neighborhood or district in which the lot is located;
(ii) substantially impair the appropriate use or development of adjacent property;
(iii) reduce forest cover in the limited and resource conservation areas of the critical area;
(iv) be contrary to acceptable clearing and replanting practices required for development in the critical or bog protection area; or
(v) be detrimental to the public welfare; and
(3) that, for properties in the critical area or a bog protection area, the granting of a variance will not be inconsistent with the spirit and intent of the critical area program or bog protection program and will not adversely affect water quality or adversely impact fish, wildlife, or plant habitat.”
As can be seen, there is no specific provision relating to self-created hardship in the general provisions of the Anne Arundel County ordinance. There is, however, a special section in the Anne Arundel County Code, Section 11-102.1.(b), that *182relates only to properties in the “critical area or a bog protection area.” It does contain a self-created hardship type of provision. Section 11-102.1.(b)(4)(i) provides: “the variance request ... is not based on conditions or circumstances that are the result of actions by the applicant.” Petitioner indicated in the present case that the Critical Area Commission had not objected to her application. Respondents did not proffer to the contrary. Accordingly, except as noted, the extent to which self-created hardships under the general provisions of this statute would impact upon the granting of a variance outside the critical area (whether sufficient in and of itself to justify the denial of a variance, or whether merely a factor to consider along with all other factors in the consideration of the variance application) depends upon the holdings of our cases. While the critical area variance provisions contain a direct reference to self-created hardships, the statute does not attempt to define what is meant by “result of actions by the applicant.” Therefore, even in respect to property within the critical areas of the county, whether a particular situation constitutes a self-created hardship, depends, for the most part, upon our cases to the extent we have previously addressed such issues, not upon the provisions of the statute.
Standard of Judicial Review
Almost a half-century ago, in a case involving a denial of a use permit, we stated: “It is a clearly established rule in the law of zoning that a court may not substitute its judgment for that of the Zoning Board.” Dorsey Enterprises, Inc. v. Shpak, 219 Md. 16, 23, 147 A.2d 853, 857 (1959). Chief Judge Hammond wrote for the Court in State Ins. Comm’r v. National Bureau of Casualty Underwriters, 248 Md. 292, 309, 236 A.2d 282, 292 (1967), that “under ... [either] of the standards the judicial review essentially should be limited to' whether a reasoning mind reasonably could have reached the factual conclusion the agency reached (alteration added).”
Whether reasoning minds could reasonably reach a conclusion from facts in the record is the essential test. If such a conclusion is sufficiently supported by the evidence, *183then it is based upon substantial evidence. Forty years ago in Snowden v. Mayor and City Council of Baltimore, 224 Md. 443, 447-48, 168 A.2d 390, 392 (1961), we noted that:
“The substantial evidence test ‘means that the reviewing court’s inquiry is whether on the record the agency could reasonably make the finding.’ ... Substantial evidence is ‘such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.’ The heart of the fact finding process often is the drawing of inferences from the facts. The administrative agency is the one to whom is committed the drawing of whatever inferences reasonably are to be drawn from the factual evidence. ‘The Court may not substitute its judgment on the question whether the inference drawn is the right one or whether a different inference would be better supported. The test is reasonableness, not rightness.’ ” [Citation omitted.]
Over twenty years later we opined, “if the evidence makes the issue of harm fairly debatable, the matter is one for the Board’s decision, and should not be second-guessed by an appellate court.” Board of County Commissioners for Cecil County v. Holbrook, 314 Md. 210, 218, 550 A.2d 664, 668 (1988). See also Ramsay, Scarlett & Co., Inc. v. Comptroller of the Treasury, 302 Md. 825, 490 A.2d 1296 (1985) and Comptroller of the Treasury v. World Book Childcraft International, Inc., 67 Md.App. 424, 508 A.2d 148 (1986).
In White v. North, 356 Md. 31, 44, 736 A.2d 1072, 1079 (1999), we much more recently restated the general standard of review that:
“In judicial review of zoning matters, including special exceptions and variances, ‘the correct test to be applied is whether the issue before the administrative body is “fairly debatable,” that is, whether its determination is based upon evidence from which reasonable persons could come to different conclusions.’ Sembly v. County Bd. of Appeals, 269 Md. 177, 182, 304 A.2d 814, 818 (1973). See also Board of County Comm’rs v. Holbrook, 314 Md. 210, 216-17, 550 A.2d 664, 668 (1988); Prince George’s County v. Meininger, 264 Md. 148, 151, 285 A.2d 649, 651 (1972); Zengerle v. Board of *184County Comm’rs, 262 Md. 1, 17, 276 A.2d 646, 654 (1971); Gerachis v. Montgomery County Bd. of Appeals, 261 Md. 153, 156, 274 A.2d 379, 381 (1971). For its conclusion to be fairly debatable, the administrative agency overseeing the variance decision must have ‘substantial evidence’ on the record supporting its decision. See Mayor of Annapolis v. Annapolis Waterfront Co., 284 Md. 383, 395, 396 A.2d 1080, 1087 (1979); Montgomery County v. Woodward & Lothrop, Inc., 280 Md. 686, 706, 376 A.2d 483, 495 (1977), cert. denied sub nom. Funger v. Montgomery County, 434 U.S. 1067, 98 S.Ct. 1245, 55 L.Ed.2d 769 (1978); Agneslane, Inc. v. Lucas, 247 Md. 612, 619, 233 A.2d 757, 761 (1967).”
See also People’s Counsel for Baltimore County v. Mangione, 85 Md.App. 738, 743-44, 584 A.2d 1318, 1320-21 (1991); Terranova v. Board of Trustees of the Fire and Police Employees Retirement Sys., 81 Md.App. 1, 8-9, 566 A.2d 497, 500-01 (1989), cert. denied, 319 Md. 484, 573 A.2d 808 (1990); Tennison v. Shomette, 38 Md.App. 1, 5, 379 A.2d 187, 190 (1977), cert. denied, 282 Md. 739 (1978); Fitzgerald v. Montgomery County, 37 Md.App. 148, 153, 376 A.2d 1125, 1128, cert. denied, 281 Md. 737 (1977), cert. denied sub nom. Mutyambizi v. Maryland, 439 U.S. 854, 99 S.Ct. 164, 58 L.Ed.2d 160 (1978); Anne Arundel County v. Maryland Nat’l Bank, 32 Md.App. 437, 440, 361 A.2d 134, 136 (1976).
Nonetheless, we have also indicated in our cases that where an administrative agency’s conclusions are not supported by competent and substantial evidence, or where the agency draws impermissible or unreasonable inferences and conclusions from undisputed evidence, such decisions are due no deference. In Belvoir Farms Homeowners Association, Inc. v. North, 355 Md. 259, 267-68, 734 A.2d 227, 232 (1999), we stated:
“Generally, a decision of an administrative agency, including a local zoning board, is owed no deference when its conclusions are based upon an error of law. Catonsville Nursing Home, Inc. v. Loveman, 349 Md. 560, 569, 709 A.2d 749, 753 (1998) (‘[W]e may reverse an administrative decision premised on erroneous legal conclusions.’ (citing Peo*185ple’s Counsel v. Maryland Marine Mfg. Co., 316 Md. 491, 497, 560 A.2d 32, 34-35 (1989))).”
In Maryland Marine Mfg., supra, 316 Md. at 496-97, 560 A.2d at 84-35, we said:
“As we have frequently indicated, the order of an administrative agency must be upheld on judicial review if it is not based on an error of law, and if the agency’s conclusions reasonably may be based upon the facts proven. But a reviewing court is under no constraints in reversing an administrative decision which is premised solely upon an erroneous conclusion of law.” [Citation omitted.] [Emphasis added.]
We noted in Washington National Arena Limited Partnership v. Comptroller of the Treasury, 308 Md. 370, 378, 519 A.2d 1277, 1281 (1987) (quoting Ramsay, Scarlett & Co., 302 Md. at 834, 490 A.2d at 1301), that: “ ‘a reviewing court is under no statutory constraints in reversing a Tax Court order which is premised solely upon an erroneous conclusion of law.’ ”
We said in Elliott v. Joyce, 233 Md. 76, 81-82, 195 A.2d 254, 256 (1963) that:
“We hold that ‘on the record’ before us, the Board could not ‘reasonably make’ the reclassification and grant the special exception. Therefore, its action in so doing was arbitrary and capricious in a legal sense. To permit a gasoline station in the residential surroundings of the subject property would not promote the safety, health or general welfare of the community, but would constitute, we think, invalid ‘spot zoning.’ Baylis v. City of Baltimore, 219 Md. 164, 148 A.2d 429 [1959]; Hewitt v. County Comm’rs, 220 Md. 48, 151 A.2d 144 [1959].” [Alterations added.]
The standard in respect to judicial review is, generally, the same whether the agency grants or denies relief. In Maryland Advertising Company v. Mayor and City Council of Baltimore, 199 Md. 214, 222-23, 86 A.2d 169, 173-74 (1952), a case involving the denial of permit for a billboard under the *186special provisions in that zoning code, the trial court, on judicial review, affirmed the agency. We reversed, noting:
“A zoning statute, ordinance or administrative order ... is presumed to be valid.... However, the duty of the courts not to substitute their judgment for the judgment of legislative or administrative authorities ... is not more imperative than the power and duty to set aside any purported exercise of such power which is in fact arbitrary, capricious or confiscatory. Zoning in this respect can no more escape judicial review than any other purported exercise of the police power.... ‘The governmental power to interfere by zoning regulations with the general rights of the land owner by restricting the character of his use, is not unlimited, and other questions aside, such restriction cannot be imposed if it does not bear a substantial relation to the public health, safety, morals, or general welfare.’ ... ‘Building on one’s own land is still a property right, subject to all applicable provisions of law; it is not a grant of a favor from some governmental authority.’ ” [Citations omitted.]
We have additionally found actions of zoning entities to be arbitrary and capricious, and have thus affirmed trial court reversals of zoning agency decisions in reclassification cases, albeit the reversals were generally of actions where the agency had granted relief, as opposed to the instant variance application where the Board denied relief. As indicated, in Elliott, supra, we affirmed the circuit court’s reversal of agency actions. In Zang & Sons, Builders Inc. v. Taylor, 203 Md. 628, 102 A.2d 723 (1954), the circuit court declared a zoning action (a reclassification) by Anne Arundel County authorities, ‘null and void,’ and this Court affirmed. There we said:
“There is nothing here to show that the [prior] rezoning to ‘Cottage Residential’ was error or mistake ... The preamble to the resolution and the personal knowledge of the Commissioners could not be considered [by the circuit court] as evidence of change. The power of rezoning cannot be used to ‘favor’. The Courts review the action, not the opinion, of the Commissioners. The reasonableness of such *187a resolution is to be determined by the facts from which the conclusion is drawn, rather than from the conclusion itself.” Id. 203 Md. at 636-37, 102 A.2d at 727. [Citations omitted.] [Emphasis added.] [Alterations added.]
Price v. Cohen, 213 Md. 457, 463, 463, 132 A.2d 125, 128 (1957), was another case where the courts reversed a zoning entity’s granting of a reclassification. There, we stated:
“The courts will reverse only where there are no grounds for reasonable debate and where the action of the Board is capricious, arbitrary, discriminatory, or illegal. The Board here based its opinion partly on an inspection of the property by its members. The personal knowledge of the Board cannot be considered on appeal. The review of the courts is made from the facts from which the conclusion is drawn and not from the conclusion itself” [Citation omitted.] [Emphasis added.]
In the case sub judice, the Board erroneously construed a property owner’s legal attempt to comply with provisions authorized by a new county law as a self-created hardship. Compliance with a statute ordinarily is not self-created hardship and is not such in the present case.
Self-created Hardship
We stated in White, 356 Md. at 48-49, 736 A.2d at 1082, quoting from our earlier case of Aspen Hill Venture v. Montgomery County Council, 265 Md. 303, 313-14, 289 A.2d 303, 308 (1972), that:
“ ‘we must not forget the underlying principle that, “Such ordinances [zoning ordinances] are in derogation of the common law right to use private property as to realize its highest utility, and while they should be liberally construed to accomplish their plain purpose and intent, they should not be extended by implication to cases not clearly within the scope of the purpose and intent manifest in their language.” Landay v. Board of Zoning Appeals, 173 Md. 460, 466, 196 A. 293 (1938).’ [Alteration in original.]
“In Landay, 173 Md. at 465, 196 A. at 295-96, we noted that ‘[i]n a constitutional sense, the only justification for the *188restrictions ... on the use of private property is the protection of the public health, safety, or morals.’ ”
In a case somewhat similar to the case sub judice, Richard Roeser Professional Builder, Incorporated v. Anne Arundel County, 368 Md. 294, 297 n. 3, 793 A.2d 545, 547 n. 3 (2002), decided after the Board’s and the lower court decisions in the present case, we initially noted in a footnote:
“It is a relatively common practice throughout the State, and has been for decades, that buyers contract to buy properties with contingencies that make consummation of the contract conditioned on the granting of variances.... Additionally, in such instances in respect to ‘area’ variances, we have never held that such a practice, by itself, constitutes a ‘self-created’ hardship.”
Then, in Roeser, 368 Md. at 303-04, 793 A.2d at 551, quoting from Arden H. Rathkopf & Daren A. Rathkopf, The Law of Zoning and Planning § 58.22, 141-48 (Edward H. Zeigler, Jr. revision, vol. 3, West 1991), we stated:
“ ‘In other words, because a purchaser of property acquires no greater right to a variance than his predecessor, he should not be held to acquire less.
‘It should not be within the discretion of a board of appeals to deny a variance solely because a purchaser bought with knowledge of zoning restrictions.... ’ ” [Emphasis in original.] [Footnotes omitted.]
We subsequently opined in Roeser that:
“The types of hardships that are normally considered to be self-created in cases of this type do not arise from purchase, but from the actions of the land owner ... that create the hardship, rather than the hardship impact, if any, of the zoning ordinance on the property.”
Id. at 314, 793 A.2d at 558.
While we do not rely on the impact, if any, of the Antiquated Lots Law in our decision for the case sub judice, it is clear that the purpose of the Antiquated Lots Law ordi*189nance is to induce owners of adjacent non-conforming undersized lots to combine them into lots that conform to present area requirements, or to combine them into lots that are less non-conforming than prior to combination, in order to develop the property. Clearly, any person or persons that want to build a residential dwelling on an undersized, but legal, parcel 4 or lot of land adjacent to other land owned by them, is, at the least, encouraged to comply with this ordinance. Compliance with the provisions of the Anne Arundel County Antiquated Lots Law5 would not be self-created hardship. In the present case the petitioner was merely doing what she had a *190right to do, and what the Antiquated Lots Law encouraged her to do, re-subdivide the property and in the process, meet the current requirements of the statute so that the lots would be in conformity.
Respondents rely in part on Randolph Hills, Inc. v. Montgomery County Council, 264 Md. 78, 285 A.2d 620 (1972), for the proposition that problems created by a developer in creating a subdivision can be considered self-created. The facts in Randolph Hills were substantially different than the facts in the present case. The owners in Randolph Hills were not requesting a variance. In Randolph Hills, the owner was merely requesting a reclassification of its property under preexisting law. Prior to the request for reclassification, the developer had voluntarily subdivided a large portion of the overall property under the provisions of the same ordinance, leaving a certain portion of the property it owned entirely outside of the subdivision. It was the property left outside the subdivision that was the subject of the zoning reclassification request, not, as in the present case, property within the subdivision for which variance relief was sought. Generally, reclassifications involving Euclidean zones, such as involved in Randolph Hills, are controlled by the “change/mistake rule,”6 a rule not applicable in variance cases. Nonetheless, the administrative body in Randolph Hills, perhaps as dicta, opined that the developer had created its own hardship by *191leaving the subject tract outside the subdivision. In the case sub judice, the Reserved Parcel 2 is included within the re-subdivision that meets the requirements of current statutes and the only issues are whether the re-subdivision that combined sub-standard lots into the conforming “Reserved Parcel 2” was done in compliance with the applicable statutes.7 As we have clearly indicated, the re-subdivision, i.e., the combination of substandard lots, is not only permitted and encouraged by the statute anytime adjacent non-conforming lots are under the same ownership, regardless of how the property became so titled,8 it is, generally, permitted for substandard lots to be re-subdivided into standard or closer-to-standard lots.
In Randolph Hills the property outside of the subdivision ended up in the situation solely because the developer *192desired it. In the present case the recombination of lots, and thus a re-subdivision, was permitted by statute. In the process of re-subdivision the tract at issue here ended up in a subdivision with a condition imposed by the county not imposed on the other lots. The parcel,, to the extent it would reflect the old subdivision, would be a nonconforming parcel and its status would have resulted from the statute increasing dimension requirements, and, thus, any hardship resulting from the statute making the lots non-conforming, would not have been self-created. To the extent, if any, it reflects a status derived from the combination re-subdivision, its status would have resulted from the operation of the new “lot-combining” statute, and any hardship was not self-created. More important, subdividing property in accordance with all applicable statutes does not, generally, constitute a self-created hardship in respect to the property within the subdivision. Randolph Hills does not apply here.
Respondents next rely on the Court of Special Appeals decision in Cromwell v. Ward, 102 Md.App. 691, 651 A.2d 424 (1995). The facts of Cromwell are completely dissimilar to the facts in the present case. Cromwell involved an after the fact application for a variance to legalize an illegally constructed building. First, and primarily, there was no subsequent statute that permitted the landowner, Ward, to do what he did. He merely constructed a building that violated the provisions of the existing zoning code, as well as the provisions of the plans upon which his building permit was issued. He was caught. He then requested a variance approving retroactively what he had already illegally built. The intermediate appellate court held that he was not entitled to a variance because his hardship was entirely self-created. Cromwell represents the traditional application of self-creáted hardship principles in the variance context and is a far cry from the present situation, where a statute permitted to be done, what was done.
Our case of Ad + Soil, Inc. v. County Comm’rs of Queen Anne’s County, 307 Md. 307, 513 A.2d 893 (1986), is also factually dissimilar. Ad + Soil, without prior proper approvals, constructed a facility that violated the county’s zoning *193ordinance, including the setback requirements of the ordinance. After the fact, Ad + Soil applied for variances of the setback (and other) requirements. We held that the setback violations had been self-created. Again Ad + Soil, like Cromwell, was a traditional application of sell-created hardship principles in a zoning context — an attempt to legalize an illegal structure.
Montgomery County Council v. Kacur, 253 Md. 220, 252 A.2d 832, 838-39 (1969), also relied upon by respondents, is likewise inapplicable. First of all, as in Randolph Hills, it was a request for a reclassification and not an application for variances. More importantly, when we said “a property owner may not require the Council to grant a rezoning ... by creating a hardship situation of his own making in which he cannot but lose money,” we were addressing the situation where a landowner, considering the uses permissible under the zoning classification of the property when he bought it, had paid too much money for a piece of property and was trying to have its classification designation changed to a higher category solely in an attempt to make it more valuable for resale. Kacur, 253 Md. at 231, 252 A.2d at 838-39. The factual situation there is nowhere close to the situation-in the case at bar.
Evans v. Shore Communications, Inc., 112 Md.App. 284, 685 A.2d 454 (1996), involved the denial, not the granting of variances. Again it was factually dissimilar. The intermediate appellate court, as relevant here, found that the claimed peculiarity, uniqueness, of the property necessary to satisfy the first prong of most variance ordinances — that a property be unique, was that the applicant had leased a piece of property for which, pursuant to the then existing ordinance, he could not erect the tower to the required height. The applicant there did not claim that a hardship existed for the main purposes of establishing an unwarranted hardship, but merely made the argument that a lease it had entered into in anticipation of receiving a variance caused the property to be unique or constituted peculiar circumstances surrounding the property, thereby satisfying the first uniqueness prong of the *194variance requirement of that particular ordinance (and many others). That court said that “while SCI ... may have painted itself into a corner when it entered into a lease agreement ... ‘the variance that is desired ... cannot be the source of the first [uniqueness] prong of the variance process----’ ” Evans, 112 Md.App. at 308, 685 A.2d at 466 (citing Cromwell, 102 Md.App. at 695, 651 A.2d at 426) (alteration added). The applicant in Evans asserted that the uniqueness of the property allegedly caused by the lease, was, itself, an unwarranted hardship. Only in that context did the court say:
“the second ‘special condition and circumstance’ claimed by SCI — the needs of its subscribers — are not peculiar to the land, but created by SCI.... The needs of SCI’s customers have nothing to do with the peculiarity of the property in question. Thus, any hardship claimed by SCI — the second prong of the test; — is self-inflicted, and thus not a ground for a variance.” Evans, 112 Md.App. at 309, 685 A.2d at 466.
Accordingly, as is evident, Evans does not support the position as to that case, taken by respondents in the case sub judice.
The case of Wilson v. Mayor and Comm’rs of the Town of Elkton, 35 Md.App. 417, 371 A.2d 443 (1977), also relied on by respondents, is equally distinguishable from the present case. In that case, the property owner at the pertinent time, unlawfully extended a non-conforming use. Later, a variance was sought that would make using the illegal extension easier. It was held that the unlawful extension had been self-created and thus the need for the requested relief was self-created. It was also a traditional self-created hardship situation. Wilson by his sole affirmative act had built a structure that illegally extended a non-conforming use and was attempting to legalize the use. Wilson is simply not relevant to the issues in the case at bar.
The cases cited by respondents do not support the proposition they ask this court to adopt in the present case. In similar fashion, the other cases relied on by the intermediate appellate court do not apply in the circumstances of the present case.
*195In addition to extensively relying on this Court’s case of Randolph Hills, supra, and relying on its own case of Cromwell, supra, which reliance as we have indicated was misplaced, the Court of Special Appeals also cited as authority our cases of Salisbury Board of Zoning Appeals v. Bounds, 240 Md. 547, 214 A.2d 810 (1965) and Marino v. Mayor and City Council of Baltimore, 215 Md. 206, 137 A.2d 198 (1957).
Bounds and Marino are also dissimilar from the case at bar. In Bounds, the property owner did not properly procure a building permit to convert an old single family dwelling into four apartments. Therefore, the apartments were built without any consideration by the appropriate city entities as to whether the conversion complied with local zoning provisions. The conversion violated the density provisions of the statute. We stated the then relevant provision set forth in Rathkopf, The Law of Zoning and Planning, that we considered to be applicable:
“ ‘If the peculiar circumstances which render the property incapable of being used in accordance with the restrictions contained in the ordinance have been themselves caused or created by the property owner or his predecessor in title, the essential basis for a variance, i.e., that the hardship be caused solely through the manner of the operation of the ordinance ... is lacking .... the hardship, arising as a result of the act of the owner ... will be regarded as having been self-created, barring relief.’ ” Bounds, 240 Md. at 554, 214 A.2d at 814.
We then held in Bounds:
“The instant case fits squarely within the above general rule. The construction of the fourth apartment and the resultant hardship could have been avoided if the appellees had used proper diligence in ascertaining what the density requirements were.... The hardship here relied on was entirely self-created.” Id. at 555, 214 A.2d at 814-15. [Emphasis added.]
*196Bounds, like Wilson,9 involved the building or remodeling of structures in violation of zoning laws, and the subsequent attempt to legalize a prior illegality by way of the granting of variances. It was a traditional case of self-created hardship.
The case of Marino was substantially different from the present case. It involved a “special exception.”10 Along with other things, we noted that under the Baltimore City ordinance the Marinos had the burden of establishing that the hardship they were alleging was not self-created. We also noted that the zoning ordinance being challenged had been in place when the Marinos had purchased the property.11 *197More important, the Marinos had applied for and received a prior exception that permitted them to use the property lor commercial purposes. That prior grant of Marino’s application to permit commercial use, we found “[i]s without doubt one of the reasons why the remainder is less adaptable now for residential use purposes.” Marino, 215 Md. at 220, 137 A.2d at 203. It is clear that the situation in Marino was very different than the situation in the case at bar. Here the petitioner re-subdivided her property, and in the process *198eliminated, and/or reduced the nonconforming character of the lots within the subdivision. As is permitted, in the process she ended up with certain lots that still had certain potential environmental constraints, but they were constraints that she had a right to attempt to resolve through the variance process. In the re-subdivision process she was reducing the degree of non-conformity of her property.
Although we do not hold in this case that re-subdividing in compliance with statutes can never constitute self-created hardships, such actions are not in the traditional sense, in general, self-created hardships for variance consideration purposes. Traditionally, self-created hardship requires an affirmative action, exclusively by a property owner or his predecessor in title, that is itself the sole reason for the need for the variance. Bounds and Marino represent the normal types of affirmative actions by property owners that will be held to constitute self-created hardships. Several of our sister jurisdictions have recognized similar types of self-created hardship in the variance context.
In Dueger v. Zoning Board of Appeals of the Incorporated Village of Lloyd Harbor, 61 N.Y.2d 743, 472 N.Y.S.2d 922, 460 N.E.2d 1357 (1984), the Court of Appeals of New York held that a deck illegally extended into a setback was a self-created hardship, and a variance was denied in spite of the fact that the removal of the deck would substantially impair the value of the house. The Supreme Court of Oklahoma, in Board of Adjustment of the City of Oklahoma City v. Puckett, 1960 Ok. 142, 353 P.2d 4 (1960), held that the construction of a ground level parking pad in a setback in order to support a carport structure that was forbidden to be placed in the setback, and the moving of driveways in contemplation of the carport placement and other structures, constituted self-created hardships and reversed the granting of the variance. In Bloom v. Zoning Board of Appeals of the City of Norwalk, 233 Conn. 198, 658 A.2d 559 (1995), the Supreme Court of Connecticut reversed the granting of a variance that had been obtained in order to legalize a dormer and stoop that had been constructed on a non-conforming structure pursuant to an illegal build*199ing permit. Other cases that have held that illegal construction is self-created hardship include: Caccia v. Zoning Board of Review of the City of Providence, 83 R.I. 146, 113 A.2d 870 (1955); Snyder v. Waukesha County Zoning Board of Adjustment, 74 Wis.2d 468, 247 N.W.2d 98 (1976) and Martirano v. Zoning Board of Appeals of the Town of Lewisboro, 57 N.Y.2d 867, 456 N.Y.S.2d 47, 442 N.E.2d 445 (1982) (both cases involved the illegal construction of porches); Markdale Corporation v. Board of Appeals of City of Milwaukee, 27 Wis.2d 154, 133 N.W.2d 795 (1965); and Ex Parte Chapman, 485 So.2d 1161 (Ala.1986). There are also cases that have held that a hardship created by the error of a surveyor working for the land owner constitutes a traditional self-created hardship. In re Application of Fecteau, 149 Vt. 319, 543 A.2d 693 (1988) and Pollard v. Zoning Board of Appeals of the City of Norwalk, 186 Conn. 32, 438 A.2d 1186 (1982). Creating a substandard parcel by a metes and bounds description in a deed was held to be a self-created hardship in Cherry Hill Homes, Inc. v. Board of Zoning Appeals of the Incorporated Village of Sea Cliff, 28 N.Y.2d 381, 322 N.Y.S.2d 225, 271 N.E.2d 211 (1971). In Foxhall Community Citizens Association v. District of Columbia Board of Zoning Adjustment, 524 A.2d 759 (D.C.App.1987), the court held that a church that was so poorly designed that it was unable to perform its current functions was not entitled to a variance for the purposes of remodeling because the inferior design had been self-created. And see Sciacca, supra.
What occurred in the case at bar is more similar to what occurred in Whittaker v. Zoning Board of Appeals of the Town of Trumbull, 179 Conn. 650, 427 A.2d 1346 (1980), where a prospective purchaser, Esposito, obtained a variance for the re-subdivision of property he was buying. Whittaker, and other land owners in the original subdivision, petitioned the issue to the courts. The prior subdivision had been approved with the understanding that a public road, eventually, would be extended through the middle of the property. There was an indication on the prior plat that a cul-de-sac was intended to be temporary and that a road might be extended in that *200area in the future. The purpose of the re-subdividing at issue was to accommodate the extension of the public road, the contemplation of which was required by the public authorities at the time of the prior subdivision, by creating two lots, one on each side of where the authorities had wished to place the road. Whittaker argued that no true hardship had been demonstrated because the lot before the variance was granted was conforming and buildable and that the town had not taken the road area by condemnation, therefore the re-subdivision was not necessary and the division of the lot itself, into two lots, would be self-created. The Connecticut court opined:
“The plaintiffs argue essentially that the hardship complained of by Esposito is self-created and, therefore, that the variance was improperly granted. We do not agree.
“The hardship which justifies a board of zoning appeals in granting a variance must be one that originates in the zoning ordinance....
“The applicant for the variance, Esposito, was presented with a genuine hardship beyond his control and not of his or the record owner’s making. The 1.79 acre parcel involved has been designated as the location through which Quail Trail is to extend to connect to Foster Avenue since 1969, when the town planning and zoning commission approved the Lagaña subdivision upon that condition.
“Esposito’s application for a variance was filed ... long after the commission’s 1969 decision to extend Quail Trail was expressed in an official map....
“Under the circumstances of this case, the extension of Quail Trail can hardly be said to be the voluntary act of Esposito.” Whittaker, 179 Conn. at 657-61, 427 A.2d at 1350-52. [Footnote omitted.]
In the present case, before the re-subdivision of the development, the undersized lots would not have been self-*201created hardships because they were legal lots, albeit perhaps non-conforming lots. When a governmental statute permits and encourages an owner, or owners, to take certain action in order to be able to utilize property, that action cannot be characterized as self-created.
Once the process of subdivision or re-subdivision commences, it is not at all uncommon for there to be parcels or lots reserved by the owners and not offered for immediate sale or proposed for immediate use. Sometimes the reason for the existence of these parcels or lots is that, because they contain environmentally sensitive areas, the owner intends to market the unencumbered lots first and later attempt to see if the affected lots or parcels can be approved for development. Often these reserved parcels have conditions attached to them at the direction of the governmental entity that approves the plats. When conditions are so imposed, the conditions, so long as they do not result in a taking of the property, are generally enforceable.
In Howard County v. JJM, Incorporated, 301 Md. 256, 270, 482 A.2d 908, 915 (1984), although it was a “Takings Clause” case, we described, in a somewhat limited manner, the nature of dedications and reservations, saying:
“We come down to the issue in this case, which is whether the Howard County subdivision regulation requiring JJM to reserve land for a proposed State highway constitutes an exercise of the County’s police power or a taking. If the regulation is determined to be a valid exercise of the police power, then JJM has no legal cause for complaint. If, on the other hand, the regulation is determined to be a taking of the property, the County has no right to require the reservation for the proposed highway.
“D. Hagman, Urban Planning and Land Development Control Law, § 140 (1975) defines the terms dedication and reservation:
‘Dedication ordinarily involves the conveyance of an interest in land by the fee owner to the public; usually to the local government having jurisdiction over the land. *202Reservation, on the other hand, involves no conveyance but restricts the right of the subdivider and others to use the land for anything but the restricted purpose.’ ”
The “Reserved Parcel 2,” in the present case, with the restriction as to percolation tests, in essence, constitutes a reservation of the property to the owner, but with a restriction that it cannot be used until such time as it passes the percolation requirements. Petitioner, as the re-subdividing property owner, was the person who reserved the parcel in her own ownership, and, albeit imposed by governmental regulation, placed the percolation restriction upon the use of her own property. As such, our interpretation of the nature of the designation and the restriction is subject to the body of property law we have developed in respect to the creation of restrictions, whether imposed by notations on plats or by a separate Declaration applicable to the property described on a particular plat. We addressed this issue, generally, in Belleview Construction Company, Incorporated v. Rugby Hall Community Association, Incorporated, 321 Md. 152, 158, 582 A.2d 493, 495 (1990), where we said, in construing covenant restrictions against a developer:
“If an ambiguity is present, and if that ambiguity is not clearly resolved by resort to extrinsic evidence, the general rule in favor of the unrestricted use of property will prevail and the ambiguity in a restriction will be resolved against the party seeking its enforcement.”
We had previously noted in Woodland Beach Property Owners’ Association, Incorporated v. Worley, 253 Md. 442, 449-50, 252 A.2d 827, 831 (1969) (quoting Brady v. Farley, 193 Md. 255, 258, 66 A.2d 474, 475 (1949)) that:
“ ‘In the recent case of Norris v. Williams, 189 Md. 73, 76, 54 A.2d 331, 332, Judge Delaplaine speaking for the Court, said:
“ ‘ “However, restrictions upon the use of land are in derogation of the natural right which an owner possesses to use and enjoy his property, and are repugnant to trade and commerce. Consequently, restrictive covenants are *203construed strictly against their establishment and effect, and liberally in support of the unrestricted use of the land....”
‘There must be borne in mind the often repeated doctrine that doubts should be resolved in favor of the unrestricted use of property.’ ”
We said in Peabody Heights Company of Baltimore City v. Willson, 82 Md. 186, 203, 32 A. 386, 389 (1895), in reference to restrictions concerning approval of building plans and the timing of construction, that:
“[AJJthough one in conveying real estate may impose certain restrictions.... Courts will always favor a liberal interpretation ... in order to impose as few difficulties as possible in the free use and disposal of the particular estate conveyed [or reserved].... [I]f the words are doubtful, they will be resolved in favor of keeping the restriction within the narrowest limits. In other words, if there be doubt as to the intention of the parties, Courts will naturally lean in favor of freedom of the property.” [Alterations added.]
See also Markey v. Wolf, 92 Md.App. 137, 151, 607 A.2d 82, 88-89 (1992), which quoted Peabody.
While in Belleview and cases since, we have modified the rule to be a reasonableness rule, the reservation in the present case, and the percolation restriction, even if ambiguous, which we do not believe they are, would be, even under the modified “reasonableness rule” of Belleview, construed to mean that the developer retained (“reserved”) a parcel of land for her future use if that property could be, at anytime in the future, successfully percolated.
In the case sub judice, the restriction placed on the reserved parcel was that it could not be built upon until such time as it passed percolation tests. It is clear, and it was clearly the governmental agency’s opinion, that if and when the parcel could be perked, it was a buildable lot. No other express limitations were contained on the plat. There was no *204evidence that the county had imposed any conditions forbidding petitioner from seeking variances. In fact, there was ample evidence that the county considered the parcel to be a legal lot, restricted only by the necessity to conduct satisfactory percolation tests.
Self-created Hardship as a Sole Factor
Petitioner presents the issue of whether self-created hardship, by itself, is sufficient to deny a variance without consideration of the remaining conditions contained in the ordinance. In other words, is it a sole disqualifying finding, or is it a factor to be considered along with other factors to determine whether practical difficulties or unwarranted hardships exist. The Board and the Court of Special Appeals held that in all cases, whether an area or a use variance is sought or whether practical difficulty or unwarranted hardship is the standard, a self-created hardship, by itself, is sufficient to deny the granting of a variance without any consideration of any other factors. In other words, if self-created hardship exists, the administrative entity need go no further.
We do have cases in which we have upheld the denial of variance relief where the agency has found that a self-created hardship existed. We have been unable to determine from the language of our cases whether this Court was ever expressly asked to address the question presented here — the issue of whether self-created hardship alone is sufficient to deny an area variance. We have appeared, in the absence of having it presented as a question by the parties in the various cases, to have assumed, without any extensive investigation of the matter, that it was sufficient.
We shall not resolve that issue in this case as we are holding that there is no self-created hardship in the first instance. Accordingly, we leave that issue for a future case, in so far as Maryland law is concerned.12
*207In the present case, the only condition required by Anne Arundel County was that the reserved parcel not be used until such time as it passed a percolation test. It imposed no other conditions. Often the need to reserve parcels is caused by then present circumstances that make the parcels, areas, or lots, then un-buildable, and thus, generally, unmarketable. Nonetheless, they are legal parcels or legal lots. They in fact are sellable, although rare may be the buyers for parcels with notations on the plats that they are presently defective, for whatever reason, as to building use. Later, if the circumstances change and the express and implied conditions placed upon the use of the property can be satisfied, the parcel stands in the same position as any other lot in respect to the right to seek variance relief. It is a legal parcel of property. The parcel in question has always been considered a legal lot by the county.
During the re-subdivision process permitted and encouraged by the Antiquated Lots Law and the pre-existing statute which placed the lots in nonconformance prior to the re-subdivision, the property combinations resulted in a parcel of land that was not then suitable for the erection of a residential structure because the portion of the parcel that remained after areas had been used for subdivision infra-structure would not, at that time, percolate or otherwise permit development due to critical area requirements.13 The area was designated as a *208reserve parcel, i.e., not then qualifying as real property upon which a house could be built. Nonetheless, the parcel remained the property of the subdivider. The only express restriction as to the reserve parcel is contained on the re-subdivision plat itself: “Reserve Parcel No. 2,” “unbuildable until a passing perc test is performed.” That limitation was required by Anne Arundel County authorities. The county subsequently approved the re-subdivision plat.14
It was clear to anyone examining the Administrative Plat that there was only one express limitation imposed on the subject property by the re-subdivision approval, i.e., that no residences could be built on the parcel until, and if, it passed a percolation test. No other limitations were noted on the plat. Our examination of the record does not reflect that any other limitations were imposed on the parcel during the process.
Subsequently, it was determined that there was an area within the parcel that could, and did, pass a percolation test. However, the use of that area for the sanitary system to be utilized for a residence on the parcel left an insufficient remaining area to accommodate the type of structure required to be built by covenants that affect the lots within the development and still be in compliance with “yard,” and other requirements, both critical areas and otherwise, of the zoning ordinance. At that point, the petitioner sought the various approvals, by way of area variances, which would be needed in order for a residential structure to be constructed on the parcel. Because the land, or a portion of it, was either in the critical area, or the critical area buffer zone, review by the Chesapeake Bay Critical Area Commission also was sought. That Commission interposed no objection to the project. Petitioner then sought critical area and other variances necessary to accommodate her proposed project.15 The relief she *209sought via the variance process was of the same type, if not scope, of the relief she might have had to seek had she never re-subdivided the property in the first instance.16
Respondents proffer in their brief that “The very laws Stansbury seeks to abridge were in existence before she created her reserved parcel.” To be sure, some, if not all, of *210those laws were in effect prior to the re-subdivision. It was the impact of those “very laws” upon the preexisting lots and parcels that created the conditions necessitating the applications for the variances. Prior to the time those “very laws” were passed, Stansbury would have had the right to either rely on the non-conforming character of the lots, a nonconformity created by subsequent statute, or would have had the right to seek a variance of the statutory provisions that put the pre-existing lots out of conformity. The Antiquated Lots Law, which we presume respondents are referring to, created another potential restriction on petitioner’s property by imposing a condition that adjacent lots had to be recombined, if in the same ownership, in an attempt to put the lots in conformity, or closer conformity, with the lot size requirements of the new statute. If the Antiquated Lots Law applied, petitioners re-subdivision brought the property into closer compliance. Permissive re-subdivision (or any subdivision for that matter) that decreases nonconformance is not a self-created hardship in respect to remaining small areas of property that require variance considerations before they may be developed.
Conclusion
It is clear that the circumstances here present are far removed from the traditional concept of a self-created hardship. Petitioner, in re-subdividing in compliance with county requirements was left with, as is generally the case, a parcel of land not then buildable in that re-subdivision. In re-subdividing, which met the combination requirements and the requirement to file an Administrative Plat, and was in compliance with other county laws, she insured that the only express condition attached to her ability to fully use the reserve parcel was the provision in respect to percolation. There is no evidence in this case that the county intended to impose any other express conditions on the re-subdivision. It was equally clear that the county always considered this parcel to be a legal lot.
*211Therefore, the owner of the parcel is fully entitled to seek any relief that any other property owner is entitled to seek. She may not, on remand, get the relief, but she is entitled to try without having the Board or the courts disqualify her from seeking relief on the grounds that what occurred during her specific re-subdivision amounted to a self-created hardship. In light of our decision, we decline to resolve any other issues presented in this case.
JUDGMENT OF THE COURT OF SPECIAL APPEALS REVERSED AND THE CASE IS REMANDED TO THAT COURT WITH DIRECTIONS TO AFFIRM THE JUDGMENT OF THE CIRCUIT COURT FOR ANNE ARUNDEL COUNTY. COSTS IN THIS COURT AND IN THE COURT OF SPECIAL APPEALS TO BE PAID BY THE RESPONDENTS.