In In re Appeal of Council Member Cindy Bass, 2024 Pa. Commw. LEXIS 172 (July 19, 2024), the Pennsylvania Commonwealth Court affirmed, in part, a decision by the city of Philadelphia's Zoning Board of Adjustment (ZBA), finding that a real estate developer's evidence established an unnecessary hardship because it proved that the property, a vacant lot that needed costly environmental remediation, was practically valueless without the granting of a variance under the Philadelphia Zoning Code.