dissenting.
In enacting N.J.S.A. 18A:54~37 the Legislature apparently was attempting to spare the City of Bayonne financial responsibility for a vocational school its students would not attend. Bayonne has maintained its own high-quality vocational-educational program since 1931. For Bayonne students, the Hudson County vocational program, established in 1972, was a duplication of effort; for Bayonne taxpayers, it was a duplication of expense.
*509By concluding that N.J.S.A. 18A:54-37 offends the constitutional prohibition on special legislation relating to taxation, the majority unnecessarily interferes with the Legislature’s authority to balance competing municipal interests. Because the majority overlooks the well-established principles governing this Court’p consideration of special legislation, I dissent from so much of the Court’s judgment as holds the statute to be unconstitutional special legislation. I would uphold the validity of the statute.
I.
N.J.S.A. 18A:54-37 provides:
Notwithstanding any of the provisions of chapter 54 of Title 18A of the New Jersey Statutes, in any county of the first class having a population of not more than 700,000 according to the latest federal decennial census, each municipality included within a school district which has maintained for a minimum of 20 years a vocational education program approved for the purposes of federal or State allotment of vocational funds by the Commissioner of Education under the regulation of the State Board of Education shall be exempt from assessment, -levy or collection of taxes based on any apportionment of amounts appropriated for the use of a county vocational school district.
Plaintiffs allege that that statute violates the constitutional mandate that “[t]he Legislature shall not pass any private, special or local laws: * * * Relating to taxation or exemption therefrom.” N.J. Const, art. IV, § 7, ¶ 9(6). The principles generally applicable to challenges addressed to the constitutionality of statutes likewise guide our consideration of a claim that a statute violates the special legislation prohibition.
That “[a] statute is presumed to be constitutional and will not be declared void unless it is clearly repugnant to the Constitution,” Newark Superior Officers Ass’n v. City of Newark, 98 N.J. 212, 222, 486 A.2d 305 (1985), is well-established. When a statute is susceptible of more than one interpretation, courts favor an interpretation sustaining its constitutionality. In re Loch Arbour, 25 N.J. 258, 264-65, 135 A.2d 663 (1957). Furthermore, a party challenging the validity of a statute under the special-legislation prohibition of article IV has the burden of demonstrating clearly *510the constitutional violation. Newark Superior Officers Ass’n, supra, 98 N.J. at 222, 486 A.2d 305.
In Vreeland v. Byrne, 72 N.J. 292, 298-301, 370 A.2d 825 (1977), we established a three-part test to determine whether a statute is unconstitutional special legislation. We first consider the purpose of the law in question. Next, we apply the law to the factual context to determine whether exclusions from the statute’s applications can be identified. Finally, we determine whether a rational basis exists that is related to the object of the statute on which the exclusion or classification may rest. Ibid. In ascertaining whether such a rational basis exists, we are not “limited to the stated purpose of the legislation, but should seek any conceivable rational basis.” Township of Mahwah v. Bergen County Bd. of Taxation, 98 N.J. 268, 286, 486 A.2d 818, cert. denied sub nom. Borough of Demarest v. Township of Mahwah, 471 U.S. 1136, 105 S.Ct. 2677, 86 L.Ed.2d 696 (1985).
In Vreeland, supra, that test guided our consideration of the validity of a statute that increased the salaries of Associate Justices of the Supreme Court but denied that increase to any member of the Legislature who might be appointed to the Court after enactment of the salary increase and during the term for which he or she had been elected to serve in the Senate or General Assembly. The Court first determined that the sole purpose of the statute was to increase judicial salaries. 72 N.J. at 298-99, 370 A.2d 825. The Court then inquired whether “there are persons similarly situated to those embraced within the act, who, by the terms of the act, are excluded from its operation.” Id. at 299, 370 A.2d 825. Any member of the Legislature who might succeed to a vacancy on the Court was excluded by the terms of the statute. Ibid. In considering whether some rational basis existed for that exclusion, the Court concluded that “[i]t would be fatuous to suggest that distinctions exist among the Associate Justices of the Court such as to justify a salary differential.” Id. at 300, 370 A.2d 825. Having found no rational basis for the exclusion, and concluding that “the legislative intent [would] be more nearly realized by exscinding this provision than by declar*511ing the entire statute unconstitutional,” id. at 301, 370 A.2d 825, the Court excised the arbitrary classification from the statute. Ibid.
In Newark Superior Officers Ass’n, supra, 98 N.J. 212, 486 A.2d 305, we applied the Vreeland test to a statute that permitted mayors of first-class cities having a “Mayor-Council Plan C” form of government to appoint police chiefs to unclassified civil-service positions. We first determined that the object of the legislation was to provide for greater cooperation between a police chief and the administration of cities of the first class. Id. at 224, 486 A.2d 818. We then observed that the statute was applicable only to Newark and Jersey City and that the population requirement of the statute acted to exclude all other cities. Ibid. Acknowledging the nexus between accountability and population, and drawing on earlier judicial recognition of the validity of population classifications, we concluded that the exclusions created by the statute were rationally based. Id. at 225-28, 486 A.2d 818.
We explained in Newark Superior Officers Ass’n that “in deciding whether an act is special or general legislation, the determining factor is what is excluded and not what is included.” Id. at 223, 486 A.2d 818. We also emphasized our focus on statutory exclusions in Paul Kimball Hospital, Inc. v. Brick Township Hospital, Inc., 86 N.J. 429, 432 A.2d 36 (1981), in which we observed that “the particular determinant of a special law is the appropriateness of the objects which it excludes.” Id. at 445, 432 A.2d 36. The principles generally applicable to equal-protection analysis similarly are applicable to a consideration of the propriety of a statutory exclusion. Id. at 445, 432 A.2d 36. Thus, we noted in Paul Kimball Hospital that
the Legislature has wide discretion in determining the perimeters of a classification, distinctions may be made with substantially less than mathematical exactitude, and an adequate factual basis for the legislative judgment is presumed to exist. We must also be mindful of the strong presumption in favor of constitutionality, and the traditional judicial reluctance to declare a statute void, a power to be delicately exercised unless the statute is clearly repugnant to the Constitution.
[Id. at 446-47, 432 A.2d 36 (citations omitted).]
*512Our adjudication of a special-legislation challenge must proceed in accordance with those principles. Generally, we uphold the constitutionality of a statute unless the party challenging the statute can demonstrate that no rational basis exists to support the exclusionary classification. Newark Superior Officers Ass’n, supra, 98 N.J. at 222-23, 486 A.2d 305.
II.
The object of N.J.S.A. 18A:54-37 is threefold. First, the statute spares municipalities that maintain a vocational program that has been approved for federal or State funding for at least twenty years and are located in large, densely-populated counties the financial burden of contributing to the funding of a county vocational program. In turn, that exemption serves as an incentive to those municipalities to preserve the quality of their vocational programs and to continue their operation. Finally, the availability to municipal residents of a high-quality vocational program renders them less likely to attend a county vocational program. Their attendance at the local vocational school reduces to some extent the demand for admission to a vocational-school program operated by a first-class county.
We next consider which, if any, municipalities are excluded from the statute’s scope and whether that exclusion is rationally based. The statute requires that in order to be eligible for the exemption, a municipality must maintain a vocational program that is approved for State or federal funding. Funding may be withheld from local vocational programs that do not meet the standards established by the State Board of Education and the United States Department of Education. See generally N.J.A.C. 6:43-2.1 to 3.19. Unquestionably, a rational basis existed for the Legislature to have selected only those municipalities with comprehensive, regulated vocational programs to be included in the class exempted from participating in the funding of county vocational programs.
*513Further emphasizing the importance of vocational programs of established quality, the statute also requires that the program have been in existence for at least twenty years. That limitation necessarily excludes from the scope of N.J.S.A. 18A:54-37 all vocational-school programs that have been operating for fewer than twenty years. Surely, the Legislature could have designated a period shorter than twenty years as the standard for assuring that a vocational-school program is sufficiently well-established to merit the tax exemption for its municipality, but we need not second-guess the rational legislative decision that only programs operating twenty years or more demonstrate the required measure of quality and durability.
The statute also excludes from the class any municipality not located in a first-class county. Bergen, Essex, and Hudson are the only first-class counties in New Jersey. Thus, only municipalities in those counties are eligible for the N.J.S.A. 18A:54-37 exemption. First-class status is determined by the population and density of the county. As noted earlier, “A classification based on population does not automatically render a law unconstitutional special legislation.” Newark Superior Officers Ass’n, supra, 98 N.J. at 225, 486 A.2d 305. Because first-class counties have the largest population and the largest vocational-student population, the potential for overcrowding of county-vocational programs may be greater in first-class than in other counties, arguably prompting the Legislature to focus its attention on encouraging municipal vocational-school programs in first-class counties. Although a need for municipally-operated vocational schools may exist in other than first-class counties, we should not condemn as irrational the Legislature’s determination to restrict the tax exemption only to municipalities in first-class counties. See Mahwah, supra, 98 N.J. at 289-90, 486 A.2d 818 (emphasizing that “in population classification cases, legislative bodies may undertake the progressive resolution of problems dealing first with those aspects that are most pressing”).
The classifications thus far described narrow eligibility of municipalities to those located in a first-class county that have *514maintained an approved vocational program for at least twenty years. The list of approved vocational programs reveals that no municipality either in Bergen or Essex Counties maintains such a program. Bayonne has maintained its program for over twenty years.
N.J.S.A. 18A:54-37 is further limited to municipalities in first-class counties with a population of not more than 700,000. That limitation does not exclude any municipality from the benefits of the statute because no municipality in a first-class county with a population exceeding 700,000 has maintained an approved vocational program for twenty years or more. The population of Hudson County is less than 700,000. Because we look to what is excluded and not what is included, we need not determine the rationality of the population cap because it has no effect. As noted in Mahwah, supra, “While we might not agree that the population line should have been drawn where it has been, we submit that that determination is a legislative function subject to many considerations beyond the purview of this Court.” 98 N.J. at 291, 486 A.2d 818; see also State ex rel. Owens v. Fury, 55 N.J.L. 1, 25 A. 934 (S.Ct.1892) (upholding statutory classification that excluded all cities with populations below 50,000 or above 100,000).
Even if the population ceiling were to exclude a municipality that is otherwise similarly situated, the Court could invalidate that ceiling and sever it from the balance of the statute, rather than conclude that the statute is unconstitutional as special legislation. Because the 700,000 population ceiling excludes no qualifying municipalities from the statute’s coverage, the Legislature clearly would prefer its excision to complete invalidation of the exempting statute. See Mahwah, supra, 98 N.J. at 294-95, 486 A.2d 818 (preserving statute’s constitutionality by severing grandfather clause that would render statute special legislation); Vreeland, supra, 72 N.J. at 301, 370 A.2d 825 (finding legislative intent more nearly realized by excising irrational statutory classification than by declaring statute unconstitutional).
*515The rationally-based classifications in N.J.SA 18A:54-37 operate to exclude all municipalities except Bayonne. That a statute operates in favor of only one municipality does not render that statute invalid. Mahwah, supra, 98 N.J. at 285, 486 A.2d 818. When a statute addresses the needs of a specific community, the Court should consider whether “other municipalities could, and from time to time have, come within its scope.” Ibid. Other municipalities may become eligible for the exemption provided by N.J.S.A. 18A:54-37; for example, Kearny will be eligible for the statutory exemption in the year 2000.
III.
The majority concludes that “N.J.S.A 18A:54-37, as it actually operates does not represent a reasonable legislative classification.” Supra at 501, 628 A.2d at 298. In reaching that conclusion, the majority overlooks the direction of Newark Superior Officers Ass’n, supra 98 N.J. at 222, 486 A.2d 305, that courts should not substitute their judgment for that of the Legislature in determining whether a legislative classification is rational. “If we can conceive of any reason to justify the classification, the statute will be upheld.” Id. at 227, 486 A.2d 305. The majority offers several justifications for the statutory classifications. For example, the majority states that “it is possible to conjecture that the Legislature had a special interest in encouraging the development of local vocational education programs in the State’s most densely-populated areas.” Supra at 497, 628 A.2d at 296. Nevertheless, the majority concludes that that possibility is remote. Ibid. Our prior holdings emphasize, however, that if “any conceivable rational basis,” Mahwah, supra, 98 N.J. at 286, 486 A.2d 818, exists to justify a statutory classification, the Court must uphold that statute. Id. at 285-86, 486 A.2d 818; Vreeland, supra, 72 N.J. at 301, 370 A.2d 825. As we explained in Newark Superior Officers Ass’n, supra:
Ultimately, the generality or speciality of a statute becomes a question of reasonableness. There is no general rule to distinguish a reasonable from an unreasonable classification, the question being a practical one varying with the facts in each case. As stated previously, where the question of reasonableness is fairly debata*516ble, courts will uphold the classification. The burden of showing that the classification is not reasonable is upon the party attacking the statute. If we can conceive of any reason to justify the classification, the statute will be upheld.
[98 N.J. at 227, 486 A.2d 305]
Because I believe that the reasonableness of the classifications in N.J.S.A. 18A:54-37 are, at the very least, “fairly debatable,” I would uphold the validity of the statute.
For modification and affirmance — Chief Justice WILENTZ and Justices HANDLER, CLIFFORD, POLLOCK and GARIBALDI — 5.
For reversal — Justices STEIN and O’HERN — 2.