DISSENTING OPINION BY
Judge SMITH-RIBNERI join in Judge McGinley’s dissent but offer additional reasons for my conclusion that the majority erred in affirming the order of the Court of Common Pleas of Potter County, which reversed the County’s roll-back tax assessment imposed under the Pennsylvania Farmland and Forest Land Assessment Act of 1974(Aet), Act of December 19, 1974, P.L. 973, as amended, 72 P.S. §§ 5490.1-5490.13. The substantial alterations made by Wending Creek to a part of the land “split off’ from the parcel of land subject to preferential tax assessment removes the entire parcel from the forest reserve use for the purpose of imposing roll-back taxes in this case. The intent of the Act with respect to forest reserve use is to promote the conservation of privately-owned woodlands covering an area of ten or more acres. Feick v. Berks County Board of Assessment Appeals, 720 A.2d 504 (Pa.Cmwlth.1998).
Section 6(a.l)(l) of the Act, 72 P.S. § 5490.6(a.l)(l), provides in part:
The split-off of a part of land which is subject to preferential assessment under this act shall subject the land so split off and the entire tract from which the land was split off to roll-back taxes as set forth in section 5.1. The landowner changing the use of the land to one inconsistent with this act shall be liable for payment of roll-back taxes. The landowner of land which continues to be eligible for preferential assessment shall not be liable for any roll-back taxes triggered as a result of a change to an ineligible use by the owner of the split-off tract. (Emphasis added.) (Footnote omitted.)[1]
Section 5.1 of the Act, added by Section 6 of the Act of December 21,1998, P.L. 1225, 72 P.S. § 5490.5a, in turn provides:
If a landowner changes the use of any tract of land subject to preferential assessment under this act to one which is inconsistent with the provisions of section S [72 P.S. § 5490.3] or for any other reason the land is removed from a land use category under section S, ..., the land so removed and the entire tract of *695which it was a part shall be subject to roll-back taxes plus interest on each year’s roll-back tax at the rate of six percent (6%) per annum. After the first seven years of preferential assessment, the roll-back tax shall apply to the seven most recent tax years. (Emphasis added.)
It is undisputed that, after obtaining approval for the golf course, the developer altered the natural topography of Wending Creek’s 41.62-acre parcel by excavating and stripping a 4-acre portion of the parcel, piling topsoil and installing pop-up sprinklers, underground pipes, surface fixtures, electric cable systems and sewer manholes. These changes are not merely some substantial landscaping alterations as the trial court concluded, and it is irrelevant that they never progressed to the point of changing the forest and field as the majority stated.
Provisions of a statute exempting persons and property from taxation or creating a preferential tax treatment must be strictly construed against the taxpayer. Section 1928(b)(5) of the Statutory Construction Act of 1972, 1 Pa.C.S. § 1928(b)(5); Citadel Dev. Co. v. Board of Assessment Appeals of Erie County, 574 Pa. 84, 828 A.2d 1057 (2003). Under the plain and unambiguous language of Sections 5.1 and 6(a.l)(l), the only relevant inquiry for determining when to impose roll-back taxes is whether the use of a parcel has been converted to a use that is inconsistent with the use receiving preferential tax treatment. The Act does not require a complete and permanent change to an inconsistent use. Rather, Wending Creek’s intent to convert forest reserve use to a golf course use along with the actual performance of substantial alterations to the land dictate a roll-back tax assessment against the entire parcel. See Sections 5.1 and 6(a.l)(l).
This conclusion is consistent with Deigendesch v. County of Bucks, 505 Pa. 555, 563, 482 A.2d 228, 232 (1984), in which the Supreme Court held:
The Act contemplates that the entire tract covenanted will remain continually eligible for special tax consideration by preserving the integrity of each of the essential qualifications during the term of the covenant. All of the statutory requirements which make the land eligible in the first instance must continue until the expiration of the covenant. A change in any of the requirements during the term of the covenant constitutes a breach in the sense that the property which is the subject of the covenant is no longer qualified under the Act.
The covenant was breached when Wending Creek commenced construction of the golf course on a part of the parcel subject to preferential assessment. The fact that the parcel has not been used as a golf course due to intervening personal and business difficulties of Wending Creek’s owner, or that the part of land converted represented less than ten percent of the 41.62-acre parcel, is irrelevant in determining whether a change of use occurred for purposes of imposing the tax.
In Hydrusko v. County of Monroe, 699 A.2d 828 (Pa.Cmwlth.1997), the owner constructed her residence, a one-bedroom apartment and a bed and breakfast on a portion of a 62-acre tract receiving preferential tax assessments. Section 6(b) of the Act, 72 P.S. § 5490.6(b), permitted a residential use on up to two acres of the tract receiving the assessment. Rejecting the argument that the tract was not subject to roll-back taxes because the primary use of the parcel was for permitted purposes, this Court held that the construction and operation of a bed and breakfast could not be characterized as an agricultural, agricultural reserve or forest reserve use and *696that the entire tract therefore was subject to roll-back taxes. As in Hydrusko, the fact that the remaining portion of Wending Creek’s parcel has been unaltered and has remained as forest reserve does not preclude the imposition of roll-back taxes on the entire tract. See also Godshall v. Montgomery County Board of Assessment Appeals, 42 Pa. D. & C.3d 191 (1985) (holding that roll-back taxes properly imposed although 75-acre parcel receiving preferential assessments only temporarily used for five days a year for a Philadelphia folk festival requiring certain structures to be affixed to the land). Accordingly, I would reverse.
. A "split-off” is defined as “[a] division, by conveyance or other action of the owner, of lands devoted to agricultural use, agricultural reserve or forest reserve and preferentially assessed under the provisions of this act into two or more tracts of land, the use of which on one or more of such tracts does not meet the requirements of section 3 [72 P.S. § 5490.3].” Section 2 of the Act, 72 P.S. § 5490.2. "Forest reserve” is defined as "[l]and, ten acres or more, stocked by forest trees of any size and capable of producing timber or other wood products.” Id. Section 3(a), 72 P.S. § 5490.3(a), provides that "[f]or general property tax purposes, the value of land which is presently devoted to agricultural use, agricultural reserve, and/or forest reserve shall, on application of the owner and approval thereof ... be that value which such land has for its particular land use category....”