dissenting.
The majority opinion sets forth the proper scope of review in this annexation case— is there substantial evidence to show that the annexation was reasonable and proper? City of Branson v. Biedenstein, 618 S.W.2d 665, 667 (Mo. banc 1981). Is the question of reasonableness fairly debatable? If so, then the action of the legislative body is conclusive. Binger v. City of Independence, 588 S.W.2d 481, 483 (Mo. banc 1979). Review is not by trial de novo. City of St. Charles v. Schone, 569 S.W.2d 769, 774 (Mo.App.1978); City of Perryville v. Brewer, 557 S.W.2d 457, 463 (Mo.App.1977).
The majority opinion finds that there was substantial evidence to support the trial court’s decision that the annexation was reasonable and necessary. According to the majority, the issue of annexation was reasonable and necessary. In so doing the majority thoroughly attenuates City of Olivette v. Graeler, 338 S.W.2d 827 (Mo.1960) (Graeler I) and City of Olivette v. Graeler, 369 S.W.2d 85 (Mo.1963) (Graeler II).
Contrary to the majority, I must conclude that the City of Town and Country has failed to carry its burden of showing that the annexations were reasonable and necessary under the circumstances. Furthermore, I am convinced that this case provides substantial reason for sustaining and following the fine principles of the Graeler cases. I do not believe that the legislative modification of chapter 71 dealing with annexation by consideration of the voters of the annexation area should have any impact on the effect of the Graeler decisions.
Since becoming a fourth class city in 1974, highly fashionable Town and Country has been governed by a four person board of aldermen and a mayor. Each of the officials receives a yearly compensation of one dollar. It also employs a small administrative and professional staff. The municipal government office is open four and a half hours a day, five days a week, but many of the city employees are part-time and have no scheduled office hours. It does not have a public works department, parks department, recreational department or environment services department; it has no parks. Its sewer system is within the Metropolitan St. Louis Sewer District. The police and fire departments are melded into one small department called the Department of Public Safety, with police and fire fighting personnel changing costumes of authority as the particular occasion arises. The city employs outside contractors, in many cases St. Louis County, to enforce health and safety regulations, fire, plumbing and building codes, mosquito and rabies control and provide maintenance to a limited number of streets. An alderman serves as street commissioner in charge of contracting for road services on the 3.2 miles of roads outside subdivisions. The private subdivisions, which incorporate most of the city, maintain their own roads, except for certain signs and snow removal to aid emergency vehicles required to operate within the subdivisions.1
The proposed areas of annexation are three irregularly shaped tracts of unincorporated land adjacent to Town and Country’s western and southern borders. The first parcel is the largest of the three. It is 50 percent developed and has various and diverse residential, commercial and institutional developments. Western Electric Company and its companion intervening defendants are located in parcel 1. The second parcel is the smallest of the three parcels. It is 90 percent developed and is almost totally residential. The third parcel *610is 50 percent developed. Parcel 3 contains both residential and industrial developments. Intervenor McGraw-Hill is located in parcel 3. The total area of the proposed annexations is larger than Town and Country. In the areas proposed to be acquired, St. Louis County provides ample municipal services including police, planning and zoning, highway and traffic, public works, parks and recreation and health. The Manchester Fire Protection district provides substantial fire protection service to most of the proposed annexation area and backup service to Town and Country. The Creve Coeur and Chesterfield Fire Protection Districts cover the rest of the annexation areas; a small portion is protected under contract by Town and Country. St. Louis County police provide twenty-four hour service in both areas, but Town and Country disputes its effectiveness.
The concepts of “reasonableness” and “necessity” as used in § 71.015 and pertaining to annexation are recognized as closely related, though separate. City of O’Fallon v. Bethman, 569 S.W.2d 295, 302 (Mo.App.1978). Both the city and the area to be annexed are entitled to the test of reasonableness. City of Olivette v. Graeler, 338 S.W.2d 827, 837 (Mo.1960) (Graeler I); City of Cameron v. Stafford, 466 S.W.2d 115, 120 (Mo.App.1971). And the annexing city bears the burden of demonstration that its proposed action is reasonable. Young v. Mayor, Council and Citizens of the City of Liberty, 531 S.W.2d 732, 737 (Mo. banc 1976).
A case of reasonableness is accomplished when it appears that the land annexed is so situated as to be adaptable to urban purposes, and necessary or convenient to reasonable exercise of the city government. Brewer, 557 S.W.2d at 462. The city bears the procedural burden of establishing the statutory elements in an annexation proceeding. Graeler I, 338 S.W.2d at 833; City of Cameron v. Stafford, 466 S.W.2d at 119.
Annexation cases necessarily involve a multitude of factors2 which may be considered in determining the reasonableness of the legislative decision to annex. It is fundamental that each relevant factor should be considered in relation to the others with no single factor being determinative. City of Des Peres v. Stapleton, 524 S.W.2d 203, 207 (Mo.App.1975). Necessarily, each case must be decided on its own individual facts. City of St. Peters v. Kodner Development Corp., 525 S.W.2d 97, 99 (Mo.App.1975).
The need for individual consideration is especially relevant in annexation cases involving St. Louis County because of the uniqueness of the circumstances. Specifically, the City of Town and Country is substantially less sophisticated in development and as a provisioner of municipal services than the unincorporated area of St. Louis County which it seeks to bring into the fold of its limits and limited services.
*611The incongruency of this situation has been recognized previously. In City of St. Peters v. Kodner Development Corp., 525 S.W.2d 97 (Mo.App.1975), the anomaly of annexations in urban areas as compared to rural areas was specifically discussed:
Certain guidelines which have applicability to annexations involving a city or town located in an essentially rural area are of little benefit when dealing with urban or suburban areas. In the former cases people are locating within an established city and annexation becomes a necessity when the geographic limits are unable to contain the population desirous of locating in the city and it begins spilling over into surrounding land. But it is ■ still the city or town, surrounded by rural or non-residential land, to which the population is affixing itself. A different phenomonon is involved when dealing with America’s middle-age problem — urban spread. There the population is associating itself with a large metropolitan area, without regard generally to the particular city, town, village or county in which it is locating. Rather the considerations are proximity and access to an overall metropolitan job market.
Id. at 99.
City of Olivette v. Graeler, 369 S.W.2d 85, 95 (Mo.1963) (Graeler II) is foremost in speaking for the distinctive character of St. Louis County in relation to annexation:
It seems obvious that in this highly developed and substantially urbanized community we have a situation materially different from those which exist in annexation proceedings elsewhere. This “area” has more services and advantages available and has less need for the City’s services; the County has the facilities and the organization to furnish the necessary services; the area is, in large part, highly developed through no act of the City, directly or indirectly; and the County here, by annexation, would lose control of an area which constitutes an integral part of its future plans. In such a situation it would be difficult to establish an overall reasonableness and necessity, considered in the light of our recent constructions of the Sawyers Act.
Graeler I and Graeler II each identifies several factors to be considered in annexation cases arising in St. Louis County:
[T]hat upon the consideration of reasonableness, the fact that municipal services were presently being rendered in the area should be weighed; that the people of both the City and the proposed area are entitled to the benefit of the test of reasonableness; ... that it is in order to consider what the ‘proper development’ of a city is in light of existing conditions (such as the multitude of annexations and incorporations in St. Louis County), as an element of necessity and reasonableness; that the development of the county must be considered and ‘the interest of the county as a community must be weighed against the claims of the city .... ’
Graeler II, 369 S.W.2d at 93; Graeler I, 338 S.W.2d at 838. (Emphasis added.)
Town and Country argues that the impact of the Graeler decisions has been so thoroughly enervated as to cause each to fall into desuetude. In support, it cites numerous cases in which the County unsuccessfully opposed annexation in the trial court.3 But with the increased sophistica*612tion of the unincorporated area of the County and its services, rather than being anachronistic, the substance of the Graeler cases is more to the fore and cogent; those cases should endure, for their holdings are even more pertinent and poignant to the circumstances of this case.
The Graeler decisions would not destroy the vestigial remnants of annexations in St. Louis County as lamented by the City. Yet, the vitality of the “county as a community” concept must be recognized and, accordingly, the effect of the annexation on St. Louis County must be considered as a proper concern — as it has in the past — in order to determine reasonableness. So I must disagree with the majority’s devitali-zation of the concepts contained in those cases.
A review of the trial court’s findings of fact and conclusions of law indicates that it failed to weigh the interest of the County as a community against the claims of the city. Graeler II, 369 S.W.2d 93. The trial court made forty-two separate findings of fact but only one related in any regard to the interest of the “county as a community.” The trial court found:
There was no evidence that the operation of any of the departments of the County government would be adversely affected by the annexation of Parcels 1,2 and 3 by the City of Town and Country. There was evidence that there would be a loss of revenue received by the Division of Highways and Traffic and by the Police Department, but there was no evidence in either instance as to whether or not such loss of revenue would be offset by a reduction in expenditures by either department by reason of elimination of annexation of Parcels 1, 2 and 3.
None of the court’s conclusions of law addresses the factors identified in the Graeler cases regarding the County’s interest.
This Court in Graeler II stated that a determination of reasonableness requires “a consideration of the interest of the County in the area generally and the effects of the proposed annexation, not only in connection with services rendered, but in a loss of control of the area and in such other ways as would vitally affect the County.” Graeler II, 369 S.W.2d 94. In the trial court’s decision there was no consideration given to the special aspects that are presented by an annexation in St. Louis County, and the findings of the trial court cannot be construed as a balancing of the interests of the County and Town and Country. Thus, the trial court’s determination of reasonableness is antagonistic to the requirements and holdings of the Graeler cases. But, of course, the majority vitiates the Graeler decisions.
An examination of the competing interests establishes that St. Louis County has several important interests at stake. Af-firmance of these annexations pertaining to St. Louis County would set an unfortunate precedent for future annexations with immediate and direct deleterious effects. The County would lose substantial tax revenues. An example would be an anticipated cigarette and utility gross receipts tax loss of $317,000 to the St. Louis County Police Department. The County projects that if the annexations are approved, its loss in tax revenue will begin at $1,000,000. The trial court determined that some County departments would lose revenue as a result of the annexations, but that there was no evidence to show whether or not the loss would be offset by a reduction in County services to the annexed areas. However, that rationale is out of phase with Graeler II. An exchange of a loss in revenue for a reduction of service would result in a “whittling away” of the County’s governmental organization. Graeler II, 369 S.W.2d at 95.
Considering the impact of the revenue loss, in conjunction with the loss of control and planning, and the loss of developable land, the adverse effect on the County as a community is consequential. The annexations would deprive the County of its control and planning over the annexed areas’ development, and County government is positively active in the planning and zoning *613of the unincorporated areas. The annexations would also deprive the County of valuable developable land beneficial for all its residents. Instead of being beneficial to the entire County, any development within the parcels would be limited in benefits to only Town and Country. The evidence shows that Town and Country lacks the County’s expertise in planning; in fact, it has no expertise but relies on the County for its own purposes. After studying the proposed annexations, the County’s Department of Planning concluded that the annexations would:
[FJreeze development in one of the most accessible and developable portions of Central West County and would enlarge the tax base of the City of Town and Country considerably. The proposed annexation is clearly not in the best interest of all area residents or the citizens of St. Louis County as a whole.
The evidence adduced at trial firmly established that basically, Town and Country has two interests at stake: increased tax revenues and zoning protection, neither of which is a proper basis for annexation. As early as 1975 Town and Country began to view annexation as a possible solution to its perceived financial problems and as a way of gaining a stronger rezoning position against commercialization. In 1975 a committee appointed by the Mayor reported that by annexing unincorporated lands to the west and south the City would derive an additional $77,500 to $115,000 a year in taxes. After the decision to annex had been made, the City explained its decision to the voters. In a letter to the residents of Town and Country dated February 2, 1977, somewhat striking against County hegemony, the Mayor and Board of Aldermen explained the rationale for annexing the three parcels:
Through annexation, Town and Country would—
1. Gain a sizable commercial tax base and a growing residential tax base;
2. Achieve vital zoning protection on its borders;
3. Insure the survival of Town and Country beyond the mid 1980s;
4. Reduce real estate taxes;
5. Avoid imposition of nondeductible taxes.
The letter urged Town and Country’s residents to approve the annexation of the parcels because rejecting them would, by law, foreclose a resubmission of the proposals for two years, and “[b]y that time other cities could have annexed the area.” The Mayor and Board mailed similar letters in March and April. These letters indicate the same type of race for land that this Court termed “unseemly” in Graeler II, 369 S.W.2d at 95.
Neither of the two major articulated interests of the City for annexation provides legitimate purpose. Courts have long disfavored the use of annexation solely for tax purposes. See City of Fulton v. Dawson, 325 S.W.2d 505, 518 (Mo.App.1959). Nor is annexation solely for zoning protection a reasonable justification. City of Odessa v. Carroll, 512 S.W.2d 862, 868 (Mo.App.1974).
An examination of the proposed annexations leads to one conclusion: Whether each parcel is considered separately or together, the reasonableness of these annexations is not fairly debatable. Town and Country’s letters to its residents evince a desire to win the race against other municipalities in a contest to annex valuable unincorporated territory. In approving the annexation, the trial court failed to consider the interest of St. Louis County as a community, and it is necessary that it do so.
Town and Country and the amici curiae Missouri Municipal League decry anything short of full approval of the annexation. They urge that denial rings the death knell for any annexation in St. Louis County. That is not so. But it is so that the Graeler cases and those following would make it more difficult for an annexing authority to meet its burden of showing that its taking over in an area in St. Louis County is reasonable, applying the proper dialectical test.
I am guided in the application of existing law to the facts of this case by the distinctive nature and circumstances pertaining to *614St. Louis County and its substantially advanced, highly urbanized development — a fact even more apparent now than at the time of the Graeler cases (1960 and 1963). That makes the impact of those two cases with the other law recited in this dissent increasingly appropriate at this time.
Town and Country directs our attention to Mayor, Councilmen and Citizens of the City of Liberty v. Beard, 613 S.W.2d 642 (Mo.App.1981), modified 613 S.W.2d 641 (Mo. banc 1981), approving a Sawyers Act annexation in Liberty near Kansas City. That case was cited by the City to emphasize the standard of review. And it does follow those cases previously indicted in this opinion regarding review, e.g., Binger v. City of Independence, supra, and City of St. Peters v. Kodner Development Corp., supra. But the remarkable feature of the Liberty case is that it places a highlight on the precise reason for denying annexation in this case. In Liberty, the emphasis of the annexing city was that it was growing and becoming more urbanized. As a consequence, it was essential that the city control future development in the adjoining unincorporated area. As stated by the court:
Plaintiff City argues that the evidence shows the annexation was proposed because it was believed by the City officials and their professional consultants that the entire area was beginning to urbanize; that once urbanization begins on the doorstep of a city, it not only continues, but accelerates, making it essential for the City to control that urbanization and development. * * * In addition, the area itself is attractive to the existing City and its services. * * *
Since urbanization has begun in the entire area, and since it can be expected to continue and accelerate because- the area lends itself to urbanization, the expert witnesses testified that it should be annexed by the City. The evidence was based on the experts’ testimony that county government cannot cope with the sophisticated control of urban type development. As more and more development occurs in this area, there will be an increasing need by the people in the area proposed for annexation for city services.
Id. at 644.
The foregoing from Liberty stands as gleaming contradistinction between the situation in this ease in St. Louis County and annexations elsewhere. In Liberty, the city was growing and developing. It needed to control the adjoining unsophisticated territory. However, in this case the unincorporated area of the County outurbanizes the City so that scant basis exists for comparison. Town and Country’s effort is the classic case of the tail attempting to wag the dog. And that does not constitute a legitimate purpose for annexation.
Under the circumstances of this case and applying applicable legal standards, there was no fairly debatable showing that the annexations were reasonable and necessary. In my opinion Town and Country has failed to carry its burden. The annexations should fail, and I must dissent from the majority finding otherwise.
. Town and Country maintains a portion of one city street and all of three others for a total of 3.2 miles. There are 21 miles of private roads which are not maintained by the City. The state maintains the balance of the roads which are within or border the City.
. Some factors which courts have considered for annexation approbation include the following: (1) there must be a need for residential or industrial sites within the proposed area; (2) the city is unable to meet its needs without expansion; (3) only needs which are reasonably foreseeable and not visionary should be considered; (4) past growth may be relied on to show future necessity; (5) in evaluating future needs, the extent to which past growth has caused the city to spill over into the proposed area should be considered; (6) the beneficial effect of uniform application and enforcement of municipal zoning ordinances in the city and in the annexed area may be considered; (7) the need for or the beneficial effect of uniform application and enforcement of municipal building, plumbing and electrical codes; (8) the need for or the beneficial effect of extending police protection to the annexed area; (9) the need for or the beneficial effect of uniform application and enforcement of municipal ordinances or regulations pertaining to health; (10) the need for and the ability of the city to extend essential municipal services into the annexed area; (11) enhancement in value by reason of adaptability of the land proposed to be annexed for prospective city uses; and (12) regularity of boundaries. City of Perryville v. Brewer, 557 S.W.2d 457, 462 (Mo.App.1977).
See also Note, Annexation by Municipality of Adjacent Area in Missouri: Judicial Attitude Toward the Sawyer Act, 1961 Wash.U.L.Q. 159,160-62. For a capsulated rendering of the abundance of Missouri law dealing with the modalities of annexation, see 1 Antieau, Municipal Corporation Law, § 1A.40 (1983) and 1 Sands and Libonati, Local Government Law, § 8.30 (1981).
. Town and Country cites the following cases in which the County unsuccessfully opposed annexation in the trial court: Witt v. City of Webster Groves, 398 S.W.2d 16 (Mo.App.1965); City of Creve Coeur v. Huddleston, 405 S.W.2d 536 (Mo.App.1966); City of Creve Coeur v. Brame, 446 S.W.2d 173 (Mo.App.1969); Hudson Community Ass’n v. City of Ferguson, 456 S.W.2d 581 (Mo.App.1970); St. Louis County v. Village of Peerless Park, 494 S.W.2d 673 (Mo.App.1973); City of Des Peres v. Stapleton, 524 S.W.2d 203 (Mo.App.1975). However, in both Des Peres and Hudson Community Association, the court noted that the interest of the County must be considered. In the majority of cases cited by Town and Country, St. Louis County did not appeal the judgment in favor of annexation. Therefore, on appeal, the County’s interest was not at issue. These cases do not signal an abandonment of the requirement in the Graeler decisions to consider the interest of the County as a community. See Lauer, Municipal Law in Missouri, 28 Mo.L.Rev. 555, 580-82 (1963) for a discussion *612of the impact of the Graeler decisions on annexations in St. Louis County.