CONCURRING AND DISSENTING OPINION BY
Judge FRIEDMAN.I respectfully concur and dissent. I disagree only with the majority’s holding that the Order of St. Paul the First Hermit (Appellant) failed to establish that the forty overnight rooms in the Retreat House at The National Shrine of Our Lady of Czestochowa (Shrine) are exempt from taxation under section 204(a)(1) of The General County Assessment Law (Assessment Law).1
Section 204(a)(1) of the Assessment Law provides that all “churches, meetinghouses, or other actual places of regularly stated religious worship, with the ground thereto annexed necessary for the occupancy and enjoyment of the same” are exempt from taxation. 72 P.S. § 5020-204(a)(1).
I. Benedictine Sisters
In Benedictine Sisters v. Fayette County Board of Assessment Appeals, 844 A.2d *4286, 89 (Pa.Cmwlth.2004) (emphasis added), this court held that a Christian retreat center, including three bedrooms, is entitled to tax exemption as an actual place of regularly stated religious worship “where the primary purpose of the [retreat center] is worship, and other activities are merely incidental.” This court explained that the word “worship” in section 204(a)(1) of the Assessment Law is not limited to a type of formal ceremony involving a church-type budding where congregants gather. The word “worship” includes prayer, teaching, adoration, meditation, spiritual readings and discussions. Id. (citing Evangel Baptist Church v. Mifflin County Board of Assessment Appeals, 815 A.2d 1174 (Pa.Cmwlth.), appeal denied, 573 Pa. 712, 827 A.2d 1202 (2003), and Mount Zion New Life Center v. Board of Assessment and Revision of Taxes and Appeals, 94 Pa.Cmwlth. 439, 503 A.2d 1065 (1986)).
Here, Appellant presented evidence establishing that the primary purpose of the overnight rooms in the Retreat House is “worship.” Testimony shows that the rooms are furnished with very simple beds, a very simple desk, crosses on the walls and no television. (R.R. at 31a.) “[W]hen the people come ... for retreats, they just come ... to be ... alone with God.” (R.R. at 31a.) It is not the same as taking a rest; the people “want to come and meditate and ... spend time with God.” (R.R. at 47a.) In addition to the testimony, the brochure for the Retreat House states that it “is not a hotel or motel in which one just spends a night, but a place where one comes to experience peace in their search for God.” (R.R. at 76a.) “There are no TVs, radios, VCRs, DVD players or CD players. Our lack of these items and other amenities may seem to the outside world as a deficit, but none of these will be needed for your stay with us.” (R.R. at 76a.)
In other words, the forty overnight rooms, by design, serve as an environment for “worship,” i.e., prayer and meditation. They are, in essence, personal chapels for the pilgrims and others who come to the Shrine for retreats. The fact that people sleep in the rooms is merely incidental to their primary purpose as an extension of the many and varied spaces available for “worship” at the Shrine. Thus, applying Benedictine Sisters, I would conclude that the forty overnight rooms in the Retreat House are exempt from taxation under section 204(a)(1) of the Assessment Law.
II. Wesley United Methodist Church
In Wesley United Methodist Church v. Dauphin County Board of Assessment Appeals, 844 A.2d 57 (Pa.Cmwlth.), appeal granted, 578 Pa. 718, 854 A.2d 969 (2004), this court held that a parking lot was entitled to tax exemption because it was “necessary for the occupancy and enjoyment” of the place of worship. In so holding) this court stated that section 204(a)(1) of the Assessment Law provides for consideration of what is reasonably necessary to permit actual worship in a particular place. Id.
Here, ■ pilgrims travel great distances from countries all over the world, as well as from the United States, to worship at the Shrine.2 The record shows that pilgrims have come from Poland, Haiti, Hungary, Italy and Spain. (R.R. at 11a.) Moreover, to accommodate the diverse pilgrim groups, the Shrine offers masses in different languages led by priests of various nationalities. (R.R. at 12a-14a.) I submit that, to permit actual worship at the Shrine by pilgrims, it is reasonably *43necessary for the Shrine to provide overnight accommodations for pilgrims. For that reason also, I would conclude that, under Wesley United Methodist Church, the forty overnight rooms in the Retreat House are tax exempt under section 204(a)(1) of the Assessment Law.
Accordingly, I would reverse the trial court’s order to the extent it denies tax exemption to the forty overnight rooms in the Retreat House.
. Act of May 22, 1933, P.L. 853, as amended, 72 P.S. § 5020-204(a)(l).
. A "pilgrim” is "one who travels to visit a shrine or holy place as a devotee.” Webster's Third New International Dictionary 1715 (1993).