DISSENTING OPINION BY
Judge PELLEGRINI.I respectfully dissent from the majority’s decision because neither the ranch-style house nor the four acres of land upon which it sits in Fayette County that is used by the Benedictine Sisters of Pittsburgh (Benedictine Sisters) constitutes an “actual *91place of regularly stated religious worship” as mandated by Article VIII, Section 2(a) of the Pennsylvania Constitution in order to be exempt from real estate taxation.
The Benedictine Sisters filed an application with the Fayette County Board of Property Assessment Appeals and Review (Board) for a tax exemption for tax year 2003 for property which they use as a retreat. The property consists of four acres of land with a three-bedroom ranch house, a swimming pool and a detached garage. After a hearing was held before the Board, the application was denied. The Benedictine Sisters appealed to the Court of Common Pleas of Fayette County (trial court) which also held a hearing. At that hearing, one of the Sisters testified that the 77 Benedictine Sisters, who five in a monastery outside of Pittsburgh, were required to make an annual retreat that lasted three to seven days. The property was used as a spiritual retreat for prayer and reflection nine months of the year for this purpose, and sometimes the retreats were with groups where they discussed various spiritual topics, listened to tapes or watched videotapes. The remaining three months of the year it was unoccupied. She also stated that the property was used for relaxation two or three weeks a year. The trial court reversed the Board and granted the property a real estate tax exemption because it was being used as an actual place of regularly scheduled worship. The County of Fayette (County) filed this appeal.
The majority affirms the trial court relying on Mount Zion New Life Center v. Board of Assessment and Revision of Taxes and Appeals, 94 Pa.Cmwlth. 439, 503 A.2d 1065 (1986) and Evangel Baptist Church v. Mifflin County Board of Assessment Appeals, 815 A.2d 1174 (Pa.Cmwlth. 2003), concluding that because the Benedictine Sisters use it for adoration, prayer and mediation, the property is used as a place of regularly stated worship. I disagree with the majority because a retreat house is not what the drafters of Article VIII, Section 2(a)(i) of the Pennsylvania Constitution envisioned when they exempted an “actual place of regularly stated worship” from taxation.
Before the adoption of the 1874 Constitution, there was no limitation on power to grant exemptions from taxation. Because the General Assembly was granting exemptions capriciously, the drafters of that 1874 Constitution included a provision that placed limits on the power of the General Assembly as to how it could levy taxes as well as to whom it could grant exemptions.1 As adopted by the electorate, Article IX, § 1, read: “All taxes shall be uniform, upon the same class of subjects, within the territorial limits of the authority levying the tax, and shall be levied and collected under general laws; but the General Assembly may, by general laws, exempt from taxation public property used for public purposes, actual places of religious worship, places of burial not used or held for private or corporate profit, and institutions of purely public charity.” The 1968 Amendments to the Constitution, among other things, renumbered Article IX, § 1, as the current Article VIII, §§ 1 and 2, splitting the uniformity provision *92from the exemption provisions. The provision dealing with religious exemptions is now numbered as Article VIII, Section 2(a)(i) of the Pennsylvania Constitution, specifying the extent to which the General Assembly can grant an exemption to churches and the like. It provides in relevant part:
The General Assembly may by [not be] law exempt from taxation:
(i) Actual places of regularly stated religious worship ...
The drafters of the 1874 Constitution were quite explicit in their debates when circumscribing the type of property the General Assembly could exempt from taxation for religious purposes by limiting a religious exemption to an “actual place of regularly stated religious worship” rather than a place which was used for religious activities. At the debates which took place at the 1872 Convention to Amend the Constitution prior to Article IX’s enactment, certain delegates attempted to expand the proposed language, which is similar to how it reads today, “the Legislature may exempt from taxation actual places of religious worship ...,” to also include parsonages and land not exceeding five acres. In ultimately disallowing such an expansion of land and buildings, one delegate, Mr. Broomall, stated:
The privilege of exemption from taxation has been very much abused by the Legislature, and the people desire a correction of that evil. I think, however, that they will be satisfied with simply having their places of worship exempted, but would not be satisfied if the exemption were to be extended to the parsonages.
Debates of the Convention to Amend the Constitution of Pennsylvania 95 (1872). When it was suggested that the inclusion of the five acres could be withdrawn, Mr. Broomall stated that such a change alone would not help achieve the desired result. Another delegate, Mr. Cochran, explained: “If congregations are able to build parsonages, they are able to pay the taxes on them.” Id. Ultimately, neither the additional acreage nor the parsonages were included in the language of the Constitutional amendment allowing for exemptions of real estate taxation for “actual places of religious worship.”2
The drafters of the 1874 Constitution only wanted “actual places of regularly stated religious worship,” not places where religious formation or religious education took place. Notwithstanding the restrictive language that the Constitution uses, we have exempted religious summer camps, Mount Zion, and fellowship halls where social events and Bible studies take place, Evangel Baptist Church. This is far afield from a church, temple or sanctuary, and more than the drafters of the 1874 Constitution desired to exempt. Because the Constitution only provides an exemp*93tion for actual places of regularly stated religious worship and does not provide for any additional exemptions on houses, swimming pools, acreage or for places where religious classes take place, I would overrule our decisions in Mount Zion and Evangel Baptist Church and reverse the trial court.
Accordingly, I dissent.
. See Donohugh’s Appeal, 86 Pa. 306, 309-10 (1878) ("[I]t is conceded that the legislature cannot go outside the class of cases in which the constitution permits exemption from taxation, but it is to be remembered that the provision of the constitution is not a grant of power to the legislature, which belongs elsewhere, and is therefore to be strictly construed as in derogation of the people's right. On the contrary, it is a restriction upon a legislative power which would otherwise be unlimited and unquestionable. It is a tying up of the legislative hand ...”).
. “The Pennsylvania Constitution only permits the legislature to do so within certain limits.” G.D.L. Plaza v. Council Rock School District, 515 Pa. 54, 58, 526 A.2d 1173, 1175 (1987), quoting Donohugh’s Appeal. The General Assembly, in Section 204 of the General County Assessment Code, Act of May 22, 1933, P.L. 853, Art. II, Sec. 204, as amended, 72 P.S. § 5020-204, provided:
The following property shall be exempt from all county, city, borough, town, township, road, poor and school tax, to wit:
(a) All churches, meeting-houses, or other regular places of stated worship, with the ground thereto annexed necessary for the occupancy and enjoyment of the same;
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No one has challenged that this provision is beyond the power conferred on the General Assembly by the Constitution.