dissenting:
I respectfully dissent. In my view, whether Heilker’s placement of “indoor” furniture on the outside of his business constitutes a nonconforming “use” is a question of law for this *413Court. Furthermore, I would find Heilker’s business practice is a nonconforming use and affirm.
As an initial matter, I agree we must defer to a zoning board’s factual findings if there is any evidence in the record to support them. See Vulcan, 342 S.C. at 488, 536 S.E.2d at 896 (describing deferential standard of review to equate zoning board’s findings of fact with those of a jury, i.e., that such findings “will not be disturbed unless a review of the record discloses that there is no evidence which reasonably supports the [Board’s] findings”) (quoting Sterling Dev. Co. v. Collins, 309 S.C. 237, 240, 421 S.E.2d 402, 404 (1992)). However, as the majority acknowledges, it is the duty of the reviewing court to decide if a zoning board’s decision is legally sound. See § 6-29-840 (“In determining the questions presented by the appeal, the court shall determine only whether the decision of the [zoning] board is correct as a matter of law.”); City of Myrtle Beach v. Juel P. Corp., 337 S.C. 157, 172, 522 S.E.2d 153, 161 (Ct.App.1999) (“[T]he determination of whether [zoning] ordinances deprive a citizen of constitutional rights is a judicial function and not legislative. And where an ordinance is clearly violative of constitutional rights, it is the duty of the court to so hold.”) (quoting Conway v. City of Greenville, 254 S.C. 96, 101, 173 S.E.2d 648, 650 (1970)), rev’d on other grounds, 344 S.C. 43, 543 S.E.2d 538 (2001); Historic Charleston Found. v. Krawcheck, 313 S.C. 500, 505-06, 443 S.E.2d 401, 405 (Ct.App.1994) (“[W]e will not reverse ... unless the [zoning] [b]oard’s findings of fact have no evidentiary support or the [b]oard commits an error of law.”) (emphasis added).
In my opinion, whether a landowner’s activities on his property constitute a nonconforming use is a question of law for the courts, because it requires an interpretation of the ordinance at issue. See Charleston County Parks & Recreation Comm’n v. Somers, 319 S.C. 65, 67, 459 S.E.2d 841, 843 (1995) (finding determination of council’s intent in drafting ordinance was not a finding of fact because “[t]he determination of legislative intent is a matter of law”; supreme court therefore concluded the board’s “determination that a park is not a municipal use under the Isle of Palms zoning ordinance” was reviewable); see also Stanton, 317 S.C. at 502, 455 S.E.2d at 173 (reversing the circuit court’s affirmance of a zoning board determination that the lower level of appellant’s house “does not constitute a separate nonconforming use from the *414single structure of the entire house”); F.B.R. Investors v. County of Charleston, 303 S.C. 524, 402 S.E.2d 189 (Ct.App.1991) (upon analyzing facts, court determined trial court erred in finding F.B.R. had established a nonconforming use and therefore a vested right to continue it).3
The majority relies on Vulcan Materials and Stanton v. Town of Pawleys Island for the proposition that a determination of use is a question of fact. In my view, these cases do not support this contention.
Without question, both Vulcan ánd Stanton correctly set forth the standard of review to be used in zoning cases. *415Interestingly, however, in Vulcan this Court affirmed the circuit court’s reversal of the Greenville County zoning board’s decision denying Vulcan a “nonconforming use” certificate to continue mining its land in the face of rezoning restrictions. The County’s decision was based on the testimony of Peter Nokimos, the Greenville County Zoning Administrator, who claimed he denied Vulcan’s certificate application “because he found no indication of any mining or occupancy at the site.” See Vulcan, 342 S.C. at 486, 536 S.E.2d at 895 (emphasis added). In affirming the lower court, this Court rejected the zoning board’s determination of what constituted “mining,” finding Vulcan in fact “mined” its site “as a matter of law.” Id. at 496, 536 S.E.2d at 900. In so doing, the Court also affirmed the lower court’s reversal of the zoning board’s conclusion that Vulcan’s activities did not constitute a protected, nonconforming use. Id. at 498, 536 S.E.2d at 901.
Similarly, in Stanton our supreme court reversed the zoning board’s determination that the lower level of a beaeh house “constitute^] a separate nonconforming use from the single structure of the entire house.” Stanton, 317 S.C. at 502, 455 S.E.2d at 173. Thus, the court held the zoning board erred “as a matter of law.” Id. at 503, 455 S.E.2d at 173. Accordingly, I believe the dispositions in these two cases lend further support to the conclusion that the determination of use is a question of law.
It is undisputed the City of Beaufort’s newly amended ordinance prohibits Heilker’s outdoor furniture displays. The only question, therefore, is whether his “practice” of placing indoor furniture outside is a nonconforming use under the ordinance. See, e.g., Big Blue, 605 N.E.2d at 192 (“The doctrine of nonconforming use is an affirmative defense asserted by a party who is alleged to be [in] violation of an existing zoning ordinance.”). The majority affirms the Board’s conclusion that Heilker’s displays do not constitute a “use” of his property because they are “merely a practice associated with a land use.” I cannot concur.
In upholding the Board’s decision, the majority defines a “ ‘use’ in the zoning context” as “the purpose or activity for which land or buildings are designed, arranged, or intended, or for which land or buildings are occupied or maintained.” *416While I agree this is an acceptable definition of “use,” it is certainly not the only appropriate one under the circumstances. Moreover, I would find the majority’s proposed definition in fact covers Heilker’s practice of displaying his wares outdoors.
Here, “use” is not defined, either in the general Beaufort zoning ordinance on nonconforming use contained in the record (§ 5-6108) or the subordinate nonconforming uses section amending the “Highway Corridor Overlay Zoning” provisions of that ordinance (§ 5-6213). Although “legislative intent must prevail if it can be reasonably discovered in the language used,” when interpreting an ordinance we must give words their “plain and ordinary meaning without resorting to subtle or forced construction to limit or expand” their operation. City of Myrtle Beach v. Juel P. Corp., 344 S.C. 43, 47, 543 S.E.2d 538, 540 (2001); see Somers, 319 S.C. at 68, 459 S.E.2d at 843 (“In construing ordinances, the [undefined] terms used must be taken in their ordinary and popular meaning.”).
Furthermore, “[ordinances in derogation of natural rights of persons over their property are to be strictly construed as they are in derogation of the common law right to use private property so as to realize its highest utility and should not be impliedly extended to cases not clearly within their scope and purpose.” Juel, 344 S.C. at 47, 543 S.E.2d at 540 (quoting Purdy v. Moise, 223 S.C. 298, 302, 75 S.E.2d 605, 607 (1953)). Because no cases in our jurisdiction define the term “use,” it is necessary to look to other sources for assistance.
Fundamentally, the noun “use” means “the act of using or the state of being used.” Webster’s New World College Dictionary 1574 (4th ed.1999). Moreover, in the legal arena “use” has been defined as “[a] habitual or common practice.” Black’s Law Dictionary 1540-41 (7th ed.1999); see also Blank’s Law Dictionary 1541 (6th ed.1990) (defining use as “[t]hat enjoyment of property which consists in its employment, occupation, exercise or practice.”). Most specifically, in the context of zoning ordinances “use” connotes “a utilization of premises so that they may be known in the neighborhood as being employed for a given purpose.... In this context, it has been held that ‘use’ means what is customarily or habitually done or the subject of a common practice.” 101A C.J.S. *417Zoning and Land Planning § 60 at 489 (1979) (emphasis added); see also 83 Am.Jur.2d Zoning and Planning § 624 at 520 (1992) (stating that “nonconforming use” includes “conduct which is proscribed by applicable zoning restrictions”) (emphasis added).
In my view, Heilker’s customary habit or practice of placing his furniture on display outdoors is unquestionably a “use” as defined above.4 It is a way of physically using his property to advertise his business.
*418The majority cites City of Columbus Bd. of Zoning Appeals v. Big Blue, a case with a strikingly similar fact pattern, as support for “the assertion that the outdoor display of merchandise is an activity or practice separate and distinct from a retail establishment’s ‘use’ of its property.” I find this case not only inapposite, but also that it lends credence to the conclusion that displaying merchandise outdoors can be a “use” in the context of zoning law.
Significantly, in Big Blue the Indiana Court of Appeals did not find a retailer’s outdoor display and storage of goods was not a “use” of its property. Rather, the court held that where the zoning ordinance in question did not include a prohibition on selling or storing merchandise outside in its enumerated list of permitted “Uses,” it would not infer an expanded meaning of the term “to regulate the manner in which Big Blue advertises merchandise as it operates its retail store.” Id. at 191. In other words, the ordinance at issue in Big Blue did not reveal “any restriction or regulation on outside displays by owners of retail stores.” Id. Notably, the court went on to state that “[b]oth zoning in general and ‘uses’ in particular focus on how a building or parcel of land is utilized,” and ultimately concluded: “In sum, City is inviting this court to read into its ordinance a provision which is not present, namely: the prohibition of outside sales and storage of merchandise. We must decline the invitation. Zoning ordinances must be construed to favor the free use of land.” Id. at 191— 92.
Moreover, nowhere in the Big Blue opinion does the court conclude, or even hint, that the retailer’s outdoor display was “an activity or practice separate and distinct” from its “use” of the property. To the contrary, and in direct contrast to the case at bar, the Indiana court clearly and properly limited its decision on “use” to the definitional language of the ordinance at hand.5
*419In any event, I would find Heilker’s displays clearly fit within the majority’s “conventional” definition of “use.” Even assuming “use” can only be defined as “the purpose or activity for which land or buildings are designed, arranged, or intended, or for which land or buildings are occupied or maintained,” the record clearly reflects Heilker opened his businesses and occupied his land with the intended purpose of advertising his merchandise through outdoor displays. Accordingly, because I believe Heilker’s placement of merchandise on outdoor display constitutes an integral part of his intended purpose for each of his properties, I address the Board’s alternative reasons for denying Heilker’s appeal.
The concept of nonconforming use is grounded in the rule that “one’s property may be continued to be used for the same purpose it was being used at the time of the passage of a [prohibitive] zoning ordinance.” Vulcan, 342 S.C. at 499, 536 S.E.2d at 902 (quoting James v. City of Greenville, 227 S.C. 565, 578, 88 S.E.2d 661, 667 (1955)). Thus, the Board’s contention that the City did not intend to “grandfather” existing businesses regarding outdoor displays is irrelevant.
The purpose of grandfathering in nonconforming uses is to protect the constitutional rights of the property owner. See Friarsgate, Inc. v. Town of Irmo, 290 S.C. 266, 269, 349 S.E.2d 891, 894 (Ct.App.1986) (“Generally, in American jurisdictions a landowner who uses his property for a lawful purpose before the enactment of zoning which subsequently prohibits that use may continue the nonconforming use____ Otherwise, the landowner would be deprived of a constitutionally protected right. The right to continue a prior nonconforming use is often stated in terms of the owner having acquired a “vested right” to continue the prior use.”); Vulcan, 342 S.C. at 499, 536 S.E.2d at 902 (“[T]he substantial value of property lies in its use. If the right of use [is] denied, the value of the property is annihilated, and ownership is rendered a barren *420right.”) (quoting James v. City of Greenville, 227 S.C. 565, 579, 88 S.E.2d 661, 668 (1955)). Thus, if it is determined that a nonconforming use existed at the time of the new ordinance, the use may continue in the absence of evidence that it is detrimental to the public welfare. See Whaley v. Dorchester County Zoning Bd. of Appeals, 337 S.C. 568, 578, 524 S.E.2d 404, 409-10 (1999) (“A landowner acquires a vested right to continue a nonconforming use already in existence at the time of a zoning ordinance absent a showing the continuance of the use constitutes a detriment to the public health, safety, or welfare.”); Vulcan, 342 S.C. at 499, 536 S.E.2d at 902 (“[0]ne’s property may be continued to be used for the same purpose it was being used at the time of the passage of a [prohibitive] zoning ordinance.”) (quoting James, 227 S.C. at 578, 88 S.E.2d at 667).
Admittedly, a zoning board may regulate or proscribe changes in a nonconforming use. See Krawcheck, 313 S.C. at 505, 443 S.E.2d at 404. Indeed, the Board has done so here. See City of Beaufort Zoning Ordinance § 5-6108(d) (“A nonconforming building, structure, or land use shall not be changed to another nonconforming use.”). Not every shift in activity, however, constitutes a change in use. See City of Jewell Junction v. Cunningham, 439 N.W.2d 183, 186 (Iowa 1989) (“[N]ot every change in particulars or details in the method of a nonconforming use or in equipment, object or processes, in connection therewith constitutes an unauthorized change in the use.”). Rather, to justify finding a particular use has changed to another nonconforming use, it is generally held that the change must be substantial. See id. (“[Considerable latitude will be allowed a landowner in making changes in the original nonconforming use if the changes are not substantial----”); Turbat Creek Pres., LLC v. Town of Kennebunkport, 753 A.2d 489, 492 (Me.2000) (“To qualify for ‘nonconforming’ or ‘grandfathered’ status, it must be shown that the use existed prior to the enactment of the zoning provisions prohibiting it and that the use was ‘actual and substantial.’ ”) (citation omitted); Inst. for Evaluation & Planning, Inc. v. Bd. of Adjustment, 270 N.J.Super. 396, 637 A.2d 235, 238 (Law Div.1993) (“The proposed use may continue so long as the continuance is ‘substantially the same kind of use as that to which the premises were devoted at the time of the *421passage of the zoning ordinance.’ ”) (citation omitted); see also Waukesha County v. Pewaukee Marina, Inc., 187 Wis.2d 18, 522 N.W.2d 536, 540 (Ct.App.1994) (”[A] mere increase in the volume, intensity or frequency of a nonconforming use is not sufficient to invalidate it.).
Several states have adopted some version of the following three-part test to aid in determining the substantialness of a change in nonconforming use: whether the modified use (1) reflects the nature and purpose of the use prevailing when the restrictive ordinance took effect; (2) is merely a different manner of utilization rather than a use different in quality, character, nature or kind; and (3) has a substantially different effect on the neighborhood. See, e.g., Turbat, 753 A.2d at 492; Derby Refining Co. v. City of Chelsea, 407 Mass. 703, 555 N.E.2d 534 (1990); Conforti v. City of Manchester, 141 N.H. 78, 677 A.2d 147 (1996). As one court noted:
The law does not require it to be shown that each garage is used today to store exactly the same items or kinds of items which were stored prior to [the effective date of the zoning restriction]. Nor does it require that the light industry or repair work which occurs on the premises be precisely identical to what occurred before.... What is required to be shown is that the overall use of the property for the rental of facilities for storage and light industrial purposes has not been significantly altered since [that time].
Zoning Bd. of Adjustment of the City of Philadelphia v. Libros, 85 Pa.Cmwlth. 485, 482 A.2d 1181, 1183-84 (1984).
Applying these authorities, I do not believe Heilker’s daily permutations in his outdoor display constitute a change from one nonconforming use to another. Although by Heilker’s own admission the merchandise on display varies frequently, his use of the property for advertising purposes does not. See Baker v. Town of Sullivan’s Island, 279 S.C. 581, 585, 310 S.E.2d 433, 436 (Ct.App.1983) (holding conversion of apartments to condominiums did not violate Town’s zoning ordinance forbidding change from one nonconforming use to another because conversion would not change the property’s use, i.e., “[a]fter conversion, the property would still be used for residential purposes as it was before”); see also Motel 6 Operating Ltd. Partnership v. City of Flagstaff, 195 Ariz. 569, *422991 P.2d 272, 275 (Ct.App.1999) (holding alterations updating sign to reflect current company logos and tenants “do not trigger the loss of nonconforming use rights”); DiBlasi v. Zoning Bd. of Appeals of the Town of Litchfield, 224 Conn. 828, 624 A.2d 372, 376 (1993) (finding shift in use from a “business office” to a “medical office” was not sufficiently different in character to constitute a “change in use”); Cunningham, 439 N.W.2d at 186 (“If a grocer or other merchant is storing and selling merchandise of one type, [the] status as a nonconforming use should not be lost if he changes to another type of merchandise so long as the impact of the business on the neighborhood remains the same.”); Derby Refining, 555 N.E.2d at 540 (in finding change from storage of gasoline, kerosene and aviation fuel to storage of liquid asphalt did not constitute a prohibited change from one nonconforming use to another, court stated the uses were “nearly identical in nature” and “the fact that the product being delivered, stored, and distributed has changed from one petroleum product to another ... does not mandate a conclusion that a change in the nature or purpose of the use has occurred”); Kramer v. Town of Montclair, 33 N.J.Super. 16, 109 A.2d 292, 293 (App.Div.1954) (fact that property once used for storing one-and-a-half-ton trucks now stored six-ton tractor trailer trucks was “insignificant” change such that prior nonconforming use was not destroyed);
Stewart v. Pedigo, 2 Ohio App.2d 53, 206 N.E.2d 429, 431 (1965) (finding change from “display of motor-driven garden and lawn tools to that of motor-driven vehicles for transportation” was not a “substantial change” in nonconforming use, because although the “purpose and policy of zoning is to effect the gradual elimination of nonconforming uses,” zoning restrictions should not operate “to prohibit all changes of nonconforming use”); Hendgen v. Clackamas County, 115 Or. App. 117, 836 P.2d 1369, 1370 (1992) (holding no change in nonconforming use status despite rental of storage buildings to a different business storing different items because “[t]he common nucleus of both activities [is] storage”); Libros, 482 A.2d at 1184 (current use of premises qualified as pre-existing, non-conforming use where, although items stored in garages were newer and perhaps different, the use of the garages for personal storage had remained constant).
*423The Board’s additional reason for denying Heilker’s appeal, that existing nonconformities must be brought into compliance, to the degree practicable, “if any portion of the building, site design, or lighting is changed, expanded, or altered,” also lacks merit. It is without question, and the Board concedes, that neither the “building” nor “lighting” provisions of the ordinance are implicated by Heilker’s activities. Thus, the only conceivable basis for finding the above language controlling is that Heilker’s rearrangement of furniture constitutes a change in “site design.” I would reject this contention.
Section 5-6205 of the overlay zoning amendment defines site design as “the process of arranging buildings, parking, open spaces, and other improvements such as landscaping, walkways, and roads on the land. Site design is an art concerned with shaping functional and enjoyable outdoor spaces while working carefully with the existing landscape and community character.” In my opinion, this definition may not be broadened to encompass Heilker’s arrangement of furniture outside his store. The only possible construction would require a determination that his practice fell within the ambit of “arranging ... open spaces.” To me, however, the arrangement of open space referenced in the amended ordinance means where one places “open space” in relation' to buildings, sidewalks, parking, roads and other landscape features. Indeed, if Heilker’s rotating displays of furniture are included in this definition, then the “space” referred to is no longer “open.”
Finally, I disagree with the Board’s conclusion that, because Heilker’s outdoor display of furniture changes often, “conformance to the ordinance can be effected with relative ease.” In so finding, the Board actually begs the question by failing to recognize that compliance would effectively destroy Heilker’s use of the property. Moreover, this assertion is simply not supported by the record evidence.
The City, in its own brief, states the following:
A use of land may be continued as a nonconforming use, in spite of prohibitory zoning legislation, only if it is a “substantial” one. The nature and extent of use which will be regarded as substantial was described as one involving improvements or businesses built up over the years, the *424destruction of which would cause the property owner serious financial harm.
Final Brief of Appellant at 11 (quoting Anderson, American Law of Zoning, § 6.20 (1986)) (emphasis added). The record is replete with uncontradicted evidence that Heilker opened his businesses using an outdoor advertising concept and continued to build them over a period of years on that basis. Because direct testimony in the record reflects that anywhere from 25 to 35% of his sales are a consequence of this form of advertising, there is no question Heilker would suffer “serious financial harm” if forced to discontinue his displays. Thus, I would hold this factual finding by the Board is without evidentiary support.
For the foregoing reasons, I would affirm the circuit court’s decision finding Heilker’s nonconforming use can continue.
. Other states have held similarly. See City of Columbus Bd. of Zoning Appeals v. Big Blue, 605 N.E.2d 188, 191 (Ind.Ct.App.1992) ("Construction of a zoning ordinance is a question of law. Since there are no factual disputes in this case, our sole task in reviewing the trial court’s decisions is to determine whether any of the zoning regulations relied upon by the City are applicable to Big Blue’s operation and act to prohibit the outside displays [of merchandise].”) (internal citations omitted); Christy’s Realty Ltd. Partnership v. Town of Kittery, 663 A.2d 59, 62 (Me. 1995) ("Whether a proposed use falls within a given category contained in a zoning ordinance is a question of law.”); Graham v. Itasca County Planning Comm'n, 601 N.W.2d 461, 467 (Minn.Ct.App.1999) ("The application of an ordinance to established facts is a question of law for the court.”); Hannigan v. City of Concord, 144 N.H. 68, 738 A.2d 1262, 1266 (1999) ("The interpretation of a zoning ordinance and the determination of whether a particular use is an accessory use are questions of law for this court to decide.”); Davis v. Town of Stallings Bd. of Adjustment, 141 N.C.App. 489, 541 S.E.2d 183, 186-87 (2000) (finding whether a video store fell within an ordinance’s definition of "adult bookstore” was a question of law); McMahon v. Kingston Township Bd. of Supervisors, 771 A.2d 96, 99-100 (2001) ("Whether a ["cellular monopole”] falls within a ["semipublic use” as] specified in a zoning ordinance is a question of law and subject to review on that basis. [Since] [t]he issue is one of statutory construction, it is this Court’s function to determine the intent of the legislative body which enacted the ordinance.”); Sabatine v. Zoning Hearing Bd. of Washington Township, 651 A.2d 649, 652-53 (1994) ("The question of' whether a proposed [flea market] use falls within a given category [of warehouse and wholesale trade] specified in an ordinance is a question of law.”); County of Sawyer Zoning Bd. v. State Dep’t of Workforce Dev., 231 Wis.2d 534, 605 N.W.2d 627, 630 (Ct.App.1999) ("Once the facts are established, however, the application of those facts to the statute or [ordinance] is a question of law.”); Brooks v. Hartland Sportsman’s Club, Inc., 192 Wis.2d 606, 531 N.W.2d 445, 449 (Ct.App.1995) ("[The] determination [of nonconforming use] involves the application of the facts to a legal standard and, consequently, presents a question of law____”).
. Other jurisdictions employ similar definitions. See United Fed. Savings Bank v. McLean, 694 F.Supp. 529, 537 (C.D.Ill.1988) ("[T]he word ‘use’ of real estate is deemed by the Illinois courts to address the purpose to which the property is put (whether it concerns issues of zoning, erecting structures on the property, the type of business for which the property is employed, or the way in which the owner or possessor benefits from the enjoyment of the property).") (emphasis added); Phoenix City Council v. Canyon Ford, Inc., 12 Ariz.App. 595, 473 P.2d 797, 801 (1970) (defining “use” as "the act of employing anything, or state of being employed” and finding it "obvious" that company’s signs which were in process of being constructed were not being "used” at the time the restrictive ordinance was enacted); Boss Hotels Co. v. City of Des Moines, 258 Iowa 1372, 141 N.W.2d 541, 544 (Iowa 1966) (where city ordinance stated buyers of property "shall be obligated to devote such real property only to the use specified in the urban renewal plan,” but did not define the term, court held hotel’s use of property would not be changed by an increase in height from three stories to eight because "use refers to the activity carried on on the premises”) (emphasis added); Borough of Northvale v. Blundo, 81 N.J.Super. 201, 195 A.2d 221, 223 (1963) ("The established concept of a ‘nonconforming use’ does not cover an activity simply because it takes place on the premises. It must bear a relationship to [ljand use.”); 138 West 49th Street Corp. v. Hotel Coleman, Inc., 237 N.Y.S.2d 441, 444 (N.Y.Civ.Ct.1963) (under "Multiple Dwelling Law,” " ‘[u]se’ is interpreted to mean not an isolated act but a practice or relation”; court stated further that "[t]he term ‘use’ implies the doing of something customarily or habitually or making a practice of doing a certain act”); Seckinger v. City of Atlanta, 213 Ga. 566, 100 S.E.2d 192, 195 (1957) (defining "use” as it appeared in restrictive ordinance to mean " 'to convert to one’s service’”) (quoting Webster’s Int’l Dictionary 1684 (2d. ed.)); American Sign Corp. v. Fowler, 276 S.W.2d 651, 654 (Ky.1955) (“Zoning has as one of its main purposes the regulation of the use of properly. This means regulation of the purpose or object of the use, rather than the mere conditions or circumstances of the use.”) (internal citation omitted); Durning v. Summerfield, 314 Ky. 318, 235 S.W.2d 761, 763 (1951) (" ‘Use,’ in [ordinance provision on nonconforming use] means what is customarily or habitually done or the subject of a common practice.”); see generally Baltimore Heritage, Inc. v. Mayor & City *418Council of Baltimore, 316 Md. 109, 557 A.2d 256, 259 (1989) (" ‘Use’ is a very broad concept in zoning law.... ”).
. I note that, with one exception, the cases cited by the majority concern ordinances which explicitly define the term "use”; hence, these cases are facially distinguishable. Furthermore, the excepted case, Kam v. Noh, 70 Haw. 321, 770 P.2d 414 (1989), describes “use” *419as synonymous with "purpose,” because other subsections of the statute in question gave the term that connotation, as did statutes construed in pari materia. See id. at 416 ("Where the meaning of a word is unclear in one part of a statute but clear in another part, the clear meaning can be imparted to the unclear usage on the assumption that it means the same thing throughout the statute.”). Kam, therefore, also is distinguishable.