Andre's City Has Zoning Regulations Which Govern the Placement of a Dwelling

Andre's city has zoning regulations which govern the placement of a dwelling on property. Andre wants to build a new garage which would likely violate the zoning laws as it would extend beyond the space on which he is allowed to build a dwelling. What is Andre's best option if he wants to build the garage in that particular place on his property?

A) If Andre owns the property without any restrictions, he can build the garage wherever he wants.
B) Andre may seek a non-conforming use permit from the zoning board or planning commission, which is generally granted if he can show a legitimate private interest.
C) Andre may file suit against his city.
D) Andre may seek a variance from the zoning board or planning commission, which is generally granted if he can show undue hardship.
E) Andre has no option; he cannot build the garage where he wants to place it.