**54The question in this case is whether the voter-initiated amendment proposed by intervening defendant Voters Not Politicians (VNP) should be placed on the ballot. VNP launched a petition drive to propose an amendment that would reestablish a commission to oversee legislative redistricting. Plaintiffs brought suit to stop the petition from being placed on the ballot, making the now familiar argument that the proposed amendment is actually a "general revision" that can only be enacted through a constitutional convention.

We took this case to determine whether the VNP petition is a constitutionally permissible voter-initiated amendment under Const 1963, art 12, § 2. To answer this question, we must fulfill our Court's most solemn responsibility: to interpret and apply the pertinent provisions of our Constitution. After closely examining the text, structure, and history of the Constitution, we hold that, to be permissible, a voter-initiated amendment must propose changes that do not significantly alter or abolish the form or structure of the government in a manner equivalent to creating a new constitution. We reach this conclusion for the following reasons:

**55• The text of the relevant constitutional provisions, Const 1963, art 12, §§ 2 and 3, makes it clear that a constitutional convention is required to produce a new constitution. (See pages 20 through 31 of this opinion.)

• The primary substantive limitation in the text of the predecessor provision to Const 1963, art 12, § 2 originally imposed on voter-initiated amendments was removed more than 100 years ago. (See pages 20 through 22 of this opinion.)

• Our caselaw on this topic-undeveloped and largely not on point-fails to establish any controlling standard in this area. (See pages 12 through 19 of this opinion.)

In this case, VNP's amendment does not propose changes creating the equivalent of a new constitution:

• VNP's proposed redistricting commission is materially similar to the commission provided for in our current *250Constitution, and VNP's proposed redistricting standards are similar to the ones presently used. (See pages 38 through 44 of this opinion.)

• VNP's proposal does not substantially change the powers of the three branches of government when compared to where the people placed those powers in the 1963 Constitution. (See pages 44 through 50 of this opinion.)

• Finally, treating VNP's proposal as an amendment accords with the stated expectations of key delegates to the 1961-1962 constitutional convention, statements from this Court on this very topic, and the treatment of this issue by other states. (See pages 50 through 55 of this opinion.)

Therefore, we affirm the judgment of the Court of Appeals that VNP's proposal is a permissible voter-initiated amendment.

**56I. FACTS AND PROCEDURAL HISTORY

VNP is a ballot-question committee. It filed with defendant Secretary of State the initiative petition at issue in this case. The initiative proposal would, among other things, amend Const 1963, art 4, § 6, which established a commission to regulate legislative redistricting. The commission prescribed by our present Constitution is inactive because this Court declared that it could not be severed from apportionment standards contained in the Michigan Constitution that had been held to be unconstitutional, as explained further below.1 After that ruling, this Court oversaw redistricting until the Legislature took control of the process. VNP's proposal would bring Michigan's constitutional redistricting standards in line with federal constitutional requirements and revive the redistricting commission's authority to set redistricting plans for the state house, state senate, and federal congressional districts.

A sufficient number of registered electors signed the petition for it to be placed on the November 2018 general election ballot. Before the Board of State Canvassers could certify the petition for placement on the ballot,2 plaintiff Citizens Protecting Michigan's Constitution (CPMC), along with other plaintiffs,3 filed the present complaint for a writ of mandamus directing the Secretary of State and the Board to reject the VNP proposal. CPMC argued that the proposal was not an amendment of the Constitution that could be proposed by petition under Const 1963, art 12, § 2 ; rather, the **57proposal amounted to a "general revision" of the Constitution and could be enacted only through a constitutional convention under Const 1963, art 12, § 3. The Court of Appeals granted the request by VNP and other parties4 to intervene as defendants and to file a cross-complaint seeking a writ of mandamus requiring the proposal to be placed on the ballot.

In a unanimous published opinion, the Court of Appeals rejected plaintiffs' requested relief and granted the relief sought by intervening defendants, ordering the Secretary of State and the Board "to take all necessary measures to place the proposal on the November 2018 general *251election ballot."5 The Court noted that our courts have long distinguished between an "amendment" and a "revision."6 The former was a narrower concept focusing on specific changes to the Constitution, while the latter was a more comprehensive modification of fundamental government operations.7 To determine if a particular proposal changed the fundamental nature of the government, the Court of Appeals considered the quantitative and qualitative features of the proposal.8

Comparing the present proposal to those addressed in past cases, the Court observed that the proposal **58would continue, with modifications, the redistricting commission already in the Constitution (although not enforced).9 Also, the proposal "involve[d] a single, narrow focus-the independent citizen redistricting commission."10 While the proposal reduced this Court's oversight of redistricting plans from the level contemplated by the present Constitution, our Court would nonetheless retain control over challenges to redistricting plans.11 Regarding quantitative considerations, the Court of Appeals noted the number of words the proposal would add to the Constitution (4,834) and the fact that 11 sections would be changed across 3 articles of the Constitution.12 None of this, however, was enough to convince the Court that fundamental government operations would be altered. Thus, the proposal was an amendment that could be brought by petition, as it had been.

CPMC sought leave to appeal here and requested a stay of proceedings below so that the Board would not certify the proposal while the case remained pending. We denied the motion for a stay,13 but we granted leave to appeal to consider "whether the proposal at issue is eligible for placement on the November 2018 general election ballot as a voter-initiated constitutional amendment under Const 1963, art 12, § 2, or whether it is a revision to the Constitution and therefore is ineligible for placement on the ballot."14

**59II. STANDARD OF REVIEW

A lower court's decision on whether to grant a writ of mandamus is reviewed for an abuse of discretion.15 To the extent that a request for a writ of *252mandamus involves questions of law, we review them de novo.16

III. ANALYSIS

A. CONSTITUTIONAL INTERPRETATION

Our Constitution is clear that "[a]ll political power is inherent in the people."17 The people have chosen to retain for themselves, in Const 1963, art 12, § 2, the power to initiate proposed constitutional amendments that, if various requirements are met, will be placed on the ballot and voted on at election time. It has been observed that "there is no more constitutionally significant event than when the wielders of '[a]ll political power' under that document, Const 1963, art 1, § 1, choose to exercise their extraordinary authority to directly approve or disapprove of an amendment thereto. Const 1963, art 12, §§ 1 and 2."18 In this case, we must determine the scope of the voters' power to initiate amendments.

**60In answering this question, we do not consider whether the proposed amendment at issue represents good or bad public policy.19 Instead, we must determine whether the amendment meets all the relevant constitutional requirements.20 There may be an "overarching right" to the initiative petition, "but only in accordance with the standards of the constitution; otherwise, there is an 'overarching right' to have public policy determined by a majority of the people's democratically elected representatives."21 In particular, we have stated that the "right [of electors to propose amendments] is to be exercised in a certain way and according to certain conditions, the limitations upon its exercise, like the reservation of the right itself, being found in the Constitution."22

*253Our inquiry here, then, is to determine the extent of the people's right to initiate constitutional amendments and whether any clear limitations may be found **61in the Constitution.23 As with any constitutional provision, the objective of our interpretation " 'is to determine the text's original meaning to the ratifiers, the people, at the time of ratification.' "24 The primary rule is that of " 'common understanding,' " as Justice COOLEY explained long ago:

A constitution is made for the people and by the people. The interpretation that should be given it is that which reasonable minds, the great mass of the people themselves, would give it. "For as the Constitution does not derive its force from the convention which framed, but from the people who ratified it, the intent to be arrived at is that of the people, and it is not to be supposed that they have looked for any dark or abstruse meaning in the words employed, but rather that they have accepted them in the sense most obvious to the common understanding, and ratified the instrument in the belief that that was the sense designed to be conveyed."^[25 ^]

To help discover the "common understanding," this Court has observed "that 'constitutional convention debates and the address to the people, though not controlling, are relevant.' "26

**62B. OVERVIEW OF THE AMENDMENT AND REVISION PROCESS

Three basic procedures allow for alterations of the Constitution. The first, not directly relevant here, provides for "amendments" proposed in the Senate or House and approved by two-thirds of the members in each chamber, then submitted to the voters for approval.27 Const 1963, art 12, § 2 provides the second manner of altering the Constitution, which is the one VNP attempted here: "Amendments may be proposed to this constitution by petition of the registered electors of this state."28 "Every petition shall include the full text of the proposed amendment, and be signed by registered electors of the state equal in number to at least 10 percent of the total vote cast" for Governor in the most recent general gubernatorial election.29 Once the "person authorized by law to receive such petition" determines that the petition signatures *254were valid and sufficient, the proposed amendment is placed on the ballot.30 Finally, under Const 1963, art 12, § 3, the third manner of changing the Constitution is by constitutional convention.31 Every 16 years, "and at such times as may be provided by law, the question of a general revision of the constitution shall be submitted to the electors of the state"; if the voters vote in favor of performing a "general revision," a constitutional convention is convened for that purpose.32

We have explained that the adoption of the initiative power, along with other tools of direct democracy, **63"reflected the popular distrust of the Legislative branch of our state government."33 While the right to propose amendments by initiative must be done according to constitutional requirements, we have observed that "it may be said, generally, that [the right] can be interfered with neither by the legislature, the courts, nor the officers charged with any duty in the premises."34 Indeed, we have held that Article 12, § 2 is self-executing,35 although the Constitution explicitly allows the Legislature to prescribe by law procedures regulating the initiative.36

C. LIMITATIONS ON VOTER-INITIATED AMENDMENTS

The scope of the initiative amendment process and its relation to the "general revision" process is at the **64heart of this case. How extensive can a voter-initiated amendment be, and does the Constitution place any relevant subject matter limitations on such amendments?

1. CASELAW

We will begin with our caselaw on this topic, which ultimately proves unilluminating. There is no controlling authority from this Court construing the meaning of the term "amendment" in Article 12, § 2. The issue has been raised twice in the last 10 years, but neither case yielded a majority opinion from this Court construing the term "amendment" in this context. In Citizens ,37 the Court of Appeals addressed this issue for the first time. In that case, a group called Reform Michigan Government Now! (RMGN) submitted an initiative *255petition proposing a vast array of changes to Michigan's Constitution.38 CPMC argued that "the RMGN initiative petition [was] not eligible to be placed on the ballot because it [was] not merely an 'amendment' to the constitution, but [was] a 'general revision' ... that only a constitutional convention [could] accomplish."39 The Court distinguished an "amendment" from a "general revision" and held:

[I]n order to determine whether a proposal effects a "general revision" of the constitution, and is therefore not subject to the initiative process established for amending the constitution, the Court must consider both the quantitative nature and the qualitative nature of the proposed **65changes. More specifically, the determination depends on not only the number of proposed changes or whether a wholly new constitution is being offered, but on the scope of the proposed changes and the degree to which those changes would interfere with, or modify, the operation of government.^[40 ^]

In reaching this conclusion, the court reviewed: (1) the text of the constitutional provisions at issue;41 (2) two cases from this Court-one interpreting a city charter under the Home Rule City Act, MCL 117.1 et seq .,42 and one interpreting the predecessor provisions of the 1908 Michigan Constitution;43 and (3) several cases from other jurisdictions, including two leading cases decided by the California Supreme Court.44 The Court "agree[d] with the reasoning of these decisions" and found them "to be consistent with Michigan law as stated in Laing and Pontiac School Dist ."45

Much of the Court of Appeals' analysis hinged on Laing and Pontiac Sch. Dist. , so it is worth considering whether those cases did, in fact, establish the above standard, and whether they are binding or persuasive authority. Despite the Court of Appeals' reliance on Laing and Pontiac Sch. Dist. , we find these cases to be of limited value on this topic. Laing is clearly distinguishable **66because, while it addressed the distinction between a "revision" and an "amendment," it did so in the context of a city charter under the Home Rule City Act.46 And, in any event, its discussion was unnecessary to resolving the case, since it occurred immediately after the Court's holding that "[t]he petition on its face is not in the form required by law, and raised no duty in defendants to provide for an election."47 We agree with the Solicitor General that this case is not binding; however, *256the Court's opinion does give some insight into the plain meaning of the terms "amendment" and "revision" 24 years after the 1908 Constitution was ratified:

"Revision" and "amendment" have the common characteristics of working changes in the charter and are sometimes used inexactly, but there is an essential difference between them. Revision implies a re-examination of the whole law and a redraft without obligation to maintain the form, scheme, or structure of the old. As applied to fundamental law, such as a constitution or charter, it suggests a convention to examine the whole subject and to prepare and submit a new instrument, whether the desired changes from the old be few or many. Amendment implies continuance of the general plan and purport of the law, with corrections to better accomplish its purpose. Basically, revision suggests fundamental change, while amendment is a correction of detail.^[48 ^]

**67Nine months later, in Pontiac Sch. Dist. , this Court again addressed the distinction between an "amendment" and a "revision," this time in the context of a challenge to an amendment of the Constitution proposed under Article 17, § 2 of the 1908 Constitution, the predecessor to Article 12, § 2 of the 1963 Constitution.49 Without any discussion of the text of the provision, or citation of any authority (notably absent was any citation of Laing , decided less than a year earlier), the Court summarily rejected the argument that the amendment amounted to a revision because it "does not so interfere with or modify the operation of governmental agencies as to render it other than an amendment by way of an addition to the Constitution."50 It is hard to glean much meaning from this statement, since the Court did not purport to set forth a standard to govern this question but instead merely rejected the argument in the form that it was presented. Notably, the distinction between an amendment and a revision was contained only in the parties' arguments to the Court; speaking for itself, the Court did not actually embrace a dichotomy between "amendments" and "revisions" but simply concluded that the proposal was not so dramatic a change as to "render it other than an amendment ...."51

In Citizens , this Court had an opportunity to resolve the case under the amendment/revision dichotomy but declined to do so, affirming the result only and fracturing on the reasoning. Three justices gave a qualified endorsement of the Court of Appeals' articulation of the distinction between an "amendment" and a "general **68revision" of the Constitution.52 The remaining four justices declined to adopt the *257Court of Appeals' standard. Three of the four agreed with the order affirming, but did so based on grounds not addressed by the Court of Appeals, namely, that "a proposal of this extraordinary scope and multitude of unrelated provisions clearly cannot be reasonably communicated to the people in 'not more than 100 words,' " as required by Article 12, § 2.53 By its willingness to dispose of the case on the alternative ground that "[t]his language establishes a clear limitation on the scope of the constitutional amendments under [ Article 12, § 2 ],"54 the statement by this grouping of justices may be read as an implicit recognition that the "amendment/general revision" dichotomy did not provide such a clear limitation, at least not under the Court of Appeals' standard.55 Justice KELLY 's dissent questioned the test developed by the Court of Appeals and lamented that our failure to construct a clearer test left the state of the law unsettled.56 **69The Court of Appeals again confronted this issue in Protect Our Jobs v. Bd. of State Canvassers .57 As the Court summarized it, the ballot proposal at issue was narrow, providing in one constitutional section the "people with the right to organize and bargain collectively" with public and private employers, to the extent not preempted by federal law, and in another section "protecting the rights of classified civil service employees to bargain collectively concerning all conditions and aspects of employment except promotions."58 CPMC challenged the proposal on the same grounds it asserted in Citizens and is asserting in this lawsuit, i.e., that it was a general revision of the Constitution under Article 12, § 3.

The Court of Appeals rejected CPMC's challenge, using the "qualitative and quantitative" standard from its decision in Citizens and concluding that although the proposal might affect "various provisions and statutes," it was "limited to a single subject matter" and changed only two sections of the Constitution.59 By contrast, the RMGN proposal in Citizens

sought to replace vast portions of the constitution and massively modify the structure and operation of Michigan's government. The initiative proposal here is far more akin to a correction of detail than a fundamental change, when viewed in the proper context of the constitution as a whole. See Kelly v. Laing , 259 Mich. 212, 217, 242 N.W. 891 (1932).^[60 ^]

*258**70This Court did not order briefing on the issue61 and our opinion declined to address it.62

Thus, we could locate no controlling authority from this Court construing the meaning of the term "amendment" in Article 12, § 2. At most, Pontiac suggests there may be undefined limitations on what can be achieved by an amendment. Moreover, our caselaw lacks a detailed examination of this issue, especially one that conducts the proper analysis by examining the constitutional text. Perhaps as a result of veering from the text, the rather vague standard that has developed below affords courts considerable discretion in this area.63 We believe the constitutional text provides a clearer standard, which we turn to now.

**712. ARTICLE 12, § 2

The textual analysis begins with examining the meaning of "amendment" as used *259in the text.64 "Amendment" is relevantly defined as "an alteration of a legislative or deliberative act or in a constitution; a change made in a law, either by way of correction or addition," or "the correction of an error in a writ, record, or other judicial document."65 The definition does not directly speak to the breadth of the change **72that can be made by amendment or provide any substantive limitations on amendments.

With regard to limitations on the scope of amendments, the text of the predecessor provision to Article 12, § 2 was meaningfully changed soon after its ratification in 1908. When it was ratified, the Constitution gave the Legislature a veto over voter-initiated amendments before the election at which the proposal would appear on the ballot, and the Legislature could also submit alternative or substitute amendments.66 Yet despite the Legislature's considerable oversight, the framers of the Constitution nonetheless thought that "the effect of this provision [i.e., the initiative provision] will be the submission to a vote of the electors of **73practically all amendments petitioned for."67 In a telling passage of the Address to the People, the framers explained that legislative oversight of the amendments proposed by initiative was a crucial factor to the convention:

The convention realized the far-reaching effect that each amendment to the constitution may have beyond the immediate purpose intended by it, and it was deemed essential in so important a matter as changing the fundamental law of the state that the very greatest care should be required in both the form and substance of amendments to it. Such care is secured by requiring the amendments proposed to pass the scrutiny of the legislature .^[68 ^]

But even the legislative veto-the clearest and most significant substantive check on *260the petition power-was deleted by amendment in 1913.69 In light of this history, we should be wary of finding a textual limitations on voter-initiated amendments.

The critical limitation in Article 12, § 2-at least based on the amount of discussion it prompted at the 1961-1962 convention-is instead the procedural requirement of obtaining a certain number of signatures. Originally, signatures in a number equal to 20 percent of the vote at the most recent election for secretary of state had to be collected, but in 1913 this threshold was reduced to 10 percent of the votes for Governor at the **74most recent general gubernatorial election.70 The importance of this restriction in the constitutional framework was made abundantly clear by the framers of the 1963 Constitution, who engaged in a spirited debate regarding the signature requirement. At the convention, it was proposed, and briefly added to the constitution under consideration, that the 10 percent requirement be amended to include "or 300,000 such registered electors, whichever shall be less."71 The effect would have been to make it progressively easier to obtain enough signatures as the population increased. Delegate J. Harold Stevens successfully recommended striking this addition, arguing that the voter-initiated amendments should not be too easy to accomplish.72 But his concern reflected his belief that initiative amendments should not be akin to "statutory matter."73 He did not want to debase the Constitution by cluttering it with trivial amendments-in other words, he wanted amendments to be important enough to merit inclusion in a constitution. He was not, then, suggesting that initiative amendments should be limited to trivial matters; quite the contrary.74 **75Thus, the convention decided to keep voter-initiated amendments difficult because amendments, like the Constitution itself, were intended to deal with serious matters. The convention accomplished its goal by imposing what it viewed as the clearest and most stringent limitation on initiative amendments: a signature requirement.75 *2613. ARTICLE 12, §§ 2 AND 3 : THE NEW-CONSTITUTION TEST

The relevant substantive limitation on the scope of voter-initiated amendments arises from the text of Article 12, § 2 when read together with Article 12, § 3. By adopting these two different procedures for altering the Constitution, the framers intended that the mechanisms must be different in some regard. As one treatise similarly observed in 1910:

It may be argued ... that if a constitution specifically provides two methods of alteration, the language employed with reference to the proposal of amendments by the legislative method may, when read with that concerning the convention method, often be construed as an implied prohibition of complete constitutional revision by the legislative method.^[76 ^]

**76In other words, the distinction between changes proposed by amendments and changes proposed by a convention indicates a substantive difference that limits the breadth of amendments.

Our Constitution tells us what this basic difference is. The result of a constitutional convention called to consider a "general revision" is a "proposed constitution or amendments" adopted by the convention and proposed to the electors.77 The convention, then, can propose amendments to the existing Constitution or offer a new constitution.78 By contrast, if approved, a *262**77voter-initiated amendment under Article 12, § 2"shall become part of the constitution, and shall abrogate or amend existing provisions of the constitution ...."79 Consequently, an amendment does not replace a constitution in full, but simply adds to or abrogates specific provisions in an existing constitution.80 Thus, the constitutional text distinguishes between amendments that can be made by petition and new "constitutions." Because only the convention has the power to propose a constitution, by logical implication an initiative amendment cannot do so. And since this limitation would be meaningless if it only required a new constitution to be labeled as an amendment, it follows that an initiative amendment cannot propose changes that are tantamount to the creation of a new constitution.81 **78The phrase "general revision" supports this dichotomy between amendments and "new" constitutions, although the phrase has engendered some confusion. The "purpose" of a convention is to consider "the question of a general revision of the constitution ...."82 "General" means "dealing with all or the overall, universal aspects of the subject under consideration ...."83 "Revision," in turn, is relevantly defined as "the act or work of revising."84 *263This is how we **79characterized the term in Laing85 and how it was described at the 1908 convention: "What is meant by revision or to revise? Why simply to re-examine for the purpose of correction-the act of reviewing or re-examination for the purpose of correction."86 The "revision" is simply the process for reconsidering the constitution as a whole. It is not, as some Court of Appeals opinions suggest,87 a particular document or proposed change. Thus a "revision" is not contradistinguished from an "amendment." Rather, as noted, the distinction between the Article 12, § 3 convention process and the Article 12, § 2 amendment process is that the former can produce a proposed constitution, while the latter is limited to proposing less sweeping changes.88 **80Having determined that the relevant substantive limitation is that a voter-initiated amendment cannot be equivalent to a new constitution, we must determine what this limitation entails. As an initial matter, the number of changes is not dispositive, as even a limited number of changes can have the effect of creating a new constitution.89 A constitution, after all, is more *264than words on a page. Its most basic functions are to create the form and structure of government, define and limit the powers of government, and provide for the protection of rights and liberties.90 These are **81the basic threads of a constitution, and when they are removed, replaced, or radically rewoven, the whole tapestry of the constitution may change.

Therefore, changes that significantly alter or abolish the form or structure of our government, in a manner equivalent to creating a new constitution, are not amendments under Article 12, § 2.91 Contrary to the suggestion in Pontiac Sch. Dist. ,92 it is not necessarily the impact on the operations of government that matters-like the United States Supreme Court, we decline to accept "the narrow-minded assumption" that the only purpose of our constitutional provisions "is to make the government run as efficiently as possible."93 Further, a change that recalibrates the relative power **82of the branches of government-such as limiting or taking away a specific power from one branch-is not, absent a significant effect on the structure of government, a change that is tantamount to the creation of a new constitution.94 Indeed, we have stated that, despite its eliminating power from the judiciary *265or executive branch, an amendment permitting indeterminate criminal sentences was "the people['s] exercise[ ] [of] a right inherent in them to adopt a constitutional amendment taking away from, or adding to, the powers of either of the departments of government."95 In fact, it would be difficult to imagine many amendments that leave the proportionate powers of the branches completely unchanged.96

IV. APPLICATION

Given the above analysis, VNP's proposal will be considered a permissible amendment if it does not propose changes that significantly alter or abolish the form or structure of our government in a way that is tantamount to creating a new constitution. To answer this question, we must examine our current law on redistricting and apportionment and how VNP's proposal would change that law.

**83A. APPORTIONMENT AND REDISTRICTING

Under our first three Constitutions, the Legislature was granted authority to redistrict.97 But the Legislature did not always carry out this responsibility.98 In light of this history, two competing voter-initiated amendments to the then-existing Constitution were placed on the November 1952 ballot.99 One was approved, which wrote directly into the Constitution the then-existing alignment of seats in the Senate provided for in the 1952 amendment, added 10 seats to the House, and conferred upon the Board of State Canvassers the obligation to draw up new house districts if the Legislature failed to act.100

Our present Constitution, as ratified by the voters in 1963, laid out a different framework for reapportionment and redistricting, although for reasons that will become clear below, it is not currently followed.101

**84Under the Constitution, "the 38 *266members of Michigan's senate and the 110 members of the house of representatives are elected according to the district in which they reside. The Constitution sets forth the apportionment factors and rules for individual districts, which are redrawn after" the federal census is published.102 The Constitution aligns the senate districts with counties and apportions senators based on "factors" consisting of percentages of the county's population and "land area" in the state.103 The house districts were based on counties and apportioned according to population.104 In other words, the apportionment was based on "weighted land area/population formulae."105

A key innovation of the 1963 Constitution was to create a bipartisan "commission on legislative apportionment" to draw the relevant district lines.106 The commission consisted of eight seats, with the major political parties each entitled to appoint four members.107 The Secretary of State was the commission's nonvoting secretary, required to furnish "all necessary technical services," and the Legislature was required to "appropriate funds to enable the commission to carry out its activities."108 The commission was required **85to "hold public hearings as may be provided by law."109 The commission had to complete its work within 180 days of the census data becoming available.110 Each final apportionment and districting plan adopted by the commission had to be published and would become law 60 days after publication.111 If the commission could not agree on a plan, commissioners could submit plans to our Court, which was required to "determine which plan complies most accurately with the constitutional requirements" and direct that the plan be adopted.112 The Court was also given jurisdiction over any application filed by electors within 60 days of publication of the plan.113

As our present Constitution was being deliberated at the 1961-1962 constitutional convention, the United States Supreme Court was also considering constitutional challenges to apportionment schemes. In 1962, that Court held that challenges to apportionment plans were justiciable, setting the stage for vast changes in this area of law.114 Two years later, in Reynolds v. Sims , the Court held that "the Equal Protection Clause requires that the seats in both houses of a bicameral state legislature must be apportioned on a population basis."115 Geographical considerations, such as apportionment based on counties, could no longer play a role in apportionment if they **86produced population deviations between *267the districts.116 One week after Reynolds was decided, the United States Supreme Court peremptorily reversed a federal district court's earlier judgment that Michigan's apportionment rules were constitutional, which invalidated them.117

Days after Reynolds was decided, we ordered the commission to adopt a new plan for redistricting and apportionment that complied with the Supreme Court's decisions in Reynolds and various related cases decided the same day.118 When the commission failed to reach an agreement, we issued an opinion directing it to adopt the so-called Austin-Kleiner Plan, as it most closely adhered to the new constitutional requirements.119 In a concurrence, Justice SOURIS argued that the commission "was so dependent upon the continuing validity of the [now unconstitutional apportionment formula] by which the commission's duties were specified and expressly limited, that it could not survive alone."120

The apportionment issue was back before the Court in 1972 after the commission once again deadlocked **87and invoked our supervision.121 We ordered the adoption of a proposed apportionment plan, but did not comment on the viability of the commission.122 Justice T. G. KAVANAGH dissented, reaching the same conclusion Justice SOURIS had in 1964: the commission could not exist-i.e., was not severable from-the unconstitutional apportionment standards in our Constitution.123

In 1982, with yet another deadlocked commission seeking our supervision, we adopted the position of Justices SOURIS and T. G. KAVANAGH by declaring that the commission was not severable from the unconstitutional apportionment provisions it was directed to implement.124 We thought the commission was inseparable from the unconstitutional standards because holding otherwise would have required us to opine on whether the people would have voted for the commission without those standards.125 Because the issue of changing how legislators are chosen is "a fundamental matter," we would not "speculate on a matter of such enormous importance."126 Critically, we emphasized repeatedly that "[t]his is a decision which the people *268should make."127 It was a decision, we suggested, that the people could initiate through a constitutional amendment:

**88The power to redistrict and reapportion the Legislature remains with the people. The people, however, can only exercise that power, as a practical matter, by amending the constitution, which, unless the Legislature proposes an amendment acceptable to the people, is a difficult and time-consuming process.^[128 ^]

Tellingly, we noted in the same discussion that "[t]he initiative process is also difficult and time-consuming."129 Because that process was slow, and a plan needed to be formulated in the meantime, we appointed an individual to oversee the drawing of a redistricting and apportionment plan consistent with various principles we established.130 We noted, however, that the Legislature could draw its own plan, which would supersede the one we set in motion.131 But again, we stressed that our plan was merely a stopgap that would "stand until the people act, or it is changed by the collective action of the other two branches of this government, composed of persons who are the most immediate representatives of the people."132 It was not until 1996 that the Legislature codified apportionment standards and committed itself to drawing districts in the future.133

Thus, the last time the voters had direct input on this issue, they opted for apportionment and redistricting to be conducted by a commission. The rules to be implemented by that commission have been declared unconstitutional, and we deactivated the commission by concluding **89that it was not severable from those unconstitutional rules. The Legislature now exercises a power that the Constitution of 1963 expressly denied to it-to draw legislative districts-because our Constitution has never been amended to modify the unconstitutional provisions concerning apportionment and redistricting.

B. THE VNP PROPOSAL

That is precisely what VNP's constitutional amendment proposes to do. To accomplish this task, the proposal would eliminate the current language in the Constitution laying out the apportionment formulae.134 Instead, seven criteria are proposed, requiring that the districts must, in order of priority: (1) have "equal population as mandated by the United States Constitution," (2) "be geographically contiguous," (3) "reflect the state's diverse population and communities of interest," (4) "not provide a disproportionate advantage to any political party," measured by "accepted measures of partisan fairness," (5) "not favor or disfavor an incumbent elected official," (6) "reflect consideration of county, city, and township boundaries," and (7) "be reasonably compact."135

Rather than rewriting the constitutional section governing the commission, the *269VNP proposal simply deletes the language in Const 1963, art 4, § 6 establishing the commission.136 In its place, the proposal offers a reformed commission that is similar to its **90predecessor.137 Like the old one, it consists of four members from each major political party, but it would have five additional members who are declared independent voters.138 All 13 members would be selected from a pool of candidates who have submitted applications, taken oaths, and met various other requirements.139 The leaders of both parties in the Senate and House can strike, in total, 20 names from the applicant pools.140 The commission, once selected, must hold public hearings and its contact with the public is regulated in detail by the proposal.141 A plan is adopted only with at least two votes from each subgroup (Republicans, Democrats, and independents), as well as a majority of the whole.142

The proposal continues nearly verbatim various ancillary provisions from the 1963 commission. The Secretary of State, for example, remains a nonvoting secretary of the commission, charged with providing the commission "all technical services that the commission deems necessary."143 Likewise, the Legislature remains obligated to "appropriate funds" for the commission, although the proposal provides a detailed breakdown of what the funds go to, whereas the 1963 Constitution simply required the appropriation of sufficient funds "to enable the commission to carry out its activities."144 Our Court has a similar, if perhaps narrower, **91jurisdictional grant under the proposal: we can "direct the Secretary of State or the commission to perform their respective duties," and we may also "review a challenge to any plan adopted by the commission" and "shall remand a plan to the commission for further action if the plan fails to comply with the requirements of this Constitution, the Constitution of the United States or superseding federal law."145 The proposal adds various provisions clarifying that the commission's power is legislative and not subject to the Legislature's146 or the Governor's147 control, and the vesting clauses of the judicial, executive, and legislative branches are amended so as to vest power in their respective branches "except to the extent limited or abrogated" by certain of the new provisions.148

C. ASSESSING THE PROPOSAL

To determine whether VNP's proposal is a permissible amendment, we must ask whether it significantly alters or abolishes the form or structure of our government in *270a manner that is tantamount to creating a new constitution.149 **93One central feature of the VNP amendment is that it sweeps away unconstitutional provisions that have remained in the Constitution for some time. The "weighted land area/population formulae" and the accompanying apportionment factors150 are gone, and so counties would not be the organizing feature of redistricting plans. But these changes involve no great transformation because these features were held unconstitutional 36 years ago. In their place our state has used federal constitutional requirements and various state "guidelines,"151 enacted in 1996, including that the districts "[be] areas of convenient territory contiguous by land,"152 "preserve *271county lines with the least cost to the principle of equality of population,"153 and remain as compact as possible when drawn within a city or township with multiple districts.154 VNP's proposed standards reflect many of the same principles, including, of course, adhering to federal law, and also requiring contiguous districts, respecting municipal boundaries, and seeking reasonable compactness.155 The proposal contains a few new items too, such as considerations of partisan fairness. But given their continuities with the current standards, VNP's proposed standards are no revolution in redistricting, and they certainly do not portend a transformation of our form or structure of government. **94As noted above, various provisions in VNP's proposal mirror those in the current Constitution. The Secretary of State has substantially the same general responsibilities, being the nonvoting secretary of the commission responsible for furnishing its needs.156 The Secretary of State has more detailed obligations under the proposal, involving the formation of the commission.157 But these tasks are ministerial and in line with our current Constitution-requiring the Secretary of State to manage applications or other records is business as usual, not a new way of governing Michigan.158

Since plaintiffs and the Chief Justice's dissent concede that "the people can alter the power of redistricting by amending the Constitution,"159 the more significant argument against the VNP proposal is that it disrupts the separation of powers. The powers are most glaringly reconfigured, according to plaintiffs, by the proposal's inclusion of limiting language in the vesting clauses of each branch. The legislative, executive, and judicial branches are given their respective powers "except to the extent limited or abrogated" by certain parts of the proposal.160 The dissent takes the position that these changes "fundamentally change the operation **95of our government" by limiting the vested powers of the branches and creating a new commission with responsibility for redistricting.161 We disagree.

The limitations in the vesting clauses are, in many ways, the result of VNP's attempt to comply with other requirements in Article 12, § 2. By including this language, the proposal simply seeks to harmonize its changes with the rest of the Constitution. This is important because Article 12, § 2 requires that the proposal republish for the voters any portion of the *272present Constitution that the proposed amendments would alter or abrogate.162 This requirement has kept at least one proposal off the ballot in the recent past.163 By explicitly adding limitations to the vesting clauses here, VNP sought to avoid any argument that it was implicitly altering or abrogating the vesting clauses or other parts of the Constitution. More broadly, by adding this language, the proposal makes explicit what would have been implicit without the language-the proposal does have some effect on the responsibilities and powers of the branches of government. But the proposed language in the vesting clauses tells us nothing useful to the critical inquiry: just how significant are the changes? The proposal is in jeopardy only if the changes are equivalent to the creation of a new constitution. To answer that question, we have to examine the proposed changes that affect the branches' relative powers.

To begin, consider how the proposal would change the present Constitution with regard to the Legislature.

**96The present Constitution does not accord the Legislature any role in the redistricting or apportionment process. Instead, like VNP's proposal, a commission is placed in charge. The commissions are materially similar. Both are charged with drawing a redistricting plan based on various guidelines. And while the guidelines have changed, as explained above, VNP's proposal actually reflects many of the same standards currently used. The major difference between the 1963 Constitution's commission and VNP's is the process by which commission members are chosen. VNP's proposal is undoubtedly more elaborate on this point. Nonetheless, as with the old commission, VNP's proposal seeks to ensure that the membership strikes a partisan balance. In fact, in doing so, VNP's proposal gives the Legislature a formal role in the process, with the majority and minority leaders of each house entitled to a certain number of vetoes on members.164 The Legislature has no such role in the 1963 Constitution's commission. If anything, then, VNP's proposal increases, slightly, the Legislature's participation in the process over the level contemplated in 1963. And the Legislature's new, minor role does not come at the expense of either of the other two branches, which have no real part in this process.

Of course, we are not oblivious to the fact that the Legislature, since 1996, has established the standards and framework for redistricting, as well as drafted the plans.165 But the current state of affairs is a deviation from what the voters chose when they ratified the 1963 **97Constitution.166 Under the 1963 Constitution, the *273power to draw districts never belonged to the Legislature. Rather, its present role is solely due to a judicial remedy we crafted in light of our conclusion that the unconstitutional apportionment standards the commission was directed to implement could not be severed from the commission itself.167 Nothing about the commission was intrinsically unconstitutional. Thus, to the extent that the Legislature's power is being diminished, that power had not been granted by the **98people through the Constitution. If anything, VNP's proposal is an attempt to correct the constitutional deficiencies so that the basic design of the 1963 Constitution-which created an independent redistricting commission-can be implemented. We cannot reasonably conclude that this effort to revivify and improve upon a feature of the present Constitution amounts to a substantial alteration in the form or structure of our government.168

The executive branch is not significantly affected by the proposal. Under the 1963 Constitution, the executive played no role in redistricting except for the Secretary of State's various responsibilities. Those would expand under VNP's proposal, as noted above, but not in any material respect. VNP's proposal neither adds to nor subtracts from any other responsibilities or powers of the executive branch compared to its position under the present Constitution. Any additional powers the executive might currently have-such as a veto over the Legislature's statutorily drawn redistricting-do not flow from a constitutional grant of power, but instead from the provisional situation that has been created by declaring the 1963 commission to be inseverable from the unconstitutional apportionment standards.

Finally, VNP's proposal only modestly changes the judicial branch's role in the redistricting process. The 1963 Constitution has provided this Court with jurisdiction when the commission reached an impasse, **99which it often did.169 In such cases, the commission members could submit *274proposed plans to this Court, and we would have to select the one that best reflected constitutional requirements.170 Additionally, the Constitution provided us original jurisdiction over applications by electors after the commission published a plan-we could then direct the Secretary of State and the commission to "perform their duties," review the commission's proposed plan, and remand the plan to the commission "if it fails to comply with the requirements of this constitution."171 Thus, the Constitution offered this Court a limited array of options to review redistricting plans. VNP's proposal does likewise. In some ways, in fact, the review is slightly broader. When the original commission failed to reach agreement under the current Constitution, this Court was empowered only to select between the plans proposed by the commission members. Under VNP's proposal, we can review any challenge to a plan for compliance not only with this Constitution, but also the United States Constitution and "superseding federal law."172 Thus, the Court would no longer have the option to choose a plan-from those presented-but it would maintain the same general powers it wielded under the 1963 Constitution as ratified.173 **100In sum, VNP's proposal leaves the form and structure of the government essentially as it was envisioned in the 1963 Constitution. Consequently, it is not equivalent to a new constitution and is therefore a permissible amendment under Const 1963, art 12, § 2.174

This conclusion finds support from a host of other considerations. It is consistent with the expectations of key members of the 1961-1962 constitutional convention, as evidenced by their discussion of the signature requirement in Article 12, § 2. During that discussion, which centered on whether to add an alternative requiring only 300,000 signatures,175 some delegates expressed the belief that a voter-initiated amendment could be used to change the apportionment system, which was a noted problem at the convention. One delegate-referring to the United States Supreme Court's then-recent decision in Baker v. Carr , which opened the door to constitutional challenges to redistricting176 -thought that the initiative could be "a remedy to the problem of reapportionment."177

*275Delegate Stevens, one of the leading proponents of keeping **101the amendment process difficult, agreed, opining that "the initiative could be used for amending the constitution to make apportionment ... or changing the apportionment easier."178

Similarly, when declaring the redistricting commission not viable in 1982, this Court suggested that our apportionment system could be addressed through an amendment to the Constitution initiated by the people.179 Our statement, quoted above, bears repeating: "The power to redistrict and reapportion the Legislature remains with the people ."180 It was only because the amendment process-whether initiated by the Legislature or the people-was time-consuming that we invited the Legislature to fill the void.181 As Justice LEVIN later explained, our approach in 1982 was based, in part, on the "assumption ... that responsible persons would come forth and place on the ballot, and the people would adopt, new apportionment rules in time for the 1992 and 1994 elections. Indeed, that was one of the arguments for non-severability-to highlight the need for a new constitutional provision regarding legislative apportionment."182 "The Court's exhortation," he added, "has not been heeded."183

**102The history of our constitutional amendments, too, supports treating VNP's proposal as a proper voter-initiated amendment.184 Most directly, the voters have in the past proposed a number of amendments dealing with apportionment,185 including one successful amendment that, in certain circumstances, expressly stripped the Legislature of the power to redistrict. In 1952, voters initiated two competing constitutional amendments addressing apportionment.186 The successful amendment "guaranteed the decennial reapportionment of the house of representatives substantially on a population basis, and fixed senate districts permanently in the constitution ...."187 The Legislature was responsible *276for reapportioning the house, but, critically, if it failed to do so "in accordance with the mandate of this [constitutional] article, the board of state canvassers" was required to reapportion the districts.188 In other words, the voters initiated an amendment that, in certain cases, eliminated the Legislature's reapportionment power and gave it to an agency in the executive branch. By comparison, VNP's proposal is more modest-the present Constitution **103prescribes a commission for these purposes, and VNP's amendment would retain that commission. The voters have also approved, in the past, various amendments creating commissions or affecting the powers of government at various levels and branches.189

Other states have created independent redistricting commissions through voter-initiated amendments, including Arizona and California.190 And the issue of whether to create such a commission has appeared on the ballot, by virtue of the initiative process, numerous times in multiple states.191 Similarly, citizens in several states have employed initiatives to accomplish redistricting.192

**104Our conclusion today is also reinforced by the reasoning in Bess v. Ulmer , which addressed a similar argument concerning a similar ballot proposal.193 In Bess , a "Legislative Resolve" placed a proposed amendment before the voters that would remove the reapportionment power from the executive branch (where the state's constitution had placed it) and transfer it to a "neutral body."194 Using a test similar to what the Court of Appeals employed in this case-focusing on the quantity and quality of the proposed changes and whether the changes were few, simple, and *277of less importance-the Alaska Supreme Court determined that the proposal was an amendment:

Reassigning this power is unquestionably a significant change in the present system of Alaskan government. It does not, however, deprive the executive branch of a "foundational power," and as a result does not constitute a revision. As the quantitative effect of the proposal is minimal, the qualitative force of this narrow change would have to be greater to satisfy our hybrid test. The essential function of the executive branch-to enforce the laws of the state-remains unchanged, as does its structure. No executive power is delegated to either of the other two branches. In fact, the intent of the Framers in giving the reapportionment power to the executive was primarily to prevent the abuse or neglect of that power in the hands of the legislature, rather than to safeguard a uniquely executive function.^[195 ^]

**105In our case, the framers of the 1963 Constitution did not assign the apportionment power to any elected body, and so the effect of the changes here would be even less significant than that in Bess .196

Thus, our holding here reflects the constitutional text, our historical experience, logic, and the wisdom of other states. For all the above reasons, then, we conclude that VNP's proposal does not create the equivalent of a new constitution by significantly altering or abolishing the form or structure of our government and is, instead, a permissible voter-initiated amendment.197

*278**106V. CONCLUSION

The question we face today has broad significance for the people of this state: what limitations have they placed, in the Constitution they ratified, on their power to put forward voter-initiated amendments? This question implicates some of the oldest and most perplexing problems in political theory, such as the nature of sovereignty, republicanism, and democracy. But it is not a judge's role to philosophize a theory of government. Rather, we are stewards of the people and must faithfully abide by the decisions they make through the laws they adopt. We accomplish this by adhering to the plain meaning of the text of those laws. Here, that approach leads us to conclude that a voter-initiated amendment under **107Const 1963, art 12, § 2 is permissible if it does not significantly alter or abolish the form or structure of our government, making it tantamount to creating a new constitution. VNP's proposal surpasses these hurdles and is a permissible voter-initiated amendment under Article 12, § 2. Accordingly, the judgment of the Court of Appeals is affirmed. Pursuant to MCR 7.315(C)(3), the Clerk of the Court is directed to issue the judgment forthwith.

David F. Viviano

Bridget M. McCormack

Richard H. Bernstein

Elizabeth T. Clement

I concur in full with Chief Justice MARKMAN 's dissent. I write separately, however, to address an additional, alternative basis for rejecting the proposal submitted by Voters Not Politicians (VNP). The VNP proposal requires that applicants to the independent citizens redistricting commission attest under oath either that they affiliate or do not affiliate with one of the two major political **146parties. Because the proposal abrogates the Oath Clause of Const 1963, art 11, § 1, which forbids requiring additional oaths or affirmations as a qualification for public office, VNP was required to republish that provision on its petitions. It is uncontested that VNP failed to do so. Because strict compliance with the republication requirement was required, an order of mandamus should issue directing the rejection of the VNP proposal.1

I. THE VNP PROPOSAL2

The VNP proposal, art 4, § 6, provides, in pertinent part:

(2) Commissioners shall be selected through the following process:

(A) The Secretary of State shall do all of the following:

* * *

(III) require applicants to attest under oath that they meet the qualifications set forth in this section; and either that they affiliate with one of the two political parties with the largest representation *300in the Legislature (hereinafter, "major parties"), and if so, identify the party with which **147they affiliate, or that they do not affiliate with either of the major parties . [Emphasis added.]^[3 ^]

Under the VNP proposal, the Secretary of State is required to eliminate the applications that are incomplete. Therefore, if an applicant fails to attest under oath regarding his or her political party affiliation, the applicant is ineligible to be selected for a position on the commission. See VNP proposal, art 4, § 6(2)(D)(I).

II. BACKGROUND REGARDING REPUBLICATION REQUIREMENTS

Both Const 1963, art 12, § 24 and MCL 168.482(3)5 require that ballot proposals that would amend Michigan's Constitution republish any existing constitutional provisions that the proposed amendment would alter or abrogate. The petition republication requirement serves "to inform the petition-signer, should he **148sign," of the effect "an initiated proposal will have upon an existing constitutional provision (or provisions) should that proposal receive electoral approval." Carman v . Secretary of State , 384 Mich. 443, 454, 185 N.W.2d 1 (1971) (emphasis omitted). Such "dissemination of necessary information to the public" is considered both "wholesome and desirable." Id ." Const 1963, art 12, § 2 and MCL 168.482(3) together establish the requirements for publishing existing constitutional provisions." Protect Our Jobs v. Bd. of State Canvassers , 492 Mich. 763, 778, 822 N.W.2d 534 (2012).

In Stand Up For Democracy v. Secretary of State , 492 Mich. 588, 822 N.W.2d 159 (2012), this Court held that a petition must fully observe mandatory statutory provisions concerning a petition's form requirements. In Protect Our Jobs , 492 Mich. at 778, 822 N.W.2d 534, this Court held that the strict-compliance principle articulated in Stand Up For Democracy applied with "equal force" to the requirement that a petition republish any existing constitutional provision that the proposed amendment, if adopted, would alter or abrogate.

Protect Our Jobs , which involved the proper interpretation of "alter" and "abrogate" in the context of a ballot proposal to amend the Constitution, id . at 772-773, 761 N.W.2d 210, reaffirmed the principles articulated in Ferency v. Secretary of State , 409 Mich. 569, 297 N.W.2d 544 (1980), and *301Sch. Dist. of City of Pontiac v. City of Pontiac , 262 Mich. 338, 247 N.W. 474 (1933), Protect Our Jobs , 492 Mich. at 778-781, 822 N.W.2d 534. "[A]n existing provision is only altered when the amendment actually adds to, deletes from, or changes the wording of the provision," and "an amendment only abrogates an existing provision when it renders that provision wholly inoperative ." Protect Our Jobs , 492 Mich. at 773, 822 N.W.2d 534 (emphasis added). **149With respect to abrogation-the only type of change asserted to be at issue by plaintiffs in the instant case- Protect Our Jobs held that republication is required if the proposed change "would essentially eviscerate an existing provision." Id . at 782, 822 N.W.2d 534. The standard for abrogation was articulated as follows:

Our caselaw establishes that an existing provision of the Constitution is abrogated and, thus, must be republished if it is rendered "wholly inoperative." An existing constitutional provision is rendered wholly inoperative if the proposed amendment would make the existing provision a nullity or if it would be impossible for the amendment to be harmonized with the existing provision when the two provisions are considered together. That is, if two provisions are incompatible with each other, the new provision would abrogate the existing provision and, thus, the existing provision would have to be republished. An existing provision is not rendered wholly inoperative if it can be reasonably construed in a manner consistent with the new provision, i.e., the two provisions are not incompatible.

Determining whether the existing and new provisions can be harmonized requires careful consideration of the actual language used in both the existing provision and the proposed amendment. An existing provision that uses nonexclusive or nonabsolute language is less likely to be rendered inoperative simply because a proposed new provision introduces in some manner a change to the existing provision. Rather, when the existing provision would likely continue to exist as it did preamendment, although it might be affected or supplemented in some fashion by the proposed amendment, no abrogation occurs. On the other hand, a proposed amendment more likely renders an existing provision inoperative if the existing provision creates a mandatory requirement or uses language providing an exclusive power or authority because any change to such a provision would tend to negate the specifically conferred constitutional requirement. [ Id . at 782-783, 822 N.W.2d 534 (citations omitted; emphasis added).]

**150Protect Our Jobs involved four distinct ballot proposals to amend the Michigan Constitution, none of which altered an existing provision of the Constitution. However, the Court held that the ballot proposal at issue in Citizens for More Michigan Jobs v Secretary of State abrogated an existing constitutional provision. Id . at 773, 822 N.W.2d 534. That proposed amendment would have allowed for the construction of eight new casinos in Michigan and would have compelled the issuance of a liquor license to each of the eight casinos. Id . The Court held that the amendment's requirement that the casinos "shall be granted" liquor licenses "render[ed] wholly inoperative the 'complete control of the alcoholic beverage traffic within this state' afforded to the Liquor Control Commission under ... Const 1963, art 4, § 40." Id . Because Article 4, § 40 was required to be republished, the fact that it was not was "fatal to the proposed amendment" and mandamus was denied. Id . at 791, 822 N.W.2d 534.

*302III. THE OATH CLAUSE

Const 1963, art 11, § 1 provides:

All officers, legislative, executive and judicial, before entering upon the duties of their respective offices, shall take and subscribe the following oath or affirmation: I do solemnly swear (or affirm) that I will support the Constitution of the United States and the constitution of this state, and that I will faithfully discharge the duties of the office of ................ according to the best of my ability. No other oath, affirmation, or any religious test shall be required as a qualification for any office or public trust. [Emphasis added.]^[6 ^]

**151Throughout Michigan history, this constitutional provision has largely remained the same. Const 1835, art 12, § 1 ; Const 1850, art 18, § 1; and Const 1908, art 16, § 2 all provided that "[n]o other oath, declaration or test shall be required as a qualification for any office or public trust." Const 1963, art 11, § 1 narrowed the provision from "test" to "any religious test."

In Dapper v. Smith , 138 Mich. 104, 101 N.W. 60 (1904), the issue before the Court was the constitutionality of a Kent County law that denied a spot on the ballot to any candidate unless the candidate declared an oath of the fact that he was a candidate for the office. The oath prohibited voters from choosing a candidate who declined to seek office on his own initiative but was "willing to consent to serve his State or his community in answer to the call of duty when chosen by his fellow citizens to do so ...." Id . at 105, 101 N.W. 60. The Court noted that the constitutional provision was "not one designed for the benefit of the aspirant for public station alone; it is in the interest of the electorate as well." Id . The Court found the law was unconstitutional, in violation of Article 18, § 1, which provided that "no other oath, declaration, or test shall be required as a qualification for any office or public trust." Id . at 105-106, 101 N.W. 60. The Court could not "escape the conclusion that the provision in question does most seriously impede the electors in the choice of candidates for office, and that it is in conflict with the provisions of section 1 of article 18 of the Constitution ." Id . (emphasis added).

In Harrington v. Secretary of State , 211 Mich. 395, 395-396, 179 N.W. 283 (1920), the Court relied on **152Dapper to strike down a statutory amendment that required primary candidates to sign an affidavit stating that the candidate was a member of a certain political party, naming the political party, and indicating that the candidate would "support the principles of that political party of which he is a member, if nominated and elected[.]" (Quotation marks and citation omitted.) The Court noted the fallacy of requiring additional oaths before a candidate even becomes a candidate: "Where is the logic of saying that when elected the officer cannot be subjected to any test oath other than the constitutional oath of office, but before he can be a candidate he must subject himself to a different test oath or he cannot be a candidate, and is therefore in practical effect barred from holding the office?" Id . at 397, 179 N.W. 283. The Secretary of State urged that Dapper be overruled, but the Court declined, concluding that "the amendment contravenes the constitutional provision above quoted." Id . at 399, 179 N.W. 283. *303IV. ANALYSIS

In the instant case, the Court of Appeals panel agreed with plaintiffs that the VNP proposal is "not an oath of office, but is merely an affirmation that the applicant satisfies the commissioner qualifications, which are enumerated in a separate section, § 6(1)," reasoning that Advisory Opinion on Constitutionality of 1975 PA 227 , 396 Mich. 465, 510, 242 N.W.2d 3 (1976), supported this conclusion. Citizens Protecting Michigan's Constitution v. Secretary of State , 324 Mich. App. 561, ----, --- N.W.2d ----, 2018 WL 2746592 (2018) (Docket No. 343517) (CPMC ), slip op at 27. In that case, the Court held that a financial disclosure oath did not violate Article 11, § 1 ; rather, it was more akin to nominating **153petition affidavits under MCL 168.558 and former MCL 168.557. Advisory Opinion , 396 Mich. at 510-511, 242 N.W.2d 3. However, the plain language of the VNP proposal requires applicants to attest under oath that they meet the qualifications "set forth in this section; and " indicate their party affiliation, if any. VNP proposal, art 4, § 6(2)(A)(III) (emphasis added). The political party affiliation question is undoubtedly a requirement of the attestation under oath in addition to the qualifications of § 6 (1). The Court of Appeals, without explanation, simply declared that a financial disclosure oath is analogous to a political affiliation attestation, and in doing so, it ignored language from Advisory Opinion that distinguished Dapper and Harrington and is particularly germane to this case:

Essentially in both Dapper v. Smith and Harrington v. Secretary of State , the Court upheld the right of belief of the citizen in the face of the government attempt to force the citizen to make a decision . In Harrington , the Court held that the government could not force a potential candidate to choose a political philosophy. In Dapper , the potential candidate could not even be forced to decide if he wanted to be a candidate . The situation we have in this case is vastly different from that in Dapper and Harrington . Sections 131 and 132 [of 1975 PA 227] do not require the potential candidate to form a belief or choose between differing thoughts . The financial disclosure requirements are not analogous to the filing of an oath, affirmation, or religious test. We believe they are more analogous to affidavits required by MCLA 168.557 (change of name) and MCLA 168.558 (name, address, residency, etc.). We find no violation of art 11, § 1 by §§ 131 and 132. [ Advisory Opinion , 396 Mich. at 510-511, 242 N.W.2d 3 (citations omitted; emphasis added).]

In this case, the Court of Appeals' analysis made no reference to Dapper whatsoever. Moreover, the panel distinguished Harrington on the basis that in its view, **154"the oath required by the VNP Proposal relates only to the information on the application and does not bind a candidate once he or she becomes a commissioner ." CPMC , --- Mich. App. at ----, slip op at 27, --- N.W.2d ---- (emphasis added). However, whether the oath in the instant case, unlike Harrington , does not purport to bind a candidate into the future has no bearing on whether an oath or affirmation exists as a qualification for office in the first instance. Nothing in the language of Article 11, § 1 limits the provision to "binding" oaths, affirmations, or religious tests.7 Rather, the language of *304Article 11, § 1 bars additional oaths or affirmations as a requirement for office-"[n]o other oath, affirmation, or any religious test shall be required as a qualification for any office or public trust." (Emphasis added.)

The plain language of the VNP proposal requires applicants to make a choice when filling out the application-they must attest under oath that they affiliate with the Democratic Party, Republican Party, or indicate that they affiliate with neither party. If the applicant fails to meet this qualification, the application is discarded and the applicant is rendered categorically ineligible for a commissioner position. As this Court stated in Advisory Opinion , Dapper and Harrington stand for the proposition that Article 11, § 1 precludes any requirement that requires a potential candidate to form a belief or choose between differing thoughts as a qualification for office. Under **155Dapper and Harrington , commissioner applicants may not be forced to attest, under oath, to which political party they most closely affiliate with, if any.

VNP cites two cases for the proposition that "appointment to public bodies" may be based upon "consideration of political affiliation in cases where the requirement in question is designed to ensure representation of diverse political interests, and does not exclude persons of any particular political persuasion from participation." In other words, defendants argue that the plain language of Article 11, § 1 may be set aside in the interests of political diversity. However, these cases are easily distinguishable.

VNP first cites Attorney General ex rel Connolly v. Reading , 268 Mich. 224, 256 N.W. 432 (1934). In that case, electors of the city of Detroit sought a writ of mandamus to compel the city election commission to comply with a law requiring that not more than 50% of the election inspectors be of the same political party. Id . at 226, 256 N.W. 432. The election commissioners refused to comply with the law, claiming that it was an unconstitutional test.8 Id . The Court rejected the commissioners' argument. Id . at 232, 256 N.W. 432. In doing so, the Court quoted Volume 20 of the Corpus Juris, which (citing Attorney General v. Bd. of Councilmen of the City of Detroit , 58 Mich. 213, 24 N.W. 887 (1885) ) stated that " 'such provisions have been held unconstitutional as making political opinions a condition to holding public office, but in [other jurisdictions] where the question has been raised it has been held that such provisions do not establish such a political test of office as is **156repugnant to the Constitution but ... rather a rule for the guidance of the appointing power .' " Id . at 227-228, 256 N.W. 432 (emphasis added). The Court distinguished the statutory language pertaining to election inspectors from the language at issue in the Corpus Juris, Dapper , and Harrington , but found it "identical" to the language in numerous other statutes creating various other boards. Id . at 228-229, 256 N.W. 432. Instead of requiring a person to declare a party affiliation in order to be an election inspector, the statute was similar to other statutes requiring "that candidates for election to any certain public office shall be limited to a certain number from each *305political party." Id . at 231, 256 N.W. 432.9

Connolly thus had nothing whatsoever to do with oaths or affirmations-the language of the statute at issue did not require anyone to make an oath or affirmation-and the case does not support VNP's claim that its proposal does not abrogate Article 11, § 1.

The other case cited by defendants is Attorney General ex rel Fuller v. Parsell , 99 Mich. 381, 58 N.W. 335 (1894). In that case, the attorney general filed a quo warranto action against Eugene Parsell, the warden of the state house of correction and reformatory at Ionia. Id . at 382, 58 N.W. 335. Parsell refused to give up his office even after he was removed by the board of control.10 Id .

**157Parsell raised six points in defense of the quo warranto action against him; the second point is the one most relevant to this case and reads as follows:

In his second rejoinder he alleges, substantially, that after the passage of Act No. 118 [of the Public Acts of 1893], the Governor, by virtue of said act, assumed to appoint the board of control, requiring of each member thereof the political test named and mentioned in section 2, and by reason thereof appointed two Republicans and one Democrat,-the said Governor himself being ex officio member of said board, and also being a Republican,-and that the said Governor would not have appointed the Democratic member of said board had he been a Republican, or the Republican members had they been Democrats, but that he made said appointment of these parties upon said board because of their political belief and for political reasons; and as to this the respondent puts himself upon the country. [ Id . at 383-384, 58 N.W. 335.]

The Court rejected his claim as follows:

The issue made by the second rejoinder is one purely of law, and raises the question of the constitutionality of Act No. 118, Laws of 1893. The constitutionality of the act was passed upon in Fuller v. Attorney General , and the act held valid. It is true the exact point made here was not presented in that case, but we see no reason for holding it unconstitutional for the reasons assigned. It is now contended that because the Governor, in making the appointments on a new board, acting under section 2 of the act, appointed from each political party, such appointments are void. That section provides that the board shall consist of three members, to be appointed by the Governor, and not more than two of such members so appointed shall be of the same political party. The Governor, by the same section, is made ex officio member of the board. This provision of the act, we think, was passed for a salutary purpose, and was within the province of the Legislature. We know of no provision of the Constitution of the State which it violates. The Governor was bound by this section to appoint each **158member of the board, and, in making the selection, to choose no more than two from the same political party. This provision was carried out, as admitted by the respondent. It is true that the *306appointments may have been made for political purposes, and because of the political beliefs of the parties appointed; but this could not make the appointments void, and no issue of fact could be framed thereon. But, if this were not so, the title to their office cannot be attacked here. They are at least de facto officers. [ Id . at 387-388, 58 N.W. 335.]

Of interest, it should be noted that Parsell did not claim a violation of Const 1850, art 18, § 1, the predecessor of Const 1963, art 11, § 1. Indeed, there was not even a claim that the board members were required to swear additional oaths or affirmations as a qualification of their appointment. In short, Parsell had nothing to do with the constitutional provision at issue and is wholly irrelevant to the analysis.

The majority argues on VNP's behalf that the oath here is merely a qualification for office. In the context of the "test" prohibition contained in former versions of Article 11, § 1, our caselaw has long held that having "special qualifications" for an office (e.g., requiring that a candidate live in a municipality for a specified period of time or be a member of the state bar) does not violate this particular constitutional provision. See Attorney General v. Macdonald , 164 Mich. 590, 129 N.W. 1056 (1911). In the context of the "oath" prohibition, this Court has acknowledged that a statutory requirement that a candidate for office of county commissioner of schools file an affidavit or other proof showing his eligibility for such office did not conflict with the "no other oaths" language of the Constitution. Tedrow v. McNary , 270 Mich. 332, 335, 258 N.W. 868 (1935). The affidavit in Tedrow passed constitutional muster because it was "simply prima facie evidence that the **159candidate [was] educationally qualified to discharge the duties of the office. No statement in any way affecting his rights as a citizen, or his religious or political affiliations, need appear therein." Id . The VNP proposal impermissibly inquires into the political affiliations of the oath-taker, and therefore, in my judgment, Tedrow does not support the conclusion that the VNP oath may be characterized as merely another qualification.

As the majority points out, judicial candidates must confirm by affidavit their qualifications for office. The affidavit of candidacy largely reflects a list of special qualifications: that the judge (1) is an incumbent judge and is domiciled within the relevant jurisdiction, (2) is a candidate for that office at the primary election, (3) is licensed to practice law in the state of Michigan, (4) has been admitted to the practice of law for at least five years, and (5) will not have attained the age of 70 years by election day. See Const 1963, art 6, § 19 ; MCL 168.544b. Again, these qualifications, like the education qualification in Tedrow , stop short of inquiring into a candidate's political affiliations and therefore are distinguishable from the VNP oath.

Perhaps most persuasive is the fact that VNP has not characterized its oath as a qualification. That is a characterization argued by the majority on behalf of VNP. The VNP proposal considers the oath separately and distinctly from the qualifications for a commissioner's position. The commissioner qualifications are listed in Article 4, § 6(1) of the VNP proposal: "[e]ach commissioner shall" be registered to vote in Michigan, not otherwise disqualified for appointed or elected office by the Michigan Constitution, and not currently, or in the past 6 years have been (or related to anyone who has been) (1) a declared candidate, elected official, or part of a governing body for federal, state, or local office; (2) a **160paid consultant or employee of any elected official, political candidate, or political action committee; (3) a legislative employee; (4) a registered lobbyist; or (5) an unclassified state employee. The VNP *307oath requirement is placed in the next subsection, VNP proposal, art 4, § 6(2), which outlines the commissioner selection process.

The VNP oath may be more accurately characterized as a political test, but at any rate it is certainly an oath-which in my view directly conflicts with the plain letter of the Constitution. Const 1963, art 11, § 1 is crystal clear-"[n]o other oath [or] affirmation ... shall be required as a qualification for any office or public trust." This appears to be absolute language. Because Const 1963, art 11, § 1 places an absolute ban on additional oaths or affirmations required as a qualification for office, it is analogous to an existing provision that "creates a mandatory requirement or uses language providing an exclusive power or authority because any change to such a provision would tend to negate the specifically conferred constitutional requirement." Protect Our Jobs , 492 Mich. at 783, 822 N.W.2d 534. Equally as important, Article 11, § 1 is unlike an existing provision "that uses nonexclusive or nonabsolute language" deemed "less likely to be rendered inoperative" in Protect Our Jobs . Protect Our Jobs , 492 Mich. at 783, 822 N.W.2d 534. Because the VNP proposal, which requires applicants to attest under oath regarding their political affiliation, appears to render the absolute language of Article 11, § 1"wholly inoperative," Protect Our Jobs , 492 Mich. at 773, 822 N.W.2d 534, it therefore constitutes an abrogation that is subject to the republication requirements of Const 1963, art 12, § 2 and MCL 168.482(3).11

**161V. CONCLUSION

The VNP proposal requires that applicants to the independent citizens redistricting commission attest under oath that they either affiliate or do not affiliate with one of the two major political parties. Because the proposal would abrogate the Oath Clause of Const 1963, art 11, § 1, which forbids requiring additional oaths or affirmations as a qualification for public office, VNP was required to republish that provision on its petitions, as required by Const 1963, art 12, § 2 and MCL 168.482(3). It is uncontested that VNP failed to do so. Because strict compliance with the republication requirement was required, an order of mandamus should issue directing the rejection of the VNP proposal.

Kurtis T. Wilder

Brian K. Zahra

I respectfully dissent from the majority's affirmance of the judgment of the Court of Appeals. The majority concludes that the proposal at issue, i.e., the Voters Not Politicians (VNP) proposal, is eligible for placement on the November 2018 election ballot by the initiative process of Const 1963, art 12, § 2. I dissent because I conclude that the proposal constitutes a "general revision" of the Constitution and thus is eligible for placement on the ballot only by the convention process of Const 1963, art 12, § 3.

I. INTRODUCTION

This case, I would emphasize, does not concern whether the VNP proposal is wise or unwise, prudent or imprudent. Nor does it concern whether the people of this state possess the ultimate authority to restructure the government of this state, for they indisputably do. Rather, it concerns only whether the VNP proposal is better understood as a constitutional "amendment," and thus eligible for placement on the ballot by the initiative process, or a "general revision" of the Constitution, and thus eligible for placement on the ballot only by the convention process.

**108The "people" have been referenced frequently during oral argument and by the majority opinion, as if merely to invoke their name compels the conclusion that the present measure must be placed on the ballot. However, the "people" wear many hats. The "people" invoke the initiative *279process, or at least 315,654 "people" do so; the "people" vote on the initiative process; "[w]e, the people" have ordained and established our Constitution, Const 1963, preamble; all political power is inherent in the "people," Const 1963, art 1, § 1 ; government is instituted for the equal benefit, security, and protection of the "people," id .; laws and ordinances issued under the Constitution define the rights and responsibilities of the "people"; and, of course, 13 "people," all randomly selected, are to sit on the commission established by the VNP proposal. After assessing the interests of the "people" in this matter, I believe that what is most significant is that these "people" have made it reasonably clear that the permanent things of their Constitution are not to be cast away lightly-that while ultimately the "people" do possess the authority to restructure their own charter of government, as to the most fundamentally redefining of these changes, this restructuring will be done only after the most reflective and deliberative processes of decision-making. And my further assessment persuades me that the "people" would find "fundamentally redefining" a restructuring of their Constitution that deprived them and their chosen representatives of any role in the foundational process of our system of self-government-the process by which election districts are established, citizens are joined together or separated by political boundaries, and the building blocks of our governing institutions are determined. Inserted in place is the governance of 13 randomly selected "people" entirely lacking in any democratic or electoral relationship with the other 10 **109million "people" of this state or their elected representatives. In the end, the "people" must be allowed to do as they see fit; they can diminish the realm of governance of their representatives (and substitute in its place an "independent" and unaccountable commission) and they can dilute the relationship between themselves and their representatives, but the "people," as I understand them to have spoken through their Constitution, have also insisted that, before a change of this magnitude takes place, a serious and considered public conversation must first take place, affording opportunities for sustained and focused debate, give-and-take, compromise, and modification.

Furthermore, references to the fact that the commission is to be "independent" obscures the fundamental change that the proposed measure would make to the "people's" Constitution as well; the great value of our Constitution is not the "independence" of public bodies but rather the separation of powers and the checks and balances that define relationships between public bodies and thereby limit and constrain their authority. While the VNP commission would indeed be "independent," most conspicuously, it would be "independent" of the people's representatives in the Legislature, independent of the people, and independent of the processes of self-government, especially the processes by which the "people"-in whose name both VNP and the majority purport to speak-exert their impact upon the "foundational" process of redistricting. Our constitutional heritage is poorly described by advocates of this proposal as one predicated upon the "independence" of public bodies; it is far better described as predicated upon the exercise of public authority that is limited, separated, subject to appropriate checks and balances, and accountable to the citizenry. The proposed new commission is grounded upon none of these. Whatever its **110merits, the creation of this commission would effect "fundamental" change upon both our constitutional charter and the system of government operating under this charter. It thus clearly warrants the kind of careful deliberation best afforded *280by the processes of constitutional "revision" set forth in Article 12, § 3 of this state's Constitution.

II. BACKGROUND

The people have reserved to themselves the authority to modify the Constitution by petition and popular vote. "This Court has consistently protected the right of the people to amend their Constitution in this way, while enforcing constitutional and statutory safeguards that the people placed on the exercise of that right." Protect Our Jobs v. Bd. of State Canvassers , 492 Mich. 763, 772, 822 N.W.2d 534 (2012). Indeed, a century ago, in Scott v. Secretary of State , 202 Mich. 629, 643, 168 N.W. 709 (1918), this Court stated:

Of the right of qualified voters of the State to propose amendments to the Constitution by petition it may be said, generally, that it can be interfered with neither by the legislature, the courts, nor the officers charged with any duty in the premises. But the right is to be exercised in a certain way and according to certain conditions , the limitations upon its exercise, like the reservation of the right itself, being found in the Constitution. [Emphasis added.]

In the instant case, we must decide whether the right is being exercised "in a certain way and according to certain conditions ... being found in the Constitution." Id .

Const 1963, art 12, § 2 addresses amendments of the Constitution through the initiative process and provides:

**111Amendments may be proposed to this constitution by petition of the registered electors of this state. Every petition shall include the full text of the proposed amendment, and be signed by registered electors of the state equal in number to at least 10 percent of the total vote cast for all candidates for governor at the last preceding general election at which a governor was elected. Such petitions shall be filed with the person authorized by law to receive the same at least 120 days before the election at which the proposed amendment is to be voted upon. Any such petition shall be in the form, and shall be signed and circulated in such manner, as prescribed by law. The person authorized by law to receive such petition shall upon its receipt determine, as provided by law, the validity and sufficiency of the signatures on the petition, and make an official announcement thereof at least 60 days prior to the election at which the proposed amendment is to be voted upon.

Any amendment proposed by such petition shall be submitted, not less than 120 days after it was filed, to the electors at the next general election. Such proposed amendment, existing provisions of the constitution which would be altered or abrogated thereby, and the question as it shall appear on the ballot shall be published in full as provided by law. Copies of such publication shall be posted in each polling place and furnished to news media as provided by law.

The ballot to be used in such election shall contain a statement of the purpose of the proposed amendment, expressed in not more than 100 words, exclusive of caption. Such statement of purpose and caption shall be prepared by the person authorized by law, and shall consist of a true and impartial statement of the purpose of the amendment in such language as shall create no prejudice for or against the proposed amendment.

If the proposed amendment is approved by a majority of the electors voting on the question, it shall become part of the constitution, and shall abrogate or amend existing provisions of the constitution at the end of 45 days after *281the date of the election at which it was approved. If two or **112more amendments approved by the electors at the same election conflict, that amendment receiving the highest affirmative vote shall prevail.

Const 1963, art 12, § 3 addresses general revisions of the Constitution through the convention process and provides:

At the general election to be held in the year 1978, and in each 16th year thereafter and at such times as may be provided by law, the question of a general revision of the constitution shall be submitted to the electors of the state. If a majority of the electors voting on the question decide in favor of a convention for such purpose, at an election to be held not later than six months after the proposal was certified as approved, the electors of each representative district as then organized shall elect one delegate and the electors of each senatorial district as then organized shall elect one delegate at a partisan election. The delegates so elected shall convene at the seat of government on the first Tuesday in October next succeeding such election or at an earlier date if provided by law.

The convention shall choose its own officers, determine the rules of its proceedings and judge the qualifications, elections and returns of its members. To fill a vacancy in the office of any delegate, the governor shall appoint a qualified resident of the same district who shall be a member of the same party as the delegate vacating the office. The convention shall have power to appoint such officers, employees and assistants as it deems necessary and to fix their compensation; to provide for the printing and distribution of its documents, journals and proceedings; to explain and disseminate information about the proposed constitution and to complete the business of the convention in an orderly manner. Each delegate shall receive for his services compensation provided by law.

No proposed constitution or amendment adopted by such convention shall be submitted to the electors for approval as hereinafter provided unless by the assent of a majority of all the delegates elected to and serving in the **113convention, with the names and vote of those voting entered in the journal. Any proposed constitution or amendments adopted by such convention shall be submitted to the qualified electors in the manner and at the time provided by such convention not less than 90 days after final adjournment of the convention. Upon the approval of such constitution or amendments by a majority of the qualified electors voting thereon the constitution or amendments shall take effect as provided by the convention.

This Court has long recognized that there is a rational distinction between an "amendment" and a "revision." Kelly v. Laing , 259 Mich. 212, 242 N.W. 891 (1932) ; Sch. Dist. of City of Pontiac v. City of Pontiac , 262 Mich. 338, 345, 247 N.W. 474 (1933). In Kelly , this Court addressed this distinction in the context of proposed changes to a municipality's home-rule charter. As we then explained:

Revision implies a re-examination of the whole law and a redraft without obligation to maintain the form, scheme, or structure of the old. As applied to fundamental law, such as a constitution or charter, it suggests a convention to examine the whole subject and to prepare and submit a new instrument, whether the desired changes from the old be few or many. Amendment implies continuance of the general plan and purport of the law, with corrections to better accomplish its purpose. Basically, revision suggests fundamental change, while amendment is a correction of detail .

*282[ Kelly , 259 Mich. at 217, 242 N.W. 891 (emphasis added).]

Furthermore:

An amendment is usually proposed by persons interested in a specific change and little concerned with its effect upon other provisions of the charter . The machinery of revision is in line with our historical and traditional system of changing fundamental law by convention , which experience has shown best adapted to make necessary readjustments. [ Id . at 221-222, 242 N.W. 891 (emphasis added).]

**114Finally, we held in Kelly that "[b]oth from the number of changes in the charter and the result upon the form of government , the proposal to abolish the office of city manager requires revision of the charter and must be had by the method the statute provides therefor." Id . at 223-224, 242 N.W. 891 (emphasis added).1

Subsequently, in Pontiac Sch. Dist. , 262 Mich. at 345, 247 N.W. 474, we held that a proposed amendment regarding property taxes constituted an amendment, rather than a revision, because it "does not so interfere with or modify the operation of governmental agencies as to render it other than an amendment by way of an addition to the Constitution." (Emphasis added.)2

**115Thereafter, in *283Citizens Protecting Michigan's Constitution v. Secretary of State , 280 Mich. App. 273, 305, 761 N.W.2d (2008) ( Citizens ), the Court of Appeals held that "in order to determine whether a proposal effects a 'general revision' of the constitution, and is therefore not subject to the initiative process established for amending the constitution, the Court must consider both the quantitative nature and the qualitative nature of the proposed changes ." (Emphasis added.) "More specifically, the determination depends on not only the number of proposed changes, or whether a wholly new constitution is being offered, but on the scope of the proposed changes and the degree to which those changes would interfere with, or **116modify, the operation of government ." Id . (emphasis added). The Court of Appeals ruled that the Reform Michigan Government Now! (RMGN) proposal constituted a general revision, id . at 307, 761 N.W.2d 210, and this Court affirmed in an order, Citizens Protecting Michigan's Constitution v. Secretary of State , 482 Mich. 960, 755 N.W.2d 157 (2008).3 **117Most recently, in *284Protect Our Jobs v. Bd. of State Canvassers , unpublished per curiam opinion of the Court of Appeals, issued August 27, 2012 (Docket No. 311828), 2012 WL 3660260, addressing whether a proposed amendment concerning collective bargaining rights was a general revision or an amendment, the Court of Appeals reasoned that the proposed initiative was an amendment because it "is limited to a single subject matter, and it only directly adds one section to the constitution and changes one other ...." Id . at 2. The panel further held that "[t]he initiative proposal here is far more akin to a correction of detail than a fundamental change , when viewed in the proper context of the constitution as a whole." Id . at 2-3 (emphasis added). On appeal, this Court affirmed, but on wholly different grounds dealing with the republication requirement. Protect Our Jobs , 492 Mich. 763, 822 N.W.2d 534.

III. STANDARDS

What I believe fairly can be derived from these decisions is that for at least the past 85 years in Michigan, governing law concerning direct constitutional change has been characterized by the following:

**118(a) alternative constitutional procedures exist for instituting such change and (b) determining which of these procedures is to be utilized in a particular instance requires an assessment of the "qualitative nature" of the proposed change-that is, the extent to which the proposal "[impacts] our form of government," entails "fundamental" change, or "would interfere with, or modify, the operation of government." While these standards have been phrased differently over time in judicial decisions, they are nonetheless consistent in supplying this common guidance.

While reasonable persons therefore may articulate these standards in slightly different ways, as indeed might the justices on this dissent, these standards are nonetheless consistent and compatible with each other, as well as with what is required by our Constitution, in distinguishing between the realms of the initiative and the convention. And while election disputes tend disproportionately to arise in the same circumstances as this case, this counsels in favor of greater rather than lesser deference to reasonably settled standards, while the majority purports to alter these standards. I say "purports" because, as discussed in further detail later, I do not believe that the majority's application of its standard in this case is actually all that different from these longstanding standards, only that the majority articulates its standard in a novel manner.

The Court of Appeals in the instant case purported to apply the standards set forth in Citizens and Protect Our Jobs . Citizens Protecting Michigan's Constitution v. Secretary of State , 324 Mich. App. 561, --- N.W.2d ----, 2018 WL 2746592 (2018) (Docket No. 343517) (CPMC ). The first question then concerns whether these decisions articulated the proper standard for determining whether a proposal constitutes an "amendment" or a "revision," and I **119believe that they do, although I would clarify several points. Most importantly, I believe that the ultimate judicial assessment depends most upon the qualitative nature of the proposed changes, i.e., whether these would "fundamentally" alter *285the nature or operation of our government. Although the quantitative nature of the proposed changes may sometimes also be relevant in this assessment, it is not determinative or even on an equal footing with the qualitative nature of the proposed changes. For example, if there were a proposal to modify all the references to "he" in the Constitution with "he or she," that would constitute a substantial quantitative change. However, it would not seemingly implicate anything fundamental in a qualitative sense, and therefore the proposal would almost certainly constitute an "amendment" rather than a "revision." On the other hand, if there were a proposal to transform the position of the governor into a lifetime appointment, although this would require relatively few textual modifications in the Constitution, such a change would be significant in a qualitative sense, and therefore the proposal would likely constitute a "revision" rather than an "amendment." Accordingly, I would clarify the focus of our caselaw to emphasize the qualitative impact of the proposed changes rather than the quantitative impact.

Similarly, I would clarify that while the sheer number of subjects to which a proposal pertains is also a relevant consideration, it is for the same reason as just observed pertaining to the sheer number of textual changes, not necessarily a dispositive consideration. For example, if there was a proposal to change our Legislature from bicameral to unicameral, although that would relate to a single subject, it would nonetheless constitute a fundamental change to the nature and operation of our government and therefore would constitute **120a "revision" rather than an "amendment."4 Article 12, § 2 of Michigan's 1963 Constitution requires the ballot to contain "a statement of the purpose of the proposed amendment ...." (Emphasis added.) Because "the" is a definite article and "purpose" is a singular noun, it seems reasonably clear that this phrase "statement of the purpose of the proposed amendment" likely contemplates a single purpose. See Robinson v. Detroit , 462 Mich. 439, 462, 613 N.W.2d 307 (2000). Therefore, if a proposal contains multiple purposes, it would not seem to constitute an amendment under Const 1963, art 12, § 2. However, this is not the only constitutional limitation on the meaning of an amendment.5 In other *286words, although a proposal that **121contains multiple purposes cannot be considered an amendment under Const 1963, art 12, § 2, a proposal that contains a single purpose is not necessarily an amendment under that same provision.

Article 12 of Michigan's Constitution sets forth two very different ways by which our Constitution can be directly modified.6 One way is by the amendment process set forth in Const 1963, art 12, § 2. This process requires the supporters of a proposed amendment to obtain a certain number of signatures from registered electors of the state in order for the proposal to be placed on the ballot, i.e., "10 percent of the total vote cast for all candidates for governor at the last preceding general election at which a governor was elected," and then once it is placed on the ballot, it requires "approv[al] by a majority of the electors voting on the question ...." Id . The other way the Constitution can be directly modified is by the revision process set forth in Const 1963, art 12, § 3. This process requires a majority of electors to vote in favor of a convention; it then requires electors to choose delegates; it then requires delegates to meet, deliberate, and propose new constitutional language; and finally, it requires a majority of qualified electors to support the new or modified constitutional language.

The latter obviously sets forth a lengthier and more deliberative process. It is a process by which issues can be thoroughly discussed and debated in a structured and sustained manner, and in which proposed language can be clarified and refined. It is also a process in which give-and-take among persons of disparate viewpoints **122can be pursued, proposals and counterproposals fleshed out, compromises undertaken, and risks to our historical form of government assessed and minimized. That is, it is a process considerably different from the amendment process in which voters, after a reasonably brief period of consideration (roughly 90 days in the present case), and after a very different type of public debate, must accept or reject the proposed amendment in whole. It makes sense that our Constitution would provide, and our Court would recognize, as both have for the past 85 years, that there are distinctions between "amendments" and "revisions" and that each process serves a distinctive need within our governmental and constitutional systems. The broader and the more fundamental the proposed changes, the more likely these would be of a character requiring the deliberativeness of the convention process; the more discrete and limited the proposed changes, the more likely these would be of a character requiring the expedition of the initiative process.7 *287**123For the reasons generally set forth in this opinion, I disagree with the majority that the standard set forth by our precedents over 85 years ago is not reasonably grounded in the text of the Constitution itself or that I myself "do[ ] not engage in a textual analysis of our Constitution[.]" Given that the people decided to incorporate two very different processes of modifying the Constitution, these differences must be given meaning, and one way by which to do this, in addition to assessing text and caselaw, is to examine the manifest purposes of these alternative processes in light of their respective strengths and weaknesses. Such an analysis makes reasonably clear that the people intended for broader and more fundamental changes to the Constitution to be accomplished by way of the general revision/convention process, while more narrow and discrete changes would be accomplished by way of the amendment/initiative process. This understanding is reinforced by the fact that when the people adopted the 1963 Constitution containing these alternative processes, Kelly and Pontiac Sch. Dist. had already been decided; therefore, the people already would have been apprised that this reflected the judicial understanding of the differences between the two processes. See People v. Nutt , 469 Mich. 565, 575, 677 N.W.2d 1 (2004) ("We conclude that, at the time of the ratification of our 1963 Constitution, the people of this state intended that the words 'same offense' be construed consistent with state and federal double jeopardy jurisprudence as it then existed."). In other words, this would have been the "common understanding" of the people at the time the 1963 Constitution was ratified. See **124Goldstone v. Bloomfield Twp. Pub. Library , 479 Mich. 554, 558, 737 N.W.2d 476 (2007) ("When interpreting constitutional provisions, our primary objective is to realize the intent of the people by whom and for whom the constitution was ratified. That is, we seek the 'common understanding' of the people at the time the constitution was ratified.") (quotation marks and citation omitted).

Furthermore, I do not believe that the majority's standard is any less "vague" than the standard set forth by our precedents over the course of 85 years. Indeed, I do not believe that the majority's standard, in particular its application of that standard, is very much different from the standard set forth by our precedents. This is especially true when one looks to the meaning that the majority ascribes to "changes that are tantamount to the creation of a new constitution."8 The majority *288articulates the standard in terms **125of whether the proposal "propose[s] changes that significantly alter or abolish the form or structure of our government in a way that is tantamount to creating a new constitution." Kelly , too, spoke of a revision in terms of creating "a new instrument," producing "fundamental change," and changing "the result upon the form of government ...." Kelly , 259 Mich. at 217, 223-224, 242 N.W. 891. Similarly, Pontiac Sch. Dist. spoke in terms of whether the proposal would "so interfere with or modify the operation of governmental agencies as to render it other than an amendment ...." Pontiac Sch. Dist. , 262 Mich. at 345, 247 N.W. 474.9

The majority, to its credit, does not hold that any changes short of a total rewrite of the Constitution can be considered an "amendment." Rather, the majority recognizes that an amendment is "limited to proposing less sweeping changes," and the majority focuses, just **126as I do, on the "qualitative" significance of the proposed changes to determine whether the changes would significantly alter our government, as the majority recognizes that "[a] constitution ... is more than words on a page," "[i]ts most basic functions are to create the form and structure of government, define and limit the powers of government, and provide for the protection of rights and liberties," and "[t]hese are the basic threads of a constitution, and when they are removed, replaced, or radically rewoven, the whole tapestry of the constitution may change." Well said!10 Indeed, in its application section, the majority considers, just as I do, the extent to which the VNP proposal would take power away from the three different branches of government, i.e., how the proposed changes would "affect *289the branches' relative powers," for example, "how the proposal would change the present Constitution with regard to the Legislature," whether "[t]he executive branch [would be] significantly affected by the proposal," and how "VNP's proposal [would] change[ ] the judicial branch's role in the redistricting process." In other words, although the majority and I reach very different conclusions, I do not believe that our tests are all that different; we engage in similar inquiries and consider in common whether the proposed changes would fundamentally alter our system of government.

To emphasize again, it is not that the people in Michigan, if they choose to do so, cannot radically restructure their government by the direct processes of constitutional change (subject, of course, to federal constitutional requirements, such as the obligation of **127states to preserve a "Republican [or representative] Form of Government," US Const, art IV, § 4 ), but merely that the most consequential of proposed changes require greater forethought and deliberation. This is a precondition for direct constitutional change prudently recognized 100 years ago-a century before today's "emergency" decision-when this Court observed that the process of direct change must be carried out "in a certain way and according to certain conditions ... found in the Constitution." Scott , 202 Mich. at 643, 168 N.W. 709.

IV. PRESENT CONSTITUTION

In order to determine whether the VNP proposal would fundamentally alter the nature or operation of our government and Constitution, we must obviously understand the manner in which these presently operate. We begin with what the Constitution, ratified in 1963, originally stated, although we have not operated under that system for the past 36 years. The Constitution as ratified in 1963 called for state legislative districts to be apportioned under a weighted formula based on land area and population. Const 1963, art 4, §§ 2 and 3. It also provided that senatorial districts should be "compact, convenient, and contiguous by land, [and] as rectangular in shape as possible ...." Const 1963, art 4, § 2 (2). In addition, house districts were to "consist of compact and convenient territory contiguous by land." Const 1963, art 4, § 3. It also established a commission on legislative apportionment "consisting of eight electors, four of whom shall be selected by the state organizations of each of the two political parties whose candidates for governor received the highest vote at the last general election at which a governor was elected preceding each apportionment."

**128Const 1963, art 4, § 6. And it provided that the commission should "receive compensation provided by law" and that the Legislature should "appropriate funds to enable the commission to carry out its activities." Id . With regard to this Court's involvement in redistricting, that Constitution also provided:

If a majority of the commission cannot agree on a plan, each member of the commission, individually or jointly with other members, may submit a proposed plan to the supreme court. The supreme court shall determine which plan complies most accurately with the constitutional requirements and shall direct that it be adopted by the commission and published as provided in this section.

Upon the application of any elector filed not later than 60 days after final publication of the plan, the supreme court, in the exercise of original jurisdiction, shall direct the secretary of state or the commission to perform their duties, may review any final plan adopted by the commission, and shall remand such plan to the commission for further action if it fails to comply with *290the requirements of this constitution. [Id .]

However, in Reynolds v. Sims , 377 U.S. 533, 577, 84 S.Ct. 1362, 12 L. Ed. 2d 506 (1964), the United States Supreme Court ruled that weighted land area/population formulas violated the Equal Protection Clause and that states must "make an honest and good faith effort to construct districts, in both houses of its legislature, as nearly of equal population as is practicable."11 In **129In re Apportionment of State Legislature-1982 , 413 Mich. 96, 116, 321 N.W.2d 565 (1982), this Court held that "[t]he weighted land area/population formulae, invalidated by Reynolds v. Sims ... and the remaining apportionment rules of art 4, §§ 2 - 6, are inextricably interdependent and therefore are not severable." "Similarly, the function of the commission, which depends on those rules, and indeed the commission itself, are not severable from the invalidated rules." Id . Accordingly, this Court struck down both the apportionment rules and the commission itself.12

Subsequently, the Legislature, in 1996, enacted guidelines for the redistricting of the Senate and **130House of Representatives, see MCL 4.261 et seq ., and, in 1999, it enacted the Congressional Redistricting Act, MCL 3.61 et seq . Thus, after the past two federal decennial censuses, redistricting has occurred without a commission, as the Legislature has decided the districts. The commission originally formulated in the 1963 Michigan Constitution has not been active since 1972, and it has in no way been a part of that Constitution since 1982.13 *291MCL 4.261 grants the Legislature the authority to enact a redistricting plan and sets forth the guidelines that it must follow. This Court has original and exclusive jurisdiction to hear and decide all cases or controversies involving a redistricting plan. MCL 4.262(1). This Court has the authority to modify the plan or remand the plan to a special master for further action if the plan fails to comply with the statutory requirements. MCL 4.262(3). If the Legislature fails to enact a redistricting plan before the deadline, this Court has the authority to create a redistricting plan. MCL 4.263. To summarize, the redistricting commission created by the 1963 Constitution was shortly thereafter struck down and in its place the people, through their elected representatives, restored the power to redistrict back to the Legislature.14 **131V. VNP PROPOSAL

The VNP proposal would strike all that is currently in the Constitution regarding redistricting and in Article 4, § 6 would create an "independent citizens redistricting commission."15 Article 4, § 6(1) would provide **132that the commission shall consist of 13 commissioners, each of whom would have to complete an application and attest under oath that he or she does or does not affiliate with one of the two major political *292parties. VNP proposal, art 4, § 6(2)(A)(III). Each commissioner would also have to:

(B) not currently be or in the past 6 years have been any of the following:

(I) a declared candidate for partisan federal, state, or local office;

(II) an elected official to partisan federal, state, or local office;

(III) an officer or member of the governing body of a national, state, or local political party;

(IV) a paid consultant or employee of a federal, state, or local elected official or political candidate, of a federal, state, or local political candidate's campaign, or of a political action committee;

(V) an employee of the Legislature;

(VI) any person who is registered as a lobbyist agent with the Michigan bureau of elections, or any employee of such person; or

(VII) an unclassified state employee who is exempt from classification in state civil service pursuant to article XI, Section 5, except for employees of courts of record, employees of the state institutions of higher education, and persons in the armed forces of the state.

(C) not be a parent, stepparent, child, stepchild, or spouse of any individual disqualified under part (1)(B) of this section[.] [VNP proposal, art 4, § 6(1).]

In addition, "for five years after the date of appointment, a commissioner [would be] ineligible to hold a partisan elective office at the state, county, city, village, or township level in Michigan." VNP proposal, art 4, § 6(1)(E).

**133The Secretary of State would have to make applications available to the general public and mail these to 10,000 registered voters "selected at random." VNP proposal, art 4, § 6(2)(A)(I). The Secretary of State would then have to "randomly" select 60 applicants for each pool of affiliating applicants and 80 applicants from the pool of nonaffiliating applicants and submit these names to the majority and minority leaders of the Senate and the Speaker of the House of Representatives and the minority leader of the House of Representatives.16 VNP proposal, art 4, § 6(2)(D). They would be able to each strike five applicants from any pool or pools, up to a maximum of 20 total strikes by the four legislative leaders. VNP proposal, art 4, § 6(2)(E). The Secretary of State would then randomly draw the names of four commissioners from each of the two pools of remaining applicants affiliating with a major party and five commissioners from the pool of remaining nonaffiliating applicants. VNP proposal, art 4, § 6(2)(F).

Article 4, § 6(5) would provide that "the Legislature shall appropriate funds sufficient to compensate the commissioners and to enable the commission to carry out its functions, operations and activities" and that "the state of Michigan shall indemnify commissioners for costs incurred if the Legislature does not appropriate sufficient funds to cover such costs." Article 4, § 6(6)

**134would provide that "the commission shall have legal standing to prosecute an action *293regarding the adequacy of resources provided for the operation of the commission ...."

Article 4, § 6(13) would provide:

The commission shall abide by the following criteria in proposing and adopting each plan, in order of priority:

(A) Districts shall be of equal population as mandated by the United States Constitution, and shall comply with the voting rights act and other federal laws.

(B) Districts shall be geographically contiguous. Island areas are considered to be contiguous by land to the county of which they are a part.

(C) Districts shall reflect the state's diverse population and communities of interest. Communities of interest may include, but shall not be limited to, populations that share cultural or historical characteristics or economic interests. Communities of interest do not include relationships with political parties, incumbents, or political candidates.

(D) Districts shall not provide a disproportionate advantage to any political party. A disproportionate advantage to a political party shall be determined using accepted measures of partisan fairness.

(E) Districts shall not favor or disfavor an incumbent elected official or a candidate.

(F) Districts shall reflect consideration of county, city, and township boundaries.

(G) Districts shall be reasonably compact.

"A final decision of the commission to adopt a redistricting plan [would] require[ ] a majority vote of the commission, including at least two commissioners who affiliate with each major party, and at least two commissioners who do not affiliate with either major party." VNP proposal, art 4, § 6(14)(C).

Article 4, § 6(19) would provide:

**135The Supreme Court, in the exercise of original jurisdiction, shall direct the Secretary of State or the commission to perform their respective duties, may review a challenge to any plan adopted by the commission, and shall remand a plan to the commission for further action if the plan fails to comply with the requirements of this Constitution, the Constitution of the United States or superseding federal law. In no event shall any body, except the independent citizens redistricting commission acting pursuant to this section, promulgate and adopt a redistricting plan or plans for this state.

Article 4, § 6(22) would provide that "the powers granted to the commission are legislative functions not subject to the control or approval of the Legislature, and are exclusively reserved to the commission."

VI. APPLICATION

To begin with, the Court of Appeals (and now the majority) err in assessing the nature of the change that would be effected by the VNP proposal by comparing the commission to be established by VNP with the commission created by the 1963 Constitution but thereafter struck down. In short, by the time of the Court of Appeals' asserted comparison, the commission created by the 1963 Constitution had not been a part of that Constitution for 36 years and had not actually been used to establish a districting plan for 46 years.17

**136The Legislature *294has been in charge of redistricting since at least 1996. Therefore, the pertinent question is not whether replacing the commission created by the 1963 Constitution with the VNP commission would fundamentally change the operation of government, but whether removing the power to redistrict from the Legislature and conferring that power in the VNP commission would fundamentally change the operation of government. We are obligated to consider how the government is currently operating in order to make the necessary comparison, not how the government might once have operated. And it currently operates (as it has almost always operated in the history of our state) with the Legislature responsible for redistricting.18 **137As this Court has recognized, "[e]lection redistricting is principally a legislative function," LeRoux v. Secretary of State , 465 Mich. 594, 619, 640 N.W.2d 849 (2002), redistricting "goes to the heart of the political process in a constitutional democracy," In re Apportionment of State Legislature-1982 , 413 Mich. at 136, 321 N.W.2d 565, and "[a]ny change in the means by which the members of the Legislature are chosen is a fundamental matter," id . at 136-137, 321 N.W.2d 565 (emphasis added). Indeed, one of RMGN's proposed changes would have removed from the Legislature its authority over redistricting, resituated this authority in a redistricting commission within the executive branch, and removed the procedure for judicial review of redistricting. The Court of Appeals concluded that such a proposal "affects the 'foundation power' of government by 'wresting from' the legislative branch and the judicial branch any authority over redistricting and consolidating that power in the executive branch, albeit in a new independent agency with plenary authority over redistricting." Citizens , 280 Mich. App. at 306, 761 N.W.2d 210. *295The same is true in the present case. The VNP proposal would affect the "foundation" power of government by removing altogether from the legislative branch authority over redistricting and consolidating that power instead in an "independent" commission made up of 13 randomly selected individuals who are not in any way chosen by the people, representative of the people, or accountable to the people .19 This, in my **138judgment, reflects a fundamental alteration in the relationship between the people and their representatives. Instead of 10 million Michigan citizens possessing some measure of influence over the system by which election districts are established in this state and citizens joined together or separated by political boundaries and the building blocks of our governing institutions determined, the VNP proposal would substitute the decision-making of 13 randomly selected citizens. And instead of the democratically elected representatives of these 10 million people having a constitutional role in this same process, the VNP proposal would substitute the decision-making of these self-same randomly selected citizens. And thus instead of this "foundation" power of redistricting being carried out by traditional institutions of American self-government, it will instead be carried out by an "independent" **139commission, utterly removed from the processes of self-government.

Furthermore, although this commission would nominally be placed within Article 4, describing the legislative branch of government, and invested with the legislative power of redistricting, it would nonetheless be "independent" from the Legislature. See VNP proposal, art 4, § 6(22) ("[T]he powers granted to the commission are legislative functions not subject to the control or approval of the Legislature, and are exclusively reserved to the commission."). For that reason, it is incumbent that VNP redefines, as it does, the threshold description of the "legislative power" in Article 4, § 1. That language now reads, "The legislative power of the State of Michigan is vested in a senate and a house of representatives." It would be modified to read, "Except to the extent limited or abrogated by [the VNP proposal], the legislative power of the State of Michigan is vested in a senate and a house of representatives." (Emphasis added.) This is a change occasioned by the fact that one of the Constitution's three separated powers, the "legislative power," would be exercised by a body that is neither the "senate" nor the "house *296of representatives," but an "independent" commission. While this new language might avoid what would otherwise be an unconstitutional exercise of authority by the commission, that is only because such language alters the Constitution's fundamental expression of the legislative power.

Indeed, the proposal goes on to introduce the same prefatory language in Articles 5 and 6 of the Constitution, addressing respectively the executive and judicial powers of the Constitution,20 each of which hitherto **140has remained essentially unchanged since our state's first constitution in 1835. All of which merely underscores that the impact of these changes is quite "fundamental." While it is reasonably clear that the new prefatory language set forth in Article 6 is designed to communicate that current understandings of the "judicial power" are somehow to be altered, at a minimum by striking the present authority of the judiciary to initiate redistricting plans where necessary,21 it is less clear why the prefatory language set forth in Article 5 is similarly required, although it must be presumed that this is because alterations in the exercise of the executive power are also contemplated, possibly in the extent of its ability to exercise its present veto authority22 or its **141general supervisory authorities over the so-called administrative branch of government. I do not know exactly what was in the mind of the drafters of the VNP proposal in these regards, but we soon will doubtlessly be apprised of this in the course of litigation seeking to make clear how truly "independent" the VNP commission is of all checks and balances, and restraints, of the sort imposed upon every other institution of government. Whereas descriptions of the administrative state as a "fourth branch" may heretofore have been exaggerated, it is difficult to survey the express authorities and the constitutional placement of the VNP commission and not conclude that it is designed to be an "independent" body of a genuinely unique character.

In sum, Article 4, § 1, Article 5, § 1, and Article 6, § 1, the foundational articles of our system of separated powers, have each *297been modified in recognition of the authority bequeathed upon the new commission. While lawyers, scholars, and public officials may now be increasingly engaged in reconsidering the proper expanse of the administrative state-its impact upon our three branches, understandings of governmental accountability to the citizenry, and the rule of law, Michigan now embarks upon the establishment of a super-administrative, or "independent," commission to carry out the foundational role of self-government. This measure is precisely of a kind that warrants the reflection, deliberation, and consensus decision-making of the convention processes of Const 1963, art 12, § 3.23 **142What these three "[e]xcept to the extent limited or abrogated by" provisions most of all suggest is that the commission itself is an entirely novel institution that would fundamentally breach our Constitution's separation of powers, see Const 1963, art 3, § 2 ("The powers of government are divided into three branches; legislative, executive and judicial. No person exercising powers of one branch shall exercise powers properly belonging to another branch except as expressly provided in this constitution."), but for the addition of these three provisions. Why would it be necessary to expressly redefine the wielder of each of our Constitution's three separated powers unless the VNP proposal was thought to implicate each of these?24 Yet, *298to the **143extent that the commission would , in fact, wield these combined powers, it would not only be a unique constitutional institution, but in express breach of Const 1963, art 3, § 2, one of the several constitutional provisions not republished by VNP proponents. See note 27 of this opinion. Thus, this VNP commission would be as close to representing a "fourth branch" of government as any within our Constitution-an "independent" body certainly, but more relevantly for purposes of constitutional analysis, an "unaccountable" body.25 The present issue, once again, is not the wisdom of the changes being made by the VNP proposal, but whether these changes are fundamental . I believe that they are, even by the most rigorous understanding of what is and is not "fundamental" to our constitutional system of governance.26 **144VII. CONCLUSION

For these reasons, I conclude that the VNP proposal, if adopted, would fundamentally change the operation of our government and, as a result, it is not an "amendment" that can be properly placed on the ballot by the initiative process under Const 1963, art 12, § 2, but rather a general "revision" that requires resort to the convention process under Const 1963, art 12, § 3.27

**145It is precisely the kind of *299"alteration of first governing principles" proposal that requires the opportunities for debate, modification, give-and-take, and compromise that are only available in the convention process. It is not the kind of proposal that the electorate should be required to "take or leave" as they cast their votes over the course of the next 90 days after digesting a "100-word or less" summary. That is, it is not the kind of proposal under our Constitution that is appropriate for the "amendment" process. Therefore, I respectfully dissent from this Court's decision to affirm the judgment of the Court of Appeals.

Stephen J. Markman

Brian K. Zahra

Kurtis T. Wilder