concurring and dissenting.
I agree with the Majority’s conclusion that the plain language of Section 17.1 of the First Class City Home Rule Act (“Home Rule Act”), 53 P.S. § 13131.1, eliminated the right of Philadelphia taxpayers, absent aggrievement, to appeal zoning decisions impacting facilities or locale in Philadelphia, which had previously been granted by Section 14-807(1) of the Philadelphia Code. Nevertheless, I would not find this ruling dispositive of this case because I believe that House Bill No. 1954, which amended Section 17.1 of the Home Rule Act, violated the single subject rule of Article III, Section 3, of the Pennsylvania Constitution.
As the Majority recognizes, Article III, Section 3, sets forth a dual mandate for the General Assembly, precluding the passage of a bill that contains more than one subject, and requiring that such subject be clearly expressed in the bill’s title. Pennsylvanians Against Gambling Expansion Fund v. Commonwealth (“PAGE”), 583 Pa. 275, 877 A.2d 383, 394 (2005).1,2 The general aim of this constitutional provision is to “place restraints on the legislative process and encourage an open, deliberative, and accountable government.” Id. at 395 (citations omitted). More specifically, Article III, Section 3, was adopted “to curb the practice of inserting into a single bill a number of distinct and independent subjects of legislation and purposefully hiding the real purpose of the bill.” Id. at 395. Related thereto, the single subject requirement prohibits *119the attachment of riders that could not become law on their own to popular legislation, and ensures more considered review of proposed legislation by lawmakers. Id. Thus, in accord with the constitutional language and the goals it furthers, we have held that the various provisions of legislation must assist in carrying out the bill’s main objective or be otherwise “germane” to the bill’s principal subject to pass constitutional muster. Id. (citing City of Philadelphia v. Commonwealth, 575 Pa. 542, 838 A.2d 566, 587 (2003)).
Application of the germaneness test to real-life scenarios, however, has proven to be difficult, as the restrictions set forth in Article III, Section 3, do not lend themselves to a bright-line rule. This Court has recently acknowledged that interpretations of this constitutional provision have historically fluctuated from fairly strict constructions, which constrain the Legislature by striking as unconstitutional presumably multisubject legislation, to more liberal interpretations, which afford deference to the Legislature’s bill-drafting procedures. See City of Philadelphia, 838 A.2d at 587.
For example, in Commonwealth ex rel. Woodruff v. Humphrey, 288 Pa. 280, 136 A. 213, 217 (1927), this Court applied somewhat of a strict constructionist approach and viewed a bill that regulated land surveyors and professional engineers as containing two separate subjects. We rejected the contention that the legislation addressed the single subject of the regulation of the engineering profession, which would encompass land surveyors as a minor branch thereof. Instead, the Court relied on the legislation’s repeated reference to the profession of engineering “or” land surveying, thus conveying the idea of two separate professions, which indicates two separate subjects of the bill.
Similarly, in Yardley Mills Co. v. Bogardus, 321 Pa. 581, 185 A. 218 (1936), this Court examined legislation which contained three provisions, which: (1) relieved water canal companies of the obligation to maintain waterways obtained from the Commonwealth; (2) granted such companies the right to sell the water from these waterways for commercial purposes; and (3) authorized the Commonwealth to acquire water canal lands by *120gift, and to sell portions of them. Notwithstanding that all of the provisions pertained to the subject of water canals, we held that the various provisions were not sufficiently germane to one another to survive scrutiny under the single subject test. Id. at 221.
Conversely, in Fumo v. Public Util. Comm’n, 719 A.2d 10 (Pa.Cmwlth.1998), the Commonwealth Court applied the germaneness test and upheld a bill which addressed the number of years that a taxicab could be operated and the deregulation of electricity generation. Allegedly affording deference, the court found that the statute did not violate Article III, Section 3’s single subject requirement, reasoning that both topics involved aspects of public utility regulation and amendments to the Public Utility Code. Id. at 14.
Similarly, in City of Philadelphia v. Schweiker, 817 A.2d 1217 (Pa.Cmwlth.2003), the Commonwealth Court upheld legislation which: (1) authorized the Governor, rather than the Mayor, to appoint members of the Philadelphia Parking Authority; and (2) required the Municipal Authority to transfer enumerated funds to the Philadelphia School District. Notwithstanding the disparate nature of the provisions, the Commonwealth Court held that the bill at issue did not violate Article III, Section 3, because municipalities and parking authorities are “inextricably intertwined,” and that the overall subject of the legislation was “authorities that benefit municipalities.” Id. at 1225.3
While I am confident that the General Assembly can perform its legislative function under either a strict or liberal construction paradigm, it clearly has the right to know the standard under which it is required to operate. As this case presents an opportunity for this Court to juxtapose two recent pronouncements, City of Philadelphia and PAGE, on this important constitutional issue and to reconcile them, I offer *121my views as to why this case falls under the holding of the former, and is thus unconstitutional, as opposed to the Majority’s conclusion that it is controlled by the latter, and is therefore constitutional.
In City of Philadelphia, the bill at issue amended Title 53 (Municipal Corporations) of the Pennsylvania Consolidated Statutes by, inter alia, modifying local governance and related administrative matters; altering the size and composition of the Pennsylvania Convention Center’s governing board; repealing a portion of the Pennsylvania Intergovernmental Cooperation Authority for Cities of the First Class; and adding to Title 53 a new “Chapter 58,” entitled “Contractor Bonds and Financial Security for Redevelopment Contracts.” Id. at 571. In response to a challenge that the legislation violated the single subject requirement of Article III, Section 3, the Commonwealth parties maintained that all of the provisions of the bill related to the single subject of “municipalities.”
Our Court rejected this contention, holding that the vast subject of “municipalities” encompassed virtually all matters of local government, and was too broad to qualify for single-subject status under Article III, Section 3. Id. at 589. Finding the object of the bill to be an omnibus amendment of Title 53 of the Pennsylvania Consolidated Statutes, we concluded that there was no single unifying subject to which all of the provisions of the act were germane. Id. While recognizing that it was appropriate, to some degree, under a “deference standard” to hypothesize reasonably broad topics of legislation in evaluating Article III, Section 3 challenges, we stated, “[tjhere must be limits, however, as otherwise virtually all legislation, no matter how diverse in substance, would meet the single-subject requirement.” Id. at 588.
We cautioned that, absent such limitation, “Section 3 would be rendered impotent to guard against the evils that it was designed to curtail.” Id. Significant to the instant case, this Court expressly discounted the constitutional significance of the fact that all of the provisions of the challenged statute were ultimately codified within Title 53. Id. at 590. Specifically, we stated:
*122Finally, that all of the statute’s provisions are ultimately codified within Title 53 is of little constitutional importance. Cf. DeWeese [v. Weaver, 824 A.2d 364,] 370 [(Pa.Cmwlth. 2003)] (“The fact that the changes in substantive law ... were set forth as amendments to the Judicial Code does not, in and of itself, satisfy the requirements of Article III, Section 3.”).
City of Philadelphia, 838 A.2d at 590.
While I was not a member of the Court when City of Philadelphia was decided, I am bound by the decision and, in any event, agree with its sound reasoning.
Two years later, after I joined the Court, we again examined Article III, Section 3, in a unanimous opinion in PAGE. PAGE involved legislation that authorized the Pennsylvania State Police to aid the State Harness and Horse Racing Commissions by performing criminal history checks and verifying fingerprints of applicants for licensure under the Race Horse Industry Reform Act of 1981. The bill was extensively amended, and, in its final form, created the Pennsylvania Gaming Control Board; addressed the issuance of gambling licenses authorizing the creation of slot machine casinos; dealt with the generation and distribution of revenues from the licenses and the creation of numerous funds; and provided for administration and enforcement of the legislation, placing in our Court exclusive jurisdiction over enumerated gaming appeals.
We upheld the statute against a challenge based on Article III, Section 3, finding that the single unifying subject of most provisions of the bill at issue was the regulation of gaming.4 Thus, we concluded that this complex piece of legislation passed constitutional muster because the provisions therein logically related to the single subject of gaming. We distinguished City of Philadelphia, noting “[t]he single topic of gaming does not encompass the limitless number of subjects *123which could be encompassed under the heading of ‘municipalities.’ ” Id., at 396.
I find City of Philadelphia and PAGE to be in harmony with one another because the purported subjects of the bills at issue are distinguishable in their scope. As noted above, the different subjects covered in City of Philadelphia were simply too disparate. Conversely, the legislation at issue in PAGE, regardless of the bill’s length or complexity, involved the single issue of gaming (except for those few provisions that this Court properly struck for lack of germaneness).
In the matter before us, the Legislature passed a simple and understandable bill. In its first section, the bill increased fines and forfeitures for violations of the Philadelphia Code. In the second provision of the bill, it eliminated taxpayer standing in Philadelphia zoning cases. In applicable part, the question before us is whether these two provisions are germane to each other; in other words, whether these two provisions are legitimately tied to a single subject. I am compelled, in good faith, to answer “no” because I find that the subject of “amendment to the Home Rule Act” or “Philadelphia government” is more akin to the constitutionally infirm subject of “municipalities” in City of Philadelphia, than the cohesive subject of “gaming” present in PAGE.
I fully recognize that this Court should not strike a legislative enactment unless it clearly, plainly and palpably violates the Constitution. DePaul v. Pennsylvania Gaming Control Board, 969 A.2d 536, 545 (Pa.2009). However, I hearken back to the sage wisdom of City of Philadelphia, which warned that acceptance of “municipalities,” and here, “Philadelphia home rule government” as constitutionally authorized single subjects would stretch the constitutional safeguards beyond recognition, and relegate the constitutional protection to little more than rhetoric. See City of Philadelphia, 838 A.2d at 588, citing, Payne v. School Distr. of Borough of Coudersport, 168 Pa. 386, 31 A. 1072, 1074 (1895) (per curiam) (indicating that “no two subjects are so wide apart that they may not be brought into a common focus, if the point of view be carried back far enough”).
*124For these reasons, I would clarify for the Pennsylvania Legislature that both City of Philadelphia and PAGE were correctly decided, and that the statute under scrutiny herein falls under the precedent established in City of Philadelphia, and consistent therewith should be stricken as unconstitutional.
. Article III, Section 3 of the Pennsylvania Constitution provides:
No bill shall be passed containing more than one subject, which shall be clearly expressed in its title, except a general appropriation bill or a bill codifying or compiling the law or a part thereof.
PA. CONST. Art. 3, § 3.
. The Majority correctly notes that any challenge to the clearly expressed title requirement of Article III, Section 3, was waived, as it was not preserved before the trial court. Majority Op. at 109 n. 9, 977 A.2d at 1147 n. 9. Thus, this opinion addresses only the single subject provision of Article III, Section 3.
. In recognition of this trend, this Court expressed concern that this application of Article III, Section 3, "has resulted in a situation where germaneness has, in effect, been diluted to the point where it has been assessed according to whether the court can fashion a single, overarching topic to loosely relate the various subjects included in the statute under review." City of Philadelphia, 838 A.2d at 587.
. In PAGE, a few provisions of the bill addressing funding issues were found to violate the single subject rule, while the clear majority of the provisions were upheld.