concurring in the result in part and dissenting in part.
I.
I respectfully dissent from Section IV of the majority opinion. I believe the Governor acted within the Governor’s constitutional authority in allocating monies from the Trust Fund to be used for General Fund expenditures in order to avoid a budget deficit. I concur in the result for the remainder of the majority opinion. I would fully affirm the ruling of the trial court.
Questions of constitutional construction are in the main governed by the same general principles which control in ascertaining the meaning of all written instruments, and “the fundamental principle of constitutional construction is to give effect to the intent of the framers of the organic law and of the people adopting it[.]” The heart of the law is the intention of the lawmaking body. And in arriving at the intent, we are not required to accord the language used an unnecessarily literal meaning. Greater regard is to be given to the dominant purpose than to the use of any particular words, for “the letter of the law is its body; the spirit, its soul; and the construction of the former should never be so rigid and technical as to destroy the latter.” “The letter killeth, but the spirit giveth life.”
Perry v. Stancil, 237 N.C. 442, 444, 75 S.E.2d 512, 514 (1953) (internal citations omitted). The intent of the General Assembly, when drafting a constitutional amendment, unlike drafting a statute, is but a part of the intent analysis. We must also consider the intent of the voters of North Carolina who ratified the amendment. State ex rel. Martin v. *638Preston, 325 N.C. 438, 449, 385 S.E.2d 473, 478 (1989); Stancil, 237 N.C. at 444, 75 S.E.2d at 514.
The will of the people as expressed in the Constitution is the supreme law of the land. In searching for this will or intent all cognate provisions are to be brought into view in their entirety and so interpreted as to effectuate the manifest purposes of the instrument. The best way to ascertain the meaning of a word or sentence in the Constitution is to read it contextually and to compare it with other words and sentences with which it stands connected.
Preston, 325 N.C. at 449, 385 S.E.2d at 478 (quoting State v. Emery, 224 N.C. 581, 583, 31 S.E.2d 858, 860 (1944)). “[Reconciliation is a fundamental goal... in constitutional. . . interpretation[.]” Sessions v. Columbus County, 214 N.C. 634, 638, 200 S.E. 418, 420 (1939).
The majority contends that “ ‘effect the necessary economies’ is an ambiguous term, requiring judicial construction” and the “dispositive issue ... is determining the meaning of the phrase ‘effect the necessary economies’ as contained in N.C. Const, art. Ill, § 5(3), and how this was accomplished by the transfer of $80,000,000 from the Trust Fund to the General Fund.” However, I disagree that when Article III, Section (5) (3) is read as a whole, and in pari materia with the other provisions of our Constitution, Preston, 325 N.C. at 449, 385 S.E.2d at 478, the meaning of “effect the necessary economies” is ambiguous. Additionally, the ultimate intent and purpose behind the amendment to Article III, Section 5(3) is more important in construing that constitutional provision than interpreting its precise wording. Stancil, 237 N.C. 442, 444, 75 S.E.2d 512, 514. Article III, Section 5(3) states in relevant part: *639N.C. Const, art. Ill, § 5(3). I would hold that the clear intent of the amendment to Article III, Section 5(3) is to grant the Governor broad discretion and powers to ensure that a budget, as enacted by the General Assembly, will not lead the State into a deficit. Because Article III, Section 5(3) mandates that the Governor has responsibility for: (1) executing the budget, (2) continually monitoring the budget to identify potential budgetary shortfalls, and (3) effecting the necessary economies in order to prevent a deficit, the Governor has the authority and duty to reallocate funds within the current budget, without the consent or approval of the General Assembly, in order to prevent any projected deficit.
*638The total expenditures of the State for the fiscal period covered by the budget shall not exceed the total of receipts during that fiscal period and the surplus remaining in the State Treasury at the beginning of the period. To insure that the State does not incur a deficit for any fiscal period, the Governor shall continually survey the collection of the revenue and shall effect the necessary economies in State expenditures, after first making adequate provision for the prompt payment of the principal of and interest on bonds and notes of the State according to their terms, whenever he determines that receipts during the fiscal period, when added to any surplus remaining in the State Treasury at the beginning of the period, will not be sufficient to meet budgeted expenditures.
*639The majority argues: “In order for the Governor to exercise his powers to ‘effect the necessary economies,’ he must survey revenue collections to avoid a deficit in the State Budget[.]” The relevancy of focusing on the definition of “deficit” in the majority opinion is unclear, as there has been no argument made on appeal that the State was not facing a deficit. However, from the language of Article III, Section 5(3), the Governor must, in a practical sense, predict whether the “receipts during the fiscal period, when added to any surplus remaining in the State Treasury at the beginning of the period, will not be sufficient to meet budgetary expenditures.” Article III, Section 5(3) vests the power and the duty to make this determination with the Governor. It is the Governor’s determination that the State is facing a potential budget deficit that triggers the Governor’s authority to “effect the necessary economies” to avoid the anticipated deficit.
Were the Governor to wait until after the State incurred a deficit, which would be a certain means of identifying an actual budget crisis, the Governor would violate the mandate of Article III, Section 5(3)— the prevention of a deficit, not the correction of an existing deficit.4
II.
• The majority seems to determine that the Governor, by directing the transfer of $80,000,000.00 from the Trust Fund to the General Fund, violated the separation of powers doctrine because the sole power to direct transfer of funds from the Trust Fund to the General Fund lies with the General Assembly. While I agree that the determi*640nation of this issue is inextricably intertwined with the separation of powers doctrine, my review of the case law, legislative history, and constitutional history cited by the majority leads me to reach a different result.
As our Supreme Court stated in Advisory Opinion In Re Separation of Powers, 305 N.C. 767, 773, 295 S.E.2d 589, 592 (1982): “ ‘Separation of Powers. The legislative, executive, and supreme judicial powers of the State government shall be forever separate and distinct from each other.’ ” In Re Separation of Powers, 305 N.C. at 773, 295 S.E.2d at 592 (citing N.C. Const. art. I, § 6). “[E]ach of our constitutions [has] explicitly embraced the doctrine of separation of powers.” State ex rel. Wallace v. Bone, 304 N.C. 591, 595, 286 S.E.2d 79, 81 (1982) (footnote omitted).
The majority correctly states that the powers of the Governor in relation to the state budget are “ ‘preparing and recommending the state budget to the General Assembly and then for administering it after enactment].]’ ” (Citation omitted). In relation to the state budget, the constitutional power of the General Assembly is to enact the state budget. “[0]ur Constitution vests in the General Assembly the power to enact a budget — to appropriate funds — but after that is done, Article III, Section 5(3) explicitly provides that ‘the Governor shall administer the budget as enacted by the General Assembly.’ ” In re Separation of Powers, 305 N.C. at 780, 295 S.E.2d at 596. “It is clear that the framers of our Constitution followed the instructions given to them that our government ‘shall be divided into three branches distinct from each other, viz:
The power of making laws
The power of executing laws and
The power of Judging.’ ”
Id. at 774, 295 S.E.2d at 593 (citation omitted). Our Supreme Court quoted a portion of Article III, Section 5(3) to emphasize its point:
The Governor shall prepare and recommend to the General Assembly a comprehensive budget of the anticipated revenue and proposed expenditures of the State for the ensuing fiscal period. The budget as enacted by the General Assembly shall be administered by the Governor.
Id. (emphasis added by our Supreme Court). “Consistent with Section 5(3) of Article III of the Constitution, . . . G.S. 143-2 designates the *641Governor as ex officio Director of the Budget.” Id. at 776, 295 S.E.2d at 594.
In re Separation of Powers was an advisory opinion issued by our Supreme Court to determine whether certain statutes enacted by the General Assembly were constitutional. The first issue concerned a statute, N.C. Gen. Stat. § 143-23(b), which attempted to give the “Joint Legislative Commission on Governmental Operations” the power to veto certain transfers or changes “from a program line item” of the then current budget. The Joint Legislative Commission on Governmental Operations was comprised primarily of elected members of the General Assembly. Id.
Obviously, the intended effect of G.S. 143-23(b) ... is to give to a 13-member commission composed of 12 members of the House and Senate, and the President of the Senate who is usually the Lieutenant Governor, power to control major budget transfers proposed to be made by the Governor in his constitutional role as administrator of the budget.
Id. Our Supreme Court rendered its opinion that
the power that G.S. 143-23(b) purports to vest in certain members of the legislative branch of our government exceeds that given to the legislative branch by Article II of the Constitution. The statute also constitutes an encroachment upon the duty and responsibility imposed upon the Governor by Article III, Section 5(3), and, thereby violates the principle of separation of governmental powers.
Id. at 776-77, 295 S.E.2d at 594. I do not find support in In re Separation of Powers for the majority’s holding that the General Assembly must be a partner with the Governor when the Governor is administering the state budget as mandated by Article III, Section 5(3). Instead, In re Separation of Powers seems to hold the opposite. In re separation of Powers holds that N.C. Gen. Stat. § 143-23(b), which seeks to give “power to control major budget transfers proposed to be made by the Governor in his constitutional role as administrator of the budget” to a commission made up of members of the General Assembly, “constitutes an encroachment upon the duty and responsibility imposed upon the Governor by Article III, Section 5(3), and, thereby violates the principle of separation of governmental powers.” Id.
*642III.
The majority further states that Article III, Section 5(3) “equates with article V, section 7 and article III, section 5(4) of this State’s Constitution.” As stated -by the majority: “Article III, section 5(4) requires that the Governor take care that the laws be faithfully executed. The Governor as head of the executive department is charged with the duty of seeing that legislative acts are carried into effect.” If we follow the logical implication of the majority in citing Article III, Section 5(4) in support of its holding, we would have to interpret Article III, Section 5(4) to mean that the Governor would have no discretion when it comes to state spending when the General Assembly, by enacting a budget, earmarks certain amounts for certain items. In other words, once the General Assembly has enacted a budget, the Governor would have no power to deviate from the amounts allocated for the items in that budget. This interpretation seriously weakens the mandate of Article III, Section 5(3), the provision immediately preceding, which charges the Governor with “effect[ing] the necessary economies” in order to prevent a deficit. We must, if at all possible, reconcile the different provisions of our Constitution so that all provisions have meaning and effect. Sessions, 214 N.C. at 638, 200 S.E. at 420.
If the General Assembly enacts a budget and the Governor determines that the budget, as enacted, will lead to a deficit, but the Governor has no authority to modify the allocation of funds within the budget or even to make budgetary cuts — as that would not be ensuring that the “legislative acts are carried into effect” exactly as passed — then the Governor is without power to effect the constitutional duty imposed upon the Governor by Article III, Section 5(3). This interpretation of the powers granted to the Governor pursuant to Article III, Section 5(3) is undercut by In re Separation of Powers, supra, and this Court’s decision in County of Cabarrus v. Tolson, 169 N.C. App. 636, 637, 610 S.E.2d 443, 445 (2005); see also Preston, 325 N.C. at 449, 385 S.E.2d at 478.
The plaintiffs in Tolson specifically “alleged that the Secretary [of Revenue] was required to distribute [funds allocated by statute] to local governments pursuant to chapter 105 of the North Carolina General Statutes.” Id. at 637, 610 S.E.2d at 445. The Tolson Court held that the Governor acted pursuant to his duties under Article III, Section 5(3) in transferring funds allocated by the General Assembly for the purpose of funding local government for use in funding other budgetary items, in order to prevent a deficit. Id. at 638-39, 610 S.E.2d *643443, 446. This holding contradicts the majority’s suggestion that Article III, Section 5(4) mandates that the Governor must always execute the budgetary laws exactly as the General Assembly has enacted them, even when acting pursuant to the powers granted by Article III, Section 5(3).
If, in drafting Article III, Section 5, the General Assembly intended for itself to have the actual power to make budgetary changes to prevent a deficit, then the General Assembly could certainly have done so by enacting new budgetary legislation to remedy the problem, thereby placing the burden of preventing a deficit on the General Assembly. As set out in more detail below, using legislation as the only tool for addressing an impending deficit would be both inefficient and impractical. I believe the intent of the General Assembly in drafting Article III, Section 5(3) was to provide the Governor with the necessary discretion and authority to immediately address a predicted deficit by using appropriate means, including budget cuts or reallocation of funds, so long as the Governor limits these actions to items included within the current budget.
The majority further states: “Article V, section 7 requires that ‘[n]o money be drawn from the State treasury but in consequence of appropriations made by law[.]’ [This] means that there must be legislative authority in order for money to be validly drawn from the treasury.” I do not disagree with the majority’s interpretation as a general principle. However, there is no evidence in the record, nor argument made on appeal, that any of the $80,000,000.00 withdrawn from the Trust Fund was spent on any item not included in the relevant budget passed by the General Assembly. As the majority states “it is unclear to which statutory appropriation [the $80,000,000.00] went.”
If Article V, Section 7 can be construed in any manner to support the majority holding, it would have to be interpreted as giving the General Assembly broad and continuing powers over a budget after it has been passed, which would, according to In re Separation of Powers, violate the separation of powers doctrine. In re Separation of Powers, 305 N.C. at 776-77, 295 S.E.2d at 594. Such an interpretation would serve to exceed the powers granted the General Assembly by Article II, and infringe upon the rights and duties of the Governor as established in Article III, Section 5(3).
IV.
The majority cites two opinions from our Court, Tolson and Stone v. State, 191 N.C. App.-, 664 S.E.2d 32 (2008), that it finds relevant *644to this case. First, I would distinguish Stone as it is not relevant on the facts before us. The majority states: “The [Stone] Court. . . held that placing the funds in temporary escrow was an impermissible ‘diversion’ in violation of the state constitution].]” The majority further states that the holding in Stone “is instructive in that it illustrates that the Governor’s powers under article III, section 5 are not constitutionally unlimited.” There has been no argument made, and I would reject any such argument, that Article III, Section 5 grants the Governor unlimited powers in carrying out his or her constitutional duties pursuant to Article III, Section 5(3).5 Stone, however, is clearly limited in its holding. In Stone, the Governor attempted to divert funds from a retirement fund for State employees. Our Court held that the Governor’s action was impermissible because “Article V, section 6(2) of the North Carolina Constitution not only precludes retirement system funds from being ‘applied,’ ‘loaned to,’ or ‘used by’ the State, but also precludes those funds from being ‘diverted’ by the State.” Stone, 191 N.C. App. at —, 664 S.E.2d at 37. Article V, Section 6(2) of our Constitution expressly prohibits use of State employee retirement funds for any purpose other than funding retirement benefits and necessary expenses for former State employees.
Neither the General Assembly nor any public officer, employee, or agency shall use or authorize to be used any part of the funds of the Teachers’ and State Employees’ Retirement System or the Local Governmental Employees’ Retirement System for any purpose other than retirement system benefits and purposes, administrative expenses, and refunds].]
N.C. Const, art. V, § 6. There is no equivalent constitutional provision expressly preventing the use or diversion for other purposes of the funds at issue in this case. Stone illuminates no issue in this appeal.
The majority conducts a more extensive analysis of Tolson, an opinion construing part of Executive Order 19, the same executive order at issue in this case, in an attempt to distinguish it from the facts of this case. The plaintiffs in Tolson, a group of North Carolina counties, cities and towns, argued inter alia that Executive Order 19 *645violated our constitution because it took “funds allocated for local governments and [used] them for other puiposes that the General Assembly did not authorize.” Tolson, 169 N.C. App. at 639, 610 S.E.2d at 446. Our Court is clearly bound by Tolson, In Re Civil Penalty, 324 N.C. 373, 384, 379 S.E.2d 30, 36 (1989), and Tolson is not distinguishable from the relevant analysis of the appeal before us.
The majority first states “the Tolson Court held that article III, section 5(3) permitted the Governor to transfer the funds in question to a temporary escrow account[.]” (Emphasis added). The majority further states: “The case sub judice is factually distinct from Tolson because this case does not just involve escrowing money in a reserve account but also involves transferring funds, which the General Assembly has allocated for highway purposes to the General Fund, in violation of statute, the ‘Appropriations Act of 2001’.” (Emphasis added). The majority then holds that “while the Governor may ‘escrow’ the Highway Trust Fund monies to prevent a deficit, he or she may not transfer appropriated Highway Trust Fund monies without awaiting appropriate legislative authority from the General Assembly.” (Emphasis added). The majority’s holding appears to contradict its stated understanding of the Tolson holding. The majority states that, pursuant to the Tolson holding, “article III, section 5(3) [did permit] the Governor to transfer the funds in question to a temporary escrow account[.]” (Emphasis added). The Tolson Court stated that Article III, Section 5(3) “clearly places a duty upon the Governor to balance the budget and prevent a deficit.” Tolson, 169 N.C. App. at 638, 610 S.E.2d at 445.
[W]e interpret expenditures to be payments, disbursements, allocations or otherwise, that are budgeted to be paid out of State receipts within a fiscal period. It is these expenditures that the Governor must effect to balance the budget against the expected or anticipated receipts within that same period.
Under the circumstances in this case, the Governor issued Executive Order 19 in order to prevent expenditures from unbalancing the state budget. A failure to exercise his duty under the Constitution via Executive Order 19 would have resulted in a deficit, a state of budgetary crisis that is precisely what Article III, Section 5(3) of the North Carolina Constitution prohibits.
Furthermore, Executive Order 19 did not violate the separation of powers doctrine, as plaintiffs suggest. A violation of the separation of powers doctrine occurs when one branch of state gov*646ernment exercises powers that are reserved for another branch of state government. Ivarsson v. Office of Indigent Def. Servs., 156 N.C. App. 628, 631, 577 S.E.2d 650, 652 (2003). Implicit in the duty to prevent deficits is the ability of the Governor to affect the budget he must administer. See, e.g., Advisory Opinion In re Separation of Powers, 305 N.C. 767, 295 S.E.2d 589 (1982) (noting that the Governor’s constitutional duty to balance the budget was paramount to the General Assembly’s desire to control major budget transfers'). In this case, the Governor exercised powers that were constitutionally- committed to his office without invasion on the legislative branch’s power.
Id. at 638-39, 610 S.E.2d at 445-46 (emphasis added).
The majority in the case before us next adds:
What further distinguishes this case from Tolson is that the action of the Governor in transferring $80,000,000 of Trust Fund monies directly into the General Fund without awaiting legislative action is that the transfer does not effect an economy, to wit: it does not reduce spending or diminish the deficit.
However, by transferring money from the Trust Account, it is fair, or at a minimum possible, to infer that spending on transportation-related items was diminished (i.e., spending on certain approved projects was reduced or withheld altogether). That this money might have then been spent on different items included in the budget does not mean that the reallocation of the money did not serve to prevent a deficit.
By definition, a projected deficit occurs when revenue is projected to fall short of what was predicted, spending is projected to exceed what was predicted, or a combination thereof is projected. Therefore, it is not always necessary to reduce overall spending to prevent a deficit; it is only necessary to ensure that overall spending does not outpace overall revenue (plus monies already held by the State Treasury) for the relevant fiscal period.
For example, it is possible for the Trust Fund to have a projected surplus, but for the General Fund to have a projected deficit larger than the projected Trust Fund surplus, thereby creating an overall projected deficit. The Governor must then determine how to allocate funds to prevent the projected deficit. The Governor might cut funding for multiple items paid out of the General Fund, but make a determination that further cuts were not possible because all that re*647mained were items vital to the continued functioning of State government. The Governor could then cut spending of Trust Fund monies, and potentially reduce spending in this way to a point where projected spending did not outpace projected revenue. However, vital government agencies and programs would still be underfunded, resulting in the inability of our government to function effectively, or respond to crises. As an alternative, by reallocating monies from the Trust Fund rather than simply cutting spending within the Trust Fund, the Governor would be able to fund those items vital to the effective functioning of State .government, and also prevent a deficit, meeting the intent of Article III, Section 5(3).
This scenario and the facts of the case before us are indistinguishable in any meaningful manner from those in Tolson. In Tolson, Executive Order 19 required certain funds slated for payment to local governments to be suspended, and those monies held for reallocation to help prevent a projected deficit. Restated, in order to prevent a projected deficit, that portion of Executive Order 19 transferred monies that were budgeted for one purpose — funding local governments — from one fund to another. It reallocated the monies to purposes for which they were not originally budgeted by the General Assembly. In this case, the only difference is that the monies were transferred from a different source — monies budgeted for transportation-related projects instead of monies budgeted for local governments. As the majority affirms,
the General Assembly has determined that one of the ‘objects’ of the Trust Fund is to supplement the General Fund. Use of the Trust Fund monies for [supplementing the General Fund] thus cannot be viewed as a ‘raid’ of the Trust Fund for purposes not previously sanctioned by the General Assembly.
Additionally, the holding of the majority appears internally inconsistent with its analysis. The ultimate effect of the majority opinion is a requirement that the General Assembly pass legislation for any expenditure changes in a current budget. The majority attempts to make a distinction between “escrowing” and “reducing,” and “transferring” and “spending.” If the General Assembly has passed a budget stating that a certain amount of funds shall be expended for a certain item, pursuant to the reasoning of the majority, the Governor would be violating the separation of powers if the Governor “reduced” spending on that item just as surely as if the Governor “transferred” funds away from that item to be spent on another item in the current *648budget. This is so because the Governor, in refusing to fund an item in the amount stated in the current budget, would be acting without legislative authority in a budgetary action that had not been approved by the General Assembly, and in direct conflict with the provisions of the approved budget.
However, even pursuant to the interpretation of the majority, our Court in Tolson has expressly held that transferring funds from one budgetary item to an escrow account set up for the potential funding of another budgetary item is constitutional pursuant to the powers and duties of the Governor under Article III, Section 5(3). I see no way to reconcile the majority holding with our Court’s holding in Tolson.
The majority also states: “Executive Order 19 states that the [transferred] funds [initially budgeted for local government] would be returned to ‘local government reimbursement funds, if possible, after determination that such funds are not necessary to address the deficit.’ ” The majority then reasons: “Neither the Executive Order nor the Tolson Court addressed which branch or branches of government would make the determination as to whether such funds would be necessary to address the budgetary deficit.” I believe this issue was not addressed in either Executive Order 19 or the Tolson opinion because there was no issue or question concerning this matter. Article ni, Section 5(3) mandates that the Governor
shall continually survey the collection of the revenue and shall effect the necessary economies in State expenditures, . . . whenever he determines that receipts during the fiscal period, when added to any surplus remaining in the State Treasury at the beginning of the period, will not be sufficient to meet budgeted expenditures.
N.C. Const. art. Ill, § 5(3). In Tolson, the determination as to whether the funds would be necessary to address the budgetary deficit was, by constitutional mandate, the Governor’s determination to make. Any attempt by the General Assembly to exercise the powers and duties mandated in Article III, Section 5(3) would constitute a violation of the separation of powers doctrine.
I do not agree with the majority’s argument that the subsequent actions of the General Assembly demonstrate “this determination was made by the Legislative and Executive branches jointly” simply because the General Assembly eventually repealed the statutes establishing local government tax reimbursements. Any argument that *649Executive Order 19 and the repeal of these statutes are connected is mere speculation. There is less support for the majority’s blanket statement that none of the sections included in Executive Order 19, other than the one dealing with the Trust Fund, “appear to divert funds in a manner which excluded participation by the General Assembly.” Tolson does not suggest any of the sections of Executive Order 19 required legislative authority for the executive actions proposed. The Tolson opinion does not hold, nor, in my opinion, anywhere infer, that the Governor, or other executive officials, could not act upon Executive Order 19 “until such time as the co-equal branch[es] of government [could] meet and the Governor and Legislature [could] remedy the deficit by either reducing expenditures or increasing revenue[,]” as the majority states.
The Tolson Court held that “nothing about Article V, Section 5 of the Constitution suggests that it is directed at the Governor and his duty to ‘effect the necessary economies in State expenditures.’ N.C. Const, art. Ill, § 5(3). Rather, the special objects language is directed at the General Assembly.” Tolson, 169 N.C. App. at 639, 610 S.E.2d at 446. Article V, Section 5, which this Court held in Tolson only applies to the General Assembly, states: “Every act of the General Assembly levying a tax shall state the special object to which it is to be applied, and it shall be applied to no other purpose.” N.C. Const. art. V, § 5; Tolson, 169 N.C. App. at 639, 610 S.E.2d at 446.
In rejecting the Tolson plaintiffs’ argument that Article V, Section 5 applied to the Governor and prevented him from using funds for some purpose other than “the special object to which [théy were] to be applied,” our Court sanctioned the actions of the Governor in doing exactly that — using revenue collected and approved by the General Assembly for a “special object” in the budget for other purposes — pursuant to the authority granted him under Article III, Section 5(3). Tolson, 169 N.C. App. at 640, 610 S.E.2d at 446. If the Tolson Court’s holding intended that the Governor must act together with the General Assembly in carrying out the directives of Executive Order 19, then Article V, Section 5 would have applied, as Tolson holds that section is directed to the General Assembly. By holding that Article V, Section 5 did not apply in Tolson, our Court was necessarily holding that the executive branch alone was responsible for carrying out the directives of Executive Order 19. Id.
Furthermore, even if the Governor requested that the General Assembly repeal the relevant statutes, and the General Assembly then decided it was in the best interest of the State to do so, this kind of *650“working together” is consistent with the separation of powers doctrine. What would be inconsistent with the separation of powers doctrine is a requirement that the General Assembly approve acts the Governor decides to take in “effecting the necessary economies” to avoid a budget deficit pursuant to Article III, Section 5(3). The acts of the General Assembly cited by the majority do not suggest that the General Assembly was in any manner giving “necessary approval” for the portions of Executive Order 19 addressed in Tolson. In fact, there is nothing cited by the majority upon which to base any assumption that these separate executive and legislative actions were in any manner directly related. The Tolson Court simply held that the Governor was acting pursuant to the mandate of Article III, Section 5(3) when he issued Executive Order 19. Tolson, 169 N.C. App. at 640, 610 S.E.2d at 446 (“we determine that Executive Order 19 was a constitutional exercise of the Governor’s authority”). Tolson further held that Executive Order 19 did not violate the separation of powers doctrine, stating:
Implicit in the duty to prevent deficits is the ability of the Governor to affect the budget he must administer. See, e.g., Advisory Opinion In re Separation of Powers, 305 N.C. 767, 295 S.E.2d 589 (1982) (noting that the Governor’s constitutional duty to balance the budget was paramount to the General Assembly’s desire to control major budget transfers). In this case, the Governor exercised powers that were constitutionally committed to his office without invasion on the legislative branch’s power.
Id. at 639, 610 S.E.2d at 446 (emphasis added). The Tolson opinion does not support the majority’s determination that the Governor could carry out the directives of Executive Order 19 only if he received approval from the General Assembly, whether in the form of legislation or through some other means. Instead, Tolson strongly suggests just the opposite — that both issuing Executive Order 19 and carrying out its provisions were the sole province of the executive branch. Tolson is in line with prior opinions of our Supreme Court suggesting that to determine otherwise would be to violate the separation of powers doctrine. See Ivarsson v. Office of Indigent Def. Servs., 156 N.C. App. 628, 631-32, 577 S.E.2d 650, 652-53 (2003). As noted above, this does not mean the Governor may not seek action from the General Assembly, only that the Governor is not required to do so. Furthermore, contrary to the majority’s inference, this dissent does not “contend that the Governor alone holds the power to amend the budget wholesale in violation of statute.” The General Assembly *651is always free to exercise its constitutional power to enact legislation, including budgets and budgetary amendments. Constitutionally, what the General Assembly does not do, however, is administer the budget or any amendments thereto.
V.
The majority, in attempting to determine the intent of the General Assembly in order to interpret the meaning of “effecting the necessary economies,” states that after the passage of Article III, Section 5(3), and before the passage of the Separation of Powers Act of 1982, “the determinations of budget reductions and transfers between budgets were handled jointly by the Governor and the ‘Advisory Budget Commission’ (‘ABC’).” The ABC was made up of both executive and legislative branch employees. As noted in the majority opinion, these joint executive and legislative actions ceased after our Supreme Court issued its opinion in State ex rel. Wallace v. Bone, 304 N.C. 591, 286 S.E.2d 79 (1982), following which our General Assembly enacted the Separation of Powers Act of 1982. 1981 N.C. Sess. Laws (Reg. Sess. 1982), Ch. 1191.
Our Supreme Court stated in Wallace: “There should be no doubt that the principle of separation of powers is a cornerstone of our state and federal governments.” Wallace, 304 N.C. at 601, 286 S.E.2d at 84. Relying on this premise, and after analyzing multiple opinions from other states, our Supreme Court held that the separation of powers doctrine was violated by the enactment of N.C. Gen. Stat. § 143B-282 et seq., which provided for an “Environmental Management Commission” (EMC), including members of the General Assembly, to exercise executive functions (for example, “supervision over the maintenance and operation of dams”6). Id. at 607, 286 S.E.2d at 88. The Wallace Court stated:
It is crystal clear to us that the duties of the EMC are administrative or executive in character and have no relation to the function of the legislative branch of government, which is to make laws. . . . [T]he legislature cannot constitutionally create a special instrumentality of government to implement specific legislation and then retain some control over the process of implementation[.]
Id. at 608, 286 S.E.2d at 88 (emphasis added). “ ‘[N]o person shall be capable of acting in the exercise of any more than one of [the three *652branches of government] at the same time lest they should fail of being the proper checks on each other and by their united influence become dangerous].]’ ” Id. at 597-98, 286 S.E.2d at 83 (quoting instructions given to the Orange County delegation working on our State’s first Constitution, which was adopted 18 December 1776) (emphasis added by the Wallace Court).
[Violations [of the separation of powers doctrine] have occurred several times in the history of our state. See State ex rel. Wallace v. Bone and Barkalow v. Harrington, 304 N.C. 591, 286 S.E.2d 79 (1982) (holding that members of the General Assembly could not concurrently hold membership on the Environmental Management Commission, an executive branch agency, without violating the separate power of executive branch); State v. Elam, 302 N.C. 157, 273 S.E.2d 661 (1981) (allowing the General Assembly to make rules of practice and procedure for the state’s appellate courts would violate the separation of powers, because those powers were reserved for the Supreme Court by Art.IV, § 13(2) of the Constitution of North Carolina); and Person v. Watts, 184 N.C. 499, 115 S.E. 336 (1922) (granting a taxpayer’s request that the judiciary force the collection of taxes on stockholder income would violate the legislature’s constitutional control over the power of taxation). Each of these cases dealt with the exercise of a power by one branch of government when the power was specifically outlined by the state constitution as belonging to another branch.
Ivarsson, 156 N.C. App. at 631-32, 577 S.E.2d at 652-53. Our Supreme Court decisions leading up to the Separation of Powers Act of 1982 hold that when the General Assembly exercises authority beyond the enactment of laws, and participates in the execution of those laws, it violates constitutional provisions defining and separating the powers of the three branches of government.
The General Assembly passed the Separation of Powers Act of 1982; and in response to the Wallace opinion, the General Assembly specifically re-wrote the relevant statute to ensure that members of the General Assembly could not serve on the EMC. 1981 N.C. Sess. Laws (Reg. Sess. 1982), Ch. 1191. §§ 2 and 19. The Separation of Powers Act of 1982 listed 32 specific boards and commissions on which members of the General Assembly could not serve, in recognition of the executive functions of those boards and committees. 1981 N.C. Sess. Laws (Reg. Sess. 1982), Ch. 1191. § 2. In effect, the General Assembly, in enacting the Separation of Powers Act of 1982, codified *653the prior separation of powers holdings from our Supreme Court by re-writing multiple statutes in an attempt to ensure members of the General Assembly did not serve on any board or commission it believed acted in an executive or judicial capacity.
The General Assembly further ensured that boards or commissions which included members of the General Assembly were restricted to making recommendations to the executive and judicial branches of government, or advising the General Assembly on potential future legislation. For example, the statute involving the Economic Development Board was “rewritten to read: ‘There, is created within the Department of Commerce an Economic Development Board. The Board shall advise the Secretary of Commerce on: [specified duties, including] . . . the formulation of a budget[.]’ ” 1981 N.C. Sess. Laws (Reg. Sess. 1982), Ch. 1191. § 18 (emphasis added). The Separation of Powers Act of 1982 was entirely focused on limiting powers of the General Assembly in an attempt to avoid violation of the separation of powers doctrine.
The General Assembly subsequently curtailed the limits of its authority even further by enacting the Separation of Powers Act of 1985. 1985 N.C. Sess. Laws, Ch. 122. The Separation of Powers Act of 1985 revised numerous statutes to amend provisions requiring approval from the ABC (as noted by the majority, a joint executive-legislative commission) for executive acts, mandating instead that the Governor and certain executive agencies consult with the ABC before performing certain acts. 1985 N.C. Sess. Laws, Ch. 122. §§ 1-7 (e.g. “Sec. 3. G.S. 143B-426.11(7) is amended by deleting ‘the approval of [the ABC]’ and substituting ‘consultation with [the ABC]’ ”.).
The following year, the General Assembly enacted “An Act to Further Provide for the Separation of Powers,” referred to as the Separation of Powers Act of 1986. 1985 N.C. Sess. Laws (Reg. Sess. 1986), Ch. 955. In this act, the General Assembly removed language from the General Statutes that required the Governor or executive agencies to even consult with the ABC prior to taking executive action. All of the statutes amended in the Separation of Powers Act of 1985, along with many additional statutes, were further amended to this purpose. For example, N.C. Gen. Stat. § 108A-33(d) was amended “by deleting ‘and consultation with the [ABC,]’ and adding: ‘Prior to taking any action under this subsection, the Director of the Budget [i.e. the Governor] may consult with the [ABC].’ ” 1985 N.C. Sess. Laws (Reg. Sess. 1986), Ch. 955. §§ 11-12 (emphasis added). N.C. Gen. Stat. § 143B-426.11(5) was amended *654from: “At no time may the total outstanding indebtedness of the Agency, excluding bond indebtedness, exceed five hundred thousand dollars ($500,000) unless the Agency has consulted with the [ABC,]” to: “At no time may the total outstanding indebtedness of the Agency, excluding bond indebtedness, exceed five hundred thousand dollars ($500,000) unless the Agency has consulted with the Director of the Budget.”7 1985 N.C. Sess. Laws (Reg. Sess. 1986), Ch. 955. § 99. N.C. Gen. Stat. § 143B-426.11(7) was amended from: “Subject to consultation with the [ABC] and under such conditions as the Board may deem appropriate to the accomplishment of the purposes of this Part, [the North Carolina Agency for Public Telecommunications] may distribute in the form of grants, gifts, or loans any of the revenues and earnings received by the Agency from its operations[,]” to: “Under such conditions as the Board may deem appropriate to the accomplishment of the purposes of this Part, [the Agency] may distribute in the form of grants, gifts, or loans any of the revenues and earnings received by the Agency from its operations[.]” 1985 N.C. Sess. Laws (Reg. Sess. 1986), Ch. 955. § 100. N.C. Gen. Stat. § 143B-426.il was further amended by adding at the end of the statute: “Prior to taking any action under subdivisions (5) or (7) of this section, the Board may consult with the [ABC].” 1985 N.C. Sess. Laws (Reg. Sess. 1986), Ch. 955. § 101 (emphasis added). The language stating that the “Board may consult with the ABC” was ultimately deleted from N.C. Gen. Stat. § 143B-426.il entirely. 2005 N.C. Sess. Laws (Reg. Sess. 2006), Ch. 203. § 107. These examples are but a fraction of the extended and continual revisions by the General Assembly, following opinions of our Supreme Court, codifying limitations of the General Assembly’s constitutional powers in relation to the other two branches of state government.
This extensive legislative history concerning the separation of powers doctrine demonstrates increasing attention by the General Assembly to ensure it was not encroaching upon the powers and duties granted to the executive branch by Article III, Section 5(3), nor exceeding the powers granted to it by Article II. The actions of the General Assembly and the opinions of our appellate courts lead to the conclusion that the General Assembly may not interfere with the Governor’s constitutional duties pursuant to Article III, Section 5(3) to prevent a deficit by effecting the necessary economies related to a budget the General Assembly has already enacted. Once a budget has been passed, it is solely the duty of the Governor to administer that *655budget. The General Assembly’s check on the budgetary powers of the Governor may be exercised in the form of new legislation, not in requiring the Governor to obtain approval from the General Assembly for administrative budgetary decisions.
VI.
The majority’s suggestion that Executive Order 19 can be construed as constitutional only if it is assumed that none of the funds “escrowed” by the order may be utilized by the Governor in order to prevent a budget deficit without legislative action, is contrary to both the General Assembly’s understanding of its role and authority in administering the budget, as evidenced by the Separation of Powers Acts and other legislation, and the decisions of our appellate courts. The General Assembly has recognized that active participation in administering the budget exceeds the authority granted it under Article II.
Informatively, the issue of separation of powers was directly addressed in a memorandum dated 20 May 1977 from Joe Ferrell (Ferrell) of the Institute of Government, to Dr. John R. Gamble (Chairman Gamble), then the Chairman of the House of Representatives Committee on Constitutional Amendments (the Committee) and sponsor of the bill to amend Article III, Section 5(3). Ferrell, who was closely involved in drafting the amendment of Article III, Section 5(3), responded to concerns raised by then director of the Institute of Government John Sanders (Sanders) that “the amendment should be neutral on the issue of whether and to what extent the General Assembly may constitutionally direct the manner in which the Governor administers the budget.” Ferrell informed Chairman Gamble that he believed Sanders’ point was a “good one,” and further stated to Chairman Gamble:
I assume the General Assembly will continue to hold to the position that it had taken since 1925 that it had constitutional power to prescribe the way that the budget will be administered. This has not been challenged for fifty years and is not likely to be challenged soon I would think. I conceded [Sanders’] point by omitting the language “in such manner as the General Assembly may prescribe.” I do not believe leaving it out will change the present constitutional situation, and putting it in would add weight to one side of the argument.”
Five days later, the Committee substitute for the amendment was adopted, excluding the language “in such manner as the General *656Assembly may prescribe.” This memorandum serves to refute the majority assertion that “supporting cases” decided prior to the “enactment of present article III, section 5 . . . inform bur decision here because they represent settled law as to the understanding of the legislative power under this State’s Constitution with regard to [the General Assembly’s] power to appropriate and the duty of the Governor to execute the laws.” (Emphasis added).
The proposed amendment ultimately adopted by the General Assembly and ratified by the voters was purposefully left noncommittal on the question of the General Assembly’s authority to participate in the administration of budgets it had enacted. Ferrell’s assumption that the issue would remain unchallenged proved to be incorrect, however, as our Supreme Court in Wallace and other opinions did address this question shortly after the ratification of the amendment of Article III, Section 5(3), which began both the judicial and legislative process of more clearly defining the role of the General Assembly with respect to powers granted by our Constitution to the executive branch. See Ivarsson, 156 N.C. App. at 631-32, 577 S.E.2d at 652-53.
Whatever the intent of the General Assembly in drafting and approving the language to the amendment of Article III, Section 5(3), the General Assembly did continue to directly participate in varying degrees with the administration of the budgets it had enacted, which participation was later deemed unconstitutional by our Supreme Court. Wallace, 304 N.C. at 608-09, 286 S.E.2d at 89; In re Separation of Powers, 305 N.C. at 776-77, 295 S.E.2d at 594; see also Ivarsson, 156 N.C. App. at 631-32, 577 S.E.2d at 652-53. Our Court should not conduct an analysis of the General Assembly’s intent in drafting the amendment of Article III, Section 5(3) based upon this erroneous understanding of the powers of the legislative branch, and acts by the General Assembly later held to be unconstitutional.
At the threshold of our consideration of the questions here presented we note the well-recognized rule that where a statute or ordinance is susceptible to two interpretations — one constitutional and one unconstitutional — the Court should adopt the interpretation resulting in a finding of constitutionality. State v. Frinks, 284 N.C. 472, 201 S.E.2d 858 (1974); Randleman v. Hinshaw, 267 N.C. 136, 147 S.E.2d 902 (1966); Finance Co. v. Leonard, 263 N.C. 167, 139 S.E.2d 356 (1964).
Smith v. Keator, 285 N.C. 530, 534, 206 S.E.2d 203, 206 (1974).
*657Even assuming arguendo that the intent of the General Assembly and the people of North Carolina in proposing and ratifying the amendment to Article III, Section 5(3) in the manner suggested by the majority could be determined, because I believe the majority’s interpretation would lead to an unconstitutional violation of the separation of powers doctrine, we must interpret this amendment in a manner not violative of our Constitution if such an interpretation is possible. Id. Such an interpretation is possible and, in fact, more in line with the clear intent behind the amendment when read as a whole, and in pari materia with the other provisions of our Constitution. Preston, 325 N.C. at 449, 385 S.E.2d at 478.
VII.
It is clear from the plain language of Article III, Section 5(3) that the purpose of the amendment is to grant the Governor the power to administer the budget to prevent a budgetary deficit. Budgetary crises may present themselves in a myriad of forms. If the Governor believes a deficit is pending but is not immediate, the Governor may decide that working with the General Assembly (i.e. proposing budgetary legislation for the General Assembly to debate and potentially enact) is the best option. When, however, the Governor anticipates an immediate budget crisis and deficit, the restrictions on executive action as mandated by the majority are inefficient, impractical, and likely to thwart the Governor in the Governor’s constitutional duty to prevent a deficit.
Our Supreme Court has held unconstitutional any system where the Governor must obtain the permission of the General Assembly (or members thereof) in carrying out the Governor’s executive duties. Therefore, a result of the majority opinion may be to compel the Governor to ask the General Assembly to enact legislation to authorize reallocation of funds within a current budget. The General Assembly may refuse to act, or may disagree with the recommendation of the Governor, and pass legislation in an attempt to prevent a deficit that is wholly unrelated to the Governor’s determination of what is the best path to avoid the anticipated deficit. The General Assembly may fully agree with the recommendations of the Governor, but the legislative process may take too long, and the State may incur a deficit despite the best intentions of the Governor and the General Assembly to work together. The Governor would then, even if the Governor had acted with the utmost expediency, good faith and diligence, be in violation of the constitutional mandate of Article *658III, Section 5(3) — without power to perform the Governor’s constitutional duties in this regard.
Under the majority opinion, the true power to “effect the necessary economies” to prevent a deficit will lie with the General Assembly pursuant to an incorrect interpretation of Article III, Section 5(3). The majority opinion would remove the Governor’s ability to act quickly in a crisis to perform the Governor’s constitutional duty to “effect the necessary economies” in order to prevent a deficit. It would remove the Governor’s ability to make discretionary determinations in a budget crisis and then act upon them. I believe the majority’s interpretation of Article III, Section 5(3) runs contrary to the plain language of that amendment, its “dominant purpose” and “spirit” when read in pari materia with other relevant constitutional provisions, Stancil, 237 N.C. at 444, 75 S.E.2d at 514; see also Preston, 325 N.C. at 449, 385 S.E.2d at 478, and will result in severe limitations on the Governor’s authority and power to “effect the necessary economies” to fulfil the Governor’s constitutional duty to prevent a deficit.
. The majority states that the actions of the Governor did “not effect an economy, to wit: [they did] not reduce spending or diminish the deficit.'’ (Emphasis added). Again, Article III, Section 5(3) mandates proactive steps from the Governor to prevent a deficit, not reactive steps to diminish an existing deficit. By providing this mandate in broad and general language, Article III, Section 5(3) grants the Governor discretion in the manner in which the Governor acts to prevent a budget deficit.
. The majority also states “our history and experience with authority cautions us against entrusting unbridled expenditure authority in any one person.” Nothing in this dissent suggests the Governor has “unbridled expenditure authority.” The Governor’s actions in “effecting the necessary economies” are limited by Article III, Section 5(3) to situations where there is a projected deficit. The Governor may only operate within the budget passed by the General Assembly. The Governor may not authorize expenditures for items not included within the current budget.
. This power would necessarily include making funding decisions.
. I.e., the Governor.