with whom KAUGER, Justice joins, concurring in part and dissenting in part:
I concur with today’s pronouncement that the ad valorem tax revaluation program is not a state function. The Oklahoma Constitution, Article 10, § 8, expressly authorizes the Legislature to enact laws “defining classifications of use for the purpose of applying standards to facilitate uniform assessment procedures in this state.” [Emphasis added.] However, neither § 8 nor any other constitutional provision authorizes an additional ad valorem tax levy to defray the costs of uniform assessments. Today’s pronouncement that the writ of mandamus issued herein constitutes a judgment for payment of the involved expenses of revaluation and that judgment may be paid from ad valorem tax revenues held in sinking funds is contrary to the Oklahoma Constitution, Article 10, § 28. Accordingly, I respectfully dissent to Part VII of the opinion herein.
The maximum ad valorem tax millages, the purposes for the levies, and the entities entitled to levy taxes on property are strictly provided for in the constitution. The constitution prohibits the levy of ad valo-rem tax except as may be therein provided. Okla. Const., art. 10, § 9. The plain words of our constitution prevent either the Legislature or this Court from authorizing ad valorem tax levies in excess of those set forth in the constitution.
Levies of ad valorem taxes for sinking funds of various political subdivisions of the state are authorized by the Oklahoma Constitution, Article 10, § 28, which states:
Counties, townships, school districts, cities, and towns shall levy sufficient additional revenue to create a sinking fund to be used, first, for the payment of interest coupons as they fall due; second, for the payment of bonds as they fall due; third, for the payments of such parts of judgments as such municipality may, by law, be required to pay.
The express language of § 28 limits the use of revenues in sinking funds to the payment of specific debts: bonded indebtedness or judgment debts owed by the political subdivisions. Ad valorem tax levies needed to generate revenues to retire local indebtedness or to pay judgments may be imposed without a vote of the people. Okla. Const., art. 10, § 28. Underlying § 28 is the prerequisite approval of the electorate to create a debt, Okla. Const., art. 10, § 26, and, the need to preserve the *811integrity of judicial orders. Use of revenues in sinking funds to defray the ordinary expenses of political subdivisions is simply not within the ambit of § 28.
The Oklahoma Constitution, Article 10, §§ 9, et seq. authorizes ad valorem tax levies for ordinary expenses of political subdivisions. Generally, ad valorem tax levies in excess of the 34 mills authorized in subsections (a), (b) and (c) of § 9 must be approved by a vote of the electorate. Part VII authorizes levies in excess of the constitutional máximums and it defeats the right of the electorate to approve additional ad valorem tax levies, even if the levies were within the máximums. Further, Part VII is not critical to the preservation of the integrity of the judiciary. Part VII of the majority opinion, authorizing payment of the ordinary expenses of the defending political subdivision parties from their respective sinking funds under the guise of a “judgment”, is contrary to the constitution.
The Court of Appeals in its published opinion in Matter of Protests of Southwestern Bell Company v. Muskogee County Excise Board, 727 P.2d 108 (Okla.App.1986), declared the levy of ad valorem tax for the payment of the municipality’s proportionate share of the expense of revaluation from its sinking fund to be illegal under the express language of the constitution, Okla. Const., art. 10, § 28. At issue in that appeal was the levy to pay the municipality’s 1984-1985 revaluation expense involved herein. Part VII effectively vacates the Court of Appeals opinion in this collateral matter.
The propriety of the assessor’s expenses of revaluation are not at issue herein. The issue is legal: Whether a school district or a municipality is legally obligated to pay a proportionate share of the county assessor’s annual costs of performance of revaluation? The majority opinion resolves that legal issue in favor of the county and directs payment of the unchallenged expenses. The writ of mandamus directs payment of portions of the county assessor’s costs of revaluation from revenues in sinking funds. In essence, Part VII instructs the local ad valorem taxing entities to withhold payment of its ordinary annual expenses and force collection through judicial proceedings, thereby allowing payment from sinking funds. The constitution does not contemplate either the levy or the use of ad valorem tax revenues in sinking funds to defray annual expenses of political subdivisions of this state that have been reduced to judgment.
The Legislature impermissibly provided for payment of proportionate shares of the assessor’s revaluation expenses from sinking funds in 68 O.S.1981, § 2481.4 and 68 O.S.Supp.1988, § 2823. Those impermissible laws have been corrected. In 1991, the Legislature amended §§ 2481.4 and 2823, expressly excluding sinking funds from the payment of the county assessor’s revaluation expenses. 1991 Okla.Sess.Laws, ch. 124, § 34, and ch. 249, § 8.1 This Court, as the final arbiter of our constitution, should mandate the municipality and the school district parties to pay the involved revaluation costs from their revenues appropriated for those ordinary operating expenses. Accordingly, I respectfully dissent in part.
. The Legislature repealed 68 O.S.1981, § 2482.4, as amended by 1991 Okla.Sess.Laws, ch. 124, § 34. 1991 Okla.Sess.Laws, ch. 249, § 5. However, in the same bill, the Legislature amended 68 O.S.Supp.1988, § 2823, which contained the provisions of § 2481.4, to exclude sinking funds from the payment of the expenses of revaluation.