concurring.
I completely concur in the principal opinion. I write separately for the purpose of explaining why the rather winsome arguments of the dissenters do not persuade me, despite my personal agreement with the result the dissenters reach.
The discussion of the constitutional debates found in Judge Donnelly’s dissent provides an interesting historic aside to the issues before the Court in this case. However, this Court has long held that “ ‘[i]t is, of course, fundamental that where the language of a statute is plain and admits of but one meaning there is no room for construction.’ This rule applies with equal force to constitutional provisions.” Rathjen v. Reorganized School District R-II of Shelby County, 365 Mo. 518, 284 S.W.2d 516, 517, 523 (banc 1955) quoting Cummins v. Kansas City Public Service Co., 334 Mo. 672, 66 S.W.2d 920, 931 (banc 1933).
Were there some ambiguity in the constitutional language, we would be clearly justified in consulting the minutes of the Constitutional Convention for their persuasive, though not binding, effect. Metal Form Corp. v. Leachman, 599 S.W.2d 922, 926 (Mo. banc 1980). However, Mo. Const, art. X, § 4(a) is not ambiguous. It provides in pertinent part that the General Assembly may “provide for further classification within classes 2 [tangible personal property] and 3 [intangible personal property], based solely on the nature and characteristics of the property, and not on the nature, residence or business of the owner, or the amount owned_” [Emphasis added]. No reference is made to real property in the pertinent sentence.
The fact that § 4(a) does not discuss the subclassification of real property is consistent with the debates. Delegates to the convention thought that “a great many people in Missouri had a great deal of fear that it [subclassification] ought not to apply to real estate.” Tr. of Debates of Mo. Const., 1945, page 6306. Such subclassifi-cation was, therefore, not under active consideration at the time of the debates. With the 1982 amendment to Mo. Const, art. X, § 4(b), the people of Missouri, contrary to the fears expressed on their behalf at the 1945 Constitutional Convention, and contrary to any discussion about the subclassi-fication of real estate which may have taken place at that convention, chose to allow the subclassification of real estate for tax purposes in Missouri.
A second canon of constitutional construction must be noted. “This Court has recognized that in the construction of constitutional provisions it should undertake to ascribe to words the meaning which the people understood them to have when the provision was adopted.” State ex rel. Danforth v. Cason, 507 S.W.2d 405, 408 (Mo. banc 1973). Based on the plain language submitted to the voters approving the 1945 Constitution, there can be little doubt that the makers1 of our Constitution — the people — while approving the sub-classification of class 2 and 3 property, formed no intent with regard to the sub-classification of real property.
*921I cannot agree that § 4(a) contains a “base line” with regard to class one property. The “base line” which § 4(a) provides is limited by its own terms to property in classes 2 and 3; real property is not discussed. Thus, it is only by the surgical excision of the constitutional references to Class 2 and Class 3 property that such a “base line” can be found.
Nor, in my view, is there a need to harmonize § 4(a) and § 4(b). There is no conflict between the sections. To repeat, § 4(b) provides for subclassification of real property; § 4(a) does not consider that subject.
Even if one assumes for the sake of argument, that the General Assembly is restricted by the language of § 4(a), the issue presented in this case is not resolved. Real property developed as apartments partakes of a dual nature. Like commercial property, it produces income; like residential property it provides shelter. Thus, apartments are both residential and commercial.2 In the presence of this dual nature, I am unwilling to say that the General Assembly violated the constitution by choosing to define the primary nature of larger apartment complexes as commercial.
Nor does § 137.016.1 violate equal protection and due process, U.S. Const. Amend. XIY, or the uniformity clause of Mo. Const, art. X, § 3. An act of the legislature enjoys a presumption of constitutionality. It will not be declared unconstitutional unless it clearly and undoubtedly contravenes the Constitution. Prokopf v. Whaley, 592 S.W.2d 819, 824 (Mo. banc 1980). Further, the legislature is granted a broad discretion and wide latitude in constructing its classifications for taxation. Lockport v. Citizens for Community Action, 430 U.S. 259, 272, 97 S.Ct. 1047, 1055, 51 L.Ed.2d 313 (1977); Lehnhausen v. Lake Shore Auto Parts Co., 410 U.S. 356, 359, 93 S.Ct. 1001, 1003, 35 L.Ed.2d 351 (1973). “[I]n taxation, even more than in other fields, legislatures possess the greatest freedom in classification.” Madden v. Kentucky, 309 U.S. 83, 88, 60 S.Ct. 406, 408, 84 L.Ed. 590 (1940).
Respondents do not claim that this case involves a fundamental right or invidious class discrimination. Thus, as Judge Rend-len appropriately notes in his dissent, the proper standard of review under the equal protection clause, the due process clause, and the uniformity clause is that the tax classifications established by the legislature have a rational basis; they cannot be palpably arbitrary. State ex rel. Transport Manufacturing and Equipment Co. v. Bates, 359 Mo. 1002, 224 S.W.2d 996, 1000 (banc 1949); Bridges Asphalt Co. v. Jacobsmeyer, 346 Mo. 609, 142 S.W.2d 641, 643 (1940); Allied Stores of Ohio, Inc. v. Bowers, 358 U.S. 522, 527, 79 S.Ct. 437, 441, 3 L.Ed.2d 480 (1959).
Is there a legitimate state end? No one challenges the legitimacy of the State exercising its taxing power through the imposition of ad valorem taxes on real property. Thus, the constitutional challenge turns on whether the classifications created by the legislature are rationally related to the State’s interests in taxation.
It is argued that apartments are purely residential. Yet, as has already been discussed, apartments have an undeniably commercial aspect. Thus, in my view, the legislature would have been justified in classifying all apartment property as commercial property.
The more thoughtful argument challenges the distinction drawn by the General Assembly between apartment property containing four or fewer units and apartment complexes containing five or more units. Does this distinction have a rational basis? As the principal opinion correctly holds, the distinction drawn by the legislature may have been based on the legislature’s understanding that those “complexes” containing four or fewer units, because of their lack of size, are not truly commercial; such property may also have been developed for *922the purpose of providing housing for the extended family of the owner. These rationales are sufficient to ward off this constitutional challenge.3 As the principal opinion indicates, the cases upon which Judge Rendlen’s dissent relies for the proposition that this statute is unconstitutional are distinguishable.
As I have already confessed, I disagree with the policy choice made by the General Assembly. The temptation we face as judges, when equal protection is invoked, is to assume that any policy choice with which we disagree is irrational and therefore in violation of the Constitution. To succumb to the temptation to substitute our chosen policy for that adopted by the elected representatives of the people is, however, to confuse power with authority. The fact that our system of government entrusts us with the power to declare an act of the legislature unconstitutional does not mean that we can exercise that power to effectuate our policy choices, absent a violation of the Constitution. The fact that the General Assembly’s decision may be considered odd by us, does not, in my view, also render it unconstitutional.
[A] court is not free under the aegis of the Equal Protection Clause to substitute its judgment for the will of the people of a State as expressed in laws passed by their popularly elected legislatures. “The Constitution presumes that, absent some reasons to infer antipathy, even improvident decisions will eventually be rectified by the democratic process and that judicial intervention is generally unwarranted no matter how unwisely we may think a political branch has acted.” Vance v. Bradley, 440 U.S. [93], 97, 99 S.Ct. 939, 942, 59 L.Ed.2d 171 [(1979)].
Parham v. Hughes, 441 U.S. 347, 351, 99 S.Ct. 1742, 1745, 60 L.Ed.2d 269 (1979).
. "Constitutions are not designed for metaphysical or logical subtleties, for niceties of expression, or for the exercise of philosophical acuteness or judicial research. They are instruments of a practical nature, founded on the common business of life, adapted to common wants, designed for common use, and fitted for common understandings. The people make them, the people adopt them, the people must be supposed to read them with the help of common sense, and cannot be presumed to admit in them any recondite meaning or any extraordinary gloss." State v. Adkins, 284 Mo. 680, 225 S.W. 981, 984 (1920) (Williamson, J. concurring) quoting 1 Story, Constitution, § 451.
. The same can be said of a hotel, which provides an overnight (or longer) residence to its residents and income to its owner. In my opinion, it would be difficult to sustain an argument that a hotel is not commercial in nature, however.
. The fact that clever apartment developers may defeat the commercial designation of their property under § 137.016.1 by dividing larger complexes into separate ownership for each four apartments does not require a different result.