HARGRAVE, J.
¶ 1 The Oklahoma Development Finance Authority (“ODFA”) has filed an application pursuant to 20 O.S. § 14.11 asking this Court to assume original jurisdiction and approve industrial development taxable revenue bonds to be issued pursuant to the Oklahoma Quality Jobs Incentive Leverage Act, 68 O.S. Supp.2002 § 3651 et seq. The purpose of the bonds is to provide funds to pay or reimburse The Goodyear Tire & Rubber Company and Michelin North America, Inc. for a portion of the costs of expanding and re-tooling their existing manufacturing plants in Oklahoma. The ODFA has authorized the issuance of Industrial Development Taxable Revenue Bonds (Goodyear Project) Series 2003 in a principal amount not to exceed $36,720,000 and Industrial Development Taxable Revenue Bonds (Michelin Project) Series 2003 in a principal amount not to exceed $29,615,000.
¶ 2 Section 3653 of the Oklahoma Quality Jobs Incentive Leverage Act (the Act), 68 O.S. Supp.2002 § 3651, et. seq., defines a qualifying establishment as a business: that has at least $115,000,000.00 in annual gross compensation paid with respect to jobs located in Oklahoma; that has an average salary of at least $40,000 paid annually to employees; that intends to add substantial gross compensation with respect to full-time-equivalent employment located in Oklahoma within three years of filing an irrevocable election with the Oklahoma Department of Commerce as provided in the Act; that has at least $200,000,000.00 total investment in Oklahoma; that intends to add investment for modernization and retooling of a facility located in the state of at least $50,000,000.00, within five years of filing an irrevocable election with the Oklahoma Department of Commerce as provided in the Act; that has and maintains at least 1,550 full-time employees in the state; that is described by Industry [1078]*1078Number 3011, Industry Group Number 301, Major Group, 30 of the Standard Industrial Classification Manual (SIC) latest revision; and that qualifies for proceeds under the Act and as of the date the irrevocable election is filed, has received or will receive funds as a result of a voter-approved economic development incentive derived from a tax levy as described in the definition. Two manufacturers have qualified under the Act, to date: The Goodyear Tire & Rubber Company and Miehelin North America, Inc. (referred to herein as “Goodyear” and “Miehelin”, or collectively as “qualifying establishments”).
¶3 Section 3652 of the Act states the legislative purpose behind its enactment:
“The Legislature finds that certain establishments which qualify for incentive payments pursuant to the Oklahoma Quality Jobs Program Act [68 O.S. § 3601 et seq.] are a source of economic benefits for the state, its political subdivisions and its residents that can only be achieved through the use of specialized economic incentives. The Oklahoma Quality Jobs Incentive Leverage Act is enacted in order to provide a mechanism for the leverage of incentive payments for the purpose of promoting and sustaining economic growth and activity within the State of Oklahoma. The Legislature finds that the use of the incentive payment, together with other fiscal resources, is a method that provides a beneficial correlation between the use of monies in the quality Jobs Program Incentive Leverage Fund and the total economic benefits to be derived from the use of proceeds from the sale of obligations provided by Section 4 of this Act. [68 O.S. Supp.2002 § 3654].”
¶ 4 The Act directs the ODFA to issue obligations in a principal amount determined as required by the section, upon certification by the Oklahoma Department of Commerce that an establishment has filed the irrevocable election described in the Act.2 The Act provides that no obligation issued by the ODFA pursuant to the Act shall be considered a general obligation of the State of Oklahoma for any purpose, and the indebtedness incurred shall be a debt of the ODFA and not a debt of the State of Oklahoma. 68 O.S. Supp.2002 § 3654(A).
¶ 5 The Act goes on to provide that the total principal amount of the indebtedness incurred by the ODFA shall not be greater than an amount required for proceeds equal to 14.4% of the maximum amount of projected investment for the facility of an establishment that will receive funds as a result of a voter-approved economic development incentive. 68 O.S. § 3654(B)(1). The voter-approved economic incentive is described in § 3653(l)(h).3
¶ 6 Miehelin and Goodyear have shown evidence that each has or will receive the voter approved local economic development incentive. Miehelin and Goodyear have filed the irrevocable election to forego the incentive payments that they are authorized to receive under the Oklahoma Quality Jobs Program Act, 68 O.S.2001 § 3601 et seq.4 The irrevocable election means that the in[1079]*1079centive payments that otherwise would have been paid to Michelin and Goodyear under the Oklahoma Quality Jobs Program Act will instead be deposited in the Quality Jobs Program Incentive Leverage Fund. 68 O.S. § 3658(B). That section specifically provides that such incentive payments shall be treated as an asset of the qualifying establishment that has been paid to the State of Oklahoma for purposes of the Act. In addition, .68 O.S. Supp.2002 § 3658(F), (H) and (I) prohibit the qualifying establishments from claiming certain tax credits or exemptions that otherwise would be available to them.5
¶ 7 Applicant states that the bonds are self-liquidating revenue bonds, payable solely from funds transferred from other, sources to the ODFA. Section 3657 of the Act creates a special fund within the State Treasury to be designated the “Quality Jobs Program Incentive Leverage Fund” (the Fund), and all amounts deposited into the Fund shall be used by ODFA solely as authorized by the Act, including payment of principal, interest and other costs associated with the issuance of the bonds under the Act. The ODFA is to maintain separate accounts within the Quality Jobs Program Incentive Leverage Fund for each qualifying establishment, and to provide for the deposit therein of the incentive payments and withholding taxes apportioned to the fund by the Act.
¶ 8 The bonds are secured first by transfers to the Fund of the incentive payments under the Oklahoma Quality Jobs Program Act that Michelin and Goodyear have elected to forego. The second level of security for payment of the bonds consists of transfers of withholding taxes attributable to a qualifying establishment, as provided in sections 3658(E) and 3659 of the Act. Those two sections provide that for each fiscal year during which any obligations issued by the ODFA under the Act remain unpaid, the Oklahoma Tax Commission is directed to compute the amount of withholding taxes attributable to employees of the qualifying establishment whose wages are subject to the levy, and transfer to the Fund an amount of withholding taxes required to equal the difference between the incentive payment deposit and the amount to be certified by the ODFA not later than January 1 and July 1 of each year that will be necessary for payment of principal interest and other costs for the succeeding six-month period.
¶ 9 Section 11 of the Act (Laws 2002, ch. 299 § 11) is not codified; it provides that if there are modifications to the income tax laws of the State of Oklahoma resulting in a significant decline in the amount of withholding taxes attributable to the wages of employees of a qualifying establishment, the Legislature declares its intent to direct such revenues into the Fund as may be required in order for the ODFA to repay the obligations issued pursuant to the Act.
¶ 10 Michelin and Goodyear are required to execute Guaranty Agreements that provide that they will pay if the incentive leverage payments and withholding taxes are inadequate. 68 O.S. Supp.2002 § 3654(M)6. [1080]*1080Section 3660 of the Act provides that if the establishment should cease to qualify for an incentive payment and if the withholding tax collections from the establishment are not sufficient to make required payments of principal and interest, it shall be liable to the ODFA for the amount of any required principal or interest payment.
¶ 11 If the other security levels are inadequate to pay debt service on the bonds, the bonds will be payable from income tax revenues allocated to the Fund as provided in 68 O.S. Supp.2002 § 2352(E).7 That section applies to revenue derived from the income tax imposed on corporations pursuant to 68 O.S. § 2355(C) and (D). No revenues authorized under section 2352 shall be transferred to the Fund until the guaranty terms have been invoked and payment received, or in the event of default under the guaranty. 68 O.S. § 3654(M).
¶ 12 No other security will be pledged, and, according to the ODFA, no third-party bond insurance or credit will be pledged to the payment of the bonds. The bonds will have fixed rates of interest for the maturing amounts, with a final maturity not to exceed twenty (20) years from date of issue.
¶ 13 The Authority sought and received approval by the Council of Bond Oversight as required by 62 O.S.2001 § 695.9. Jerry R. Fent, a resident taxpayer of the State of Oklahoma, has filed a protest to issuance of the bonds. At the outset, he objects to the Council of Bond Oversight as violating the separation of powers doctrine and hence unable to approve the bonds. The constitutionality of the Council of Bond Oversight was recently upheld in In the Matter of the Application of the Okla. Dept. of Transp., 2003 OK 105 ¶ 16, 82 P.3d 1000, and we need not address the issue again.
¶ 14 Protester Fent’s objections fall into three main areas: 1) the bonds are not for a public purpose and they fall within prohibitions against granting exclusive rights or privileges to private corporations; 2) the employee withholding taxes are “trust funds” that cannot be used for other purposes and 3) the bonds are not “revenue bonds” and therefore they create a debt against the State of Oklahoma.
¶ 15 We would reiterate that a heavy burden is placed on those challenging a legislative enactment, and every presumption is to be indulged in favor of the constitutionality of a statute. Application of Oklahoma Capitol Improvement Authority, 1998 OK 25, 958 P.2d 759, 763, cert. den., 525 U.S. 874, 119 S.Ct. 174, 142 L.Ed.2d 142. If two possible interpretations of a statute are possible, only one of which would render it unconstitutional, a court is bound to give the statute an interpretation that will render it constitutional unless constitutional infirmity is shown beyond a reasonable doubt. Fent v. Oklahoma Capitol Improvement Authority, 1999 OK 64, 984 P.2d 200, 204.
I.
BONDS AUTHORIZED FOR VALID PUBLIC PURPOSE WITHIN THE MEANING OF OKLA. CONST. ART. [1081]*108110 § 14,8 AND THE USE OF BOND PROCEEDS IS NOT A GIFT OR SPECIAL PRIVILEGE IN VIOLATION OF OKLA CONST., ART. 10, § 159 OR ART. 5, § 5110
¶ 16 Protester argues that the proposed bond issue violates: Okla. Const., art. 10 § 14, which provides that taxes shall be levied and collected by general laws, and for public purposes only; art. 5 § 51, which prohibits the state from granting any corporation an exclusive right, privilege or immunity; and art. 10 § 15 which restricts a pledge or loan of credit to a corporation.11
¶ 17 Encouragement and promotion of commerce and industry in the state is an authorized function of the State of Oklahoma,. We addressed the “public purpose” requirement in Shipp v. Southeastern Oklahoma Indiistnes Auth., 498 P.2d 1395 (1972). Shipp involved the Southeastern Oklahoma Industries Authority, a public trust created under 60 O.S. § 176. The Authority desired to issue bonds to construct sewer facilities and pollution control devices and the bonds were challenged on the grounds that pollution prevention was not a function that the city was authorized to do, nor one that was specifically authorized by the trust documents. After observing that the State of Oklahoma was the beneficiary of the trust, we said:
“The State of Oklahoma, in performing its basic purposes and functions is invested with the authority to promote and encourage the development of industry and commerce within the state, and to further industrial, manufacturing, cultural, medical and/or educational activities within the state. Doing so are “authorized functions” of the State of Oklahoma.” Shipp at 1399.
¶ 18 In State ex rel. Brown v. City of Warr Acres, 1997 OK 117, 946 P.2d 1140, a qui tarn action, we heard a challenge to the city’s expenditure of public fund to induce a private land trust to lease land to a retailer. We held that the expenditure of public funds met the public purpose requirements of Okla. Const., art. 10, §§ 14 and 17. We said that an economic development plan, in whatever form it takes, will be upheld so long as it serves a public purpose and otherwise meets constitutional requirements. Warr Acres at 1144-45. We said:
Courts are to give great deference to a legislative body’s determination that a particular project will serve a public purpose. In reviewing that determination, courts cannot interfere to arrest legislative action where the line of distinction between that allowable and that which is not is faint and shadowy, [citation omitted]. Such a determination should be reversed only upon a clear showing that it was manifestly arbitrary, capricious, or unreasonable, [citation omitted]. Warr Acres at 1144.
¶ 19 In Burkhardt v. City of Enid, 1989 OK 45, 771 P.2d 608, 610, we stated that the term “public purpose” in relation to art. 10, § 14, should not be construed in a narrow or restrictive sense. We noted that for taxation purposes, public use requires that the work shall be essentially public and for the general good of all the inhabitants of the taxing body. Id. We went on to say that a public purpose affects the inhabitants of the state or taxing district as a community and not merely as individuals. Burkhardt at 611. In that case, the City of Enid desired to purchase Phillips University, a private college, which it would lease back to the university to prevent its closure. Voters had narrowly approved a [1082]*1082sales tax to accomplish the purchase by the City. In discussing the benefits of a university to the public, we listed many factors that are analogous to the benefits to the communities in which the Goodyear and Michelin plants are located. We said that the citizens of Enid will receive many benefits both directly and indirectly: the plan would directly benefit Enid’s economy by the preservation of hundreds of jobs at the university and by the continued presence of students who spend money in Enid. The scholarship fund would enable more area students to attend a local university. The presence of the university would undoubtedly have a significant effect on the city’s ability to attract new industry and new jobs. Finally, we said, Enid would continue to enjoy the social, education and cultural benefits that flow from near access to higher educational opportunities. The overwhelming benefits to the community of Enid, we said, brought the plan within the definition of public purpose.
¶20 Protester Fent asserts that the bonds violate Okla. Const., art. 10 § 15 and art. 5 § 51, which provide that the credit of the State shall not be given, pledged or loaned to any corporation and that the legislature shall pass no law granting any exclusive rights or privileges to any corporation, etc. Fent cites no cases in support of the art. 5 § 51 assertion, but we would note that the inhibition against special privileges and immunities contained in that section was intended to preserve equality between citizens who are similarly situated. Kimery v. Public Service Co. of Okla., 1980 OK 187, 622 P.2d 1066, 1071 An example of an art. § 51 violation was. given in Childers v. West Pub. Co., 1945 OK 85, 195 Okla. 220, 156 P.2d 809, discussing Guthrie Daily Leader v. Cameron, 3 Okla. 677, 41 P. 635, by a law that required that all printing, binding, stationery, and all proclamations and notices that were to be paid for out of the territorial treasury must be purchased from the State Capital Printing Company. Art. 5 § 51 does not apply to the present case.
¶ 21 Burkhardt v. City of Enid, 1989 OK 45, 771 P.2d 608 considered the challenge that the proposed expenditure of public funds was a “gift” or extension of credit to a private institution. We found that the public benefits to the community of Enid constituted consideration to the city and refuted any argument that the plan was a gift or extension of credit to a private institution in violation of art. 10, § 17.12 The challengers had argued that because the lease back to the university was below the market rate for commercial property in Enid, there was inadequate consideration and the transaction was therefore a gift or a loan. We said that this argument ignored the public benefits to the community of Enid and the obligations assumed by Phillips in the transaction. We said that consideration may be measured by benefit to one party or by forbearance, detriment, loss or responsibility assumed by the other part, citing Sharp v. City of Guthrie, 49 Okla. 213, 152 P. 403, 408 (1915). The lease payments were, we said, only one obligation assumed by Phillips in the lease arrangement; Phillips sold its assets to the city at less than market value and agreed to limitations on the use and control of the sale proceeds; Phillips may repurchase the campus, but only at fair market value, but not for less than the amount paid by the city plus the costs of bonds and other financing. These obligations, we said, provided adequate consideration to demonstrate the plan is not a gift or loan to Phillips, but rather a legitimate plan to further economic development by attracting industries to a city that provides higher education opportunities. Burkhardt at 611-612. The Burkhardt court contrasted Veterans of Foreign Wars v. Childers, 197 Okla. 331, 171 P.2d 618 (1946), which involved a direct appropriation by the legislature to the VFW, a private agency, that was free of any control or management by any officer or agency of the state.
¶ 22 In Children’s Home & Welfare Ass. v. Childers, 197 Okla. 243, 171 P.2d 613, 614 (1946), we defined a “gift” in violation of art. 10 § 15 as: “gratuitous transfers of property of the state voluntarily and without consideration.” As discussed herein, the promotion of economic development is a legitimate state function and the benefits to be derived from economic development consti[1083]*1083tute adequate consideration to defeat assertions that economic incentives are in the nature of a “gift.” See, Burkhardt, supra. In addition, section 15(b) of art. 10 specifically authorizes the use of public funds by the Oklahoma Center for the Advancement of Science and Technology “in order to promote economic development” as set out therein.
¶23 In conclusion, we said in Burkhardt that:
Economic development is a public purpose for which a municipality may expend public funds. A municipality may spend public funds for economic development in concert with private actors provided that constitutional requirements are met. Although a municipality may be flexible in structuring its plans for economic development, it must obtain adequate consideration and accountability from a private actor in exchange for the expenditure of public funds. 771 P.2d at 614.
¶ 24 Applicant suggests that the thrust of the Burkhardt and Warr Acres opinions is whether the benefits to the state outweigh the costs of an economic development plan. They note that the Act in the case at bar provides direct savings to the state in the form of benefits foregone by Goodyear and Michelin, which are in excess of the amounts of the bond proceeds to be made available for the plant expansions. The certificate of the Secretary of Commerce estimates that Goodyear’s election means that it will not receive $39,829,748 in benefits and that Michelin’s election not to receive the benefits amounts to $35,813,948. Other benefits to the state are the retained jobs and new jobs, jobs created during construction, and incidental and related business that is generated by the plants and their expansions, resulting in stimulation of the economy of these two communities, as well as the state. The principal amount of the bonds, and therefore the indebtedness incurred by the ODFA, represents only 14.4% of the maximum amount of projected investment for each facility. The Act requires the qualifying establishment to provide evidence that each has or will receive the voter-approved local economic development incentive required by § 3654(B)(1) of the Act. To qualify, an establishment must intend to add substantial gross compensation within three years and it must provide documentation to the ODFA that a minimum of $50,000,000 has been expended or legally committed for a modernization and retooling of an existing facility located in the state before the ODFA is authorized to transfer proceeds to it. 68 O.S. Supp.2002 §§ 3653(l)(c) and 3654(H). The Act requires the manufacturers to execute Guaranty Agreements for the benefit of the ODFA. The Act requires adequate consideration and accountability from the qualifying establishments in exchange for the expenditure of public funds. See, Burkhardt, 771 P.2d at 614.
¶ 25 The protester has failed to meet the burden of showing that the proposed bond issue violates the public purpose requirement or that the sale of the bonds constitutes a gift or special privilege to Goodyear and Michelin.
II.
TRANSFER OF EMPLOYEE WITHHOLDING TAXES BY OKLAHOMA TAX COMMISSION TO THE QUALITY JOBS INCENTIVE LEVERAGE FUND IS NOT A TRANSFER OF TRUST FUNDS
¶26 The second tier of transfers to the ODFA to provide for repayment of the bonds consists of the Goodyear/Michelin employee withholding taxes to be transferred by the Oklahoma Tax Commission to the Quality Jobs Incentive Leverage Fund pursuant to 68 O.S. Supp.2002 § 3659.13 Protester challenges this provision on the grounds that the [1084]*1084employee withholding taxes are “trust funds” to be held for the payment of possible refunds to those employees. Protester Fent argues that this violates Okla. Const., art. 10 § 19, which provides that taxes levied and collected for one purpose shall not be devoted to another purpose. Fent argues that the taxes withheld are trust funds that are to be used only for the submitted purpose and that employee withholding funds are subject to claims by the taxpayers for reimbursement. Allowing these funds to be transferred elsewhere means that other funds would have to be used to pay refund claims by these taxpayers. This argument implies that the employer’s withholding is to be segregated, subject to claims being made for refunds to it’s employees, which is not the case.
¶ 27 The income tax withholding provisions are set out at 68 O.S.2001 § 2385.1 et seq. Section 2385.314 provides that every employer required to deduct and withhold taxes under section 2385.2 of title 68 shall pay over the amount so withheld to the Oklahoma Tax Commission (OTC), and shall file a return in such form as the OTC shall prescribe. Section 2385.3(D) provides that any sums so withheld shall be deemed held [by the employer] in trust for the State of Oklahoma and, as trustee, the employer shall have a fiduciary duty to the State of Oklahoma as to such sums. The duty of the employer, however, is to deduct the proper amount of taxes, pay them over to the Oklahoma Tax Commission and file a return. Once the employer has done that, it has done everything that it is required to do under the statute. The statute provides for penalties for the employer’s failure to do' so. Title 68 O.S.2001 § 2385.14 provides that all taxes deducted and withheld by the employer shall be deemed and credited as payments on account of the tax levied on income for the taxable year.
¶28 Once transferred to the Oklahoma Tax Commission, the funds are under the exclusive control of the OTC and are deposited with the State Treasurer to be deposited in the Oklahoma Tax Commission’s Official Depository Clearing Account. 68 O.S. 2001 § 2385.16. OTC is empowered and directed each month to transfer the amount that OTC estimates to be necessary to make tax refunds into a separate account, to be designated “Income Tax Withholding Refund Account” and to maintain a balance in the refund account sufficient to cover anticipated tax refunds. As to funds remaining in the Official Depository Clearing Account, the OTC is directed to make apportionments from such funds of the amount it considers available as income tax collection. Id. It is readily apparent that there is no suggestion or requirement that the withholdings from a particular employer shall be held in trust for the purpose of paying refunds to that employer’s employees. Once transferred to OTC by the employer, the withheld employee taxes are under the complete control of the OTC and OTC decides which amounts are needed to cover anticipated tax refunds, and which amounts it considers available as income tax collection. Further, 68 O.S. Supp.2002 § 3659(E)15 provides that the amount of withholding taxes transferred to the Quality Jobs Incentive Leverage Fund shall be deemed to be monies held in trust for the benefit of the ODFA in order to repay obligations issued by the ODFA under the Act.16
[1085]*1085¶ 29 Protester Fent also asserts that taxes levied for one purpose shall not be used for another, citing Okla.- Const., art. 10 § 19.17 He argues that the employee withholding taxes are state income tax trust funds-that are not being used for governmental purposes. He cites Vette v. Childers, 102 Okla. 140, 228 P. 145 (1924) for the proposition that under art. 10 § 19, no appropriation of funds in the state treasury can be made for other than a public purpose. That case states that under Okla. Const, art. 10 §§ 14 and 19, money in the state treasury can only be appropriated and used for public púrposes, and in order to constitute a public purpose, the purpose must not only be affected with a public interest, but must be performed by the state in the exercise of its governmental functions. This is essentially the same “public purpose” argument raised by Fent in this case.
¶ 30 The stated purpose of the income tax is to “provide revenue for general governmental functions of state government.” 68 O.S. Supp.2003 § 2352. As discussed in the preceding section, previous cases of this court have demonstrated that economic development is a legitimate purpose of state government. The Shipp case, supra, held that the State of Oklahoma, in performing its basic purposes and functions, is vested with authority to promote and encourage the development of industry and commerce within the state and to further industrial, manufacturing, cultural, medical and/or educational activities within the state. We said that these are “authorized functions” of the State of Oklahoma.” Skipp at p. 1399.
¶ 31 In City of Sand Springs v. Dept. of Public Welfare, 1980 OK 36, 608 P.2d 1139, 1148, the use of sales tax revenues for the construction of a juvenile detention facility was challenged as an illegal use of earmarked funds in violation of art. 10 § 19. After noting that the sales tax statute had been amended to include assistance to delinquent children, we looked to Okla. Const., art. 10 § 23, which gives the Legislature express authority to enact laws transferring existing revenues or surpluses from one fund to another.18 We said that in light of the provision in art. 10 § 23, allowing transfer of existing funds without re-enactment of the tax-levying statute, it was necessary to conclude that art. 10 § 19 of the Constitution had been modified by such express authorization. We stated that the Constitution vests the whole matter of taxation exclusively within the power of the Legislature, as limited by the Constitution, and observed that the appropriation of moneys for the various state purposes rests in the sole discretion of the Legislature, limited only by the Constitution. Those limitations, we said, generally pertain to methods of levying and appropriating taxes and leaves the state purposes served by the use of such tax money largely to the unfettered discretion of the Legislature. Id. See also, Calvey v. Daxon, 2000 OK 17, 997 P.2d 164, 171-172.
¶32 The Court previously has approved bonds that were to be retired by apportionment of taxes to be placed in a special fund. See, Application of Oklahoma Turnpike Authority, 1960 OK 1, 348 P.2d 510, which approved the apportionment of that part of the tax collected from motor fuel consumption on the turnpikes of Oklahoma into a trust fund to be used as a guarantee for the payment of interest on turnpike bonds thereafter issued for the construction of additional turnpikes. In previous turnpike legislation, all money collected as tolls was placed in a general turnpike trust fund to be used to pay for construction and maintenance of the turnpike. The Oklahoma Turnpike Act of 1959 created a separate, segregated trust fund to be created by and contributed to by alloca[1086]*1086tion of a stated portion of the motor fuel tax collected on motor fuel consumed on all Oklahoma turnpike projects, with a limit on the aggregate amount of the allocations and with contingent use of the fund by the Turnpike Authority. We held that the apportionment of part of the tax from motor fuel consumed on the turnpikes into a trust fund, and the possible making of expenditures therefrom did not constitute an illegal use of such tax money, nor did such provision create a debt against the State of Oklahoma. 348 P.2d at 516. See also, Application of Oklahoma Capitol Imp. Auth., 1998 OK 25, 958 P.2d 759, 764, where the funds came from pre-paid user fees and direct taxes dedicated specifically to the State Transportation Fund and earmarked for payment of highway bonds on an annual basis. Those taxes derived from direct taxes on motor fuels and other fuels, vehicle license and registration fees and ap-portionments levied under an environmentally-based indemnity fund. In addition, there was a newly-authorized revenue stream that dedicated Rainy Day Funds to fund highway improvements. Id.
¶ 33 Unless there is a specific constitutional prohibition, the Legislature has the right and responsibility to declare fiscal policy. Fent v. Oklahoma Capitol Improvement Authority, 1999 OK 64 ¶ 5, 984 P.2d 200, 204. The Legislature has determined that the use of incentive payments, and a mechanism for leveraging those payments, is a method of promoting economic benefits for the state, its political subdivisions and its residents. 68 O.S. Supp. § 8652. In Fent, we said:
Simply, in ruling on the constitutional validity of a statute relating to this State’s fiscal affair’s, we are not allowed to consider whether it is based on sound economic theory or whether it is the best means to achieve the desired result because such matters are for legislative determination, (citation omitted). Id.
¶ 34 We find that the apportionment of the employee withholding taxes under the Act does not violate Okla. Const., art. 10 § 19 and does not constitute a transfer of “trust funds” as alleged by the protester.
III.
BONDS NOT IN VIOLATION OF DEBT-LIMITATION PROVISIONS OF OKLA. CONST., ART. 10 §§ 23 AND 2519
¶35 In Fent v. Oklahoma Capitol Improvement Authority, 1999 OK 64, 984 P.2d 200, we determined that the bonds to be issued, along with the two statutes involved, did not violate Okla. Const., art. 10 §§ 23 and 25 because neither statute authorized state debt as contemplated by those constitutional balanced-budget provisions. We said that at most the statutes authorized only appropriation-risk or moral obligations bonds, and that under our previous cases, the issuance and sale of such bonds did not create a debt in a constitutional sense.
¶ 36 Likewise in Application of Oklahoma Capitol Improvement Authority, 1998 OK 25, 958 P.2d 759, we said that no constitutional debt was created where no legal obligation to pay beyond the current annual appropriation existed because future legislatures were not obligated to provide funding to retire the bonds.
¶ 37 Protester Fent argues in the present case that the bonds are not revenue bonds because the state’s withholding taxes are being used to pay off the bonds, in violation of Okla. Const. Article 10 §§23 [1087]*1087and 25, and that the employee withholding portion of the Act, § 3659(E) is illegal and unconstitutional as in violation of art. 10 § 23 Okla. Const. Fent has cited no cases in support of these propositions. It appears that the argument is that because no revenue stream is generated, such as by the sale of electricity or 'other services, the bonds are not self-liquidating and are in violation of the debt limitation provisions.
¶ 38 This bond issue is similar to previous bond issues approved by this Court. As early as 1960, this Court characterized bonds as self-liquidating where the legislature appropriated money to enable state agencies to pay the rent on the state office buildings to be constructed by the bond issue. There, the only source of revenue consisted of state appropriations. , Application of Okla. Cap. Imp. Auth., 1960 OK 207, 355 P.2d 1028, 1031. In Application of Okla. Cap. Imp. Auth., 1998 OK 25, 958 P.2d 759, 764, the bonds were determined to be self-liquidating where a dedicated tax on motor fees and other special fuels, as well as vehicle licenses, were specifically earmarked to retire the bonds, as well as an apportionment of assessments levied under an environmentally-based indemnity fund and appropriations from the Rainy Day Fund.
¶ 39 In the present case, the primary source of payment of the bonds is the foregone incentive payments that Goodyear and Michelin are otherwise entitled to receive under the Oklahoma Quality Jobs Program Act, 68 O.S. § 3601 et seq. Instead of being paid these sums directly, the amounts will be transferred to the Quality Jobs Incentive Leverage Fund to be used for repayment of the bonds. See, 68 O.S. Supp.2002 § 3658(A). The Act specifically provides that the incentive payments shall be treated as an asset of the establishment that has been paid to the State of Oklahoma. 68 O.S. Supp.2002 § 3658(B). The Secretary of Commerce of the State of Oklahoma has certified that these foregone benefits are in amounts sufficient to pay the bonds. The liability of the State of Oklahoma to make the incentive payments under the Oklahoma Quality Jobs Program Act-is limited to the balance contained in the Quality Jobs Program Incentive Payment Fund. 68 O.S.2001 § 3605. Protester Fent has not taken exception to the incentive payments provided by the Oklahoma Quality Jobs Program Act; it is these same funds that are transferred to the Quality Jobs Incentive Leverage Fund to be used for repayment of the bonds. No debt is created thereby.
¶40 The second level of security consists of the employee withholding taxes attributable to the qualifying establishment that are transferred to the Fund in the amount needed each fiscal year if the incentive payments are not enough. Again, the amount to be transferred shall be determined in each fiscal year and there is no obligation to make the transfers beyond a fiscal year.
¶41 Michelin and . Goodyear are also required to execute the Guaranty Agreement required by section 3654(M) of the Act that they will pay the debt service on the bonds if the incentive and withholding amounts are not sufficient. Section 3660 of the Act pro: vides that if the establishment should cease to qualify for an incentive payment and if the withholding tax collections from the establishment are not sufficient to make required payments of principal and interest, it shall be liable to the ODFA for the amount of any required principal or interest payment.
¶42 If the foregoing are inadequate, 68 O.S. Supp.2002 § 2352(E) authorizes an allocation to the Quality Jobs Program Incentive Leverage Fund of income tax revenue for any period of time certified by the ODFA and the Oklahoma Department of Commerce to be necessary for the repayment of obligations issued under the Act. Again, the determination of amounts that may be required is determined for each fiscal year.
1Í43 In addition, Section 11 of the Act,20 which is not codified, contains an expression of intent on the part of the legisla[1088]*1088ture to provide for the payment of the bonds in the event the state income tax laws are changed. Protester Fent argues that the Legislature’s promise to pay the future debts of the state Quality Jobs Program Incentive Leverage Fund is an unconstitutional violation of art. 10, §§ 23 and 25 of the Oklahoma Constitution. Section 11 provides that if there are changes to the income tax laws of the State of Oklahoma that result in a significant decline in the withholding taxes referred to in the Act, the Legislature declares its intent to direct such revenues for deposit into the Quality Jobs Program Incentive Leverage Fund as may be required in order for the ODFA to repay the obligations issued pursuant to the Act. Applicant points out that this later source of payment is merely a “moral obligation” to pay, just as in Fent v. Okla. Cap. Imp. Auth., 1999 OK 64, 984 P.2d 200.
¶ 44 In Fent, the statutes under consideration authorized the Oklahoma Capitol Improvement Authority to issue bonds to fund various government projects ranging from the construction of a new building for the J.D. McCarty Center to the purchase of computer hardware and software for the Oklahoma Department of Central Services. The bonds were to be retired by payments made to the OCIA by the various departments and/or instrumentalities using and/or benefit-ting from the projects. The statutes expressed an intention to appropriate sufficient monies to the various agencies, etc., to make the payments to OCIA for retiring the bonds; nowhere in either statute was there a provision obligating future legislatures to do so. Fent at pp. 206-207. We determined that no debt as contemplated by Okla. Const., art. 10 §§ 23, 24 and 25 was created against the State if money was not appropriated and, thus, those provisions of our fundamental law were not applicable. 984 P.2d at 208.
¶ 45 Section 11 creates what are referred to as “moral obligation bonds.” In Application of Oklahoma Capitol Improvement Authority, 1998 OK 25, ¶ 56, 958 P.2d 759, 775, we said:
“The statute specifically provides that bonds shall not at any time be deemed to eonstitute a debt of the state or of any political subdivision and it requires that the bonds contain on their face a statement that neither the full faith and credit nor the taxing power of the state or any political subdivision is pledged for the payment of the principal and interest of the bonds. There is no legally enforceable contract between this State’s Legislature and either the Authority, the Department or the citizens of this state to make the anticipated appropriations necessary to satisfy the debts created by the issuance of the bonds. At most, a ‘moral obligation’ arises to continue funding.”
¶ 46 In the instant case, the Act provides, and the bonds will reflect on the face thereof, that they do not constitute obligations of the State of Oklahoma. The Indentures and the Bonds provide:
THIS BOND IS BEING ISSUED UNDER THE PROVISIONS OF THE OKLAHOMA DEVELOPMENT FINANCE AUTHORITY ACT AND IT SHALL NEVER CONSTITUTE AN INDEBTEDNESS OF THE STATE OF OKLAHOMA WITH IN THE MEANING OF ANY STATE CONSTITUTIONAL PROVISION OR STATUTORY LIMITATION, BUT SHALL BE INDEBTEDNESS PAYABLE SOLELY FROM SOURCES INDICATED HEREIN, AND SHALL NEVER CONSTITUTE NOR GIVE RISE TO A PECUNIARY LIABILITY OF THE STATE OF OKLAHOMA OR UNSPECIFIED FUNDS OF THE OKLAHOMA DEVELOPMENT FINANCE AUTHORITY OR A CHARGE AGAINST THE GENERAL CREDIT OF THE STATE OF OKLAHOMA OR TAXING POWER OF THE STATE OF OKLAHOMA.
We said in Fent v. Oklahoma Capitol Improvement Authority, 984 P.2d at 208:
“Unquestionably, provisions obligating future legislatures are unconstitutional. However, here there is simply nothing to bind future legislative bodies to make the anticipated appropriations. Future revenues are not pledged ... for retirement of [1089]*1089the proposed bonds. The present Legislature’s intent to appropriate the monies is not a binding commitment on future legislatures to do so.” (quoting from Application of Oklahoma Capitol Improvement Authority, 1998 OK 25, 958 P.2d 759, at 771)
CONCLUSION
¶ 47 Title 20 O.S.2001 § 14.1 provides that if the Court is satisfied that the obligations have been properly authorized in accordance with the law and that, when issued, they will constitute valid obligations in accordance with their terms, the Court shall render its written opinion approving the obligations. Accordingly the bond issue is approved. Any petition for rehearing in regal’d to this matter shall be filed within twenty (20) days of the date of this opinion.
ORIGINAL JURISDICTION ASSUMED; PROPOSED BOND ISSUE APPROVED.
¶ 48 Concur: WATT, C.J., HODGES, HARGRAVE, WINCHESTER, EDMONDSON, JJ.
¶ 49 Dissent: OP ALA (joins BOUDREAU, J.), V.C.J., LAVENDER (joins BOUDREAU, J.), BOUDREAU (by separate writing), JJ.
¶ 50 Recused: KAUGER, J.