[537]*537JONES, J.
The issue in this case is whether Article IX, section 3a, of the Oregon Constitution1 prohibits the use of highway funds for the construction of a parking lot and covered walkway at the Eugene municipal airport. Lane County (County) and the City of Eugene (City) entered into an agreement for the purpose of sharing certain highway funds. The County and the City brought a validation proceeding pursuant to ORS 33.710(2) (d) to obtain judicial approval of the agreement. William R. Rogers, Jr. (Rogers), appeared and objected to the validation. The trial court held that the construction of such improvements with highway funds is authorized by Article IX, section 3a, of the Oregon Constitution. The Court of Appeals reversed the decision of the trial court. Rogers v. Lane County, 91 Or App 579, 756 P2d 665 (1988). We affirm the decision of the Court of Appeals.
I. FACTS
On January 23, 1987, the County and the City entered into an agreement entitled “Intergovernmental Agreement” (Agreement) in order to share certain funds authorized by ORS 294.950(2), which provides:
“Subject to the limitation contained in subsection (3) of this section, a county may share the proceeds of any tax or excise described in section 3a, Article IX of the Oregon Constitution, with any city situated in whole or in part within the county for the purposes stated in that section.”
Pursuant to the Agreement, the County granted $1,574,144 to the City to be used in connection with the expansion and improvement of Mahlon Sweet Field, an airport owned and operated by the City. These funds were highway fund monies distributed to the County by the State of Oregon. Because Article IX, section 3a, of the Oregon Constitution states that such funds “shall be used exclusively for the construction, reconstruction, improvement, repair, maintenance, operation and use of public highways, roads, streets and roadside rest [538]*538areas,” the Agreement limited the use of the granted funds to “expenditures allowable under Oregon Constitution, Art. IX, sec. 3a.” More specifically, the Agreement provided that the funds were to be used for the following improvements: (1) entry and exit roads for travel to and from the airport, (2) a public parking lot adjacent to the entry and exit roads, and (3) a covered walkway from the parking lot to the airport terminal.
Under ORS 33.710(2)(d), certain public bodies may petition a circuit court “for the purpose of having judicial examination and judgment of the court as to the regularity and legality of * * * [t]he authorization of any contract.” Under this statute, the County and the City filed a validation proceeding to test the legality of the Agreement, seeking a judgment that they had authority to enter into the Agreement under ORS 294.950 and that the expenditures described in the Agreement were lawful. ORS 33.720(3) allows “[a]ny person interested * * * [to] appear and contest the validity of such proceeding, or of the acts or things therein enumerated.” Rogers contested the validation, arguing that the Agreement was illegal and invalid because the proposed expenditures violated Article IX, section 3a, of the Oregon Constitution.
The trial court found that the construction of the improvements provided for in the Agreement was a proper use of the road funds:
«* * * [I]t’s my opinion that the agreement entered into now between the City and the County is legal. It does meet all the statutory and constitutional requirements that are necessary for it to enter into that agreement. The use and benefit theory is one that I think makes a great deal of sense, particularly in this sort of situation. The parking lot, the access roads, the walkway all seem to me to be directly related to and for the direct use and benefit of the motoring public to use the roads that go to the airport.”
The trial court applied a so-called “use-benefit theory” which, as applied to Article IX, section 3a, originated from opinions of the Oregon Attorney General. The use-benefit theory requires that taxes derived from the use of the highways be applied for the benefit of those who pay the taxes:
“Does the program benefit those who pay the taxes which [539]*539would support it? Specifically, does it render use of the highways more convenient or more pleasurable?” 35 Op Att’y Gen 70, 75 (Or 1970).
The Court of Appeals reversed the trial court’s decision with respect to the parking lot and covered walkway. The Court of Appeals, in effect, held that the trial court erred in relying solely on the use-benefit test, quoting the following excerpt from 41 Op Att’y Gen 545, 547 (Or 1981):
“ ‘[B]enefit alone is not sufficient. Art IX, Sec 3a does not authorize expenditures for anything as broad as benefits to highway users, but limits them “exclusively for the construction, reconstruction, improvement, repair, maintenance, operation and use of public highways, roads, streets and roadside rest areas * * *.
“ ‘In short, expenditures must be for the highway itself. In 35 Op Atty Gen 198 (1970), it was concluded that indirect benefits to highway users, such as mass transit facilities which reduce highway congestion, were not included.’ (Emphasis in original.)” Rogers, 91 Or App at 582.
The Court of Appeals noted that “[although Attorney General opinions are not precedential, [Alexander v. Gladden, 205 Or 375, 383, 288 P2d 219 (1955),] the [above] excerpt is consistent with the legislative intent expressed in the Voters’ Pamphlet concerning the ballot measure by which the people adopted Article IX, Section 3a.” 91 Or App at 582. The Court of Appeals held:
“Given the specific language in Article IX, section 3a, and the legislative intent expressed in the Voters’ Pamphlet, we conclude that the proposed expenditures for a parking lot facility and covered walkways are not authorized by the constitution. They are, at best, highway-related projects.” 91 Or App at 583.
The County and the City now seek review and reversal of the Court of Appeals opinion.
II. BACKGROUND
A Transportation Research Board report provides an historical foundation for our discussion:
“Prior to the decade of the 1930’s, highways that connected major cities on an interstate basis were either nonexistent or a connection of county roads, mostly unpaved, poorly graded, and ill-equipped for motor vehicle travel.
[540]*540“To remedy this situation, the several States enacted legislation imposing a tax on gasoline or other liquid motor fuel and a further tax on any license, registration fee, or other charge with respect to the operation of motor vehicles on the public highways.
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[537]*537JONES, J.
The issue in this case is whether Article IX, section 3a, of the Oregon Constitution1 prohibits the use of highway funds for the construction of a parking lot and covered walkway at the Eugene municipal airport. Lane County (County) and the City of Eugene (City) entered into an agreement for the purpose of sharing certain highway funds. The County and the City brought a validation proceeding pursuant to ORS 33.710(2) (d) to obtain judicial approval of the agreement. William R. Rogers, Jr. (Rogers), appeared and objected to the validation. The trial court held that the construction of such improvements with highway funds is authorized by Article IX, section 3a, of the Oregon Constitution. The Court of Appeals reversed the decision of the trial court. Rogers v. Lane County, 91 Or App 579, 756 P2d 665 (1988). We affirm the decision of the Court of Appeals.
I. FACTS
On January 23, 1987, the County and the City entered into an agreement entitled “Intergovernmental Agreement” (Agreement) in order to share certain funds authorized by ORS 294.950(2), which provides:
“Subject to the limitation contained in subsection (3) of this section, a county may share the proceeds of any tax or excise described in section 3a, Article IX of the Oregon Constitution, with any city situated in whole or in part within the county for the purposes stated in that section.”
Pursuant to the Agreement, the County granted $1,574,144 to the City to be used in connection with the expansion and improvement of Mahlon Sweet Field, an airport owned and operated by the City. These funds were highway fund monies distributed to the County by the State of Oregon. Because Article IX, section 3a, of the Oregon Constitution states that such funds “shall be used exclusively for the construction, reconstruction, improvement, repair, maintenance, operation and use of public highways, roads, streets and roadside rest [538]*538areas,” the Agreement limited the use of the granted funds to “expenditures allowable under Oregon Constitution, Art. IX, sec. 3a.” More specifically, the Agreement provided that the funds were to be used for the following improvements: (1) entry and exit roads for travel to and from the airport, (2) a public parking lot adjacent to the entry and exit roads, and (3) a covered walkway from the parking lot to the airport terminal.
Under ORS 33.710(2)(d), certain public bodies may petition a circuit court “for the purpose of having judicial examination and judgment of the court as to the regularity and legality of * * * [t]he authorization of any contract.” Under this statute, the County and the City filed a validation proceeding to test the legality of the Agreement, seeking a judgment that they had authority to enter into the Agreement under ORS 294.950 and that the expenditures described in the Agreement were lawful. ORS 33.720(3) allows “[a]ny person interested * * * [to] appear and contest the validity of such proceeding, or of the acts or things therein enumerated.” Rogers contested the validation, arguing that the Agreement was illegal and invalid because the proposed expenditures violated Article IX, section 3a, of the Oregon Constitution.
The trial court found that the construction of the improvements provided for in the Agreement was a proper use of the road funds:
«* * * [I]t’s my opinion that the agreement entered into now between the City and the County is legal. It does meet all the statutory and constitutional requirements that are necessary for it to enter into that agreement. The use and benefit theory is one that I think makes a great deal of sense, particularly in this sort of situation. The parking lot, the access roads, the walkway all seem to me to be directly related to and for the direct use and benefit of the motoring public to use the roads that go to the airport.”
The trial court applied a so-called “use-benefit theory” which, as applied to Article IX, section 3a, originated from opinions of the Oregon Attorney General. The use-benefit theory requires that taxes derived from the use of the highways be applied for the benefit of those who pay the taxes:
“Does the program benefit those who pay the taxes which [539]*539would support it? Specifically, does it render use of the highways more convenient or more pleasurable?” 35 Op Att’y Gen 70, 75 (Or 1970).
The Court of Appeals reversed the trial court’s decision with respect to the parking lot and covered walkway. The Court of Appeals, in effect, held that the trial court erred in relying solely on the use-benefit test, quoting the following excerpt from 41 Op Att’y Gen 545, 547 (Or 1981):
“ ‘[B]enefit alone is not sufficient. Art IX, Sec 3a does not authorize expenditures for anything as broad as benefits to highway users, but limits them “exclusively for the construction, reconstruction, improvement, repair, maintenance, operation and use of public highways, roads, streets and roadside rest areas * * *.
“ ‘In short, expenditures must be for the highway itself. In 35 Op Atty Gen 198 (1970), it was concluded that indirect benefits to highway users, such as mass transit facilities which reduce highway congestion, were not included.’ (Emphasis in original.)” Rogers, 91 Or App at 582.
The Court of Appeals noted that “[although Attorney General opinions are not precedential, [Alexander v. Gladden, 205 Or 375, 383, 288 P2d 219 (1955),] the [above] excerpt is consistent with the legislative intent expressed in the Voters’ Pamphlet concerning the ballot measure by which the people adopted Article IX, Section 3a.” 91 Or App at 582. The Court of Appeals held:
“Given the specific language in Article IX, section 3a, and the legislative intent expressed in the Voters’ Pamphlet, we conclude that the proposed expenditures for a parking lot facility and covered walkways are not authorized by the constitution. They are, at best, highway-related projects.” 91 Or App at 583.
The County and the City now seek review and reversal of the Court of Appeals opinion.
II. BACKGROUND
A Transportation Research Board report provides an historical foundation for our discussion:
“Prior to the decade of the 1930’s, highways that connected major cities on an interstate basis were either nonexistent or a connection of county roads, mostly unpaved, poorly graded, and ill-equipped for motor vehicle travel.
[540]*540“To remedy this situation, the several States enacted legislation imposing a tax on gasoline or other liquid motor fuel and a further tax on any license, registration fee, or other charge with respect to the operation of motor vehicles on the public highways. The revenues raised by the imposition of such taxes was then set aside for highway construction and maintenance. To insure that this revenue was not diverted to other uses, legislation was enacted, and frequently constitutional amendments adopted that earmarked such funds for the sole or exclusive purpose of construction, maintenance, and supervision of the public highways of the State. The language employed in these so-called ‘antidiversion’ constitutional amendments differs somewhat from State to State, but their purpose is uniform — to preserve and limit expenditure of the funds for a ‘highway purpose.’ ” Research Results Digest 68, March 1975, pp 1-2.
Oregon was no exception to this historical development.
Prior to 1942, Oregon’s use of monies derived from gasoline taxes and other vehicle fees was governed by statute. See Title 100 of OCLA (1940). At the November 1942 election, however, the people adopted an amendment to Article IX, section 3, of the Oregon Constitution which provided in relevant part:
“* * * The proceeds from any tax levied on, with respect to, or measured by the storage, withdrawal, use sale, distribution, importation or receipt of motor vehicle fuel or any other product used for the propulsion of motor vehicles, and the proceeds from any tax or excise levied on the ownership, operation or use of motor vehicles shall * * * be used exclusively for the construction, reconstruction, improvement, repair, maintenance, operation, use and policing of public highways, roads and streets within the state of Oregon, including the retirement of bonds for the payment of which such revenues have been pledged, and also may be used for the acquisition, development, maintenance, care and use of parks, recreational, scenic or other historic places and for the publicizing of any of the foregoing uses and things.”
A joint legislative subcommittee submitted an argument for the Voters’ Pamphlet in favor of the amendment in which it stated that the amendment
“provide[d] that the state keep faith with the users of its highways who gladly pay and have paid these taxes because of [541]*541their unquestioning reliance and full expectation that the proceeds would be applied to the highway purposes to which they now are dedicated. [The amendment] make[s] certain that the present policy of this state to use highway user funds for highway purposes will be continued.”
In State ex rel Sprague v. Straub, 240 Or 272, 279, 400 P2d 229, 401 P2d 29 (1965), this court commented on the intent of the voters with respect to the enactment of this constitutional amendment:
“Article IX, Section 3 of the constitution * * * restricted the use of this form of revenue to highway purposes. It is apparent that the intent of the people when they adopted the amendment was to guarantee that none of the ‘proceeds’ of the taxes and fees listed in the amendment would be diverted to any other purpose.”
In short, this constitutional amendment made it clear and unambiguous that the people of Oregon wanted monies derived from taxes and fees on motor vehicles and motor vehicle fuels to be used only for highway purposes.
In the 1970s, a number of people were not happy with the use of their motor vehicle and gasoline taxes.2 The condition of Oregon’s state highway system had seriously declined during the latter half of the decade.3 Despite this state of affairs, Oregon voters rejected a one cent increase in gasoline taxes in 1976 (Ballot Measure No. 8 of the 1976 general election) and a two cent increase in gasoline taxes in 1978 (Ballot Measure No. 5 of the 1978 primary election). A 1979 poll indicated, however, that the majority of the people of Oregon were willing to support a gas tax increase if the monies derived therefrom were used only for highway maintenance and construction.4 The legislature was aware of this poll5 and responded by passing Senate Joint Resolution 7 (SJR 7), which proposed the repeal of Article IX, section 3, and the enactment of a new section in its place. The legislature [542]*542referred this measure to the Oregon voters, who approved it at the May 20,1980, primary election.
In relevant part, the new section 3a, which is in effect today, eliminated the use of motor vehicle and gasoline taxes for the funding of police, parks, scenic and historic places, permitting the use of such funds only for highways, roads, streets, and roadside rest areas:
“(1) * * * [R]evenue from the following shall be used exclusively for the construction, reconstruction, improvement, repair, maintenance, operation and use of public highways, roads, streets and roadside rest areas in this state:
“(a) Any tax levied on, with respect to, or measured by the storage, withdrawal, use, sale, distribution, importation or receipt of motor vehicle fuel or any other product used for the propulsion of motor vehicles; and
“(b) Any tax or excise levied on the ownership, operation or use of motor vehicles.”
The Voters’ Pamphlet contained a Joint Legislative Committee argument6 in favor of the ballot measure, which stated in part:
“It’s time to save our multi-billion dollar investment in our highway system. It’s time to stop the raid on the Highway Fund. It’s time to reduce gasoline consumption, reduce auto repairs, and make our highways safer.
“* * * Measure No. 1 will protect the Highway Fund; it will constitutionally dedicate the Highway Fund to streets, roads, and highways only.
“Under present law the Highway Fund can be used to pay for state police, parks, and other ‘highway-related programs.’ This has been done and the result has been to rob our highways of needed maintenance.
“These so-called ‘highway-related programs’ will still be funded but will be financed from the State General Fund — not from gasoline taxes, weight-mile taxes, and vehicle registration fees.
U* * * * *
“A POORLY MAINTAINED HIGHWAY SYSTEM is costing all of us a lot of money. Over 58% of our highways have been designated moderately or extremely deteriorated by the [543]*543Highway Preservation Study. This percentage will grow every year under our present funding system.
“Our rough and crumbling road system is not just uncomfortable and inconvenient. It can lead to economic decline in our state. It will mean more costly rebuilding of our highways if timely repairs are not made. Rough roads bring greatly reduced fuel efficiency. Bad roads increase the number of costly automobile repairs. Highway deterioration also contributes to automobile accidents and higher auto insurance costs.
“Ballot Measure No. 1 says that the Highway Fund ‘shall be used exclusively for the construction, reconstruction, improvement, repair, and maintenance, operation and use of public highways, roads, streets, and roadside rest areas in this state.’ IT’S ABOUT TIME.” (Emphasis added; capitalization in original.)
The Joint Legislative Committee focused on highway maintenance and made statements such as: “It’s time to stop the raid on the Highway Fund”; “[This measure] will constitutionally dedicate the Highway Fund to streets, roads, and highways only”; “Under present law the Highway Fund can be used to pay for state police, parks, and other ‘highway-related programs’^ * * * [this has] rob[bed] our highways of needed maintenance”; and “[Under this measure] [t]hese so-called ‘highway-related programs’ will * * * not [be financed] from gasoline taxes * * * and vehicle registration fees.” (Emphasis added.)7
[544]*544III. WHETHER ARTICLE IX, SECTION 3a AUTHORIZES THE SPENDING OF HIGHWAY FUNDS ON AIRPORT PARKING LOTS AND COVERED WALKWAYS
We begin by examining the language of Article IX, section 3a, of the Oregon Constitution. Article IX, section 3a, provides in relevant part that motor vehicle and fuel taxes “shall be used exclusively for the construction, reconstruction, improvement, repair, maintenance, operation and use of public highways, roads, streets and roadside rest areas.” The objects on which these highway funds may be used include only “public highways, roads, streets and roadside rest areas.” Airport parking lots and covered walkways from an airport parking lot to an airport terminal are not included in this series. Nonetheless, petitioners argue that the authorization for spending these highway funds on such projects is derived from the terms “improvement, * * * operation and use.” We now address that contention.
As discussed above, Article IX, section 3a, originated from SJR 7. SJR 7 and the Joint Legislative Committee argument in favor of the measure appeared in the official Voters’ [545]*545Pamphlet for the 1980 primary election. State ex rel Chapman v. Appling, 220 Or 41, 68-69, 348 P2d 759 (1960), stated:
“This court has recognized in a number of cases that arguments in the official Voters’ Pamphlet relative to measures submitted to the people may be resorted to as an aid to construction. Discriminating and cautious use must be made of such material because of its partisan character. We think, however, that in the present instance it is proper to refer to the argument in favor of this [constitutional amendment]. * *
As in Appling, the Voters’ Pamphlet argument in this case helps us in resolving this dispute. The language of this argument in favor demonstrates that the Joint Legislative Committee clearly intended a narrow application of this new constitutional provision to the specific purposes stated. Accordingly, we narrowly construe Article IX, section 3a.
Because the language of Article IX, section 3a, must be narrowly construed, expenditures of motor vehicle and fuel taxes within the meaning of “improvement, * * * operation and use” must be limited exclusively to expenditures on highways, roads, streets and roadside rest areas themselves and for other projects or purposes within or adjacent to a highway, road, street or roadside rest area right-of-way that primarily and directly facilitate motorized vehicle travel. In the instant case, the proposed expenditure of highway funds for the construction of an airport parking lot and a covered walkway from the parking lot to the airport terminal is simply a convenient “raid” on highway funds. The expenditure does not fall within these definitions, because the proposed expenditure is an expenditure for the construction of an airport parking lot and covered walkway, rather than an expenditure for a highway, road, street or roadside rest area itself. Further, it is an expenditure primarily for the operational convenience of an airport, rather than for a project or purpose within or adjacent to a highway, road, street or roadside rest area right-of-way that primarily and directly facilitates motorized vehicle travel.
IV. CONCLUSION
We agree with the Court of Appeals that these proposed expenditures “are, at best, highway-related projects.” 91 Or App at 583. Accordingly, we hold that the proposed expenditure of funds for the construction of an airport parking lot [546]*546and covered walkway from the parking lot to the airport terminal is not authorized by Article IX, section 3a, of the Oregon Constitution.
The decision of the Court of Appeals is affirmed, and the decision of the trial court is reversed.