Plaintiff seeks enforcement of the Taxpayer’s Bill of Rights of the Colorado Constitution (“TABOR”). Colo. Const. art. X, § 20. TABOR requires a vote of the people before the State or any local government may: create new debt, levy new taxes, increase tax rates, or institute tax policy changes directly causing a net tax revenue gain. Id. Without a vote of the people, the Colorado Bridge Enterprise has created new debt, levied new taxes, increased tax rates, and instituted tax policy changes causing a net tax revenue gain to the Colorado Department of Transportation and the Bridge Enterprise. By taking these actions without a vote of the people, Defendants have violated the rights of Plaintiff’s members to vote on the imposition of new taxes and debt, as guaranteed by TABOR. Plaintiff therefore seeks declaratory and injunctive relief to abate and correct Defendants’ unconstitutional actions.