tended to be confusing as often famous initiatives such as Proposition 13 in 1978 might be confused with another initiative in a later year if there were more than twelve proposals on the ballot in any given year. Starting with the November 1982 ballot, the proposition numbers were not re-used but continued to increment every election, eventually resulting in proposition numbers exceeding 200 by the 1996 election. For the November 1998 ballot, the count was reset back to one. It is now reset every ten years. Conflicting propositions Under Article II, Section 10(b) of the California Constitution, "If provisions of 2 or more measures approved at the same election conflict, those of the measure receiving the highest affirmative vote shall prevail." However, those provisions that do not conflict with the winning proposition may still go into effect. To get around this loophole, many initiatives include so-called "poison pill" clauses, specifying which provisions are voided in the other propositions. The rule in the constitution was clarified in 1990 by the California Supreme Court in its ruling in Taxpayers to Limit Campaign Spending v. Fair Political Practices Commission: When two or more measures are competing initiatives, either because they are expressly offered as "all-or-nothing" alternatives or because each creates a comprehensive regulatory scheme related to the same subject, section 10(b) mandates that only the provisions of the measure receiving the highest number of affirmative votes be enforced. The Court was concerned that attempts to combine the non-conflicting provisions in such competing initiatives would result in regulatory schemes completely different from what the electorate understood or intended. Criticisms Criticism has been raised of the initiative process, suggesting that with trends toward lower voter turnouts, and evidence for voter disinterest in candidates and issues other than in presidential elections, that a "direct democracy system specifically designed to be inflexible" might be infeasible to continue as a way to make important California public policy decisions. Issues have also been raised regarding the narrowing of democratic access imposed by the high cost of conducting initiatives and referendums, and by the challenges raised by attempting comprehensive governance in the face of individual, non-comprehensive (and sometimes at least partially contrary) initiatives. Generally, because of California's size and population, proponents of a ballot initiative or referendum need significant amounts of money and resources to first gather the required number of petition signatures, and then campaign across the state for