DREW, J.

The City of Memphis, Tennessee, operates a municipal public utility through its Light, Gas, and Water Division. The natural gas plant is located within the corporate limits of the City of Memphis and Shelby County and provides electric, gas, and water service to residents of the area. In the course of its operations as a municipal public utility, the Memphis Light, Gas, and Water Division ("MLGW") purchases natural gas, some of which is temporarily stored in West Carroll Parish until needed at peak times during the winter. The parties agree that:

• MLGW is a Tennessee political subdivision;

• the stored natural gas is public property; and

• equivalent volumes of the stored MLGW natural gas were later delivered exclusively to Memphis for sale to MLGW's customers.

The dispute here is whether the gas is "held for public purposes." We find that it is, and is thus exempt from Louisiana ad valorem taxes.

FACTUAL BACKGROUND

For the tax years 2009, 2010, 2011, and 2012, West Carroll Parish Assessor Deanna K. Smith assessed this natural gas inventory for ad valorem tax purposes.

West Carroll Parish Sheriff Jerry Philley issued property tax bills totaling $406,041.85 on those assessments.

During the tax years at issue, MLGW purchased natural gas from suppliers who delivered the volumes purchased into Trunkline Gas Company, LLC's interstate natural gas pipeline system at points in Louisiana and Texas. All of the natural gas received by Trunkline into its pipeline system is commingled as multiple buyers and sellers use the pipeline simultaneously. Once an amount of natural gas is delivered into the pipeline for MLGW's account, energy-equivalent volumes are deliverable to MLGW, pursuant to a computerized scheduling system.

Trunkline also offers storage as a part of its transportation services. MLGW uses a computerized system to nominate volumes for injection, storage, and withdrawal from Trunkline's storage facility in West Carroll Parish.

MLGW paid the taxes under protest and filed suit against the local public officials, seeking a refund because of its tax-exempt status.

LEGAL DISPUTE

MLGW asserts four different grounds for its claim of exemption, the first of which is dispositive of this dispute. We find that MLGW's natural gas, stored in West Carroll Parish, is "public property held for public purposes" and therefore exempt under the provisions of Art. VII, § 21(A) of the Louisiana Constitution.1

Both parties filed cross-motions for summary judgment that were brought for hearing on June 10, 2013. On July 25, 2013, the trial court issued written reasons for judgment holding that the stored natural gas was "public property used for public purposes" and was therefore exempt from property taxation under Art. VII, § 21 of the Louisiana Constitution. We have attached and adopt in toto the trial court's excellent reasons for judgment.

INITIAL ANALYSIS

Over 60 years ago, the Louisiana Supreme Court ruled on a facially similar issue in Warren County, Miss. v. Hester, 219 La. 763, 54 So.2d 12 (1951). That case held in dicta that for taxation purposes, "public property" refers only to property of Louisiana and its political subdivisions.

The trial court here referenced Hester, supra, but declined to follow the ruling, stating, "this court does not feel constrained to follow the reasoning and ruling of Hester," noting that "the limiting terms `Louisiana' or `Louisiana political subdivisions' do not appear in the constitutional provision providing for the exemption of `public property used for public purposes'."

The trial court held that:

• the general rule for interpreting constitutional provisions is to give words their generally understood meaning;

• when a constitutional provision is plain and unambiguous and its application does not lead to absurd consequences, its language must be given effect;

• the natural gas owned by MLGW is public property used for public purposes and as such, is exempt from taxation under Art. VII, § 21(A);

• the exemption of public property used for public purposes is not limited to the public property of the State of Louisiana or its political subdivisions;

• MLGW, being exempt from ad valorem taxation in Louisiana, was due a refund of all taxes paid under protest; and

• since MLGW was granted full relief on this one issue, the court pretermitted consideration of the other claims of MLGW.

Sheriff Philley and Assessor Smith appealed. We affirm in all respects.

DISCUSSION

1. Does the term "public property" apply only to Louisiana owned property?

In the ruling under review, the trial court concluded that the natural gas that is the subject of the underlying suits was exempt from property taxation under the provisions of Art. VII, § 21(A) of the Louisiana Constitution, which provides:

Hester, supra, allowed property taxes on a Warren County toll bridge that crossed the Mississippi River from Vicksburg to Louisiana. The Hester court made an extraneous comment in its opinion that the public property exemption did not extend to the property of other states and their political subdivisions.2 The trial court in the instant case disagreed, as do we.

We recognize the strict analysis required in exemption cases.3 We also know that our review is de novo. We totally agree, however, with the trial court's application of the first rule of constitutional interpretation, that when a constitutional provision is plain and unambiguous and its application does not lead to absurd consequences, its language must be given effect.4 The constitutional language here could not be clearer.

2. Is the stored natural gas being "used for public purposes"?

Keith Knowles is the supervisor of energy resources for the City of Memphis. When he was asked in his deposition how the gas was used, he answered, "This gas is used to meet the demands of our customers, either by, to heat their homes for residential customers, or to heat their hot water heaters. For commercial and industrial customers it is used to also heat their buildings, their [air] conditioned space. It can also be used in the process of a business, such as a cleaners is using natural gas in the process of their business."

In an affidavit, Mr. Knowles stated that MLGW:

• has neither physical control of nor legal authority over the pipeline;

• had the gas stored in order to meet the public need, not any profit motive;

• does not make a profit on its sales of natural gas to its customers;

• does not store natural gas for speculative purposes;

• does not "buy low" and "sell high"; and

• stores gas to ensure that it is able to meet the fundamental needs of its customers when winter comes to Memphis.

By affidavit, Rodney Cleek stated that he was an employee of MLGW, serving as the assistant manager of the Budget, Plant and Rates Department. He advised that the property tax paid by MLGW for 2009-2012 was passed through and incurred by MLGW's customers, located in Shelby County, Tennessee.

By affidavit, Cheryl W. Patterson stated that she was employed by MLGW as vice president and general counsel. She advised that MLGW:

• does not maintain an office or other physical facilities in Louisiana;

• does not own or operate the subject storage facility; and

• does not maintain any employees or representatives in Louisiana.

Ms. Patterson further stated that "the natural gas at issue in the petitions is municipally-owned property used for the public purpose of supplying the individual and corporate residents and citizens of the City of Memphis and Shelby County, Tennessee with natural gas services."

Appellants argue that:

• the passive act of storing gas does not rise to the level of "use," as required by the exemption; and

• the natural gas at issue was not used for "public purposes" after leaving storage in West Carroll Parish.

On the contrary, supplying energy for heating in the dead of winter seems to be the most basic public service owed by a city to its citizens. Accordingly, we find that the natural gas is used for public purposes.5

3. Does La. Const. Art. VII, § 21(A) exempt the stored gas from taxation?

We agree with the trial court that this property is exempt from ad valorem taxes, for these five reasons.

The position of the Louisiana public officials here is untenable. If the sheriff and assessor are correct, there will effectively be a Louisiana tariff collected from Tennessee consumers for natural gas stored in Louisiana, awaiting transit to the Memphis gates for use by its citizens.

The trial court was correct that natural gas stored in Louisiana for the account of MLGW is exempt from taxation. We find no error in the pure reasoning of the trial court on the asserted issues before us in this matter.11 MLGW is entitled to summary judgment as a matter of law that the natural gas stored for MLGW's account is exempt from property tax pursuant to La. Const. Art. VII § 21(A).

DECREE

The judgment of the trial court in favor of Memphis Light, Gas, and Water Division, appellee, and against appellants, Hon. Jerry L. Philley, in his public capacity as Sheriff and Tax Collector of West Carroll Parish, and Hon. Deanna K. Smith, in her public capacity as Assessor of West Carroll Parish, is affirmed.

All court costs have been paid. Further costs are not assessed. La. R.S. 13:4521.

AFFIRMED.

EXHIBIT A