(1) A proposed amendment to this Constitution shall be enacted in accordance with Article 256 or 257, and approved in accordance with clause (2) by a referendum, if the amendment relates to any of the following matters—The constitution sets an irreducible limit sent to counties, doesn't say anything about capping it
(a) the supremacy of this Constitution;
(b) the territory of Kenya;
(c) the sovereignty of the people;
(d) the national values and principles of governance mentioned in Article 10 (2) (a) to (d);
(e) the Bill of Rights;
(f) the term of office of the President;
(g) the independence of the Judiciary and the commissions and independent offices to which Chapter Fifteen applies;
(h) the functions of Parliament;
(i) the objects, principles and structure of devolved government; or
(j) the provisions of this Chapter.