The Alaska Supreme Court has previously held that zoning by initiative is invalid because the power of zoning would exceed the power to legislate. Under Alaskan law, boroughs must establish a planning commission that prepares a land use plan. This initiative would bypass the need for a commission and is therefore it is beyond the power of a referendum. Further, the initiative would subject all land use enactments of the borough to a popular vote, which would divest the borough’s board of its delegated powers. - Alan A. Lew