Hannah Rogers


Alaska is one of the premier cruise destinations in the world. The vessels' many amenities and luxuries, however, come with a price: cruise ships produce an inordinate amount of waste, most of which is dumped into the ocean. In 2006, Alaska voters passed a ballot measure establishing a program called the Ocean Rangers, which would monitor cruise ships in Alaskan waters to ensure that vessels were disposing of waste in accordance with state and federal law. In 2019, after an unsuccessful attempt in the state legislature to end the Ocean Rangers program, Alaska Governor Mike Dunleavy vetoed the entirety of the Ocean Rangers budget, effectively killing the program. This Note contends that because a ballot measure created the Ocean Rangers, Governor Dunleavy's veto likely violated the Alaska Constitution. First, this Note discusses the environmental risks of unregulated dumping and the cruise industry's historical lack of transparency in its waste management. Then, this Note distinguishes the Ocean Rangers veto from vetoes of other statutory program budgets in Alaskan case law. Next, this Note explains Alaska's constitutional protection of initiatives that were enacted directly by voters and argues why Governor Dunleavy's budget likely violated those protections. Finally, this Note postulates how potential litigants seeking to reinstate the Ocean Rangers could bring a case in state court under a citizen-taxpayer theory of standing.

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