State of Alaska

Department of Administration

Alaska Public Offices Commission

Alaska Department of Administration, Alaska Public Offices Commission

Advisory Opinions

Last update - July 6, 2010

ALERT: Effective July 6, 2010, all 2010 advisory opinions and those issued in the future by the Commission will be posted in a new location on this web site. Click here to view recent opinions. This application allows for enhanced search features for APOC advisory opinions, both by subject matter, AO number and type (campaign, public official financial disclosure, lobbying or legislative financial disclosure). Advisory opinions from 2009 and earlier will continue to be stored below using the existing format.

Under Alaska Public Offices Commission regulations (2 AAC 50.905), an individual or group may submit a request in writing to the Commission asking for a formal letter of advice regarding the propriety of specific activities under the law.


AO 09-15-CD Request for an Advisory Opinion on whether or not the AK Republican Party may provide credit card services to ARP affiliates, districts, and campaigns.
AO 09-14-CD Request for an Advisory Opinion on whether or not Senator Dyson can use leftover 2008 campaign funds to pay a 2008 campaign bill (debt) and how to report the activity on his APOC campaign disclosure report.
AO-09-13 LOB Request for Advisory Opinion on 1) If a lobbyist who registers and then terminates decides to re-activate the original registration in order to lobby in the same calendar year, will this result in the lobbyist incurring civil penalties for unfiled reports? 2) May a person who registers as a lobbyist and then terminates the registration lobby during the same calendar year for less than 10 hours in a 30 day period without registering or reporting to APOC?
AO-09-12 CD Request for an Advisory Opinion on the legal disbursement of an unanticipated refund check received in 2009 for a 2006 gubernatorial campaign.
AO-09-11 POFD AO 09-11-POFD was an advisory opinion request filed in April, 2009. Staff subsequently asked the filer to include additional information relevant to staff’s ability to form a response to the request. The filer declined to pursue the issue; no response was written.
AO-09-10 LOB Does a company who loans an employee to a second company have a requirement to report as an employer of a lobbyist if the company has no control over the employee's duties or actions?
AO-09-09 POFD Request for an Advisory Opinion on applicability of Public Official Financial Disclosure requirements to a Division Operations Manager in the Division of Commercial Fisheries of the Department of Fish and Game PCN 11-1068.
AO-09-08 POFD Request for an Advisory Opinion on AGIA Coordinator’s requirement to file
AO-09-07 POFD Request for an Advisory Opinion regarding AOGCC personnel and reporting    requirements under public official financial disclosure.
AO-09-06 POFD Request for an advisory opinion regarding the reporting of gifts sent to the   Governor as a result of her vice-presidential candidacy. AO 09-06-POFD
AO-09-05 POFD RE: Request for an advisory opinion regarding the reporting of gifts sent to the Governor as a result of her vice-presidential candidacy. AO 09-05-POFD
AO-09-04 POFD Request for an Advisory Opinion on reporting voluntary, unpaid office held by minor or dependent children in non-profit educational, religious, or service organizations on schedule B on the Public Official Filing Disclosure under provisions of AS 39.50
AO-09-03 CD Request for an Advisory Opinion on whether a mass mailing by a political party in a runoff municipal election would fall under the provisions of AS 15.13.400(4)(B)(iii).
AO-09-02 CD Request for an advisory opinion on the legality of a legislator receiving reimbursement for legal expenses from a political party.
A0-09-01 CD The legality of the Municipality of Anchorage and the Acting Mayor sharing in the cost of an opinion poll.
A0-08-09 LOB Is a person required to register as a lobbyist if he performs legal work for a client that doesn’t entail influencing legislative or administrative action?
A0-08-07 CD What is the legality of using Alaska Mental Health Trust Funds for advertisements regarding the Trust and Ballot Measure 4?
A0-08-06 LOB What are employers of lobbyists required to report and in what level of detail for employees performing duties in support of lobbying but not registered as lobbyists?
A0-08-05 CD May the Alaska Mental Health Trust advise Alaskans about the potential impact of Ballot Measure 4 when funds have not been specifically appropriated for this purpose?
A0-08-04 CD May a candidate, at a fundraising event paid for with his/her campaign funds, solicit support for and endorse other candidates running for state and federal office?
A0-08-03 LOB Must a lobbyist report non-reimbursed expenses and if so, how and in what level of detail? What records must be maintained by lobbyists to comply with the law?
A0-08-02 CD Request for advisory opinion regarding activities of Renewable Resources Coalition
A0-08-01 LOB Request for advisory opinion on costs connected with media campaign and reporting under the Lobbying Law (AS 24.45)
A0-07-01 CD Must a municipal charter commission candidate file financial disclosure or campaign disclosure reports?
A0-06-04 LOB May a lobbyist provide professional services to a gubernatorial campaign if the services do not include fund-raising?
A0-06-03 CD About reporting and allocating the cost of collateral use of state-owned equipment in connection with a public officer’s official duties and a public officer’s political candidate campaign activities.
A0-06-02 CD Public outreach process preliminary to fiscal interest finding for a fiscal contract under the Stranded Gas Development Act (AS 43.82)
A0-06-01 CD Distribution of Inactive PAC Funds
AO-05-06 CD Incidental use of corporate equipment during a campaign cycle
AO-05-05 CD Letter of Intent Requirements for purposes of Alaska Campaign Disclosure Law, AS 15.13
AO-05-04 CD Employment as a Radio Talk Show Host while running for public office
AO-05-03 CD Definition of a “qualified candidate”
AO-05-02 CD Disbursement of surplus campaign funds from a disbanded Political Action Committee
A0-05-01-CD Obtaining Candidate Photographs
AO-04-01-CD Is it permissible under state law for appointed executives of the Municipality of Anchorage to advocate on behalf of ballot propositions
A003-04-LOB Application of Lobbying Law to Executive Branch Meetings
Advisory Opinion
A003-03-LOB Application of Lobbying Laws to Stranded Gas Development Act Meetings
A003-01-CD Uses of a campaign fund surplus when appointed to the legislature to fill a vacancy.
A002-03-LOB Reporting requirements when a lobbyist contracts with a business entity
for assistance with lobbying activities
A002-03-CD Fundraising in same calendar year for different seat on Anchorage Board
A002-02-CD Soliciting Contributions from employees for TOTE Alaska PAC by offering an incentive
A002-01-CD

How to value the use of a bulk mail permit and its companion account as a contribution

A001-07-CD Chair of a Candidate's Campaign as Candidate for Other Municipal Office
A001-06-CD Fund raising in 2001 for 2002 Anchorage election
A001-03-CD Group to Group Contributions when one group is an out of state group
A001-02-CD On Line Fundraising for an Association PAC raffle
A000-02-CD Registration and Reporting Requirement of a Group Formed to File a Legal Challenge to a Ballot Proposition
A099-10-CD Application of AS 15.13 to On-Line Fundraising
A099-08-CD Disbursement of funds accepted to promote the voter registration efforts of the Alaska Libertarian Party
A099-06-CD Administration of a presidential straw poll by the Alaska Federation of Republican women
A099-05-CD Use of a PAC's Gaming Permit
A099-04-CD Political Participation by a Nonprofit Corporation
A099-03-CD Application of AS 15.13.145 to End of Session Communication (David Ramseur)
A099-02-CD Post-Election Fundraising Time Limits (Bob Bailey)
A098-10-CD Repayment of Candidate Money (William R. Satterberg, Jr.)
A098-09-CD Value of Campaign Signs & Materials (Senator Dave Donley)
A098-07-CD Voter Registration Activities (AFN GOTV Committee Co-Chair)
A098-05-CD Activities by Out of State Organization (Citizens for a Better America)
A098-03-CD Transfer of state member dues to the Alaska Libertarian Party (Len Karpinski)
AO98-02-CD Application of the campaign disclosure law to the voter registration efforts of the Alaska Libertarian Party (Len Karpinski)
AO97-24-CD Application of the campaign disclosure law to marketing/advertising plans for a party convention (1998 Fairbanks Convention Committee)
AO97-23-CD How does the campaign disclosure law apply to a group seeking party status? (Republican Moderate Party, Inc., Ray Metcalfe)
A097-22-CD Application of campaign disclosure law to the proposed activities of a ballot measure group (Arctic Rights Coalition, Cora Sageak)
AO97-21-CD Web Page reporting under the new law (AK. Women’s Political Caucus, Patti Higgins)
A097-20-CD Communications by labor organizations with members (AFL-CIO, Chuck Dunnagan)
AO97-19-CD Use of another organization's gaming permit (Fairbanks Central Labor Council, John S. Brown)
AO97-17-CD Alternative reporting method for monthly credit card donations; candidate contributions to a party (Alaska Democratic Party)
AO97-15-CD Prohibiting campaign contributions from a lobbyist to out-of-district legislative candidates; addressing contributions by lobbyist's family members. (Jerry Reinwand)
AO97-13-CD Permitting a party or group to donate proceeds from an event to charity. (Greater Juneau Democratic District, Douglas Rickey, Treasurer)
AO97-12-CD Residency considerations for TOTE PAC (Alaska); the amount of administrative assistance provided by TOTE to its PAC (Gordon R. Evans, TOTE
AO97-11-CD Regarding putting up polling signs to test the waters prior to filing a letter of intent (Richard "Shane" Wirtz)
AO97-10-CD Reporting of legal services to a party (Republican Party of Alaska, Ken Jacobus)
AO97-09-CD Campaign disclosure limits and reporting for a labor union and its PAC (IBEW)
AO97-08c-CD Compliance requirements of national party committees under Alaska’s campaign disclosure law (Republican Party, Ken Jacobus; Democratic National Committee / Neil Reiff)
AO97-08b-CD The application of the corporate prohibition to the Republican Party of Alaska ("RPA"), a non-profit corporation.
AO97-08-CD Definition of contribution and reporting requirements for political parties under the new law
AO97-07-CD Disbursement of unused campaign contributions by the Lt. Governor prior to January 1, 1997 (Lieutenant Governor Fran Ulmer)
AO97-06-CD Permitting a candidate to raise money through calendar year 1996 to repay personal moneys contributed to 1994 campaign (Stephen McAlpine)
AO97-05-CD Repayment of existing campaign debts from a previous election during a transition period from January 1, 1997 until December 31, 1997 (Representative Caren Robinson)
A097-04-CD Disbursement of unused campaign contributions by incumbent legislators
prior to January 1, 1997 (Senator Lincoln/Representative Kott)
A097-03-CD Reporting requirements of a state agency under AS 15.13.145 (Judicial Council)
A097-02-CD Reporting status of political party adjuncts (AK Democratic Party)
A097-01-CD The legality of a contribution collection plan under the new law. (AK life Underwriters PAC) (AKLUPAC)
A097-01-CD The legality of a contribution collection plan under the new law. (AK life Underwriters PAC) (AKLUPAC)
The following two Advisory Opinions from 1994 are in PDF format. You will need Adobe Reader to access them. They have been processed in an attempt to make them readable by users of assistive technologies. If you need assistance in accessing these documents, please contact the Juneau APOC office at the phone number below.
AO 1994 Pearce/Williams Request for an advisory opinion on multiple questions related to the involvement of a registered lobbyist in a variety of campaign activities in a state legislative race.
AO 1994 Gravo Request for an advisory opinion on multiple questions regarding what is allowable campaign activity for a registered lobbyist, including but not limited to: whether a registered lobbyist may make recommendations to clients regarding legislative candidates; what activities a registered lobbyist may perform in conjunction with a fund-raising event; whether a lobbyist may employ a non-lobbyist to engage in fund-raising activities.