Central Recycling Services, Inc. v. Municipality of Anchorage, 389 P.3d 54

Central Recycling Services, Inc. operates a post-consumer materials recycling business and submitted quarterly rebate requests (2010–2014) under Anchorage Municipal Code (AMC) 26.80.055 seeking reduced landfill disposal fees for solid waste residue.
AMC 26.80.055(A) grants a one-half reduction in disposal fees to “businesses or organizations engaged in recycling of paper, plastic, glass and steel, aluminum, copper and brass” if certain conditions (e.g., volume, residue ≤25%, non-commingled) are met; rebates are administered by Solid Waste Services (SWS).
Central Recycling argued the seven-item list identifies eligible recyclers (entities) and that rebates should apply to residue from any recyclable materials recovered by an eligible recycler, including unlisted materials.
The Municipality interpreted the list as exclusive: rebates apply only to residue arising from the seven specifically listed materials, excluding residue from other recyclable materials.
The superior court granted the Municipality summary judgment; the Supreme Court of Alaska affirmed, concluding the ordinance ambiguous but legislative history and purpose support the Municipality’s exclusive-list interpretation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether AMC 26.80.055 allows rebates for residue from unlisted recyclable materials when the recycler recycles at least one listed material	The list merely identifies eligible recyclers; rebates should apply to residue from the recycler’s entire recycling operation (including unlisted materials)	The list is exclusive; rebates apply only to residue resulting from recycling the seven listed materials	Court affirmed that the ordinance is ambiguous but, based on legislative history and purpose, the list is exclusive and rebates are limited to residue from the listed materials
Proper standard of review for the agency’s interpretation	Independent judicial interpretation (statutory interpretation not requiring agency expertise)	Apply reasonable-basis deference when agency policy and expertise are implicated	Court avoided choosing a deference standard because it would affirm under either standard

Louie v. BP Expl. (Alaska), Inc., 327 P.3d 204 (Alaska 2014) (statutory interpretation uses independent judgment considering language, history, purpose)
Davis Wright Tremaine LLP v. State, Dep’t of Admin., 324 P.3d 293 (Alaska 2014) (reasonable-basis standard for agency interpretations involving agency expertise or policy)
City of Kenai v. Friends of Recreation Ctr., Inc., 129 P.3d 452 (Alaska 2006) (apply same rules to statutes and municipal ordinances)
Alaskans for a Common Language, Inc. v. Kritz, 170 P.3d 183 (Alaska 2007) (construe statutes in light of purpose and legislative history)
Ranney v. Whitewater Eng’g, 122 P.3d 214 (Alaska 2005) (expressio unius est exclusio alterius principle)
Nelson v. Municipality of Anchorage, 267 P.3d 636 (Alaska 2011) (specific statutory provisions control over general ones when they conflict)