Alaska Statehouse Notebook July 9, 2026

Campaign Finance · HB 16 Veto

$1.3M Heilala's self-funding

2% His poll number

The Self-Funder Dunleavy Forgot to Mention

HB 16 Veto Governor's Race 2026 Campaign Finance

Governor Dunleavy's veto of HB 16 rests on a single central argument: capping what donors can give candidates is unfair because it does nothing to limit wealthy candidates who can pour their own money into a race. "This bill," he wrote, "would radically tilt in favor of the wealthy when it comes to elected office."

It is a clever framing. It is also being stress-tested in real time — in the very race Dunleavy is vacating.

"Buying your way to the governorship is just not — I just don't think that's good for Alaska."
— Tom Begich, leading the field at 21%

Anchorage podiatrist Matt Heilala has contributed nearly $1.3 million of his own money to his campaign for governor — more than 94% of his total fundraising. By Dunleavy's own logic, Heilala should be the candidate best positioned to exploit the contribution-limits gap. He has done exactly what the veto letter warns about: self-funded at a level no outside donor could have matched under HB 16's proposed caps.

The April Dittman Research poll put Heilala at 2%.

Governor's Race — April 2026 Polling (Dittman Research)

Tom Begich (D)21%

Dave Bronson (R)7%

Bernadette Wilson (R)6%

Click Bishop (R)6%

Jonathan Kreiss-Tomkins (D)5%

Treg Taylor (R)5%

Matt Heilala (R) ← $1.3M self-funded2%

This is not a coincidence to explain away — it is a data point that directly undermines the veto's premise. Self-funding at extraordinary levels did not buy Heilala a polling advantage. Candidates without personal fortunes — Begich, Bishop, Wilson — are running well ahead of him. The thing contribution limits are supposed to protect, the ability of non-wealthy candidates to compete, appears to be functioning without any limits in place at all, because money is not the only, or even the primary, currency in a crowded primary field.

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None of this means self-funding never matters. In a different race — a lower-profile legislative seat, a less-crowded field — personal wealth can be decisive. The Buckley constraint that prevents states from capping candidate self-spending is a real legal fact, not a fiction Dunleavy invented. But using that asymmetry as the primary reason to veto contribution limits entirely is a different claim — and the governor's race his own term limits created is offering a live rebuttal.

The campaign finance ballot initiative is now back on for November, after Dunleavy's veto. Alaska voters have passed similar measures by margins north of 70% before. Reformers now have a veto letter, a self-funded candidate polling at 2%, and a Supreme Court ruling loosening federal coordination limits — all in the same election cycle. That is a lot of material to run a ballot campaign on.

Filed under: Campaign Finance · Alaska Governor's Race Sources: Dittman Research / APOC / Alaska Beacon

Alaska Statehouse Notebook Updated July 9, 2026  ·  Originally June 30, 2026

He Vetoed It — Now It Goes to the Voters

Governor Dunleavy killed HB 16 on the deadline, using an unusual fairness argument. The campaign finance ballot initiative is back on for November.

Bill

HB 16 — Campaign Finance; Contribution Limits; APOC

VETOED 7/9/26

While Governor Dunleavy was making headlines vetoing nine bills in a single dramatic week — covering everything from civil rights to corporate taxes — a campaign finance bill with much bigger stakes for how Alaska elections work was moving through its final steps almost unnoticed.

House Bill 16 would reimpose limits on campaign contributions in Alaska for the first time since 2021, when a federal court struck down the state's old caps. Since then, Alaska has run two full election cycles with no limit at all on what an individual can give a candidate. HB 16 would cap individual contributions at $2,000 per candidate per election cycle, among other provisions.

"It just kind of got buried in everything else."

Here's what makes the timing notable. The bill almost died from neglect — one senator who revived it admitted as much, saying it had nearly fallen through the cracks before a late vote brought it back. It passed the Senate 12–8 and the House 21–19, was enrolled on June 22, and is now sitting on the governor's desk with a deadline of July 9 for him to sign it, veto it, or let it become law without his signature.

Unlike the nine bills he vetoed with detailed public explanations on June 18, there's been no public signal yet on where Dunleavy stands on HB 16 — even the bill's own sponsors say they hadn't spoken with him about it as of late May.

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The stakes were real either way. If signed, the bill would have canceled a separate ballot initiative that would otherwise put the same question directly to voters in November. If vetoed, that initiative goes back on the ballot instead.

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Update — July 9, 2026: Dunleavy vetoed HB 16 on the deadline. His veto letter, addressed to House Speaker Bryce Edgmon, offers an argument that will surprise people expecting a simple free-speech rationale. He wrote that the bill "does nothing to address the advantage held by self-funded candidates" — that capping outside contributions while leaving personal wealth unlimited "would radically tilt in favor of the wealthy when it comes to elected office."

"Free speech and participation in elections should not depend on personal wealth."

It's a politically unusual move — invoking economic fairness to kill a contribution-limits bill. Critics will note the tension immediately: campaign contribution limits are almost universally understood as reducing wealthy donor influence, not increasing it. The self-funded candidate carve-out is a real legal constraint going back to Buckley v. Valeo, but using it as the primary reason to veto contribution limits altogether is a significant stretch.

The practical consequence is straightforward: the campaign finance ballot initiative is back on the November ballot. Dunleavy just handed reformers a concrete veto to run against — and given Alaska's history of passing these measures by wide margins, he may have made passage more likely, not less.

Filed under: Campaign Finance, Alaska Legislature Veto issued 7/9/26 · Ballot initiative proceeds to November

Alaska Policy Commentary  ·  July 8, 2026

Sen. Sullivan Introduced Legislation Against BlackRock While Holding a BlackRock Fund — And His Anti-ESG Bill Actually Made That Investment More Valuable

Senator Dan Sullivan has made up to $2 million in stock trades while in office, his net worth has grown 176% since 2015, and he holds a BlackRock mutual fund worth up to $250,000 — while introducing federal legislation targeting BlackRock's proxy voting power. The conflict is more sophisticated than it appears. His anti-BlackRock bill benefits his BlackRock holding. And it protects the family company that is his largest personal asset.

By Tom Lamb  ·  Alaska Policy Series  ·  July 8, 2026

Sen. Dan Sullivan introduced the Investor Democracy Is Expected Act — known as the INDEX Act — to limit the proxy voting power of BlackRock, Vanguard, and State Street. He co-sponsored it with Sen. Marco Rubio. He championed it as consumer protection, shareholder democracy, and a check on Wall Street's outsized influence over corporate America. He told the Washington Examiner it would ensure that "the beneficial owner who owns the shares is the entity or person entitled to vote — not the managers of these massive passive index funds."

What Sullivan did not disclose in that interview — and what has received no scrutiny in Alaska's 2026 Senate race — is that Sullivan himself holds a BlackRock Global Allocation mutual fund worth between $100,001 and $250,000. He is legislating against a firm in which he is invested. And the legislation he introduced, properly understood, does not hurt his BlackRock investment. It makes it more valuable.

That is not a simple conflict of interest. It is a sophisticated one — and it connects directly to Sullivan's largest personal holding, the family petroleum chemicals company whose stock he trades while sitting on the Senate committee with oversight over chemical safety.

"Sullivan introduced anti-BlackRock legislation while holding a BlackRock fund. BlackRock told him it didn't oppose the bill. There's a reason for that — his legislation makes BlackRock more valuable, not less."

The Sullivan Financial Picture — What the Disclosures Show

Between 2015 and 2024, Sullivan reported nearly 80 stock trades worth between $550,000 and $2.08 million — according to Quiver Quantitative, which tracks congressional stock trading. He was the only federal politician from Alaska to report any stock transactions in this period. His net worth has increased by 176% since joining the Senate, from approximately $3 million to $8.29 million.

Sullivan's Key Financial Holdings and Transactions

RPM International (NYSE: RPM): $1–5 million stake. RPM is a $6.7 billion multinational petroleum chemicals company founded by Sullivan's grandfather, now run by his brother Frank Sullivan. Sullivan's "favorite stock for trading" per Sludge. Made multiple sales pocketing up to $300,000. RPM's PAC has given Sullivan $15,000; its employees have given $137,775 — among his top donors.

BlackRock Global Allocation Fund (MALOX): $100,001–$250,000. A BlackRock-managed mutual fund with significant exposure to energy, industrials, and global equities — including fossil fuel companies. Held while introducing federal legislation targeting BlackRock's proxy voting power.

STOCK Act violations: Disclosed sale of Mowi (salmon company) stock 93 days late and Five Below stock 65 days late — both past the 45-day congressional deadline. Sullivan's office said he was unaware of the sales until late October because a third-party manager handled them.

RPM sold while on chemical safety subcommittee: Sullivan sold up to $50,000 in RPM International shares while serving on the Senate Environment and Public Works Committee's subcommittee focused on chemical safety. RPM manufactures chemical sealants and products used in fossil fuel extraction — directly in that subcommittee's oversight jurisdiction. The New York Times included Sullivan in its September report on lawmakers trading stocks in companies their committees oversee.

Total trades 2015–2024: Nearly 80 transactions, $550,000–$2.08 million. Net worth growth: 176%. He is the only Alaska federal politician to report any stock transactions in this period.

The INDEX Act — What It Actually Does to BlackRock's Business

The INDEX Act would require managers of passive index funds and ETFs to vote proxies based on the wishes of individual investors, rather than using the fund manager's discretion. Sullivan framed this as democratizing shareholder power. What he did not explain is what it means for BlackRock's business model — and why BlackRock told him it didn't oppose the legislation.

When Sullivan told the Washington Examiner that BlackRock had "surprisingly" not pushed back against the bill, and that some firms had "even indicated they support" it, he was revealing something important. BlackRock's lack of opposition was not surprising to anyone who understands the economics. Pass-through voting does several things that benefit BlackRock as a business:

How the INDEX Act Benefits BlackRock — And Sullivan's Holdings

Reduces BlackRock's ESG liability: BlackRock has faced years of political pressure and state divestment campaigns over its ESG proxy voting. If the INDEX Act passes, BlackRock can tell Republican states: "We're just executing your votes." It becomes a neutral infrastructure provider rather than an ESG activist. The political pressure evaporates. Republican state pension funds — which have been withdrawing billions — return as clients. BlackRock's assets under management grow. Sullivan's fund value increases.

Cements BlackRock's first-mover advantage: BlackRock had already voluntarily launched its "Voting Choice" program, giving $1.8 trillion in eligible assets the option to vote their own proxies. The INDEX Act mandates what BlackRock was already offering — cementing its competitive advantage over rivals who hadn't yet built the infrastructure. Competitors face new compliance costs; BlackRock doesn't.

Reduces ESG proxy pressure on fossil fuel companies: When BlackRock is prevented from voting ESG resolutions at fossil fuel companies, those companies face less shareholder pressure to price in climate risk or reduce production. Their stock value is supported. The BlackRock Global Allocation fund Sullivan holds contains fossil fuel company positions. Those positions benefit directly from reduced ESG proxy pressure.

Protects RPM International directly: RPM International — Sullivan's $1–5 million family holding — is a petroleum chemicals company targeted by exactly the type of ESG proxy campaigns Sullivan's legislation neuters. Environmental and chemical safety resolutions at RPM's annual meetings are precisely the kind of votes BlackRock and other large managers cast. The INDEX Act reduces proxy voting pressure on RPM. Sullivan's largest personal asset is protected by his own legislation.

The result is a legislative strategy that benefits every financial interest Sullivan holds simultaneously. His BlackRock fund increases in value as BlackRock sheds ESG liability and wins back conservative institutional clients. His RPM International holding is protected from the ESG proxy campaigns his legislation neuters. And the fossil fuel companies whose stock appears in his BlackRock fund face less activist shareholder pressure on climate risk.

This is not what Sullivan described when he introduced the INDEX Act. He described it as consumer protection. The financial beneficiaries are himself, his family company, and the fossil fuel industry whose interests he has championed throughout his Senate career.

RPM International — The Family Company at the Center

RPM International deserves separate scrutiny because it sits at the intersection of Sullivan's financial interests, his committee assignments, and his legislative priorities in a way that has received almost no public attention in Alaska.

RPM International was founded by Sullivan's grandfather. It is now run by his brother Frank Sullivan as CEO, with another brother serving as a senior vice president. Dan Sullivan owns between $1 million and $5 million in RPM stock — his largest single disclosed asset. RPM's PAC and employees are among his top campaign donors — $15,000 from the PAC and $137,775 from employees since 2015.

RPM International makes chemical sealants, coatings, and specialty materials — multiple product lines designed specifically for use in fossil fuel extraction, pipeline construction, and shipping infrastructure. It is the type of company that benefits when fossil fuel infrastructure expands. It is the type of company targeted by ESG proxy campaigns on chemical safety and environmental impact. And it is in the direct oversight jurisdiction of the Senate Environment and Public Works Committee's subcommittee on chemical safety — the subcommittee Sullivan sits on.

The New York Times reported in September 2021 that Sullivan sold up to $50,000 in RPM shares while simultaneously sitting on the chemical safety subcommittee. Sullivan was one of 97 members of Congress trading stocks in companies their committees oversee — identified in the Times' investigation as a systemic conflict of interest. He was the only Alaska federal legislator in that report.

"Sullivan sold family company stock while sitting on the committee that oversees that company's industry. He introduced legislation that protects that company from ESG shareholder pressure. That company's PAC and employees are among his top donors. This is not a coincidence."

The STOCK Act Violations — Delayed Transparency

The STOCK Act requires members of Congress to disclose stock trades within 45 days of the transaction date. Its purpose is to prevent insider trading and ensure the public can monitor whether lawmakers are trading on non-public information obtained through their committee work.

Sullivan violated this deadline at least twice. He disclosed the sale of Mowi (a Norwegian salmon company) stock 93 days after the transaction — more than double the legal limit. He disclosed the sale of Five Below stock 65 days after the transaction — almost two weeks past the deadline. The combined value of the late-disclosed trades was between $16,000 and $65,000.

Sullivan's office said he was unaware of the sales because a third-party investment manager handled them and did not notify Sullivan until October 30. Liz Hempowicz of the Project on Government Oversight said that reporting disclosures late "delays transparency" with the public — making it harder to determine whether trades were made on the basis of non-public information available to Sullivan through his committee work.

Sullivan is not the only lawmaker to have violated the STOCK Act. Business Insider identified 75 members of Congress who appear to have done so since 2021. But Sullivan's late disclosures come in the context of a trading pattern — nearly 80 trades over nine years, a 176% net worth increase, trades in a family company under his committee's jurisdiction — that together raise questions no individual late filing explains away.

The 2026 Senate Race — What Alaskans Should Know

Mary Peltola — the only Democrat to win a statewide Alaska race since 2008, running against Sullivan for his Senate seat — has said she supports banning congressional stock trading entirely. She told Alaska Public Media that it "contributes to corruption" and she was surprised stronger safeguards were not already in place.

Sullivan opposes such a ban. His campaign has not addressed the specific conflicts identified in this post — the INDEX Act introduced while holding a BlackRock fund, the RPM trades while sitting on the chemical safety subcommittee, or the structural benefit his anti-ESG legislation provides to his family company.

These are not partisan accusations. They are documented transactions, disclosed by Sullivan himself under the STOCK Act and Senate financial disclosure requirements. The question they raise is simple: when a senator introduces legislation targeting a company he holds stock in, trades stock in a company his committee oversees, and champions policies that benefit his family's business — is he serving Alaska's interests or his own?

Alaska's August 18 primary is the moment to ask. Alaskans deserve a complete picture of who their senator is — not just his committee assignments and floor speeches, but the financial interests those assignments and speeches protect. The disclosures are public. The pattern is documented. The question is whether anyone is paying attention.

Tom Lamb  ·  July 8, 2026  ·  Alaska Policy Series  ·  thomasalamb.blogspot.com

Sources: Quiver Quantitative congressional stock tracker, Senate STOCK Act financial disclosures, New York Times "Lawmakers Traded Stocks" investigation September 2021, Alaska Current April 2026, Washington Examiner, E&E News, Globe and Mail, Sludge, Alaska Democrats press release, Alaska Fish News. This post discusses documented public disclosures in the context of public policy analysis. It is not legal advice and makes no allegation of criminal conduct.

Alaska Policy Commentary  ·  July 8, 2026

The Same Pattern, A Different Agency: How Alaska's Public Money Is Being Positioned for a Politically Connected Private Fund — Behind Closed Doors

Alaska Revenue Commissioner Adam Crum launched a private ETF bearing Alaska's name while sitting as a Permanent Fund trustee. The firm behind it registered lobbyists in Juneau. Yesterday they celebrated the fund's one-year anniversary. Today AIDEA received their pitch — in a public meeting whose agenda didn't explain what the fund was, followed by executive session covering the same subject. Alaskans still don't know what was decided.

By Tom Lamb  ·  Post X in the Alaska Policy Series  ·  July 8, 2026

If you have been following this series since May, you will recognize the structure immediately. A state public corporation receives a presentation from a private company in a public meeting. The public agenda doesn't fully explain what is being presented. The substantive discussion happens in executive session. The records are shielded from public view. And the private company has a documented relationship with a state official who sits on a public investment body.

This is not the Alaska LNG story. This is AIDEA — the Alaska Industrial Development and Export Authority — and the Alaska Frontier Economic Fund, ticker symbol AKAF. But the structure is identical. And the public records law arguments that apply to AGDC's secret agreement with Glenfarne apply here too.

"A state official with fiduciary responsibility to Alaska's Permanent Fund helped launch a private ETF bearing Alaska's name. That firm's executives registered as lobbyists in Juneau. Yesterday they celebrated the fund's one-year anniversary. Today they pitched AIDEA — behind closed doors."

The Documented Chain of Conduct

The facts here are not in dispute. They are documented in press releases, lobbyist registrations, and public records.

The AKAF Timeline — Documented Facts

July 2025: Alaska Revenue Commissioner Adam Crum and Prospr Aligned announce the launch of the Frontier Economic Fund (NYSE: AKAF). Business Wire press release: "Alaska Commissioner of Revenue Adam Crum, in partnership with Prospr Aligned, announced the launch of The Frontier Economic Fund." Executives of Prospr Aligned and Vident Asset Management ring the NYSE closing bell.

2025–2026: Executives of Prospr Aligned and Vident Asset Management register as lobbyists in Juneau. Their stated purpose: advancing the relationship between Prospr Aligned and Alaska state government bodies.

2026: Crum, sitting as a trustee of the Alaska Permanent Fund, brokers a call between Prospr Aligned CEO Derek Kreifels and Marcus Frampton, the Permanent Fund's chief investment officer. APFC Executive Director Deven Mitchell confirms the call occurred at Crum's request. "No plans to deploy to the fund," Mitchell said.

July 7, 2026: Prospr Aligned marks the one-year anniversary of the Alaska Investable Index (AKAF). Net assets after one year: $2.8 million — tiny by institutional standards.

July 8, 2026 — today: AIDEA board meeting includes an "AKAF-Presentation-1.pdf" on the public agenda — without explaining what AKAF is. Executive session covers AKAF, ANWR, Ambler, Port MacKenzie, AIDEA financials, and legislative matters. Resolution G26-08 — a $4.5 million annually refreshed due diligence fund — is on the agenda. What was decided is not yet public.

The Conflict at the Center

Adam Crum is Alaska's former Revenue Commissioner. He is now running for governor. Those two facts, placed against the AKAF timeline, produce a conflict that is not hypothetical — it is structural, documented, and built for the future.

The Crum-AKAF-Governor Timeline

July 2, 2025: Crum, still serving as Revenue Commissioner and sitting as Permanent Fund trustee, co-announces the launch of AKAF with Prospr Aligned. The press release names him as a partner. Prospr Aligned and Vident executives ring the NYSE closing bell. The fund launches with $2.8 million in net assets.

August 8, 2025 — three weeks later: Crum resigns as Revenue Commissioner — specifically to run for governor. His campaign platform: "unlock Alaska's natural resources" and make Alaska "the tip of the spear for American energy dominance."

August 19, 2025: Crum officially announces his gubernatorial campaign at a rally in Wasilla. He is one of seventeen candidates. He has since named a running mate — Robert Craig, former CEO of the Alaska Heart and Vascular Institute.

2026: Crum brokers a call between Prospr Aligned and Marcus Frampton, the Permanent Fund's chief investment officer — using his prior relationship as Permanent Fund trustee to open a door that a $2.8 million fund would not otherwise reach.

July 7, 2026: Prospr Aligned marks the one-year anniversary of AKAF — the day before the AIDEA board meeting where the fund is presented.

July 8, 2026 — today: AIDEA receives Prospr Aligned's pitch in a public meeting followed by executive session. Outcome not yet public. Crum's campaign for governor continues. The primary is August 18, 2026.

The conflict here is not merely about what Crum did while in office — though launching a private ETF using his state title while sitting as a Permanent Fund trustee is serious enough on its own. It is about what the AKAF relationship is being built toward.

AKAF tracks companies with significant economic ties to Alaska — energy companies, resource developers, infrastructure operators. Crum's campaign platform calls for unlocking Alaska's natural resources and making Alaska the center of American energy dominance. A Governor Crum would directly oversee both AIDEA and the Permanent Fund — the two state bodies his former firm has been actively courting. If public institutional money flows into AKAF before or after his election, the fund's value rises with Alaska's energy sector — the sector his campaign promises to expand.

That is not a future conflict of interest. It is a present conflict being constructed for the future — using state office prestige, Permanent Fund trustee access, registered lobbyists, and now a presentation to a state development authority whose outcome Alaska citizens have not yet been told.

Crum's Revenue Department was already under fire for hiding oil and gas tax audit information from the Legislature. Lawmakers obtained subpoena authority over the issue and passed — over Dunleavy's veto, which Crum supported — a bill to compel transparency. The opacity that characterized his Revenue Department is the same opacity that characterizes the AKAF process at AIDEA today. It is not a coincidence. It is an operating style.

Dermot Cole said it plainly: "At the very least this creates an appearance of impropriety." It is more than an appearance. A public official who uses his state office title to launch a private investment fund, uses his fiduciary position to broker access for that fund, then resigns to run for governor on a platform that would directly benefit the fund's holdings — while the fund is being pitched to a state authority in secret — has not merely created an appearance of impropriety. He has constructed a pipeline from public office to private financial benefit that runs directly through Alaska's energy development agenda.

The National Republican Network Behind Prospr Aligned — and What It Wants From Alaska

Prospr Aligned is not a local Alaska investment firm. It is a node in a national Republican political network whose explicit goal is to redirect state public investment away from ESG considerations and toward energy, mining, and fossil fuel development. Understanding that network is essential to understanding what the AIDEA presentation today was actually about.

Derek Kreifels — Prospr Aligned's CEO and the man Adam Crum partnered with to launch AKAF — is the co-founder and former twelve-year CEO of the State Financial Officers Foundation (SFOF). SFOF is not a neutral financial policy organization. It is an exclusively Republican network of state treasurers, auditors, and financial officers, funded through the Koch political network's preferred donor conduit DonorsTrust, and deeply integrated with ALEC, the Heritage Foundation, and Consumers' Research.

The Kreifels Network — Key Connections

State Financial Officers Foundation (SFOF): Co-founded by Kreifels. Exclusively Republican membership. Coordinated anti-ESG campaigns across 30+ states. Former Kansas Republican Party secretary. Funded through DonorsTrust — the Koch network's preferred donor conduit — which gave $15.1 million to SFOF affiliates in 2020 alone.

Heritage Foundation: Kreifels moderated panels at Heritage's 2023 Awakening meeting with Fox & Friends host Pete Hegseth. Spoke at Heritage's Leadership Summit. Kreifels, Heritage, and Texas Public Policy Foundation jointly drafted model state pension legislation prohibiting ESG consideration. Heritage's Andy Puzder participated in the Liberty University CEO Summit alongside Kreifels and Prospr Aligned's own John Coleman.

ALEC (American Legislative Exchange Council): ALEC's CEO Lisa Nelson sits on SFOF's board of directors. ALEC's chief economist Jonathan Williams sits on SFOF's National Advisory Committee. Kreifels and Williams co-drafted conservative model pension legislation together in 2022. Koch's Americans for Prosperity Foundation and Koch Companies Public Sector voted on ALEC model bills alongside SFOF at the same meetings.

Leonard Leo network: CRC Advisors — founded by Leonard Leo, the architect of Trump's judicial appointments — sent senior vice president Mike Thompson to SFOF meetings. Leo's network has been a major funder of the anti-ESG movement that SFOF and Kreifels lead.

Vivek Ramaswamy / Strive Asset Management: Kreifels spoke at the 2022 Liberty University CEO Summit alongside Ramaswamy before Strive became a major anti-ESG investment vehicle. The anti-ESG investment movement Kreifels and Ramaswamy both participated in building is the ideological predecessor to AKAF.

Kreifels promoted AKAF on LinkedIn last week with this framing: "ESG was never about returns. It's the use of capital markets to impose a political agenda Americans never voted for. AKAF flips the script: invest in Alaska's energy, mining and industry on the merits." He cited a Daily Signal article — The Daily Signal is the Heritage Foundation's media outlet. AKAF has returned approximately 33% since inception, which Kreifels describes as proof that "fiduciary duty wins." What he does not say is that a 33% return on a $2.8 million fund generates less than $1 million in gains — and that institutional money from Alaska's public bodies would transform that calculus entirely.

John Coleman — Prospr Aligned's Chairman — is the co-CEO of Sovereign Capital and a contributor to the Harvard Business Review. He appeared alongside Kreifels at the 2022 Liberty University CEO Summit. He is the investment infrastructure behind Prospr Aligned's pitch. Jerry Bowyer — Prospr Aligned's Corporate Engagement and Proxy Voting Expert — appeared with Kreifels at the Heritage Foundation discussing SEC reform of shareholder engagement rules. The entire Prospr Aligned leadership team is drawn from the same national conservative financial network.

Vident Asset Management — AKAF's Atlanta-based asset management partner — registered as a lobbyist in Juneau alongside Prospr Aligned specifically to advance this relationship with Alaska state government. Vident is the operational infrastructure that would manage any public institutional money flowing into AKAF. An out-of-state asset manager with registered lobbyists in Juneau, backed by a national anti-ESG network, seeking access to Alaska's Permanent Fund and AIDEA through a relationship built on a Revenue Commissioner's personal endorsement — that is what today's AIDEA presentation represented.

Crum's Campaign — The Outside Money and the Trump Connection

Crum's gubernatorial campaign mirrors the outside-in structure of the Prospr Aligned network. His campaign infrastructure is almost entirely sourced from outside Alaska.

Crum's Outside Campaign Infrastructure

Campaign consulting: Strategic Impact — Kentucky-based firm. Over $40,000 paid.

Fundraising management: Marriott Group — Utah-based firm. $48,000 paid.

Media production: Poorhouse Agency — Virginia-based firm.

Top individual donor: Charles McGarrity of Florida — a relative of Crum's wife — $40,000.

Total non-Alaska donations: More than $130,000 of $348,000 raised — over 37% from outside Alaska.

Family money: Over $100,000 from Crum family members — the largest single bloc of his fundraising.

Top non-family Alaska donor: Education Commissioner Deena Bishop — $5,000. His local Alaska grassroots donor base is thin by any measure.

Most significantly: Crum has made it a priority to court Donald Trump's endorsement, touting a White House visit. He is competing for Trump's support against multiple other Republican candidates including Lt. Gov. Nancy Dahlstrom — previously endorsed by Trump for Congress — and Bernadette Wilson, who hired Trump-affiliated campaign consultants. A Trump endorsement in Alaska's August 18 primary would likely be decisive in a crowded seventeen-candidate field.

The connection between Trump's endorsement, the national conservative financial network behind Prospr Aligned, and the AKAF pitch to AIDEA is not incidental. Trump's "drill baby drill" energy agenda aligns precisely with AKAF's investment thesis — Alaska energy, mining, and industry. A Governor Crum backed by a Trump endorsement, governing an Alaska whose public investment bodies have been pitched by a Koch-adjacent anti-ESG network, would be exactly the outcome that network has been building toward.

The Alaska Landmine noted that Crum's campaign was criticized for creating attack websites against other Republican candidates within days of filing his letter of intent. He is not running a retail Alaska politics campaign. He is running a national-network-backed candidacy whose infrastructure, donors, and ideological connections all point outside Alaska — toward the same political ecosystem that produced Prospr Aligned, SFOF, and the Heritage Foundation model legislation that would reshape how Alaska's public money is invested.

Alaskans should ask: whose interests does this candidacy serve? The thin local donor base, the outside consulting firms, the national network connections, and the AKAF pipeline from public office to private financial product all point in the same direction. Not toward Anchor Point, Homer, or Wasilla — where Crum says his Alaska roots lie. Toward Kansas, Kentucky, Utah, Virginia, Florida, Atlanta, and the Heritage Foundation's meeting rooms in Washington, D.C.

The Senate Dimension — How AKAF Connects to Alaska's 2026 Federal Races

The AKAF story does not exist in isolation from Alaska's 2026 federal races. It sits at the intersection of two simultaneous Republican political projects — the gubernatorial campaign and a Senate race that has suddenly become nationally competitive.

Alaska's August 18 primary is the same day as the gubernatorial primary. On the same ballot, Republican incumbent Dan Sullivan faces Democrat Mary Peltola — the only Democrat to win a statewide Alaska race since 2008 — in what has become one of the NRSC's top Senate defense priorities. The NRSC has explicitly backed Sullivan, stating it "supports and defends our Republican incumbents" in Alaska.

Sullivan's Senate seat and the Alaska governorship are both in play on the same day. The national Republican infrastructure backing Sullivan's Senate defense — the Koch network, ALEC, Heritage, the anti-ESG financial network — is the same infrastructure that produced Prospr Aligned, SFOF, and the AKAF pitch to AIDEA. These are not parallel stories. They are the same story operating at different levels of Alaska's political system simultaneously.

Sullivan's connection to this network is not indirect. It is documented and on the Senate record. Sullivan introduced the Investor Democracy Is Expected Act — federal legislation designed to limit the power of large investment managers like BlackRock, Vanguard, and State Street to vote proxies based on ESG considerations — the precise goal SFOF has been pursuing at the state level for a decade. Sullivan told the Washington Examiner his office had been in contact with major investment funds about the legislation, and praised Republican states pushing back against ESG. His federal anti-ESG legislation and SFOF's state-level anti-ESG campaign are two tracks of the same political project.

Most directly: Adam Crum personally signed the May 2023 SFOF-organized letter to major asset management firms — BlackRock, Vanguard, State Street, and proxy advisors Glass-Lewis and ISS — questioning their ESG practices, while serving as Alaska Commissioner of Revenue. He was one of 21 Republican state financial officers who signed it. Kreifels organized the letter. Crum signed it. Two years later, Crum launched AKAF with Kreifels. The relationship between the Revenue Commissioner who signed the anti-ESG letter and the SFOF founder who organized it did not begin with AKAF. It began in 2023 — on official state letterhead.

The National Republican Alignment — August 18, 2026

NRSC priority: Defend Dan Sullivan's Senate seat against Mary Peltola. National Republican money flowing into Alaska for Senate defense. NRSC has explicitly backed Sullivan.

Trump endorsement race: Crum, Dahlstrom, Wilson, and Bronson all competing for Trump's support in the gubernatorial primary. Crum touted a White House visit. A Trump endorsement would likely be decisive in the crowded field.

Energy agenda alignment: Sullivan champions Alaska LNG and ANWR development in the Senate. Murkowski wrote the ANWR opening into the Tax Cuts and Jobs Act. Crum's campaign platform is "unlock Alaska's natural resources." AKAF invests in "Alaska's energy, mining and industry." All four align on the same resource development agenda.

SFOF/Heritage/Koch network: The same national infrastructure funding anti-ESG campaigns in 30+ states is the ideological parent of Prospr Aligned, AKAF, and Kreifels' partnership with Crum. The Bradley Foundation — which funded SFOF and Kreifels' "Our Money Our Values" campaign — is a major funder of Heritage and ALEC model legislation that would reshape how Alaska's Permanent Fund is invested.

Vident Asset Management as lobbyist: An Atlanta-based out-of-state firm registered as a lobbyist in Juneau specifically to place its investment product into Alaska's public investment bodies. If Sullivan wins his Senate race and Crum wins the governorship, both AIDEA and the Permanent Fund would be overseen by officials with documented connections to the Prospr Aligned network.

Sen. Murkowski wrote ANWR development into federal law. Sen. Sullivan has championed Alaska LNG in Washington. A Governor Crum whose campaign is backed by the same national conservative financial network that produced AKAF, governing alongside two Republican senators whose energy priorities align precisely with AKAF's investment thesis, would give that network an unprecedented degree of influence over Alaska's public investment bodies — AIDEA, the Permanent Fund, and AGDC simultaneously.

The SFOF network has successfully redirected public pension investment away from ESG in Texas, West Virginia, Louisiana, and more than a dozen other states. Alaska — with its $80 billion Permanent Fund, its state development authority, and its trillion-dollar resource base — is the largest remaining prize. AKAF is the vehicle. Crum is the candidate. The August 18 primary is the moment.

Alaskans voting on August 18 are not just choosing a governor. They are choosing whether Alaska's public investment bodies will be managed under the influence of a national conservative financial network whose explicit goal is to redirect state investment toward fossil fuel development. That choice deserves to be made with full information — including what happened in today's AIDEA executive session, which Alaska's citizens still do not know.

It is Resolution G26-08 — which would re-establish and annually refresh a $4.5 million due diligence fund for early-stage project review.

On its face, a due diligence fund sounds responsible. In practice, the resolution as described authorizes AIDEA's executive director to commit up to $4.5 million annually to preliminary work on virtually any project — infrastructure, natural resources, energy, Arctic development, data centers, roads, ports, housing, broadband, manufacturing. The executive director selects which projects receive funding. Reimbursement from project sponsors is not required before funds are spent. Confidentiality agreements are authorized from the start of any engagement.

The critical question the public cannot answer today is whether Resolution G26-08 funds could be used for AKAF-related consulting, investment analysis, or transaction structuring — with Prospr Aligned as the recipient. If so, the resolution creates a mechanism to direct public development funds to a private firm whose ETF was launched by the sitting Revenue Commissioner, covered by confidentiality agreements, before the public sees any formal project proposal. That would be the Alaska LNG structure — confidential agreement, selective disclosure, public money committed to private parties — replicated inside AIDEA's operating budget.

Questions AIDEA Must Answer Publicly

1. Is AIDEA considering investing public funds in AKAF — directly or through a separately managed account?

2. Would Resolution G26-08 funds be available for AKAF-related due diligence, consulting, or transaction structuring with Prospr Aligned?

3. Did Adam Crum communicate with AIDEA board members or staff about AKAF or Prospr Aligned — and if so, when and in what capacity?

4. Did Prospr Aligned or Vident representatives meet with AIDEA staff before today's board meeting — and if so, were those meetings disclosed publicly?

5. What was the outcome of today's executive session on AKAF — and when will that information be made public?

6. What is the legal basis for placing discussion of a private ETF presentation in executive session under Alaska's Open Meetings Act?

The Same Pattern — The Same Public Records Law

This series identified two legal arguments in Post VIII that undermined AGDC's confidentiality claim over its agreement with Glenfarne. Both apply here with equal force.

Subject matter waiver. By presenting AKAF in a public board meeting — even in a presentation that doesn't name the fund — AIDEA has voluntarily disclosed the subject matter in a public proceeding. If it then invokes confidentiality to shield the substance of what was discussed in executive session, it faces the same cherry-picking problem that undermined Glenfarne's position: you cannot selectively disclose favorable information in public while withholding unfavorable information under a confidentiality claim on the same subject.

AS 40.25.110 — Alaska's Public Records Act. AIDEA is a public corporation of the State of Alaska. Its records are public records. A confidentiality clause in a contract between AIDEA and Prospr Aligned — or a board resolution authorizing confidentiality agreements — does not create a statutory exemption from Alaska's public disclosure requirements. Any Alaskan can request the full record of AIDEA's communications with Prospr Aligned, Adam Crum, and Vident Asset Management under AS 40.25.110. A denial is subject to challenge in Alaska Superior Court. The burden falls on AIDEA to identify a specific statutory exemption — not a contractual confidentiality clause — justifying the denial.

AIDEA may argue that today's executive session was authorized under the Open Meetings Act exemption for discussion of matters that could affect the state's bargaining position. That exemption requires a specific, documented basis — it does not apply merely because the subject involves a private financial relationship. The Open Meetings Act's minimum legal compliance is not the same as meaningful public accountability when hundreds of millions in public development authority are potentially at stake.

One Administration, One Pattern, Three Agencies

Step back from the specific details of any one situation and the pattern across the Dunleavy administration's energy and investment agenda becomes visible:

One Pattern — Three Agencies

AGDC / Alaska LNG: State corporation transfers $1 billion in public assets to private developer under secret agreement. Legislature cannot see governance terms. Confidential slide deck presented in public hearing accepted as disclosure. Senate senators read leaked document to discover buyback mechanism. $16 billion permanent tax break passed without full legislative knowledge of contractual terms.

AIDEA / ANWR: State development authority commits $190 million in public funds to Arctic Refuge oil leases in a meeting where public testimony urged delay. Board enters executive session, returns, immediately votes 6-1 to approve. Financial terms of $50 million HEX credit line not made public. Only bidders in June 2026 lease sale were AIDEA and HEX — the same company AIDEA extended a $50 million credit line to.

AIDEA / AKAF: Revenue Commissioner launches private ETF using state office prestige. Firm's executives register as lobbyists. Commissioner brokers call with Permanent Fund CIO. One year later — after $2.8 million in net assets — the same firm pitches AIDEA in a public meeting whose agenda doesn't explain what the fund is, followed by executive session. Resolution authorizing $4.5 million annual due diligence fund with built-in confidentiality agreements is on the same agenda.

In each case the structure is the same: public money, private beneficiary, confidential process, selective public disclosure, and a state official whose conduct raises fiduciary questions that have never been publicly answered.

This is not a series of isolated incidents. It is an operating method. And the legal tools to challenge it — AS 40.25.110, subject matter waiver, the Open Meetings Act's substantive requirements — are the same in each case.

What Alaskans Can Do Today

The meeting has happened. The votes — if any — have been cast. But the public record is not closed.

Any Alaskan can file a public records request with AIDEA under AS 40.25.110 today, requesting all communications between AIDEA staff or board members and Adam Crum, Prospr Aligned, Derek Kreifels, Vident Asset Management, and any representative of AKAF — from January 1, 2025 to the present. That request must be answered. A denial must identify a specific statutory exemption. If denied without a statutory basis, it is subject to challenge in Alaska Superior Court.

The Legislature's Audit and Budget Committee has jurisdiction over AIDEA. A request for a legislative audit of AIDEA's communications and decision-making process regarding AKAF and Resolution G26-08 is within that committee's authority and should be filed.

And the questions Adam Crum has never been required to answer publicly — about his role in launching AKAF, his communication with AIDEA about the fund, and his use of his position as Permanent Fund trustee to open doors for a private investment firm — deserve answers before the next election in which he is reportedly considering himself a candidate for governor.

Alaska's public money belongs to Alaska's citizens. It is not a resource to be directed to politically connected private firms through confidential processes by officials who have confused their public duties with their private ambitions. The pattern documented in this series — across Alaska LNG, ANWR, and now AKAF — suggests that confusion is not incidental. It is structural.

Alaskans deserve to know what happened in that executive session today. They are entitled to know under the law. And if AIDEA won't tell them, the courts will require it to.

Tom Lamb  ·  July 8, 2026  ·  Post X · Alaska Policy Series  ·  thomasalamb.blogspot.com

Sources: Alaska Beacon, Dermot Cole/Reporting From Alaska, Northern Alaska Environmental Center, Business Wire, GeneOnline, Alaska Landmine, public AIDEA meeting materials. This post discusses legal concepts in the context of public policy analysis. It is not legal advice.

Hydrothermal Iron from Western Pacific Arc Systems: Fertilization of Phytoplankton Blooms and Potential Feedbacks on Sea Surface Temperature

Prepared for The Gradient Series / Convergence Series — July 2026

Executive Summary

Hydrothermal systems linked to subduction arcs and back-arc basins in the western Pacific (Philippine Sea Plate, Mariana region, and connections to Indonesian convergence) release iron (Fe). Through speciation, ligand stabilization, and isotope-traced dispersal, this Fe can fertilize phytoplankton blooms. These blooms exert biophysical effects on sea surface temperature (SST), including local warming via light absorption and stratification. This interacts with 2026 El Niño dynamics observed in Niño 3.4 and ARMOR3D data.

1. Tectonic Sources of Iron

The Mariana Arc and Trough exemplify active settings where subduction and spreading drive hydrothermal circulation. Arc vents (shallower, acidic, volatile-rich) and back-arc spreading centers release Fe-rich fluids. These are part of the broader PSP–Sunda Plate convergence zone near Indonesia.

2. Fe Speciation, Bioavailability & Isotope Tracing

Fe is released primarily as Fe(II). In plumes, oxidation and particle formation occur, but organic ligands stabilize dissolved Fe (dFe), making it bioavailable. Key data (Wang et al. 2021/2022 on Mariana/Lau back-arc plumes):

• dFe/TFe ratios up to ~82% in low-temperature/diffuse flow.
• Organic ligands ~29% of dFe on average.
• Isotopic shifts (δ⁵⁶dFe) from sulfide/oxyhydroxide precipitation and oxidation (e.g., from -4.08‰ to +0.22‰ in diluted plumes).

3. Natural Iron Fertilization and Blooms

Shallow arc vents facilitate Fe delivery to the photic zone. Evidence includes Tonga Arc (diazotroph blooms) and Southern Ocean examples (massive recurring blooms from upwelled hydrothermal Fe).

4. Blooms and SST Feedbacks

Blooms can raise local SST via enhanced solar absorption and stratification. Complex effects include DMS/cloud formation (cooling potential) and carbon export. In ENSO contexts, these feedbacks modulate regional patterns.

5. Relevance to 2026 El Niño

SST reveals subsurface anomalies consistent with Kelvin wave/heat advection. Hydrothermal Fe inputs and bloom responses interact with these dynamics in the western Pacific warm pool.

Conclusions

Tectonic Fe sources provide a traceable nutrient input that can influence blooms and SST in tectonically active regions. This adds nuance to primary wind-driven ENSO mechanisms. Full details and references in the companion PDF.

References include Wang et al. (Fe isotopes/speciation), Bonnet et al. (Tonga fertilization), Ardyna/Schine et al. (Southern Ocean blooms), and GEOTRACES hydrothermal Fe studies.

Case File — Exhibit C: The Call

Scott Jennings Says McConnell Sounds Fine. He Didn't Ask About the One Thing That Matters.

The man vouching for Mitch McConnell's health is the same man erasing Mitch McConnell's own words on Roy Moore.

Filed July 2026

The Health Question

84, Hospitalized, Undisclosed

Cardiac arrest requiring CPR on June 14. No cause, no hospital, no discharge timeline disclosed by his office three weeks later. Already announced he's retiring in January.

Transparency from his staff: minimal

The Moore Question

2017, On the Record

"If these allegations are true, he must step aside." McConnell said it about a man who had already won his primary — the exact scenario Jennings now calls "subverting the will of the people."

Topics covered in the 20-minute call: not this one

On July 7, Scott Jennings — CNN commentator, longtime McConnell ally, and the man who ran his 2002 reelection campaign — posted that he'd spoken with the hospitalized senator for "just shy of 20 minutes." The call was framed as proof of life: McConnell, 84, hospitalized since June 14 after what dispatch audio indicates was a cardiac arrest requiring CPR, was reportedly alert enough to discuss the news of the day. That's worth taking at face value. It's also worth asking what wasn't on the agenda.

Topics Jennings Disclosed From the Call

• Iran
• Ukraine
• "The unfolding situation in Maine" (Platner)
• His visit to the TR Presidential Library
• A little Senate history
• Whether McConnell still stands by his own 2017 standard for Roy Moore

The Transparency Problem, on Its Own Terms

Set the Moore question aside for a moment. The health situation alone would justify real scrutiny. McConnell's office has confirmed almost nothing beyond "the senator is continuing his recovery." Not the cause. Not the hospital. Not a return date. His wife, Elaine Chao, traveled to Beijing days after his hospitalization and stayed silent about his condition for weeks. Online speculation filled the vacuum, some of it reckless, which is what happens when an 84-year-old official's staff stonewalls basic facts about a man who still holds a Senate seat and votes on the floor.

If the standard now being applied to Graham Platner is "the party should act when a nominee's fitness is in serious doubt, regardless of what an earlier vote decided," that standard applies with more force here, not less. Platner's disqualifying event is a denied, unresolved allegation. McConnell's is a documented cardiac event with no real dispute about what happened — only about how bad it was and how much his office is willing to say.

The Second Prong

Then there's the reason this call matters beyond the health question. In November 2017, when Roy Moore — who had already won his Senate primary in Alabama — faced allegations that he pursued relationships with teenage girls in his 30s, Mitch McConnell said this:

"If these allegations are true, he must step aside." — Sen. Mitch McConnell, November 2017

Paul Ryan, John McCain, and Mitt Romney said versions of the same thing. That's the sitting Republican Senate leadership calling for a primary-winning nominee's removal, on the same theory Jennings now describes as Democrats "breezily" discussing how to "subvert the will of the people." McConnell wasn't a bystander to this playbook. He was one of its most senior practitioners.

The Ledger

Case	Won primary	Leadership pushed removal	Standard invoked now?
Bob Ney (2006)	Yes, 68%	Yes — Hastert, Boehner, Blunt, Pryce	No
Roy Moore (2017)	Yes	Yes — McConnell, Ryan, McCain, Romney	No
Graham Platner (2026)	Yes, 72%	Yes — Schumer, Gillibrand, Warren	Yes — this is the case cited as new

Selective Memory

None of this means Jennings was obligated to interrogate a recovering 84-year-old about a nine-year-old political fight during a goodwill check-in call. It means the argument he's making publicly — that overriding a primary winner is a break from how "this is a democracy" is supposed to work — can't survive contact with his own party's most recent Senate leader saying the identical thing about the identical scenario. The call didn't need to raise Moore for the contradiction to already exist. McConnell's 2017 statement is on the record whether or not anyone reads it back to him from a hospital bed.

The Bottom Line

Two separate questions are being blurred together by design. Whether McConnell's health and his office's opacity about it warrant more public pressure is a legitimate, standalone question — one that doesn't need Platner or Moore to justify it. Whether "the party overriding its own primary winner is illegitimate" is a principle anyone making that argument actually holds is a separate question, and the record says no. McConnell answered it himself in 2017. The people amplifying his old line now are the same ones treating his silence about it today as if it were never said.

Sources: Scott Jennings on X, July 7, 2026 · ABC News, Daily Beast, Daily Wire, American Almanac, July 2026 · NPR & Wikipedia, "Roy Moore sexual misconduct allegations," Nov. 2017 · Washington Post, Oct.–Nov. 2006 coverage of Bob Ney

Alaska 2026 Senate  ·  General Election Ballot If Sullivan Jr. advances  ·  Two plaintiffs emerge

Subject

Legal standing & ballot challenge

Author

Thomas A. Lamb

Status

For public record

Date

July 2026

Two Plaintiffs, One Ballot

If the “Incumbent” designation carries into the general election, Daniel J. Sullivan Jr. and Mary Peltola both have grounds to challenge it in court — and the evidence to back it up.

Thomas A. Lamb · Alaskan Voter & Former Candidate Wasilla, Alaska

The 2026 Alaska primary ballot gave one candidate something no Alaska candidate has received in at least ten years: the word “Incumbent” next to his name. If that designation carries forward to the November general election, two candidates will have legal grounds to challenge it — and one of them has documentary proof that the same Division of Elections refused to give her the same word when she was the sitting incumbent two years ago.

What Happened on the Primary Ballot

When the Alaska Supreme Court ordered the Division to include Daniel J. Sullivan Jr. on the 2026 primary ballot, it directed the Division to list him “within the confines of existing Alaska ballot design law.” Alaska regulations already prescribed the solution for identical names: middle initials. Dan J. vs. Dan S. That’s what the law said to do.

The Division did something else. It listed Daniel J. Sullivan Jr. without any party affiliation despite his having filed as a Republican, and added the word “Incumbent” to Dan S. Sullivan’s entry — a designation the Division had not used for any candidate in at least a decade. The result was a ballot with three tiers where Alaska law contemplates one.

2026 Primary Ballot — Three Tiers Created by the Division

Tier

Candidate

What They Got

Tier One

Sullivan, Dan S.

Party + “Incumbent”

Tier Two

All other candidates

Party only

Tier Three

Sullivan, Daniel J. Jr.

Neither

No statute authorizes this structure. No prior election used it. The Division created it after losing in the Alaska Supreme Court, using its remaining ballot design authority to give the incumbent a label his party’s allies had just spent two weeks trying to secure for him through litigation.

The 2024 Proof: Peltola Got No Such Label

There is now documentary proof — from the Division of Elections’ own website — that “Incumbent” was never used even when a sitting officeholder was on the ballot.

Primary Source — Division of Elections, 2024

The 2024 Alaska primary sample ballot for House District 11, obtained directly from the Division of Elections website, lists Mary Peltola — the sitting U.S. Representative for Alaska’s at-large district — as:

“Peltola, Mary S. (Registered Democrat)”

No “Incumbent” designation. Name and party only — the same format as every other candidate on that ballot, including Nick Begich, Nancy Dahlstrom, and Eric Hafner.

Source: elections.alaska.gov/election/2024/Primary/SampleBallots/HD11.pdf

This is not a technicality or an inference. It is the Division’s own document, showing that when a Democratic incumbent ran under the same Alaska ballot design law in 2024, she received no special designation. When a Republican incumbent ran in 2026, he received one. The governing law did not change between those two elections. The Division’s practice did.

If Sullivan Jr. Advances: Two Plaintiffs Emerge

The primary is August 18, 2026. The top four vote-getters advance to the November 3 general election. If Daniel J. Sullivan Jr. is among them, the same three-tier ballot structure would appear on a general election ballot seen by all Alaska voters — and two candidates would have immediate grounds to challenge it.

Plaintiff One

Daniel J. Sullivan Jr.

Petersburg, Alaska · Republican candidate

Core injury

His party affiliation was stripped from the primary ballot despite filing as a Republican. Every other candidate’s party was displayed. He is the only candidate who received neither party nor designation — simultaneously disadvantaged twice while his name-twin received both.

Plaintiff Two

Mary Peltola

Democrat · Former U.S. Representative

Core injury

As the candidate most likely to defeat Sullivan in a general election, she is directly harmed by a designation that signals incumbency advantage to every voter. She herself served as incumbent U.S. Representative in 2024 and received no such label from the same Division.

The Legal Arguments

Alaska law may not permit “Incumbent” at all. Alaska statute and its implementing regulations prohibit titles and honorifics on ballots. The incumbent cannot be listed as “Senator” — that is a title. “Incumbent” carries the same normative signal: this person is already the established holder of the office. Whether it qualifies as a prohibited honorific has never been resolved by an Alaska court, and the Division’s own attorneys acknowledged the legal question during the Sullivan litigation.

The regulation already prescribed the answer. The Division had authority under existing regulation to use middle initials to distinguish two candidates with identical names. Dan J. for Petersburg. Dan S. for the incumbent. The Superior Court in the underlying case pointed directly to this regulation. The Division went beyond it — and going beyond the prescribed remedy requires statutory authority the Division cannot identify.

The court’s remand did not authorize this. The Alaska Supreme Court directed the Division to list Sullivan “within the confines of existing Alaska ballot design law.” “Incumbent” is not within those confines. It was never used before. It has no basis in existing law. The Division exceeded the scope of what the Court authorized.

The equal protection problem is documented. The 2024 Peltola ballot is not an allegation. It is a document. The same Division applied one standard to a Democratic incumbent in 2024 and a more favorable standard to a Republican incumbent in 2026, under the same governing law, without explanation. Courts take that kind of documented inconsistency seriously.

A standard that appears only for some incumbents and not others — with no change in law between elections — is not a standard. It is a choice. And choices made without legal authority, in ways that benefit one candidate over others, are exactly what equal protection doctrine is designed to address.

The Timeline

Unlike the Sullivan disqualification case — which required an emergency filing, same-day briefing, and oral argument on an hours-long timeline — a general election ballot challenge has room to breathe. Primary results are certified in September. General election ballots go to print in October. A challenge filed promptly after certification would give an Alaska court several weeks to consider the merits before any ballots are printed.

That is a more workable timeline than the case that started all of this. And the legal record is already built: the Supreme Court’s S-19935 order, the Division’s own sample ballot from 2024, ten years of prior practice showing no incumbent was ever labeled, and the Division’s attorney’s own courtroom admissions about the Hafner precedent.

The Unresolved Question

The Alaska Supreme Court affirmed Sullivan Jr.’s right to be on the ballot and remanded to the Division the question of how he should be listed “within the confines of existing Alaska ballot design law.” Whether the Division stayed within those confines — or went beyond them — has not been adjudicated. If Sullivan Jr. advances to the general election, that question will have two new plaintiffs with standing to raise it.

The Point

The Division tried to keep a candidate off the ballot. It lost. It then designed the ballot in a way that gave the candidate whose allies triggered the removal proceedings an unprecedented advantage — one it refused to give a Democratic incumbent two years earlier. If Sullivan Jr. makes it to the general election, the voters won’t be the only ones watching. The courts may be too.

Thomas A. Lamb · Alaskan Voter & Former Candidate, Alaska State Senate District D (2020) · Wasilla, AK
Amicus curiae, State of Alaska, Division of Elections v. Daniel J. Sullivan, Jr., Alaska Supreme Court No. S-19935 (2026)