dissenting.
Former AS 23.30.041(d) (1984) provides:
(d) A full evaluation by a qualified rehabilitation professional shall include a determination whether a rehabilitation *131plan is necessary and shall include the following specific determinations:
(1) whether the rehabilitation plan will enable the employee to return to suitable gainful employment;
(2) whether the employee can return to suitable gainful employment without the rehabilitation plan;
(3) the cost of the rehabilitation plan, including all costs to be incurred by the employer during the rehabilitation plan, and an estimate of whether the continuing benefits and compensation due to the employee under this chapter after the conclusion of the rehabilitation plan will be more or less than the benefits and compensation payable to the employee under this chapter if a rehabilitation plan is not implemented.
(Emphasis added).
The statute plainly requires that those determinations made pursuant to AS 23.30.-041(d)(l)-(3) consider an evaluation of a rehabilitation plan for the injured employee. The rehabilitation professional to whom Donna Kirby’s case was assigned did not consider any rehabilitation plan for Ms. Kirby and therefore failed to make any of the determinations that are required by the statute. Rather, she reviewed Ms. Kirby’s educational background and employment history, administered several vocational and general aptitude tests, tentatively determined that Ms. Kirby had “transferable skills” in the clerical/receptionist field, did a job survey of that field, and concluded ■that Ms. Kirby could be returned to suitable gainful employment without a rehabilitation plan.1
The Board did not make any of the section .041(d) determinations either, assuming that is its adopted role. It did allude to the cost of Ms. Kirby’s tuition and fees necessary for her to obtain her bachelor’s degree, and noted that she would be entitled to temporary disability benefits during completion of the plan she submitted, but made none of the determinations required by section .041(d)(3). The Board concluded that the rehabilitation professional was correct in her assessment that Ms. Kirby had “transferable skills” that would provide her with suitable gainful employment, and thus the plan was rejected.
In my view, the obvious failure of the rehabilitation professional and Board to make the statutorily required determinations is sufficient to justify this court remanding the case for a redetermination. We cannot determine whether there has been statutory compliance on this record, even were I convinced we know what the statute means. I am not.
Alaska Statute 23.30.265(28) (1984) provides:
“Suitable gainful employment” means employment that is reasonably attainable in light of an individual’s age, education, previous occupation, and injury, and that offers an opportunity to restore the individual as soon as practical to a remunerative occupation as nearly as possible to the individual’s gross weekly earnings as determined at the time of injury.
In turn, an employee is returned to suitable gainful employment “if the employee can return to ... (3) an occupation using different skills but using the employee’s academic achievement level at the time of injury; or (4) an occupation requiring an academic achievement level that is different from that attained at the time of the injury....” AS 23.30.041(i) (1984). The employer, Alaska Treatment Center (ATC), argues that Ms. Kirby falls under (3), apparently because of “transferable skills,” while Ms. Kirby argues that she should be considered under (4).
In her Preliminary Evaluation, the rehabilitation professional concludes that Ms. Kirby “has transferable skills in the clerical area....” The Full Evaluation states that “[i]n review of the claimant’s work history, NRS has determined that Donna has transferable skills in two areas, nurs*132ing assistant and general clerical/recep-tionist_” A nursing assistant position was not an option available to Ms. Kirby because of her chronic chlorine toxicity caused by her industrial accident.
Ms. Kirby was recently (1987) awarded an associates degree, with honors, from Anchorage Community College. Her course work emphasis was psychology. With the exception of a period of less than a year in 1980-1981, when Ms. Kirby worked for two different employers performing general secretarial, clerical, phone answering and pilot car driving duties, she has been employed as either a nurses aide (prior to 1980-1981) or as an aquatics instructor (prior to and after 1980-1981). From 1981 to 1985, she was an Aquatic Instructor, Associate Director and Acting Director at the YMCA aquatics program in Anchorage. From 1984 until her industrial accident, she was employed part time by the Municipality of Anchorage as an Adaptive Aquatics Director and Instructor. From August 1985 until the accident, she worked part time for ATC as an Adaptive Aquatics Instructor. Adaptive aquatics instructors work with adults and children who are disabled in some respect, such as the mentally retarded, emotionally disturbed, and autistic, the developmentally delayed, deaf, and blind, or those who are victims of cerebral palsy, multiple sclerosis or similar diseases. She has certificates in adaptive aquatics instruction, water safety instruction training (Ms. Kirby opined that there were only five such certified persons in Anchorage), first aid and CPR. She learned sign language to be able to communicate with her deaf students. She testified that one of the reasons she emphasized psychology at ACC was that “it ... helps you to better understand someone and be able to work with them, with their problems, and to come up with some solutions.” But can she type and answer a phone?
Ms. Kirby can type and answer a phone. However, an occupation in the general clerical/receptionist field does not require the same academic achievement level as that required to perform the tasks required of and skills displayed by Ms. Kirby during most of her working life, and hence does not satisfy AS 23.30.041(i)(3) (1984). Furthermore, section .041 nowhere speaks to “transferable skills.” Unless “transferable skills” mean “different skills” and are tied to the employee’s “academic achievement level at the time of injury,” whatever they are would seem to be irrelevant.
The rehabilitation professional determined that Ms. Kirby could start at the general clerical/receptionist level at $7.50 per hour, as did the Board. After one year she would advance to $7.84 per hour, and after three years to $9.00 per hour. There was evidence that she could start at $7.84 per hour. If we are to look at gross weekly earnings at the time of the injury, with no increase in her pre-injury occupation pay for merit, cost of living or inflation, after three years she will be earning $9.00 per hour, $1.71 per hour less than she was earning three years before.2 If we average the three to four percent raise which Ms. Kirby testified she had received at ATC, she will earn $2.47 less per hour. *133This is roughly a 22% loss for Ms. Kirby. Unfortunately, we have no way of comparing what the difference would be if Ms. Kirby’s plan were approved, since the Board chose the non-plan. Ms. Kirby testified that if her plan were approved, by the end of two years she would make as much as or more than she made at the time of her injury, thus suffering no future loss of earnings.
This court holds that Ms. Kirby is presumptively entitled to a rehabilitation plan. She submitted a plan on her own. I am of the opinion that she should have been assisted by rehabilitation services in developing her plan, and that the plan should have been analyzed by rehabilitation services in accordance with the statutory commands. The only evidence offered by ATC to rebut the plan was the report of the rehabilitation professional. This report was not in compliance with statutory directives as to its contents, nor were its defects cured by the Board. In addition, the rehabilitation professional, the Board and this court do not apply statutory criteria correctly to determine under what category of .041(i) Ms. Kirby should be placed to determine whether she is suitably employed. “Academic achievement level at the time of injury” does not seem so complex a subject as to elude determination.
I conclude that the employer has not rebutted the presumption this court applies to a claim for a rehabilitation plan. If the question is arguable, the case should be remanded for determination of whether the presumption has been rebutted and ultimate burden of proof met.3
. I assume that the reason none of the required determinations were made is that the rehabilitation plan, eventually rejected by the Alaska Workers' Compensation Board (Board), was never presented to the rehabilitation professional. Indeed, there is no evidence in the record that any plan was ever solicited from Ms. Kirby by the rehabilitation professional. Apparently it was left to her to come up with her own plan, without assistance from rehabilitation services.
. The court takes such an approach in accepting the Board’s determination that Ms. Kirby's wage at time of injury of $10.71 per hour is the appropriate standard against which to measure her potential wage as a clerical/receptionist. This approach stands contrary to our approach in Peck v. Alaska Aeronautical, Inc., 756 P.2d 282, 287 (Alaska 1988), where in considering a claim for permanent total disability benefits we held that the claimant had demonstrated a reliable, long-term earning capacity resulting in a significantly higher actual wage than that indicated by his prior annual wages. Even though dealing with a different claim, our explanation in that case is equally suited here:
The entire objective of wage calculation is to arrive at a fair approximation of claimant’s probable future earning capacity. [Her] disability reaches into the future, not the past; [her] loss as a result of injury must be thought of in terms of the impact of probable future earnings, perhaps for the rest of [her] life. This may sound like belaboring the obvious; but unless the elementary guiding principle is kept constantly in mind while dealing with wage calculation, there may be a temptation to lapse into the fallacy of supposing that compensation theory is necessarily satisfied when a mechanical representation of this claimant’s own earnings in some arbitrary past period has been used as a wage base.
Id. at 286 (quoting 2 A. Larson, The Law of Workmen’s Compensation, § 60.11(d), at 10-564 (1983) (citations omitted)).
. It is ironic that in Municipality of Anchorage v. Carter, 818 P.2d 661 (Alaska, 1991), the court extended the presumption of compensability to an issue that was peripheral to the claim and virtually uncontestable without the presumption in any event. It remanded the case for additional consideration in light of the presumed entitlement. The same irony is to be found in Adamson v. University of Alaska, 819 P.2d 886 (Alaska, 1991), where the case is remanded for additional consideration in light of the peripheral and virtually uncontestable presumed entitlement. In both cases I viewed the remand as unsupportable. Here, where the question is arguable and the presumption goes to the disposi-tive issue of Ms. Kirby’s claim, the court sees fit to conclude that the presumption was rebutted.