dissenting.
The question in this case is one of statutory construction. The statute which must be construed was passed as part of Chapter 1 of the First Special Session of the 1973 Legislature. Chapter 1 imposed a twenty mill ad valorem state tax on oil and gas exploration, production, and pipeline transportation property including, most notably, the Trans-Alaska Pipeline. Ch. 1, § 1, FSSLA 1973. Before the enactment of Chapter 1, certain municipalities, including the North Slope Borough, were taxing oil and gas production property. Chapter 1 allowed this practice to continue. However, the amount which a municipality could collect from taxation of production property was limited by alternative formulas set forth as AS 29.53.045(b) and (c). Under subsection (b), a municipality was permitted to receive revenues of not more than $1,000 per year “for each person residing within its boundaries.”1 Under the alternative method set out in (c), a municipality was permitted to apply its personal property tax rate to personal property within its boundaries, including production property, up to a maximum in value computed by calculating the average per capita value of all property in the state, and multiplying that by 2.25 and by the number of residents of the municipality.2 The Commissioner of Community and Regional Affairs was to determine the population of each municipality so that the alternative tax limitations could be used. Alaska Statute 29.53.045(e) provides: “For purposes of this section, population shall be determined by the Commissioner of Community and Regional Affairs based on the latest statistics of the United States Bureau of the Census or on other reliable population data, and shall advise each municipality of its population as so determined by January 15 of each year.”
The question in this case is whether the special method adopted by the Commissioner for use in determining the population of the North Slope Borough for 1983 complies with AS 29.53.045. That method includes as residents the annual “population of itinerant workers at segregated sites in a municipality, although the particular individu*185als would be counted at their usual residences for revenue sharing and municipal assistance programs,” as well as for tax limitation purposes. In my opinion, AS 29.-53.045 requires that residents be counted once at their usual residences, and not elsewhere or more than once.
A. The statute requires that “residents” be counted.
It is quite clear that subsection (e) commands the Commissioner to count residents. The critical determination under AS 29.53.045(b) is the number of persons “residing” within the boundaries of the municipality. Likewise, under alternative (c) “the number of residents of the taxing municipality” must be counted.
One is generally regarded as a “resident” of the place where one usually lives. That is the sense in which the U.S. Census Bureau employs the term. It counts people at their “usual place of abode,” and has always done so. Borough of Bethel Park v. Stans, 449 F.2d 575, 578 (3rd Cir.1971). That is also the meaning which has been given the term by the state, except for the special definition which the Commissioner has added to benefit the North Slope Borough. There is another meaning of “resident.” The term may refer to domiciliar-ios, or citizens, those who live in an area with the present intention of making it their home or who have left the area with the intention of returning. See Black’s Law Dictionary 572, 1473 (rev. 4th ed. 1973). It is doubtful that the legislature used the term “resident” in AS 29.53.045 in this narrower sense, since it is generally employed only as a qualification for voting or office holding. In a local population context there are no other generally accepted meanings of the term “resident”.
If AS 29.53.045 only required that “population” be determined by the Commissioner, the Commissioner would have broad discretion in deciding who to count. In demographic terms there are two general types of population counts, de facto and de jure. A de facto count enumerates everyone who is actually present at a given time, while a de jure count counts residents, either on the basis of domicile or usual place of residence. Methods and Materials of Demography, U.S. Department of Commerce, Bureau of Census 92 (June 1980). Thus, if the Commissioner were directed by the statute only to enumerate “population” he would have the discretion to make a de facto count or a de jure count or conceivably some count which combines elements of both methods. However, as we have seen, under AS 29.53.045 the Commissioner has been directed to count residents, not merely population, and therefore he is not free to make a de facto or a mixed enumeration.
B. The legislature meant “resident” in the normal sense of the word.
In enacting Chapter 1 in 1973, the legislature seems to have used the term “resident” to refer to those who usually live in the municipality in question. There are several reasons for this conclusion.
First, the legislature is presumed to use language in accordance with general usage in the absence of indication that something else was meant. “[A] statute means what its language reasonably conveys to oth-ers_” North Slope Borough v. Sohio Petroleum Corp., 585 P.2d 534, 540 (Alaska 1978).3 As noted, under general usage a person is a resident of the place where he usually lives; there is no indication that the legislature did not intend to convey this meaning.
Second, the fact that the legislature directed the Commissioner to use Census Bureau statistics is significant. It shows that the legislature intended the Commissioner to count what the Census Bureau was counting, people at their usual places of residence.
Third, a legislative committee report concerning the bill which became Chapter 1 used the terms “residents” to refer to per*186manent settlers, those who would “have their families located where they are working.” 4
Fourth, in enacting Chapter 1 in 1973, the legislature calculated anticipated future revenues for various municipalities, including the North Slope Borough, based on 1973 and projected 1978 populations. The 1978 population of the North Slope Borough was projected to be 4,000.5 This figure could not possibly have included camp populations since the pre-pipeline 1973 population for the North Slope Borough was said to be 3,322.6
C. Prior Census Bureau practice of counting camp occupants as camp residents regardless of their usual place of abode was not adopted.
The primary argument which favors counting work camp population as residents of their camps is that until 1980 the Census Bureau apparently counted people who were quartered in work camps as residents of work camps. A letter dated March 26, 1980 from Acting Regional Census Manager Schweitzer states that this had been the Bureau’s historic practice, but that it was being changed for 1980 to conform to the traditional “usual place of residence” rule. A letter dated August 20, 1981 from Acting Director Levine of the Census Bureau which refers to the Schweitzer letter states that counting construction camp occupants who have usual residences elsewhere at their usual place of residence rather than at the camp comports “with our application of the usual residence concept utilized since the first census in 1790.”
The prior practice mentioned by Schweitzer is clarified by the Rules of Residency published by the Census Bureau for 1970 Census enumerators. Rule 16 directs that persons in places “which have shifting populations composed mainly of persons with no fixed residence, such as ... highway and other construction camps” should be counted as residents of the camp. The *187record indicates that these rules were brought to the attention of the Alaska Department of Community & Regional Affairs in March of 1975, and they were used as a basis for the Department’s conclusion that construction camp occupants were residents of the North Slope Borough.
It is possible to argue that the Census Bureau’s practice of counting remote camp occupants as camp residents was meant to be incorporated into the concept of “resident” enacted in AS 29.53.045. As indicated earlier, the legislative direction to the Commissioner to use Census Bureau data indicates that the legislature wanted the Commissioner to count what the Census Bureau was counting. This is an argument of some force. However, for the following reasons I do not think that it is sufficiently strong to justify the conclusion that the legislature intended construction camp occupants having normal residences elsewhere to be considered camp residents.
First, there is no evidence that the Census Bureau practice was known to the 1973 legislature. The issue was not a controversial one in the 1970 census because camp populations were insignificant and the North Slope Borough was not yet created. The record shows that the Department of Community & Regional Affairs only became aware of the practice in 1975.
Second, the practice as described by Schweitzer was itself an aberration, inconsistent with the traditional “usual place of residence” rule.7 That was the reason it was changed.
Third, it is unclear whether an enumerator following the 1970 Rules of Residency would consider a North Slope .camp as “consisting mainly of persons with no fixed residence,” a requirement under Rule 16 for counting camp occupants as residents. In fact, many camp occupants have fixed *188residences elsewhere and if Rule 16 were followed literally, camp workers having residences elsewhere would be enumerated elsewhere.
Fourth, in considering AS 29.53.045 the legislature used the term “resident” to refer to permanent settlers who would “locate their families in the Arctic” as distinct from those such as camp occupants who would “commute” from distant cities such as Anchorage and Fairbanks. See Senate Committee Report, supra, note 4.
Fifth, as discussed above, in enacting AS 29.53.045 the legislature used population forecasts for the North Slope Borough that did not include camp populations. See supra, notes 5 and 6 and accompanying text.
D. Double counting is inconsistent with AS 29.53.045.
The Commissioner has decided to resolve the thorny question of whether to count camp occupants as camp residents or residents of the place where they usually live by counting them twice, once where they live and once where they work. Regardless of how one resolves the issue of where they should be counted, it is clear that they should be counted only once.
Under AS 29.53.045(c) a limit on taxable property is imposed. To calculate the limit one must divide the total value of property in the state by the population of the state and multiply the result by 2.25 and by the number of residents of the municipality.8 In other words, taxable property in the municipality is calculated by creating a fraction in which municipal population is the numerator and state population is the denominator; the fraction is then multiplied by total value of taxable property in the state and this is increased by a factor of 2.25.
What happens to the denominator (total state population) when there is double counting? The record does not reflect what the Commissioner does, but there are only two choices. If the denominator is increased to reflect the double count, thus overstating the total state population, the taxing limit applicable to other municipalities is too low. The 2.25 multiplier set out in the statute is in effect somewhat lower than 2.25. If, on the other hand, the denominator is not increased by the amount of the double count, the taxing limit applicable to the North Slope Borough is too high, for its population gain has not been reflected in total state population. In this circumstance the 2.25 multiplier mandated by the legislature becomes in effect a somewhat higher number. In either case the ratio intended by the legislature has not been achieved. Because double counting inevitably skews the proportions mandated by the statute, this aspect of the Commissioner’s method must be rejected.
Inherent in the term “per capita” (by the heads) as used in AS 43.56.010(c), “average per capita assessed full and true value of property in the state,” is the idea that no person should be counted more than once. Thus there should be no double counting of total state population. Unless the residents of all municipalities are counted by the same system under which total state population should be determined (without double counting) no meaningful fraction can be created. A fraction is an expression of a part of a whole; if the part is quantified by a different method than the whole the fraction does not accurately express the proportion the part bears to the whole. Because a fraction of unlike quantities is a contradiction in terms, and because “per capita” means that each head should be counted once and only once, the Commissioner’s method of determining the population of the North Slope Borough is necessarily in conflict with AS 29.53.045(c) insofar as it counts some Alaskans twice.
. AS 29.53.045(b) now provides:
A municipality may levy and collect a tax on the full and true value of taxable property taxable under AS 43.56 as valued by the Department of Revenue at a rate not to exceed that which produces an amount of revenue from the total municipal property tax equivalent to $1,500 a year for each person residing within its boundaries.
. AS 29.53.045(c) provides:
A municipality may levy and collect a tax on the full and true value of that portion of taxable property taxable under AS 43.56 as assessed by the Department of Revenue which value, when combined with the value of property otherwise taxable by the municipality, does not exceed the product of 225 per cent of the average per capita assessed full and true value of property in the state multiplied by the number of residents of the taxing municipality. For purposes of this subsection the average per capita assessed full and true value of property in the state shall be calculated without regard to the assessed value of taxable property under AS 43.58.
. AS 01.10.040 provides in relevant part: “Words and phrases shall be construed according to the rules of grammar and according to their common and approved usage.”
.Supplemental Report, Senate Committee on Community & Regional Affairs, 1973 Special Session, Senate Journal at 75-76. The report states in part:
The bill recognizes, however, that there is a continuous impact on both the North Slope Borough and the Valdez terminal not only during construction but as a permanent matter. We can take as an example the Kenai Peninsula Borough. The development of the petroleum industry in that area brought many workers to the area and finally resulted in additional schools, roads, and other local services. The development of the Valdez port will likewise bring residents who will have a permanent impact on the schools, roads, and public services.
We believe that the representatives of the North Slope Borough are correct to anticipate the ultimate formation of a community in or near Prudhoe Bay which will serve as a permanent residence for many of the Alaskans who will be employed in the North Slope Borough over the 20 to 30 years during which we expect Prudhoe Bay and the Arctic area to be engaged in a vigorous petroleum exploration, development, and production effort. It may be that many would not wish to locate their families in the Arctic, but it is equally clear that particularly as to Native Alaskans, many would prefer to have their families located where they are working (in a possible city called “Deadhorse”) than to commute to Barrow, Fairbanks, Anchorage or Bethel. Therefore, there will be a permanent impact on the North Slope Borough because the oil fields are within its geographical boundaries. However, even on the North Slope, the actual operation of the Interborough Common Carrier Pipeline would have little impact on the borough and should not be taxed by it.
(emphasis added as to "residence" and “residents”; other emphasis in original).
. The estimated 1978 population of 4,000 for the North Slope Borough was contained in a table attached to the report of the House Finance Committee, 1973 Special Session, House Journal at 36, and an amended report of the same committee, id. at 60. The Senate Committee on Community and Regional Affairs also assumed that the North Slope Borough would have a population of 4,000 as of completion of the pipeline. 1973 Special Session, Senate Journal at 77.
. By July 1, 1975, the resident count for the Borough had increased to 3,465. As of that date the camp population was 5,199. The camp population increased during construction of the pipeline in 1976 to 8,801, while the resident population increased to 3,813. At the end of 1978 as the pipeline was completed, the camp population decreased to 3,667, while the resident population had grown, in line with the legislature's assumptions, to 4,524.
. The suggestion in section II.B of the majority opinion that in the 1980 census, outside of Alaska, the Census Bureau routinely counted construction camp workers as camp residents through application of the "four-night rule,” rather than as residents of where they usually live, is incorrect. In discussing the 1980 census, the letter from Acting Director Levine referred to above makes it clear that camp residents at locations other than Alaska were counted at their usual residences rather than their camps:
Thus, there were generally no enumeration activities at coal or drilling sites in other areas of the country. Persons at off-shore drilling and mining operations on census day have usual residences ashore where they would have been enumerated, based on contacts made with the International Association of Drilling Contractors_ For the vast majority of the general population, the decision as to their usual residences is left to the individuals, based on guidelines contained on the census questionnaire. Specific rules relating to where a person slept four or more nights a week or lived the greater part of the year were meant only to assist the enumerator when the usual residence of an individual was in question or the respondent was unsure as to which of two residences to report as his or her usual address.
Additionally, an affidavit of Michael Breedlove, an employee of the Municipality of Anchorage, concludes, on the basis of discussions with certain named high level census officials, "that persons working at remote and offshore drilling and mining operations throughout the Continental United States ... were treated as having usual residences elsewhere.” That the majority opinion’s suggestion is false is also confirmed by an article, The 1980 Census of Population: Content and Coverage Improvement Plans, authored by Mark S. Litman, Special Assistant, Population Division, United States Bureau of the Census, published in volume 6, Journal of Consumer Research, September, 1979 at 204. The article states:
Several procedures are designed to pick up persons who are away from their usual residence on census day and staying in such places as hotels, motels, campgrounds, labor camps, flop houses, etc. Persons found in these kinds of places are given a type of questionnaire. Individual Census Report (ICR), which allows them to indicate whether they have a usual residence elsewhere and whether there is someone home to fill out the census form that will be delivered to that address. Persons who indicate that they have a usual home elsewhere (UHE) and who indicate that someone is home to report for them are not enumerated at the transient place. Rather, it is assumed these persons will be listed by other persons in their household. Individuals who report that no one is home to report for them fill out the ICR, which is then sent to the appropriate census district office to be added at that address — if it was determined that the address given is "good," and that the questionnaire for the address, if returned, does not already list the person in question.
Id. at 210.
. See supra, note 2. This is the method used by the North Slope Borough.