OPINION
MATTHEWS, Justice.
Under AS 43.23.005(a)(1) a “state resident” is entitled to receive a permanent fund dividend. Alaska Statute 43.23.095(8) defines “state resident” as “an individual who is physically present in the state with the intent to remain permanently in the state.... ” From 1985 to 1987, Arturo and Tomas Cosio were in the United States illegally. During that period, however, both men were physically present in Alaska and intended to remain. The Cosíos claim they were “state residents” within the meaning of AS 43.23 and thus entitled to a permanent fund dividend.
The Cosíos applied for permanent fund dividends in each of the three years at issue. They received dividends for 1985 and 1986, but were denied dividends for 1987. Additionally, the State demanded repayment of the 1985 and 1986 dividends. The Cosíos administratively appealed the State’s actions. Following a hearing, the hearing officer ruled that the Cosíos were ineligible to receive dividends from 1985 through 1987 under a regulation which stated: “An alien with resident alien status or a refugee otherwise qualifying under [the provisions of state law pertaining to such eligibility] is eligible to receive a permanent fund dividend.” 15 Alaska Administrative Code (AAC) 23.615(d) (1988). This ruling was subsequently adopted by the commissioner of the Department of Revenue.
The Cosíos appealed to the superior court. The court ruled that the regulation was inconsistent with the statutory definition of “state resident” and was therefore invalid: “[T]he establishment of the immigration status of resident alien as the minimal threshold required for alien eligibility, however convenient, is inconsistent with the plain language of the statute which determines residency by a person’s intent.” The State petitioned for review from this ruling. We granted the petition.
The legislature has authorized the commissioner of the Department of Revenue to promulgate regulations implementing the permanent fund dividend program. Alaska Statute 43.23.015(a) provides:
Application and proof of eligibility, (a) The commissioner shall adopt regulations under the Administrative Procedure Act (AS 44.62) for determining the eligibility of individuals for permanent fund dividends. The commissioner may require an individual to provide proof of eligibility, and the commissioner may use other information available from other state departments or agencies to determine the eligibility of an individual.
Alaska Statute 43.23.055(2) provides:
Duties of the department. The department shall
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(2) adopt regulations under the Administrative Procedure Act (AS 44.62) that establish procedures and time limits for claiming a permanent fund dividend;
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Pursuant to this authority, the commissioner promulgated 15 AAC 23.615(d), which limits dividend eligibility to aliens who are resident aliens or refugees.
I. The regulation is authorized by statute.
Initially, we must determine whether the authorizing statutes require the commissioner to promulgate procedural regulations, substantive regulations,' or both. Section .055(2) clearly limits the commissioner’s authority to adoption of procedural regulations concerning dividend applications and proof of dividend eligibility. Section .015(a), on the other hand, can reasonably be read to encompass both procedural and substantive regulations. We conclude that section .015(a) requires the commissioner to adopt regulations setting substantive eligibility requirements for permanent fund dividends.
We reach this conclusion for two reasons. First, if the legislature had intended the delegation contained in .015(a) to pertain strictly to matters of procedure, the legislature likely would have used language plainly expressing this limitation, as it did in AS 43.23.055(2). Second, if the legislature intended only a procedural meaning, AS 43.23.015(a) would be superfluous because of the presence of section .055(2). Since no statute should be construed to be merely superfluous if it reasonably has another meaning, Homer Electric Association v. Towsley, 841 P.2d 1042, 1045 (Alaska 1992), we conclude that section .015(a) delegates authority to the commissioner to promulgate regulations dealing with substantive eligibility requirements.
This case, therefore, reduces to a single question: whether 15 AAC 23.615(d), as construed by the hearing officer and the commissioner to restrict permanent fund dividend eligibility to aliens with resident alien or refugee status, falls within the commissioner’s delegated authority to regulate the eligibility of individuals for permanent fund dividends. In answering this question, we accord the administrative regulation a presumption of validity; the party challenging the regulation bears the burden of demonstrating invalidity. Alaska Int’l Indus, v. Musarra, 602 P.2d 1240, 1245 n. 9 (Alaska 1979). We review a “legislative” type of regulation, such as is presented here, with considerable deference:
First, we will ascertain whether the regulation is consistent with and reasonably necessary [1] to carry out the purposes of the statutory provisions conferring rule-making authority on the agency. This aspect of review insures that the agency has not exceeded the power delegated by the legislature. Second, we will determine whether the regulation is reasonable and not arbitrary. This latter inquiry is proper in the review of any legislative enactment.
Kelly v. Zamarello, 486 P.2d 906, 911 (Alaska 1971). We will not substitute our judgment for that of the agency with respect to the efficacy of the regulation nor review the “wisdom” of a particular regulation. Alaska Int’l Indus, v. Musarra, 602 P.2d at 1245 n. 9.
The commissioner argues that the regulation in question adds a permissible gloss to the statutory phrase “intent to remain permanently in the state,” AS 43.-23.095(8). The commissioner cites Whaley v. State, 438 P.2d 718 (Alaska 1968), as authority for the proposition that an agen[625]*625cy having authority to make legislative regulations may by regulation refine and add meaning to statutory language. In Wha-ley, various personnel rules excluded probationary or provisional employees from the statutory classification “employee[s] in the classified service” although the statute itself did not contain such an exclusion. We upheld the exclusion as within the authority of the director of personnel:
Such interpretative rules were made pursuant to statutory authority, and appellant does not point out, nor do we perceive, that those rules are unreasonable and not in accord with the terms and purposes of the statute pursuant to which they were adopted. We have no basis for not upholding such an administrative interpretation of AS 39.25.170 [the statute using the term “employee in the classified service”], particularly in view of the well settled rule that requires courts to give consideration and respect to the contemporaneous construction of a statute by those charged with its administration, and not to overrule such construction except for weighty reasons.
Id. at 722 (footnote omitted). We decided, then, that the agency in Whaley had the authority to promulgate a regulation that excluded employees who arguably fell within the statute’s definition. Similarly, in this case we agree that the commissioner has the authority to promulgate a regulation excluding permanent fund dividend applicants who arguably fall within the statutory definition of eligible applicants. That exclusion, however, must still be consistent with the statutory purpose and “reasonable and not arbitrary.” Kelly v. Zamarello, 486 P.2d at 911.
These conditions are met. The objective of AS 43.23.095(8) is to limit payment of dividends to permanent residents. Those who are present in the state illegally may reasonably be seen to fall outside of this category. The challenged regulation accomplishes this. The commissioner justifies this regulation by, in effect, interpreting the statutory phrase “intent to remain permanently” to mean “intent to lawfully remain permanently,” inferring a requirement of lawful action from the statute.
We have made similar inferences in other statutory contexts. For example, in Colville Environmental Services v. North Slope Borough, 831 P.2d 341, 349 (Alaska 1992), a statute gave grandfather rights to municipalities which provided garbage collection services before a certificate of authority was granted to a competing provider of such services. The question was whether the statutory language “provided similar services” referred to all services or only lawfully provided services. We construed the statute to apply only where the municipality had lawfully provided services. Similarly, in Simpler v. State Commercial Fisheries Entry Commission, 728 P.2d 227, 230 (Alaska 1986), the litigant challenged an agency regulation that required prior fishing as the holder of both an interim-use permit and a gear license in order to qualify for grandfather rights in a fishery. The regulation was challenged as inconsistent with the authorizing statute which only required prior fishing as the holder of a gear license. We upheld the regulation, noting that one could not legally fish without both a gear license and an interim-use permit. The regulation was held to be consistent with the act based on the inference that the legislature intended to establish eligibility based on lawful participation. Id. Underlying both of these decisions is an assumption that the legislature did not intend to reward unlawful conduct. The commissioner was entitled to make the same assumption in this case.
One objective of section .015(a) is to require the commissioner to make substantive regulations resolving questions as to who is and who is not a permanent resident. 15 AAC 23.615(d) is such a regulation. It makes abundant sense to conclude that aliens who may not legally live in Alaska are not permanent residents for dividend purposes. To exclude such people from the permanent fund dividend program is consistent with a public policy which regards it as unwise to reward illegality. The regulation, therefore, is not invalid on statutory grounds.
[626]*626II. The regulation is constitutional.
Amicus contends that 15 AAC 23.615(d) is unconstitutional because dividend eligibility depends upon a classification that burdens aliens who are not resident aliens or refugees. Amicus argues that this classification denies the excluded aliens equal protection of the law under the state equal rights provision, article I, section 3 of the Alaska Constitution, and under the Fourteenth Amendment to the United States Constitution.2
A. Federal Equal Protection
Like ancient Gaul, modern analysis under the federal equal protection clause3 is divided into three parts. First, the United States Supreme Court has reserved its most searching review — strict scrutiny — for legal classifications that burden suspect classes of individuals or that burden a fundamental right. Only classifications based on race, alienage, and national origin merit strict scrutiny. Strict scrutiny requires that the government show that its law is narrowly tailored to the achievement of a compelling government interest. City of Richmond v. J.A. Croson Co., 488 U.S. 469, 493-94, 109 S.Ct. 706, 721-22, 102 L.Ed.2d 854 (1989) (plurality opinion). Laws often fail to survive strict scrutiny, prompting one commentator to label the test “ ‘strict’ in theory, and fatal in fact.” Gerald Gunther, The Supreme Court Term 1971 — Foreword: In Search of Evolving Doctrine on a Changing Court: A Model for Newer Equal Protection, 86 Harv.L.Rev. 1, 8 (1972); but see Korematsu v. United States, 323 U.S. 214, 216, 65 S.Ct. 193, 194, 89 L.Ed. 194 (1944).
Second, the Supreme Court applies a less searching form of review — intermediate scrutiny — to legal classifications that burden quasi-suspect classes. Thus far, the Supreme Court has applied intermediate scrutiny to classifications based on gender and illegitimacy. See, e.g., Mills v. Habluetzel, 456 U.S. 91, 99, 102 S.Ct. 1549, 1555, 71 L.Ed.2d 770 (1982) (illegitimacy); Mississippi Univ. for Women v. Hogan, 458 U.S. 718, 724, 102 S.Ct. 3331, 3336, 73 L.Ed.2d 1090 (1982) (gender). Under intermediate scrutiny, the government must show that its law bears a substantial relationship to an important government interest. Hogan, 458 U.S. at 724, 102 S.Ct. at 3336.
Third, the Supreme Court reviews all other legal classifications under its most deferential standard of review — rational basis. Under rational basis review, the government only need show that the challenged law is rationally related to the attainment of a legitimate state interest. United States R.R. Retirement Bd. v. Fritz, 449 U.S. 166, 174-75, 101 S.Ct. 453, 459, 66 L.Ed.2d 368 (1980). Rational basis review is often as permissive as strict scrutiny is fatal. See Laurence Tribe, American Constitutional Law § 16-3, at 1443 (1988). Occasionally, however, the Supreme Court has intensified its gaze and subjected a law to a more searching inquiry, ultimately striking down the law under rational basis review. See, e.g., City of Cleburne v. Cleburne Living Ctr., Inc., 473 U.S. 432, 439, 105 S.Ct. 3249, 3254, 87 L.Ed.2d 313 (1985). One commentator refers to this stricter review as “covertly heightened scrutiny” under which the Court increases the government’s task in justifying the challenged law. Tribe, supra, § 16-33, at 1612.
The Cosíos, as illegal aliens, do not automatically fall within one of the three pre-set categories. Where they do fall is best discovered by examining Plyler v. Doe, 457 U.S. 202, 102 S.Ct. 2382, 72 L.Ed.2d 786 (1982). In Plyler, Texas denied public school funding for the children of illegal aliens. The Court began its analysis with a recognition that illegal aliens, [627]*627as a class, merit merely rational basis review: “Undocumented aliens cannot be treated as a suspect class because their presence in this country in violation of federal law is not a ‘constitutional irrelevancy.’” Id. 457 U.S. at 223, 102 S.Ct. at 2398. The Court, however, ultimately held the State to a higher standard, concluding that the challenged law “can hardly be considered rational unless it furthers some substantial goal of the State.” Id. 457 U.S. at 224,102 S.Ct. at 2398 (emphasis added). Thus, while reviewing the Texas law under the “rational” basis test, the Court required the State to produce a “substantial,” as opposed to merely “legitimate,” state interest. In doing so, the Court seemed to employ its intermediate level of scrutiny.
Plyler indicates that the Court’s increased scrutiny cannot be attributed solely to the fact that the challenged law burdened illegal aliens. Rather, the Court offered two important reasons for subjecting the Texas law to higher scrutiny:
[(1) The state law] imposes a lifetime hardship on a discrete class of children not accountable for their disabling status. [(2)] The stigma of illiteracy will mark them for the rest of their lives. By denying these children a basic education, we deny them the ability to live within the structure of our civic institutions, and foreclose any realistic possibility that they will contribute in even the smallest way to the progress of our Nation.
Id. 457 U.S. at 223, 102 S.Ct. at 2398 (emphasis added). Neither of these reasons exists in the present case. First, the Cos-íos, both adults, are fully “accountable for their disabling status.” Second, a permanent fund dividend is not comparable to education, the deprivation of which leaves the victim irretrievably stigmatized. Rather, a dividend is a matter of grace, a “governmental ‘benefit’ indistinguishable from other forms of social welfare,” id. 457 U.S. at 221, 102 S.Ct. at 2397, which the Plyler Court suggested merits mere rational basis review. Thus, the State’s dividend eligibility requirement only warrants rational basis review.
As we have recognized elsewhere, three main purposes underlie the Alaska permanent fund dividend program:
(1) to provide a mechanism for equitable distribution to the people of Alaska of at least a portion of the state’s energy wealth derived from the development and production of the natural resources belonging to them as Alaskans;
(2) to encourage persons to maintain their residence in Alaska and to reduce population turnover in the state; and
(3) to encourage increased awareness and involvement by the residents of the state in the management and expenditure of the Alaska permanent fund....
Ch. 21, § 1(b), SLA 1980 (emphasis added), quoted in Williams v. Zobel, 619 P.2d 448, 458 (Alaska 1980), rev’d, 457 U.S. 55, 102 S.Ct. 2309, 72 L.Ed.2d 672 (1982). We believe that the program’s permanent residence requirement, as interpreted to require “legal” residence, is rationally related to the attainment of these legitimate purposes.4
First, we agree with the State that “giving dividends to illegal aliens would ... contravene public policy by rewarding individuals for illegal acts.” The State may properly determine that it is inequitable to give the same treatment to those who gain their resident status illegally as opposed to those who do so legally. Compliance with the law is a legitimate consideration when the legislature considers entitlement to public funds. Thus, a regulation distinguishing between law-abiding and law-breaking state residents, and rewarding the former, is rationally related to the purpose of equitably distributing income from the permanent fund.
[628]*628Second, permanent fund dividends should “encourage persons to maintain their residence in Alaska and to reduce population turnover....” To this end, the legislature has specifically limited dividend eligibility to permanent residents of the state. AS 43.23.005(a)(1). The commissioner has defined permanent residence with regard to one’s ability to remain permanently. This definition is rational because one’s “intent to remain permanently” means little without the right or ability to effectuate that intent. Since compliance with federal immigration laws is a prerequisite for one’s continued ability to reside in this state, resident alien or refugee status is an adequate proxy for, and thus rationally related to ascertaining, an individual’s meaningful “intent to remain permanently” in Alaska.
Third, the State has legitimately tailored dividend eligibility to “encourage increased awareness and involvement by the residents of the state in the management and expenditure of the Alaska permanent fund.” The state constitution requires that twenty-five percent of “all mineral lease [revenues] be placed in [the] permanent fund_” Alaska Const, art. IX, § 15.5 The principal of the fund must remain to produce income; the income from the fund, however, may be allocated as “provided by law.” Id. The legislature has provided that half of the fund’s annual income available for distribution must be available for dividends. AS 37.13.145(b). The other half of annual income is currently reinvested in the fund directly or in the earnings reserve account of the fund. These allocations are subject to legislative change.
The dividend program was intended to create a constituency in the voting public which would favor reinvestment of permanent fund earnings rather than using such earnings to finance new government programs or to defray the expenses of existing ones. Zobel, 619 P.2d at 462. These voters would, in turn, influence legislative decisions concerning the allocation of permanent fund revenue. The result would be an eventual increase in the size of the permanent fund and a deferral of the use of permanent fund earnings for government operations until the earnings are truly needed for that purpose.
This purpose could well be achieved by limiting dividend recipients to Alaska residents eligible to vote. In the original dividend program enacted in 1980, Ch. 21 SLA 1980, children were excluded from dividend eligibility. In 1982, after three justices of this court had expressed doubts concerning the constitutionality of this exclusion,6 the legislature expanded the class of dividend recipients to include children. Similarly, the exclusion of aliens who are legal residents of the state could raise serious constitutional questions.7 Thus, the commissioner’s inclusion of legal aliens among those eligible to receive dividends can be viewed as a prudent response to current constitutional learning. Dividend recipients thus include those eligible to vote and those whose exclusion would raise serious constitutional questions.8 Such a classification is rationally related to the third purpose of the dividend program.
In sum, the commissioner’s eligibility requirements are rationally related to the [629]*629achievement of the three legitimate purposes underlying the permanent fund dividends. For this reason, 15 AAC 23.615(d) survives scrutiny under the federal equal protection clause.
B. Alaska Equal Protection
Analysis under our state equal protection clause9 is considerably more fluid than under its federal counterpart. Instead of using three levels of scrutiny, we apply a sliding scale under which “[t]he applicable standard of review for a given case is to be determined by the importance of the individual rights asserted and by the degree of suspicion with which we view the resulting classification scheme.” State v. Ostrosky, 667 P.2d 1184, 1192-93 (Alaska 1983). As the right asserted becomes “more fundamental” or the classification scheme employed becomes “more constitutionally suspect,” the challenged law “is subjected to more rigorous scrutiny at a more elevated position on our sliding scale.” Id. at 1193.
The importance of the asserted right and the suspectness of the classification scheme determine the ends-means scrutiny to be applied. Our general approach is as follows:
As the level of scrutiny selected is higher on the [sliding] scale, we require that the asserted governmental interests be relatively more compelling and that the legislation’s means-to-ends fit be correspondingly closer. On the other hand, if relaxed scrutiny is indicated, less important governmental objectives will suffice and a greater degree of over/or underinclu-siveness in the means-to-ends fit will be tolerated.
Id. (footnote omitted).
In the present case, we see no reason why 15 AAC 23.615(d) warrants greater than minimal scrutiny under our state equal protection analysis. First, “[a] dividend is merely an economic interest and therefore is entitled only to minimum protection under our equal protection analysis.” State v. Anthony, 810 P.2d 155, 158 (Alaska 1991). Second, Amicus has provided no reason why the classification “persons who have voluntarily failed to comply with the United States immigration laws” 10 should receive greater thán minimal equal protection scrutiny. For these reasons, we apply minimal scrutiny under our state equal protection analysis.
Minimal scrutiny under our state constitution may be more demanding than under the federal constitution. As under the federal constitution, the challenged exclusion must be designed to achieve a “legitimate” governmental objective; however, the exclusion must bear a “fair and substantial” relationship to the accomplishment of the legitimate objective.11 As discussed above, we have concluded that limiting the distribution of dividends to those who are lawful permanent residents is rationally related to legitimate objectives of the dividend program; we also conclude, for the same reasons that the limitation is fairly and substantially related to these goals. Thus, 15 AAC 25.615(d) survives rational basis review under our state equal protection method of review.
We REVERSE the decision of the superi- or court invalidating 15 AAC 25.615(d) and [630]*630REMAND for proceedings consistent with this opinion.