Roberto Barreto wrote that "all the recent plebiscite proposals have been colonial ones, leaving the final decision in the hands of Congress. By defining the plebiscite as 'non-binding,' the electoral exercise, far from being an act of self-determination, turns into a mere survey. These plebiscites are essentially opinion polls to be considered or ignored by the body that reserves for itself all decision-making powers, the U.S. Congress."[1] Regardless of the outcome of the referendum or the vote on the bill, action by the United States Congress would be necessary to implement changes to the status of Puerto Rico under the Territorial Clause of the United States Constitution.[2]