(dissenting)—The majority has based its decision solely upon an interpretation of RCW 84.12.350 and RCW 84.16.130. The Department of Revenue has *335interpreted these provisions to allow the use of a combined indicated ratio. Contrary to the majority, I not only believe the interpretation of the department is accurate but I also believe the rules of construction previously adopted by this court lead to the conclusion that the position of the department is correct.
The history of RCW 84.12.350 demonstrates that the term "general property" was intended to include both real and personal property. RCW 84.12.350 was derived from the Laws of 1935, ch. 123, § 14, p. 367, which provided:
The assessment rolls of companies assessed under the provisions of this act shall be reviewed, examined and corrected by the state board of equalization at its annual meeting held in September for the purpose of equalizing the assessed valuation of the taxable property of the state and said state board of equalization may correct the valuation in such manner as may in its judgment make the valuation thereof just and relatively equal with the valuation of the general property of the state.
That section in turn was taken almost in whole from Laws of 1925, 1st Ex. Sess., ch. 130, § 46, p. 256, which provided in relevant part:
The assessment rolls of railroad and telegraph companies shall, by the commission, be submitted to the state board of equalization at its annual meeting held for the purpose of equalizing the assessed valuation of the taxable property of the state; and any railroad or telegraph company interested shall have the right to appear and be heard as to the assessment of the property of such company, and as to the value and assessment of the general property of the state, and the said board of equalization may, on application or of its own motion, correct the valuation or assessment of the property of such company, in such manner as may in its judgment make the valuation thereof just and relatively equal with the valuation of the general property of the state.
The phrase "general property" of the state was defined in section 36(7) of the 1925 statute at page 246, as:
*336The term "general property of the state" shall be deemed to include all real and personal property appearing upon the assessment rolls and tax rolls throughout the state, upon which the state, county and local taxes are levied and collected, with such changes and corrections made by the tax commission as hereinafter provided.
The majority argues the purpose of defining "general property" was "to employ a shorthand expression" to avoid repeating certain words and phrases. While this notion understandably possesses a certain charm for the majority, I am not persuaded of its validity.
Although section 36 and many other sections of the 1925 act were repealed by the 1935 act, use of the original legislative definition is appropriate, particularly since the section of the original statute which contains the defined term was reenacted without significant change. See State v. Herr, 151 Wash. 623, 628, 276 P. 870 (1929).
In Great Northern Ry. v. Cohn, 3 Wn.2d 672, 687, 101 P.2d 985 (1940), we stated:
In the construction of statutes which reenact with certain changes, or repeal, former statutes, or which contain revisions or codifications of earlier laws, resort may be had to repealed and superseded statutes in pari materia.
See also 2A C. Sands, Statutes and Statutory Construction § 51.04 (4th ed. 1973).
In any event, the property tax laws have been subject to continuing interpretation by this court during the past 10 years. See Sator v. State, 89 Wn.2d 338, 572 P.2d 1094 (1977). During that same period, the same statutes have gone through a substantial reformation by the legislature. The majority points out the Department of Revenue has used the combined ratio only since 1963 while the statute has been in effect since 1933. Thus, by a ratio of 3-to-l, the former interpretation must have been correct. Although this is acceptable arithmetic, I do not believe it is good law. The record does not disclose the reasons for adopting the combined ratio in 1963. It just as reasonably could be argued the pre-1963 interpretation of the statute was in *337error and that only in 1963 did the department finally interpret the statute to accord with legislative intent.
At no time since 1963, however, has the legislature Seen fit to alter the language in question in RCW 84.16.110 or RCW 84.12.350. The Department of Revenue has used the combined indicated ratio for approximately 14 years. In interpreting these statutes, the decisions of the administrative agency should be afforded considerable weight. Smith v. Northern Pac. Ry., 7 Wn.2d 652, 110 P.2d 851 (1941). Indeed, it may be said the legislature has acquiesced in the department's interpretation of these statutes. As we stated in State ex rel. Pirak v. Schoettler, 45 Wn.2d 367, 372, 274 P.2d 852 (1954):
This [acquiescence by the legislature] is particularly true when, as here, the section is subsequently (1) considered by the legislature, (2) amended in some other particular, and (3) the administrative construction of the section is not repudiated.
This is precisely what occurred here. Compare Laws of 1961, ch. 15, § 84.12.350, p. 1118, with Laws of 1967, 1st Ex. Sess., ch. 26, § 17, p. 1525, and Laws of 1961, ch. 15, § 84.16.110, p. 1125, with Laws of 1967, 1st Ex. Sess., ch, 26, § 18, p. 1525.
While the statutes may require interpretation, the rules of construction and the circumstances to which they should be applied are clear. The judgment of the trial court should be affirmed.
Utter, J., concurs with Dolliver, J.