Bassett v. State Fish and Wildlife Commission

LEE, J.

dissenting in part.

I dissent because the "notice” requirement of ORS 183.335(2) is emasculated by the majority holding.

ORS 183.335(l)(b), (2) and (9) provide:

"(1) Prior to the adoption, amendment or repeal of *645any rule, the agency shall give notice of the proposed adoption, amendment or repeal:
"(b) In the bulletin referred to in ORS 183.360 at least 10 days prior to the effective date * * *
"(2) The notice required by subsection (1) of this section shall state the subject matter and purpose of the intended action in sufficient detail to inform a person that his interests may be affected, and the time, place and manner in which interested persons may present their views on the intended action.
"(9) No rule adopted after October 5, 1973, is valid unless adopted in substantial compliance with this section.
"* * * * (Emphasis supplied.)

The majority appears to hold that a general notice of intent to "adopt rules relating to the 1976 angling regulations for all game fish” is sufficient to permit the adoption of any rules whatsoever. For example, under the majority’s holding the Commission could also have adopted a rule restricting all Oregon streams to fly fishing only. The prospect of such unrestricted rule-making power without specific notice is contrary to my understanding of the notice required by the statutes.

ORS 183.360(3)(a) provides:

"The Secretary of State shall publish at at least monthly intervals a bulletin which:
"(a) Briefly indicates the agencies that are proposing to adopt, amend or repeal a rule, the subject matter of the rule and the name, address and telephone number of an agency officer or employe from whom information and a copy of any proposed rule may be obtained.” (Emphasis supplied.)

In my view, the provision in ORS 183.360(3)(a) that the Secretary of State shall indicate in the notice where a "copy of any proposed rule may be obtained” is to afford an interested person an opportunity to be *646heard concerning any specific rule proposed; i.e., the "copy” of the proposed rule referred to in the bulletin published by the Secretary of State is in effect incorporated into the "notice” by the reference in the bulletin. Thereby, an interested party can make an informed choice of whether to attend the hearing or not.

This statutory plan appears to me to be circumvented by the majority holding which would permit the Commission to publish a notice that it proposes to adopt specific rules which are set forth in the requisite "copy” and the next day after the hearing to adopt something more and different than that which was contained in the "copy” of the proposed rules.

As a general rule, I would hold that the copy of any proposed rules referred to in the notice would establish the parameters of the rules to be adopted. Subsequent to the hearing, the administrative agency would be at liberty to adopt all or part of the rules proposed in the "copy” — but not something more. No "unwieldy procedure” would result from such a rule and the public interest would be protected.

Since there was no mention in the copy of the proposed rules referred to in the Commission’s notice that the method of angling on the Williamson and Blitzen Rivers was to be further restricted, I would hold those rules to be invalid. It would then be unnecessary to reach the other substantive issues raised.

Accordingly, I respectfully dissent.