International Council of Shopping Centers v. Oregon Environmental Quality Commission

This case is before us on a petition for review of the validity of certain administrative rules 1 under ORS 183.400. 2 We issued an earlier opinion in this case, denying petitioners’ motion to compel respondents to supplement the record. Int’l Cncl Shopping Cntrs v. Env. Quality Comm., 27 Or App 321, 556 P2d 138 (1976), rev den (1977). Petitioners concede the correctness of the earlier opinion, but contend (under an amended petition) that the rules are invalid because they were not accompanied by a statement of a factual basis for each rule and a statement of the reasoning which led from the…