There have been discussions over several months between a company and two separate State agencies relating to the agencies' regulations.
The question presented to the Commission is whether, under the Lobbying Act of 1977 (hereinafter referred to as the Act), a company is lobbying when it attempts to influence a State agency regarding that agency's regulations.
Attempts to influence a State agency regarding that agency's regulations which have the force and effect of law is a lobbying activity. (Sec. 3(b) of the Act). The two State agencies' regulations have the force and effect of law. Therefore, by attempting to influence said agencies' decisions in formulating its regulations, the company is lobbying.
APPROVED BY COMMISSION: October 6, 1978
CONCURRING: CHAIRMAN S. STANLEY KREUTZER, VICE CHAIRMAN OWEN McGIVERN, MARGARET C. ANDRONACO, D. CLINTON DOMINICK, DANIEL GUTMAN, and DAVID C. TAIT./S/