A lobbyist submitted to the Commission a written viewpoint on what might be contained in the Commission's proposed guidelines.
The question presented to the Commission is whether, under the Regulation of Lobbying Act of 1977 (hereinafter referred to as the Act), a lobbyist is engaged in lobbying by submitting such written views to the Commission.
Any influence attempted to be used by a person for the adoption or rejection of any rule or regulation having the force and effect of law is clearly lobbying. (Sec. 3(b) of the Act). However, the Commission wishes to encourage views from the public and, therefore exempts such activity from its own statute. See also Section V(3) of the Commission's Guidelines which holds that the following persons are not required to register: "Persons who, at the specific request of the governor's office, the Legislature, or any governmental agency, provide information, advice, recommendations, or opinions on matters officially under consideration".
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/