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IN THE COURT OF APPEALS OF THE STATE OF NEW MEXICO 1 PACIFIC DENTAL SERVICES, INC., 2 Plaintiff-Appellant, 3
v. No. A-1-CA-36235 4
NEW MEXICO BOARD OF DENTAL 5 HEALTH CARE, 6 Defendant-Appellee. 7
APPEAL FROM NEW MEXICO BOA RD OF DENTAL HEALTH CARE 8 Dr. Charles Schumacher, DDS, Presiding Officer 9 Montgomery & Andrews, P.A. 10 Seth C. McMillan 11 Kari E. Olson 12 Stephen S. Hamilton 13 Matthew A. Zidovsky 14 Santa Fe, NM 15 for Appellant 16 Hector H. Balderas, Attorney General 17 Lori Chavez, Assistant Attorney General 18 Santa Fe, NM 19 for Appellee 20 MEMORANDUM OPINION 212 VANZI, Judge. 1
{1} Pacific Dental Services , LLC (Plaintiff), the mana ging member of a limited 2 liability company licensed as a non-dentist ow ner of several dentistry practices in 3 New Mexico, appeals the adoption of three regulatory amendments (the 4 amendments) to the occupational and pr ofessional licensing regulations by the 5 New Mexico Board of Dental Health Care (the Board). We affirm. 6 BACKGROUND 7
{2} The Board held three separate mee tings on January 27, 2017: an initial 8 hearing to take public comment on propo sed regulatory amendments, a committee 9 meeting to consider the impact of the pr oposed amendments on dental hygienists, 10 and a regular meeting for the Board to discuss and vote on the proposed 11 amendments. Plaintiff, through its counsel, was present at the initial public hearing, 12 along with several other members of the professional dental community. Because 13 this is a memorandum opinion and the parties are familiar with the case, we briefly 14 summarize the relevant portions of the three meetings as they relate to each of the 15 challenged amendments and reserve further discussion of the facts for our analysis 16 of the issues on appeal. 17
{3} The Board first proposed amending 16 .5.1.24 NMAC to require non-dentist 18 owners to comply with the existing gene ral record-keeping requirements applicable 19 to dentists, which require patient records to be kept for six years after a dentist 203 retires or stops practicing. Plaintiff comme nted that requiring non-dentist owners to 1 comply with the general record-keeping requirements would be redundant because 2 there is already a regulation that require s non-dentist owners to maintain patient 3 records for six years. See 16.5.9.8(L) NMAC. Additiona lly, Plaintiff argued that 4 the amendment would be confusing because non-dentist owners do not “practice[]” 5 or “retire[].” After the in itial public hearing, the dent al hygienist committee met 6 and voted unanimously to recommend adoption of the amendment without 7 comment. At the regular meeting follow ing the committee meeting, the Board 8 noted the dental hygienist committee’s approval and voted unanimously to adopt 9 the amendment without further discussion. 10
{4} The Board also proposed amendi ng 16.5.9.8(K) NMAC, a regulation 11 applicable only to non-dentist owners, whic h requires that “no person other than a 12 New Mexico licensed dentist shall have direct control or interfere with the dentist’s 13 or dental hygienist’s clinical judgment an d treatment[.]” The amendment added the 14 language “including re ferrals or prescription of laboratory services.” Plaintiff 15 commented that the proposed amendment would be confusing and redundant in 16 light of existing regulations and statutes that prohibit anyone from interfering with 17 a dentist’s clinical judgmen t. The presiding member of the Board asked how the 18 amendment would affect Plaintiff. Plai ntiff responded that while it already 19 complied with the existing statutes and regulations, it was concerned that the 204 amendment was targeting no n-dentist owners. Plaintiff believed the Board was 1 targeting non-dentist owners by amending the regulation specifically applicable to 2 non-dentist owners instead of adopting a generally applicable regulation. The 3 dental hygienist committee subsequently voted unanimously to recommend 4 adoption of the amendment. During the regular meeting, the Board noted the 5 committee’s approval and voted unanimously to adopt the amendment without any 6 further discussion. 7
{5} Finally, the Board proposed amendi ng 16.5.16.10(B)(4) NMAC, one of the 8 guidelines that the Board considers when imposing disciplinary action for 9 unprofessional conduct. Se ction 16.5.16.10(B)(4) de fined “unprofessional 10 conduct” to include “failure to seek c onsultation whenever the welfare of the 11 patient would be safeguarded or advanced by referral to individuals with special 12 skills, knowledge, and experience[.]” The proposed amendment added the 13 following subsections to 16.5.16.10(B)(4) as specific examples of this type of 14 unprofessional conduct: 15 (a) an owner dentist or supervisor causing an employee 16 dentist to make a referral for dent al treatment based on contractual 17 obligations when, in the judgment of the treating dentist, the welfare 18 of the patient would be safeguarded or advanced by re ferral to another 19 practitioner, and/or failure to notif y the patient of such contractual 20 obligations for referrals; 21 (b) an owner dentist or supervisor causing an employee 22 dentist to use a dental laboratory due to contractual obligations when, 23 in the judgment of the treating dentist, the welfare of the patient 245 would be safeguarded or advancedby the use of another dental 1 laboratory. 2 Plaintiff voiced concern that the amendm ent would create uncertainty for licensees 3 in terms of knowing whether their conduct is sanctionable. Plaintiff also asserted 4 that current regulations and statutes al ready prohibit the conduct proscribed by the 5 amendment. The dental hygienist comm ittee did not discuss or vote on the 6 amendment. During the regular meeting, th e Board voted unanimously to adopt the 7 amendment after briefly considering tab ling it to consider its possible legal 8 ramifications. 9
{6} Plaintiff subsequently brought this appeal pursuant to NMSA 1978, Section 10 61-1-31(A) (1981). 11 DISCUSSION 12 Plaintiff Has Standing to Appeal 13
{7} At the outset, we address the Board’s argument that Plaintiff lacks statutory 14 standing to appeal the Board’s adoption of the amendments. “Whether a party has 15 standing to litigate a particular issue is a question of law, which we review de 16 novo.” Nass-Romero v. Visa U.S.A. Inc. , 2012-NMCA-058, ¶ 6, 279 P.3d 772 17 (internal quotation marks and citation omitted). “[S]tanding is a jurisdictional 18 prerequisite where an action is created by statute and the statute specifies that only 19 a limited class of plaintiffs who satisfy certain conditions may sue.” Phoenix 20 Funding, LLC v. Au rora Loan Servs. , LLC, 2017-NMSC-010, ¶ 19, 390 P.3d 174. 216 In determining whether a party has standi ng under a statute, “w e must look to the 1 Legislature’s intent as expressed in th e [a]ct or other relevant authority.” Key v. 2 Chrysler Motors Corp. , 1996-NMSC-038, ¶ 11, 121 N.M. 764, 918 P.2d 350. “To 3 determine legislative intent we look firs t to the plain language of the statute.” 4 Draper v. Mountain States Mut. Cas. Co. , 1994-NMSC-002, ¶ 4, 116 N.M. 775, 5 867 P.2d 1157. “[W]hen a statute cont ains language which is clear and 6 unambiguous, we must give effect to th at language and refra in from further 7 statutory interpretation.” Truong v. Allstate Ins. Co. , 2010-NMSC-009, ¶ 37, 147 8 N.M. 583, 227 P.3d 73 (internal quota tion marks and citation omitted). 9
{8} Section 61-1-31(A) provides: “Any pers on who is or may be affected by a 10 regulation adopted by the [B]oard may appeal to the court of appeals for relief.” 11 The Board argues that, in light of Plaintiff’ s assertions that it already complies with 12 the law and that all of the regulation ame ndments are “redundant,” there is no harm 13 for which this Court may grant relief. In support of its argument, the Board cites 14 Kerr-McGee Nuclear Corp. v. New Mexi co Environmental Improvement Board , 15 1981-NMCA-044, ¶ 43, 97 N.M. 88, 637 P.2d 38, where we stated, “ ‘For relief’ 16 means that when a board adopts a regulation, which, when applied, leads to an 17 unfavorable result to any ‘person,’ that ‘person’ can appeal to this Court to 18 challenge the validity of the regulation. ” (Emphasis added.) The Board’s reliance 19

on Kerr-McGee Nuclear Corp. is misplaced. When read in context, it is clear this 207 Court intended this statement to express th e broad nature of the language “person” 1 rather than express a limitation on standi ng to appeal based on the harm to the 2 Plaintiff as a result of the adopted regulation. See id. ¶¶ 43-44. Similarly, the term 3 “for relief,” in the context of Section 61- 1-31(A), refers to the remedy that this 4 Court may grant the Plaintiff, which is the review and potential invalidation of 5 regulations adopted by the Board. See Black’s Law Dictionary 1482 (10th ed. 6 2014) (defining “relief” as “[ t]he redress or benefit . . . that a party asks of a 7 court”). 8
{9} The plain language of Sec tion 61-1-31(A) is broad as it grants to any person 9 who “is or may be affected by a regulation adopted by the [B]oard” the right to 10 appeal the Board’s decision to this Court. (Emphasis added.) Unlike other statutory 11 provisions that expressly limit standing to those adversely affected by a regulation, 12 Section 61-1-31(A) grants standing without regard to the nature of any existing 13 effect on the plaintiff. Compare id. with NMSA 1978, § 74-6-7 (1993) (“[A] 14 person who is adversely affected by a regulation adopted by the commission . . . 15 may appeal to the court of appeals for further relief.” (em phasis added)). We 16 believe the failure to expr ess a similar limitation in Section 61-1-31 indicates the 17 Legislature’s intent to grant all persons the right to appeal if th ey “[are] or may be 18 affected by the regulation,” whether or no t they can demonstrate an adverse effect. 19 Cf. State v. Chavez , 1992-NMCA-037, ¶ 9, 115 N.M. 248, 849 P.2d 1071 (“We 208 believe that if the [L]egislature intended such a result, it would have clearly said 1 so.”). 2
{10} The Board does not dispute that Plain tiff is subject to 16.5.1.24 NMAC and 3 16.5.9.8(K) NMAC as a non-dentist owner, and therefore, may be affected by the 4 amendments to those sections. However, the Board asserts that 16.5.16.10(B)(4) 5 NMAC “only applies to owne r dentists or supervisors, not non-dentist owners.” 6 Yet 16.5.16.2 NMAC provides that “[t]he provisions of 16.5.16 NMAC apply to 7 all active license holders and applicants for licensure [,]” and the Board does not 8 dispute that Plaintiff is an active licen se holder. (Emphasis added.) Thus, even 9 though 16.5.16.10(B)(4) NMAC only mentions owner dentists and supervisors, the 10 provision applies to Plaintiff. As an active license holder subject to these 11 regulations, Plaintiff “may be affected” by the Board’s decision to adopt the three 12 amendments. See Section 61-1-31(A). Plaintiff has standing to appeal the Board’s 13 decisions, and consequently th is Court has jurisdiction. 14 The Board Provided an Ade quate Statement of Reasons for Its Adoption of 15 the Amendments 16
{11} Having concluded that Plaintiff has standing, we turn to Plaintiff’s 17 arguments on appeal. “[I]n ad opting regulations, administra tive [boards] must give 18 some indication of their reasoning and of the basis upon which the regulations 19 were adopted in order for the courts to be able to perform their reviewing 20 function.” N.M. Mun. League, Inc. v. N. M. Envtl. Improvement Bd. , 1975-NMCA- 219 083, ¶ 16, 88 N.M. 201, 539 P.2d 221. Ho wever, “[f]ormal findings are not 1 required.” Pharm. Mfrs. Ass’n v. N.M. Bd. of Pharmacy , 1974-NMCA-038, ¶ 17, 2 86 N.M. 571, 525 P.2d 931. Nor does the Boar d need to state its reasons for 3 adopting each provision or address every con cern raised in testimony, as “[s]uch a 4 requirement would be unduly onerous . . . and unnecessary for the purposes of 5 appellate review.” The Regents of Univ. of Cal. v. N.M. Water Quality Control 6 Comm’n , 2004-NMCA-073, ¶ 13, 136 N.M. 45, 94 P.3d 788. Rather, “[t]he only 7 requirements are that the public and the re viewing courts are informed as to the 8 reasoning behind the regulation.” Pharm. Mfrs. Ass’n , 1974-NMCA-038, ¶ 17. 9
{12} Plaintiff contends that the Board faile d to provide a statement of reasons for 10 the amendments. In response, the Board ar gues that its members’ statements made 11 at the initial public hearing provide this Court with sufficient indications of the 12 Board’s reasons for the amendments. After reviewing the record, we agree with the 13 Board. Although neither the dental hygi enist committee nor th e Board dedicated 14 any real substantive discussion to the three amendments at their respective 15 meetings, the Board member s’ comments at the initial public meeting provide us 16 with sufficient information of the Boar d’s reasoning to allow for meaningful 17 review. 18
{13} In regard to the record-keeping requi rement of 16.5.1.24 NMAC, one of the 19 Board members pointed out that some non- dentist owners do, in fact, retire and 2010 corporate non-dentist owners occasionally close down w ithout transferring patient 1 records to another practice. The boardmember also pointed out that the 2 requirement was helpful to the Board’s complaint committee in terms of having 3 access to patient records. Another Board member stated thatthe record-keeping 4 requirement needed to “be on file with more teeth” because some patients were 5 having difficulty accessing their records af ter dental practices close down. In 6 responding to Plaintiff’s concerns about redundancy, a member of the Board’s 7 rules committee responsible for draftin g the amendments stated that it was 8 important to have the require ment appear in multiple s ections so licensees “would 9 be more likely to run into it.” Anothe r member of the Board’s rules committee 10 commented in favor of the amendment because it would require non-dentist 11 owners to comply with additional record -keeping requirements after they retire or 12 stop practicing. 13
{14} With respect to the amendment prohibiting non-dentist owners from 14 interfering with patient referrals an d prescription of laboratory services, 15 16.5.9.8(K) NMAC, a member of the rules committee commented that the 16 regulation was important to prevent non- dentist owners from questioning the 17 clinical judgments of dentists in order to increase profits. Another member of the 18 rules committee explained th at the purpose of the rule was to give young dentists 19 the authority to confront coercive superi ors. In response to Plaintiff’s concerns 2011 about redundancy, a Board member pointed out there were only regulations in 1 place to sanction dentist owners and supe rvisors for interfering with a dentist’s 2 clinical judgment; there was no similar re gulation applicable to non-dentist owners. 3 As such, the Board member concluded the regulation was necessary to protect the 4 public by ensuring that non-dentist owners were subject to the same requirements 5 as dentist owners in terms of interferi ng with a dentist’s clinical judgment. 6
{15} Finally, with reference to the last amendment relating to patient referrals 7 based on contractual obligations, 16.5.16. 10(B)(4) NMAC, a Board member stated 8 that the purpose of the regulation was to cover situations where the dentist’s 9 contractual obligations influenced their decision on where to refer patients, which 10 was not already proscribed by other regul ations or statutes. And another Board 11 member stated that the purpose was to pr otect the public by requiring dentists to 12 refer their patients to whomever the den tist believed would be best, regardless of 13 their contractual obligations. 14
{16} Plaintiff contends that these statements are insufficient to show the basis of 15 the Board’s decisions because the Board did not formally i ssue any findings or 16 explicitly adopt the reasoning behind them. However, the Board is not required to 17 expressly enunciate findings of fact, see Pharm. Mfrs. Ass’n , 1974-NMCA-038, 18 ¶ 17, or address every concern raised in testimony, see The Regents of Univ. of 19 Cal. , 2004-NMCA-073, ¶ 13. It must simply inform the public and the reviewing 2012 court of the reasoning behind the regulations. See Pharm. Mfrs. Ass’n , 1974- 1 NMCA-038, ¶ 17. We hold that the Board and rules committee members’ 2 statements satisfy this requirement. See id. (holding that the comments of one 3 board member, which were uncontradicted by the other board members, were 4 sufficient to enable appellate review). 5 The Board’s Adoption of the Amendments Was Not Arbitrary, Capricious, an 6 Abuse of Discretion, or Against the Clear Weight of Substantial Evidence 7
{17} Plaintiff argues that the Board’s adop tion of the amendments was arbitrary, 8 capricious, or an abuse of discretion, as well as against the clear weight of 9 substantial evidence because the Board did not considerany competent evidence. 10 See § 61-1-31(C) (stating that this Court may set aside a regulation only if it is “(1) 11 arbitrary, capricious, or an abuse of discre tion; (2) contrary to law; or (3) against 12 the clear weight of substantial evidence of the record”). We disagree. We review 13 the whole record to determine the validity of an administrative board’s decision. 14 See Town & Country Food Stores, Inc. v. N.M. Regulation & Licensing Dep’t , 15 2012-NMCA-046, ¶ 8, 277 P.3d 490. “The party challengi ng an [administrative 16 board] decision bears the burden on appeal of showing that [board] action falls 17 within one of the oft-mentioned grounds for reversal.” See Miss. Potash, Inc. v. 18
Lemon , 2003-NMCA-014, ¶ 8, 133 N.M. 128, 61 P.3d 837 (internal quotation 19 marks and citation omitted). An admini strative board acts arbitrarily and 20 capriciously when its actions “may be considered wil[l]ful and unreasonable, 2113 without consideration, and in disreg ard of the facts and circumstances.” 1 Application of PNM Elec. Servs., Div. of Pub. Serv. Co. of N.M. , 1998-NMSC-017, 2 ¶ 24, 125 N.M. 302, 961 P.2d 147. “An abuse of discretion occurs when the 3 administrative [board] has not acted in a manner required by the law.” N.M. 4 Regulation & Licensing Dep’t v. Lujan , 1999-NMCA-059, ¶ 8, 127 N.M. 233, 979 5 P.2d 744. “Substantial evidence is relevantevidence that a reasonable person might 6 accept as adequate to support a conclusi on. In reviewing a substantial evidence 7 claim, the question is not whether subs tantial evidence exists to support the 8 opposite result, but rather whether such evidence supports the result reached.” 9 Wilcox v. N.M. Bd. of Acupuncture & Oriental Med. , 2012-NMCA-106, ¶ 7, 288 10 P.3d 902 (alteration, internal quota tion marks, and citations omitted). 11
{18} Our review of the record establishes that the majority of comments at the 12 public hearing were in favor of all three amendments. The only comments in 13 opposition to the record-keeping ame ndment, 16.5.1.24 NMAC, came from 14 Plaintiff. On the other hand, several me mbers of the public and the rules committee 15 commented in favor of the amendment. A member of the Board’s rules committee 16 commented that, based on her experience serving on the Board for over eleven 17 years, the more times a requirement appear ed in the regulations, the more likely the 18 licensee would be aware of it. Another member of the rules committee commented 19 in favor of making non-dentist owners subject to the regulation because it 2014 contained additional record-keeping require ments. A local dentist also commented 1 that he knew of two corporate dental prac tices in other states that left patients 2 without access to their records after sudd enly going bankrupt. Plaintiff argues that 3 these “anecdotes concerning activities oc curring in other parts of the country 4 demonstrated no evidentiary nexus to any ev il present in New Mexi co that this rule 5 amendment is intended to rectify.” Yet Plaintiff provides no authority for the 6 argument that the Board cannot consider examples of relevant events from other 7 states, and we are aware of no such authority. See In re Adoption of Doe , 1984- 8 NMSC-024, ¶ 2, 100 N.M. 764, 676 P.2d 1329 (s tating that when a party fails to 9 cite authority for an argum ent, we may assume none ex ists). The purpose of the 10 Board is to protect the public from the improper and unprofessional practice of 11 dentistry. See NMSA 1978, § 61-5A-2(A) (2011) (“ In the interest of the public 12 health, safety and welfare and to protect the public from the improper, 13 unprofessional, incompetent and unlawful pr actice of dentistry and dental hygiene, 14 it is necessary to provide laws and rule s controlling the granting and use of the 15 privilege to practice dentistry and dental hygiene and to establish a board of dental 16 health care and a dental hygienists commit tee to implement and enforce those laws 17 and rules.”). Simply because the dentist’ s illustrative examples came from other 18 states does not mean that the Board must sit idly by waiting for the harms it is 19 trying to protect against to happen in our state. 2015 {19} The amendment prohibiting non-dentis t owners from exercising direct 1 control over a dentist’s referrals or pres cription of laboratory services, 16.5.9.8(K) 2 NMAC, also received substantial support during the initial public hearing. One 3 rules committee member commented on the importance of protecting against non4 dentist owners interfering with the clini cal judgments of dentists, and another 5 explained that the rule gave young dentis ts the ability to stand up to coercive non6 dentist superiors. Two local dentists, one of whom was a ru les committee member, 7 stated that they knew of instances wh ere non-dentist owned practices pressured 8 their dentists into performing more pro cedures in order to increase profits. 9 Additionally, the American Association of Orthodontists submitted an email in 10 support of the amendment. Again, the only comments in opposition to the 11 amendment came from Plaintiff. 12
{20} Likewise, the majority of the comme nts supported 16.5.16.10(B)(4) NMAC, 13 the amendment defining the practice of re ferring patients to outside providers 14 based on contractual obligations as “unpr ofessional conduct.” While Plaintiff and 15 one rules committee member voiced con cerns over the amendment, the other 16 comments were in favor of the amendmen t. A local dentist supportive of the 17 amendment stated that he knew of th ree instances—two involving Albuquerque 18 dentists—where dentists refe rred patients to inferior pr oviders based on contractual 19 obligations. Another dentist and rules co mmittee member commented in favor of 2016 implementing the regulation in order to protect patients. The amendment also 1 received support from the American Association of Orthodontists. 2
{21} Plaintiff would have us brush off the comments in support of the 3 amendments. Specifically, Plaintiff argues that the comments discussed above do 4 not constitute competent evidence becau se they were based on “conjecture,” 5 “unfounded opinion,” and “anec dote.” We disagree with th e veneer Plaintiff places 6 on the comments. “In proceedings held unde r the Uniform Licensing Act, boards . . 7 . may admit any evidence and may give proba tive effect to evidence that is of a 8 kind commonly relied on by reasonably prude nt people in the conduct of serious 9 affairs. Boards . . . may in their disc retion exclude incompetent, irrelevant, 10 immaterial and unduly repetitious evid ence.” NMSA 1978, § 61-1-11(A) (1981). 11 We fail to see how the comments are not “of a kind commonly relied on by 12 reasonably prudent people in th e conduct of serious affairs.” Id. Notably, all of the 13 commenters, besides Plaintiff’s attorney, we re local professionals in the field of 14 dentistry. Some of the commenters were also members of the Board’s rules 15 committee in charge of drafting the amen dments. Many, if not all, of their 16 comments were based on firsthand knowle dge. The root of Plaintiff’s argument 17 appears to be that the Board should have given credence to Plaintiff’s opinions and 18 not those of the other commenters. Howeve r, we will not reweigh the evidence, nor 19 substitute our judgment for that of the Board. Bd. of Cty. Comm’rs of Sierra Cty. v. 2017 Harrison , 1998-NMCA-106, ¶ 7, 125 N.M. 495, 9 64 P.2d 56. Given the number of 1 the comments in favor of the amendments and the qualifications of those making 2 the comments, we hold that the Board’ s adoption of the amendments was not 3 arbitrary, capricious, an abuse of discre tion, or against the clear weight of 4 substantial evidence. 5
{22} Plaintiff makes several additional ar guments, which we briefly address. 6 Throughout its brief in chief, Plaintiff claims that the Board’s adoption of the 7 amendments was arbitrary, capricious, or an abuse of discretion because the 8 amendments are redundant and confusing in light of existing regulations and laws. 9 Yet Plaintiff cites no authority for the pr oposition that an administrative board’s 10 adoption of a regulation is improper becaus e the regulation’s purpose is separately 11 provided for by other regulations or statut es. Where a party cites no authority to 12 support its argument, we may a ssume no such authority exists. See In re Adoption 13 of Doe , 1984-NMSC-024, ¶ 2. Thus, we dec line to address this argument. 14
{23} Plaintiff also asserts that the re gulations violate equal protection and 15 “potentially conflict” with existing law. Ho wever, we also decline to opine on 16 these arguments, as Plaintiff makes no real attempt to demonstrate how the 17 regulations are unconstitutional or inco mpatible with existing law beyond these 18 conclusory assertions. See Elane Photography, LLC v. Willock , 2013-NMSC-040, 19 ¶ 70, 309 P.3d 53 (declining to rule on an inadequately briefed argument). 2018 {24} Lastly, Plaintiff argues that the Bo ard’s adoption of the amendments was 1 error because “there was no rational co nnection between the facts found and the 2 [amendments] adopted because no facts based on record evidence or testimony 3 were found by the Board.” However, as di scussed earlier, the Board is not required 4 to enter any formal findings of fact. See Pharm. Mfrs. Ass’n , 1974-NMCA-038, ¶ 5 17. Nor does Plaintiff demonstrate how th ere is a lack of a rational connection 6 between the public comments and the Boar d’s decision to adopt the amendments. 7 Therefore, Plaintiff’s argument is unavailing. 8 CONCLUSION 9
{25} For the foregoing reasons, we affirm the Board’s decision to adopt the 10 amendments. 11
{26} IT IS SO ORDERED. 12

__________________________________ 13 LINDA M. VANZI, Judge 14 WE CONCUR: 15

_________________________________ 16 BRIANA H. ZAMORA, Judge 17

_________________________________ 18 ZACHARY A. IVES, Judge 19