branding requirement. IV. CONCLUSION I would therefore affirm. 1 .See Op. at 139. 2 . See Op. at 144-145. 3 . See Kachemak Bay Watch, Inc. v. Noah, 935 P.2d 816, 825-26 (Alaska 1997). 4 . See id. at 821. 5 . See Board of Trade, Inc. v. State, Dep't of Labor, 968 P.2d 86, 89 (Alaska 1998). 6 . See Kodiak Seafood Processors Ass’n v. State, 900 P.2d 1191, 1197 (Alaska 1995) (citing Olson v. State, Dep't of Natural Resources, 799 P.2d 289, 292-93 (Alaska 1990)); see also Kachemak Bay Watch, 935 P.2d at 825. 7 . See AS 44.62.640(a)(3). 8 . 11 AAC 60.070 provides in full: All livestock permitted on a state grazing lease shall be properly identified and such identification registered in accordance with AS 03.40.010-03.40.270. In addition, the director may require that the livestock be 8-59 (<HOLDING>). 12 . See Usibelli Coal Mine, 921 P.2d at
holding that the challenge to a university regulation was moot because the regulation had been substantially amended holding that verbal requirement of need not contained in hunting regulation was addition of substance and thus regulation under apa holding that pma process is not specific regulation because the requirements are not contained in formal regulation holding that ojrdinarily when a regulation is not promulgated in compliance with the apa the regulation is invalid however when equity demands the regulation can be left in place while the agency follows the necessary procedures citation omitted holding that agency decision calculating royalties was not regulation because it did not involve making of policy decisions and did riot make addition of substance