NOT FOR PUBLICATION

PER CURIAM.

On April 13, 2006, Senator Nia H. Gill, in her position as Chair of the Senate Commerce Committee, filed with the Department of Banking and Insurance (Department) a request for records pursuant to the Open Public Records Act (OPRA), N.J.S.A. 47:1A-1 to-13. Specifically, Senator Gill sought documents concerning the rating criteria used by automobile insurers to determine premiums, relying on the declaration in N.J.S.A. 17:29A-46.2(b) that "underwriting rules" filed by insurers with the Department "shall be subject to public inspection." The Department turned over more than 3500 pages but concluded that other documents were exempt because OPRA does not require production of government records containing "proprietary commercial or financial information," which, if disclosed, would "give an advantage to ... competitors." See N.J.S.A. 47:1A-1.1.

Senator Gill filed a complaint with the Government Records Council (GRC),1 which transmitted the matter to the Office of Administrative Law as a contested case. After conducting an in camera review of the records in question, Administrative Law Judge Jeff S. Masin issued a written opinion on June 10, 2010. He concluded that certain documents did not constitute "underwriting rules" and fell within the proprietary exclusion contained in N.J.S.A. 47:1A-1.1. After considering the exceptions filed, the GRC adopted Judge Masin's recommendations and findings by way of a written final decision filed on October 26, 2010.

Senator Gill appeals the final agency decision, arguing:

We reject these arguments and affirm the GRC's final decision substantially for the reasons set forth by Judge Masin in his comprehensive and thoughtful written opinion. We add only the following comments.

On their face, the parties' arguments suggest the existence of a conflict between two separate legislative declarations. The first, N.J.S.A. 17:29A-46.2(b), requires that insurers file with the Department "underwriting rules," which "shall be subject to public inspection." The second is OPRA's exemption from turnover government records that contain "trade secrets and proprietary commercial or financial information." N.J.S.A. 47:1A-1.1. The clash of these arguably conflicting declarations did not occur here because it was not determined that "underwriting rules" should be withheld pursuant to the OPRA exception. Instead, Judge Masin correctly determined that in the absence of a clearer direction as to what it meant by "underwriting rules," the Legislature could not have intended "that each and every element of the entire manner and method of an insurer's rate-making decision be publicly available," concluding that if the Legislature possessed this intent, "it could have said so." Accordingly, Judge Masin — and ultimately the GRC — concluded that the documents in question were not "underwriting rules" and, therefore, not accessible to the public pursuant to N.J.S.A. 17:29A-46.2(b), and, also, that they were not discoverable pursuant to OPRA in light of the exception contained in N.J.S.A. 47:1A-1.1. We agree.

Here, after properly recognizing a limitation on the types of materials falling within the meaning of "underwriting rules," the ALJ thoroughly examined the records and ascertained which were subject to public inspection. The GRC independently examined the record and the parties' contentions, see Paff v. N.J. Dep't of Labor, 379 N.J.Super. 346, 353-56 (App. Div. 2005), and agreed with Judge Masin's recommendations.

Our scope of review is narrow. In re Taylor, 158 N.J. 644, 656 (1999); Paff v. N.J. Dep't of Labor, 392 N.J.Super. 334, 340 (App. Div. 2007). As an appellate court reviewing a final agency decision, we are not free to override an agency's factual determinations or disregard the agency's expertise. Instead, we must determine whether the findings "could reasonably have been reached on sufficient credible evidence present in the record," Close v. Kordulak Bros., 44 N.J. 589, 599 (1965), while employing "a strong presumption of reasonableness to the decision of an administrative agency," Paff, supra, 392 N.J. Super. at 340; see also Smith v. Ricci, 89 N.J. 514, 525, appeal dismissed, 459 U.S. 962, 103 S.Ct. 286, 74 L. Ed. 2d 272 (1982). Application of these principles compels our deference to the GRC's factual findings, which were those expressed by Judge Masin.

To be sure, our obligation to defer to an agency's factual findings, in light of that agency's particular expertise, does not extend to the agency's interpretation of legal principles, see In re Application of Virtua-West Jersey Hosp. Vorhees, 194 N.J. 413, 422 (2008), but we have found no legal error. As observed, the GRC's disposition recognizes that the legislative direction in N.J.S.A. 17:29A-46.2(b) does not render all materials relating to rate-making subject to public inspection, and OPRA provides an exclusion for proprietary information, N.J.S.A. 47:1A-1.1, such as the materials in question. Absent further clarification from the Legislature, the statutes were properly interpreted.

Affirmed.