PER CURIAM:
On October 13,1981, we ordered “that the order of the Board [of Elections and Ethics] [509]*509hereby is set aside and the cause is remanded to the Board with directions to certify, nunc pro tunc as of August 3, 1981, Initiative Seven for inclusion on the November 3, 1981, ballot.” The order noted that Chief Judge NEWMAN and Associate Judges MACK and PRYOR dissented, and that “[o]pinions will be filed as promptly as the business of the court permits.”
The opinion of Associate Judge HARRIS is joined by Associate Judges KELLY, KERN, and NEBEKER, Chief Judge NEWMAN and Associate Judges MACK, FER-REN, and PRYOR join in Part II, and Associate Judge BELSON joins in Parts I, II, and III, of Associate Judge HARRIS’ opinion.
Chief Judge NEWMAN and Associate Judges MACK, PRYOR, and BELSON join in Part III of the opinion of Associate Judge FERREN. Associate Judge BEL-SON also joins in Parts II, IV, and V of Associate Judge FERREN’s opinion.
The dissenting opinion of Associate Judge MACK is joined by Chief Judge NEWMAN and Associate Judge PRYOR.
HARRIS, Associate Judge:
Before us in these consolidated cases are petitions for review of a decision of the Board of Elections and Ethics (“Board”) which rejected certain petitions in support of an initiative for certification on the November 1981 ballot.1 The initiative which was proposed, entitled the “District of Columbia Greater Educational Opportunities Through Tax Incentives Initiative of 1981” and known in abbreviated fashion as “Initiative Seven,” concerned potential tax credits for tuition payments by District of Columbia taxpayers. Petitioner Dankman, the proponent of Initiative Seven, sought reversal of the Board’s decision, contending primarily that the Board erroneously interpreted one of its regulations. Intervenors Dixon, et al., were the challengers to Dank-man’s initiative petitions before the Board.2 They advocated affirmance of the Board’s order, both for the reason assigned by the Board and on additional grounds which explicitly were rejected by the Board. By our order dated September 18, 1981, a division of the court set aside the Board’s order and directed that the Board certify Initiative Seven for inclusion on the November 1981 ballot. On October 5,1981, the court granted respondent’s petition for rehearing en banc and vacated the September 18 order. Immediately following the en banc argument on October 13, we issued another order directing the Board to certify the initiative for placement on the ballot. The initiative was defeated decisively in the November 3 election. This opinion sets forth the reasons for our decision that the electorate was entitled to vote on the issue.
I
A brief overview of the procedure for an initiative is appropriate. The Initiative, Referendum, and Recall Procedures Act of 1979 3 (“Initiative Act” or “Act”) was enacted to allow the electors of the District of Columbia to propose laws and to present those proposals directly to the voters for approval or disapproval. See D.C.Code 1981, § 1-1302(10). The sponsor of an initiative, known as the proponent, first must submit his proposal to the Board of Elections and Ethics. Upon receipt of the proposed initiative measure, the Board assigns a number to it, prepares a short title and an impartial summary of its purpose, places it in proper legislative form, and certifies that [510]*510the petition is in final form.4 The proponent then has 180 days within which to secure the requisite number of valid signatures to enable the initiative to be placed on the ballot. The petition must be signed by at least five percent of the registered voters in the District of Columbia, and the total signatures submitted must include five percent of the registered voters in at least five of the city’s eight wards.
After a signed petition has been submitted, the Board may refuse to accept the petition if it finds that the measure is not a proper subject for an initiative or referendum or that the petition contains any of the irregularities outlined in D.C.Code 1980 Supp., § l-1116(k)(1)-(7). If the Board accepts the petition, it has 30 days in which to certify whether the number of valid signatures on the petition meets the qualifying distribution and percentage requirements.5 The Board must post the petitions for public inspection for ten days, beginning on the third day after the petitions are filed. Within this time period, any voter may challenge the validity of any petition.
Petitioner Dankman was the proponent of Initiative Seven. On February 27, 1981, the proposed measure was submitted to the Board. On March 4, 1981, the Board adopted its short title, summary statement, and legislative form, and certified that the proposed petition was in compliance with the requirements of D.C.Code 1980, Supp., § 1 — 1116(h) [now D.C.Code 1981, § 1-1320(h)]. The relevant portion of that section provides that:
(1) Before circulating the petition, the proposer shall submit the petition to the Board of Elections and Ethics, for verification that the form of the petition is in compliance with the provisions of this section. * * *
(2) Each petition sheet or sheets for an initiative ... shall have attached ... a statement made under penalties of perjury ... which contains the following:
(A) The printed name of the circulator;
(B) The residence address of the circu-lator, giving the street and number;
******
(E) That the circulator of such initiative or referendum petition sheet is a qualified registered elector of the District of Columbia; and
(F) The dates between which the signatures to the petition were obtained.
The Board-approved initiative then was circulated among District of Columbia citizens by some 19 to 24 circulators. On June 29, 1981, petitioner presented a petition for filing containing 1,711 petition sheets and 27,415 signatures in support of the initiative.7 The Board conducted a public hearing on the question of whether the measure presented was a proper subject for initiative. On July 6, the Board advised petitioner that it had, at a special meeting, approved the subject matter of Initiative Seven.8 On that date, the Board also accepted the petitions for filing, finding that the petitions complied with the requirements of regularity outlined in D.C.Code 1980 Supp., § 1 — 1116(k).
The Board then had 30 days within which to ascertain the validity of the submitted signatures and, if their validity were established, to certify the initiative for placement on the ballot. This time period was interrupted, however, by the July 18 filing [511]*511of two challenges to the petitions.9 Inter-venor Dixon — joined by Mayor Marion Barry and 34 others — lodged the following objections to the proponent’s petitions: (1) the summary statement and the legislative text of the initiative were inconsistent and, therefore, the statement was misleading; (2) the notary public to the petitions, JoAnn Willis, had such an interest in Initiative Seven as to vitiate the signatures of the electors (see note 9, supra); (3) the circula-tors of the petitions induced citizens to sign the petitions by false and misleading statements; (4) the proposer of Initiative Seven had failed to file a verified statement of contributions pursuant to § 1-1116(k)(1); and (5) some of the circulators were not qualified electors when they circulated the petitions, in violation of § l-1116(h)(2)(E). Mayor Barry filed a separate challenge to the petitions which the Board later dismissed “because of the failure of any person to appear on his behalf to prosecute the challenge.” See note 2, supra.
Following a hearing and the submission of briefs, on August 3 the Board sustained one of intervenors’ challenges to the petitions. The Board overruled allegations of other defects assigned by intervenors, but found that the 22,624 signatures obtained by seven of the circulators working on petitioner’s behalf were to be rejected because those circulators were not residents of the District of Columbia and, therefore, they could not be qualified electors. See D.C. Code 1980 Supp., § 1 — 1116(h)(2)(E). The Board concluded that “[tjheir lacking legal status to circulate the petition so tainted this Initiative # 7 and the electoral process that all of the signatures they obtained are rejected.” The effect of sustaining interve-nors’ challenge — which meant the invalidation of the signatures of 22,624 voters — was to block Initiative Seven from appearing on the ballot. Notwithstanding its rejection of the collected signatures (and noting that “the Court could reverse the Board’s decision”), on August 5 the Board announced the results of the random statistical sampling which verified the signatures submitted in favor of the initiative. Five of the eight wards met the required number of signatures with greater than 99 percent confidence; no decision was reached as to the other three wards because the requisite five wards already had been accepted. See id., § 1 — 1116(i).
II
Dankman contended that the Dixon challenge to the Initiative Seven petitions was filed beyond the time period specified in the Initiative Act, D.C.Code 1980 Supp., § 1-1116(o), thus rendering the Board without jurisdiction over the challenge. We disagree.
After the Board has accepted a petition for filing, it has 30 days in which to determine whether certification of the initiative for the ballot is appropriate. See D.C.Code 1980 Supp., § 1 — 1116(o). During this time, the Board ascertains whether the number and validity of signatures on the initiative petition meet the Act’s qualification standards. The Board must post the petitions for public inspection
for ten (10) days, including Saturdays, Sundays, and holidays, beginning on the third day after the petitions are filed. Any qualified elector may, within such ten (10) day period, challenge the validity of any petition, by a written statement duly signed by the challenger and filed with the Board, specifying concisely the alleged defects in such petition. [Ibid.]
Petitioner urged that the language “after the petitions are filed” means that the challenge period (commencing three days after filing and then running for ten days) is triggered when a proponent submits his petition to the Board for filing after securing the appropriate number of valid signatures. Id., § 1-1116(j)(1). Having submitted his [512]*512petitions for filing on June 29, 1981, petitioner argued that the Dixon challenge of July 18, 1981, came after the specified time period had lapsed.
The section of the Initiative Act providing for challenges by qualified electors, § 1 — 1116(o), speaks of the procedure for the Board to follow “[a]fter acceptance of an initiative or referendum petition.” Thus, the operation of that section is premised on the Board’s having accepted the petitions. Petitioner's submission of the petitions alone cannot set the procedures outlined in § 1 — 1116(o) into motion. Once the Board accepts the submitted petitions, the Board’s 30-day certification period and the challenge period begin to run. Such an interpretation of § 1 — 1116(o) is consistent with a regulation validly promulgated by the Board, which provides that initiative petitions shall be available for public inspection for ten days “beginning on the third (3rd) day after the petition has been accepted for filing.”- 3 D.C.M.R. 66, § 1010.1.
Petitioner points to language in Citizens Against Legalized Gambling v. Board of Elections and Ethics, 501 F.Supp. 786, 788 (D.D.C.), aff’d per curiam, No. 80-2251 (D.C.Cir., Oct. 28, 1980), which appears to indicate that the clock starts running on the ten-day posting period from “[t]hree days after a petition is submitted.” However, a reading of that passage in isolation is misleading because the District Court — at least implicitly — read § l-1116(o) as providing that the opportunity for qualified electors to challenge the petitions exists only after the Board has accepted the petitions for filing. The District Court stated:
The Board has an independent duty to assure sufficiency. The 10-day period for opponents cannot be viewed in isolation from the 30-day period during which the Board must complete all its work. It is reasonable to conclude that if opponents to an initiative present strong evidence of petition insufficiencies within the first 13 days of the 30-day period (by using the full 10-day span allotted opponents, following the initial 3-day period prior to posting), this may well affect the Board’s decision as to how carefully the petition will be verified. [Id., at 789-90.]
The court recognized that the two time periods run concurrently. It follows that, since the Board’s time period starts only after its acceptance of the petitions for filing, then likewise the challenge period must begin with the acceptance of the petitions.
The Board accepted the initiative petitions on July 6, 1981, and the ten-day period for challenging them began three days later, on July 9. Accordingly, the July 18 challenge was timely, and the Board had jurisdiction to hear it.
Ill
Petitioner Dankman maintained that the Board improperly disregarded one of its own regulations in finding that the status of some of the petition circulators as apparently non-qualified electors invalidated the otherwise admittedly valid signatures which they had obtained. Before circulating the petition, Dankman had submitted it, together with the circulators’ statements of qualification, to the Board on February 27, 1981, for the Board’s determination that the form of the petition complied with statutory requirements. See D.C.Code 1980 Supp., § 1-1116(h). One such requirement is that “a statement made under penalties of perjury” be attached to the petition declaring “that the circulator of such initiative or referendum petition sheet is a qualified registered elector of the District of Columbia.” Id., § 1 — 1116(h)(2)(E). The Board certified on March 4, 1981, that the initiative was in final form and in compliance with the requirements set forth in § 1-1116(h)(2).10
[513]*513Nevertheless, at the hearing on interve-nors’ challenge, the Board ruled that seven of the circulators working on petitioner Dankman’s behalf were not qualified electors because they were not residents of the District. See note 20, infra. However, a Board regulation specifically provides that the failure of a circulator to be a registered qualified elector does not invalidate the signatures of persons who are registered qualified electors. Board Rule 1607.9, 3 D.C.M.R. 64, § 1008.9.11 Despite that regulation, the Board ordered that the 22,624 signatures collected by those seven circulators be rejected — on the sole basis of the circulators’ status — concluding that both Initiative Seven and the electoral process had been “tainted.”
No petition for review was directed to the regulation, which had been in effect for well over a year. In the only instance in which the regulation has been challenged, its validity was upheld. Citizens Against Legalized Gambling, supra. Because the United States Court of Appeals found “it unnecessary to rule upon the validity of Board Rule 1607.9 [Rule 1008.9]” in affirming the judgment in that case (by an unpublished order), the determination by the District Court that the regulation is valid is unimpaired.
As a validly promulgated and unchallenged regulation, Rule 1008.9 is binding upon the Board. National Conservative Political Action Committee v. Federal Election Commission, 200 U.S.App.D.C. 89, 95, 626 F.2d 953, 959 (1980) (per curiam); Panhandle Eastern Pipe Line Co. v. Federal Energy Regulatory Commission, 198 U.S. App.D.C. 387, 402, 613 F.2d 1120, 1135 (1979), cert. denied, 449 U.S. 889, 101 S.Ct. 247, 66 L.Ed.2d 115 (1980) (an agency should not “have authority to play fast and loose with its own regulations”); United States Lines, Inc. v. Federal Maritime Commission, 189 U.S.App.D.C. 361, 368 & n.20, 584 F.2d 519, 526 & n.20 (1978); Zotos International, Inc. v. Kennedy, 460 F.Supp. 268, 275 (D.D.C.1978) (“It is axiomatic that once an agency commits itself in its regulations to adhering to certain principles or procedures, it cannot violate them.”). Moreover, the regulation has the force and effect of law. Atwood’s Transport Lines, Inc. v. United States, 211 F.Supp. 168, 170 (D.D.C.1962), aff’d mem., 373 U.S. 377, 83 S.Ct. 1312, 10 L.Ed.2d 420 (1963) (“Rules and regulations promulgated by Governmental establishments pursuant to statutory authority have the force and effect of law, and concededly are subject to the same tests as statutes.”). The Board, then, like every administrative agency, was required to adhere to its own regulation. Vitarelli v. Seaton, 359 U.S. 535, 539-40, 79 S.Ct. 968, 972-973, 3 L.Ed.2d 1012 (1959); Service v. Dulles, 354 U.S. 363, 388-89, 77 S.Ct. 1152, 1165, 1 L.Ed.2d 1403 (1957); Accardi v. Shaughnessy, 347 U.S. 260, 268, 74 S.Ct. 499, 503, 98 L.Ed. 681 (1954).
During the hearing before the Board, the Chairman indicated for the first time that Board Rule 1008.9, dealing with the effect of a circulator’s status on the otherwise valid signatures he collects, apparently would not be given its facially plain meaning. Presaging the Board’s subsequent fallacious application of the regulation, the Chairman announced:
[514]*514I would like to say at the beginning that we have all of your legal objections in our mind, Mr. Mayberry [counsel for petitioner Dankman], but I hope that you are appreciative that serious allegations have been made.
The Board wants to put you on notice that you should not place too great a reliance on the Section 1008.9 of our rules. We are not saying that your argument on that particular point does not have merit. We have not passed on it, but I certainly want you to understand that it is possible that that rule could be considered to apply to a situation different from this one.
So, for the purpose of preparing your response, I understand you have relied on it as a matter of law, but I think we ought to warn you that it would be dangerous to put too much reliance on that as a matter of law.
Consistent with those admonitions, the Board, in its findings of fact, acknowledged the existence of Rule 1008.9, but stated that it “believe[d]” the rule was not intended to cover the situation presented by the seven challenged circulators. The Board concluded “[t]hat the intent of Board Rule 1008.9 is to cover those instances in which the circu-lator failed to be registered due to his or her inadvertence to register, or a candidate or proponent reasonably believes the circu-lator is a qualified elector, and the number of signatures involved was de minimis.”
Unless plainly erroneous, an agency’s interpretation of its own regulation will be accorded deference. Snider v. Board of Appeals and Review, D.C.App., 342 A.2d 50, 51 (1975); Sellers v. District of Columbia, D.C.Mun.App., 143 A.2d 96, 98 (1958); Wright v. Paine, 110 U.S.App.D.C. 100, 102, 289 F.2d 766, 768 (1961). Our review of the Board’s application of its regulations is governed by a standard of reasonableness. “[W]hen the Board attempts to apply its own regulations, we cannot substitute our judgment if the Board’s application is reasonable.” Pendleton v. Board of Elections and Ethics, D.C.App., 433 A.2d 1102, 1105 (1981) (per curiam), citing In re Haworth, D.C.App., 258 A.2d 447 (1969); see D.C.Code 1978 Supp., § 1 — 1108(p)(2).
Here the plain meaning of the regulation prohibits the whimsical applicability given it by the Board to the facts of this case.12 Board Rule 1008.9 means what it says: a defect in the circulator’s status does not invalidate the signatures he has gathered. The possible sins of the circulator are not to be visited upon the electors who signed petition sheets in good faith. The clear phrasing of the regulation does not contain a single qualifier — not for inadvertence, not for reasonable belief about a cir-culator’s status, and not for the quantity of signatures called into question.13 Accordingly, we cannot conclude that the Board’s interpretation of its rule was reasonable. We find that the Board’s interpretation— which served to qualify the rule into oblivion — was plainly erroneous and restricted rather than implemented the basic purpose of the Initiative Act. That purpose, in the final analysis, is to permit the electorate to [515]*515vote on appropriate issues. See D.C.Code 1981, § 1-1324; 25 D.C.Reg. 9454 (1979); cf. Citizens Against Legalized Gambling, supra, 501 F.Supp. at 789 (initiative legislation to be liberally construed).
We note that our view of the rule is consistent with the overall tenor of the Initiative Act which prevents “harmless error” in the signature collection process from vitiating the validity of the petitions. See, e.g., D.C.Code 1981, § 1-1320 (if “the same person has signed a petition for the same initiative or referendum measure more than once, [the Board] shall count only one (1) signature of such person”; if a person signs a petition but indicates the wrong ward as his residence, “such person shall be counted from the correct ward in determining whether or not an initiative or referendum measure qualifies for the ballot.”). The paramount concern must be with the validity of the signatures on the petitions, for “[t]o deny the persons who signed these petitions the chance to have those signatures count — solely because of misconduct by others that does not cast doubt on the signatures themselves — would force this Court to stand on form rather than substance.” Citizens Against Legalized Gambling, supra, 501 F.Supp. at 790; cf. Pendleton v. Board of Elections and Ethics, supra, 433 A.2d at 1104 (“Our purpose in reviewing elections is merely to insure that no voter was disenfranchised through improper interpretation by the Board.”).14
IV
The Dixon challengers not only intervened in Dankman’s petition for review, but also filed their own petition for review of the Board’s determination, asking that we affirm the Board’s order for reasons other than those upon which the Board relied. They urged that the Board erred in not premising its rejection of the initiative petitions on the additional grounds that (1) the summary statement was misleading; (2) the petitions were notarized improperly; and (3) the proponents failed to file a verified statement of contributions before the petitions were accepted.
Intervenors assert standing to advance such arguments under D.C.Code 1978 Supp., § l-1108(p)(2), which provides that
[wjithin three days after announcement of the determination of the Board with respect to the validity of the nominating petition, either the challenger or any person named in the challenged petition as a nominee may apply to the District of Columbia Court of Appeals for a review of the reasonableness of such determination. The court shall expedite consideration of the matter and the decision of such court shall be final and not appeala-ble.[15]
That provision alone, however, cannot clothe a party with automatic standing to challenge unfavorable rulings by an agency. As we stated in Lee v. Board of Appeals and Review, D.C.App., 423 A.2d 210, 215 (1980), “we may entertain only petitions [516]*516brought by ‘any person suffering a legal wrong, or adversely affected or aggrieved, by an order of decision of the Mayor or an agency in a contested ease .. .. ’ D.C.Code 1978 Supp., § 1-1510.” The Dixon group has failed to show that it was affected adversely by the Board’s order. Nor can it point to any injury. Because the Board sustained their challenge to the proponent’s petitions, the Dixon group, unlike petitioner Dankman, cannot be considered to have been aggrieved by the order. Dixon, et al, thus lack standing to appeal the Board’s order in their favor. See Valley Forge Christian College v. Americans United for Separation of Church and State, Inc., - U.S. -, -, 102 S.Ct. 752, 757, 70 L.Ed.2d 700 (1982); Deposit Guaranty National Bank v. Roper, 445 U.S. 326, 333, 100 S.Ct. 1166, 1171, 63 L.Ed.2d 427 (1980); American Fire & Casualty Co. v. Finn, 341 U.S. 6, 18 n.17, 71 S.Ct. 534, 542 n.17, 95 L.Ed. 702 (1951); Public Service Commission v. Brashear Freight Lines, Inc., 306 U.S. 204, 206, 59 S.Ct. 480, 481, 83 L.Ed. 608 (1939) (per curiam) (Commission, as successful party below, has no standing to appeal lower court’s decree); Sea-Land Service, Inc. v. International Longshoremen's Association, 625 F.2d 38, 40 (5th Cir. 1980); Burleson v. Coastal Recreation, Inc., 572 F.2d 509, 511 (5th Cir. 1978) (“Ordinarily only a litigant who was a party below and who is aggrieved by the judgment or order may appeal.”); Pepsico, Inc. v. FTC, 472 F.2d 179, 186 (2d Cir. 1972), cert. denied, 414 U.S. 876, 94 S.Ct. 44, 38 L.Ed.2d 122 (1973) (“The notion that being a ‘party’ before an agency either automatically confers or is a necessary condition of the right to judicial review [is no longer valid].”); Koehne v. Harvey, D.C.Mun.App., 39 A.2d 871, 872 (1944) (per curiam) (successful party below lacks standing to appeal because “he is in no position to complain that he is aggrieved by his own success”); 73 C.J.S. Public Administrative Bodies and Procedure § 176 (1951) (“As a general rule an administrative ruling or decision must result in prejudice to the rights of a person before he may secure a judicial review thereof.”); cf. Fuller v. Branch County Road Commission, 520 F.2d 307, 309 (6th Cir. 1975) (per curiam) (party to a consent decree who has been accorded the relief he agreed to is not considered aggrieved and may not appeal from order dismissing complaint). Accordingly, we would dismiss the petition to review in No. 81-978.16
Obviously, as parties to the proceeding below, Dixon, et al., may be heard as inter-venors in Dankman’s petition for review. See D.C.App.R. 15(g). Our rule governing intervention, Rule 15(g), grants automatic intervention status to anyone who was a party to the proceeding before the agency. No member of the court disputes Dixon, et al.’s right to intervene in Dankman’s petition. Rather, the question is the permissible scope of intervention. We conclude that the Dixon intervenors may not broaden the scope of contested issues but rather only may support the reasons assigned by the Board for its decision.
The limitations upon the intervenors’ function emanate from the nature of appeals from agency determinations. In a petition for review of an order in an administrative proceeding, the petitioning losing party does no more than attack some aspect of the lower tribunal’s order, leaving the tribunal itself to defend its actions. By [517]*517procedural design, the agency carries the burden of supporting its decision and occupies a defensive role. To permit an interve-nor not only to lend its voice in support of the Board’s action but also to assert additional grounds which had been rejected by the agency would afford an intervenor the power effectively to convert agency challenges into litigation between the private parties to the agency proceeding.17 See 9 Moore’s Federal Practice § 215.07 (2d ed. 1980); Shapiro, Some Thoughts on Intervention Before Courts, Agencies, and Arbitrators, 81 Harv.L.Rev. 721, 727, 754 (1968) (“When one is granted intervention, either as of right or in the exercise of discretion, it does not necessarily follow that he must be granted all the rights of a party at the trial and appellate levels. * * * Yet it should not follow from the right to intervene on a given issue that the intervenor obtains all the rights of a party with respect to every issue.”); cf. Credits Commutation Co. v. United States, 177 U.S. 311, 315-16, 20 S.Ct. 636, 638, 44 L.Ed. 782 (1900) (denial of motion to intervene appropriate where questions raised by intervenors would be handled better in separate suit).
The grant of such unintended power would enable an intervenor to come into a review proceeding to assert a point of view wholly independent from either the Board’s or petitioner’s position. Such an expansive role for an intervenor would run contrary to the intent of the intervention rule, which simply seeks to assure that issues unavoidably addressed by the court are not resolved in the absence of proper representation. Here, Dixon, et al., attempt to inject issues into the appellate phase of the litigation that neither the Board nor petitioner saw fit to contest.18
A majority of the court, unquestionably swayed by the fact that this is an election case in which the constraints of time are narrow, concludes that the mere label of “intervenor” should permit a party to such a case to raise all issues with which it is concerned, notwithstanding the positions taken by the petitioner and the respondent agency. Their purported justification for such a holding is threefold: (1) the interve-nors’ position as the prevailing party is put in jeopardy when the losing party files a petition for review;19 (2) the Initiative Act provides for equal access to the courts (only, we note, by the losing party); and (3) in an election case, time is of the essence. We find these reasons totally unpersuasive. The first argument falls short of showing how intervenors satisfy the “aggrieved” re[518]*518quirement for standing to enable them to advance arguments other than those raised by the original parties to the appeal. The statutory argument is similarly unavailing, as the relevant Code provision simply assures that the Board’s decision is reviewable on petition by the losing party. In any event, there is no sound justification for reading the statute as according intervenors all the rights of a petitioner, and, thereby, to eviscerate the requirements of standing. See Valley Forge Christian College v. Americans United for Separation of Church and State, Inc., supra, - U.S. at - n.24, 102 S.Ct. at 766 n.24. As for the third justification, while time certainly is of the essence, that truism may not be invoked to overturn established precedent governing the exercise of judicial power.
In their proscribed role as intervenors, to which we would limit them, Dixon, ef al, argue that the Board’s order should be upheld because: (1) intervenors’ challenge was timely; (2) the Board correctly construed its Rule 1008.9; and (3) the circulators were not qualified registered electors as required by D.C.Code 1980 Supp., § 1-1116(h)(2)(B), (E).20 We already have disposed of interve-nors’ first two arguments. See ante, at II and III. Because of our holding regarding the appropriate construction of Board Rule 1008.9, we need not reach intervenors’ last contention in support of the Board’s order. Even if we were to conclude that the Board properly found that seven of the circulators were not qualified registered electors, Rule 1008.9 prevents that circumstance from posing a fatal defect to the petitions.
FERREN, Associate Judge, concurring in the result:1
The Board of Elections and Ethics has adopted a rule expressly providing, without exception, that “[t]he failure of the circulator of an initiative or referendum petition to be a registered qualified elector will not invalidate the signature of an otherwise registered qualified elector.” Board Rule 1607.9; 3 D.C.M.R. 64, § 1008.9. I believe that Rule 1607.9 is valid, and that the Board violated this rule when it rejected petitions containing 22,624 signatures. Accordingly, I conclude that the Board must certify Initiative # 7 for the November 1981 ballot.
I.
The record supports the Board’s conclusion that “circulators of petitions supporting Initiative # 7, who obtained 22,624 signatures (82.52%), were not residents of the District of Columbia .. .. ” Board Conclusion of Law 8. It follows that none could be “a qualified registered elector of the District of Columbia,” a status required of everyone who circulates an initiative petition. D.C.Code 1980 Supp., § 1— 1116(h)(2)(E). Despite this clear requirement of the law, however, these circula-tors — sponsored by a local committee of the National Taxpayers Union — directed a virtual blitz of petitions at the District of Columbia electorate. I agree with the Board, and with my dissenting colleagues, that the evidence reflects “a manipulation of the initiative process in direct violation of statutory direction .... ” Board Order at 14.
This “manipulation,” however, is not conclusive here, for the record establishes three other important facts:
First, no one questions that the signatures on the petitions filed in support of Initiative # 7 — a total of 27,415 — are authentic signatures of “qualified registered electors.” D.C.Code 1980 Supp., §§ 1-[519]*5191116(g)(1), -1116(h)(2)(D), -1116(i). The Board verified the signatures through random statistical sampling. Accordingly, this is not a case where the failure of the circu-lators’ qualifications raised questions about the genuineness of the petitioners’ signatures.2
Second, although intervenors alleged that “unnamed circulators made misleading and deceptive statements to potential signatories to the petition,” the record supports the Board’s finding that the evidence presented to substantiate those allegations “was meager and inconclusive.” Board Finding of Fact No. 6.3
Third, without regard to the legal or policy merits of the tax credit proposal, the Board concluded at its meeting of July 1, 1981, that the proposal is a “proper subject” for a citizens initiative. D.C.Code 1980 Supp., § l-1116(k). No one challenges that conclusion.4
Consequently, we confront a question that no other court, to my knowledge, has had to consider: When the Board has accepted petitions containing a proper subject for an initiative, verified that a sufficient number of qualified registered electors have signed them, and concluded that the evidence fails to support allegations that the circulators made misleading and deceptive statements, does the fact that disqualified, nonresident circulators solicited 82.52% of the signatures warrant a decision that the initiative shall not reach the ballot?
II.
Initially, we confront a relevant, possibly determinative, Board rule:
The failure of the circulator of an initiative or referendum petition to be a registered qualified elector will not invalidate the signature of an otherwise registered qualified elector. [Board Rule 1607.9; 3 D.C.M.R. 64, § 1008.9.]
The Board adopted Rule 1607.9 pursuant to its statutory authority to “issue rules and regulations” to implement the Initiative, Referendum, and Recall Procedures Act of 1979, D.C.Code 1980 Supp., § 1-1119.1 (Initiative Procedures Act).
A. At oral argument, intervenors Dixon, et aL, took the position that Rule 1607.9 is void; they contended the Board had no authority to adopt the rule because the statute, properly construed, mandates disqualification of signatures collected by disqualified circulators. I disagree.
The statute requires the Board to “refuse to accept” signed petitions if they embody one or more specified defects which typically are visible when the petitions are presented. See D.C.Code 1980 Supp., § 1-1116(k).5 The statute, however, does not [520]*520specify what should be done when the Board detects an irregularity after accepting the signed petitions for filing. See id.; 3 D.C.M.R. 66, § 1010.1. The thirty-day period during which the Board is to count and validate signatures includes a ten-day period for the public to inspect and challenge the petitions, see D.C.Code 1980 Supp., § 1-1116(o); and yet the statute fails to establish remedies for irregularities found during this very period when scrutiny is invited. Under these circumstances, the Board has authority to interpret the statute by adopting reasonable rules and regulations. D.C.Code 1980 Supp., § 1 — 1119.1; see District of Columbia v. Catholic University of America, D.C.App., 397 A.2d 915, 919 (1979).
It is consistent with the statute for the Board, in such circumstances, to limit sanctions for unlawful solicitation to the criminal process. See D.C.Code 1980 Supp., §§ 1-1114(b), -1116(h)(2).6 Absent a statutory provision to the contrary, the Board is not required to keep an otherwise proper initiative off the ballot. Citizens Against Legalized Gambling v. Board of Elections and Ethics, 501 F.Supp. 786, 790-91 (D.D.C. 1980) (“noncompliance by the circulator need not — as a matter of law — invalidate any signature so long as the criminal sanctions are pursued”) (footnote omitted), aff’d per U.S.App.D.C.R. 13(c), No. 80-2251 (D.C. Cir., Oct. 28, 1980); Edwards v. Hutchinson, 178 Wash. 580, 584, 587, 35 P.2d 90, 92, 93 (1934) (solicitation of signatures by unlawfully paid workers does not “invalidate[ ] the signature of a legal voter”; legislature intended “penal provisions as the sole safeguards for the proper operation of the law, except wherein it has specifically provided other safeguards”).
More specifically, in adopting the Initiative Procedures Act, the Council required that circulators must be qualified registered electors, in order “to insure the greatest degree of integrity in the signature solicitation process.” Committee Report, District Council Committee on Governmental Operations, Jan. 31, 1979, at 4. Presumably this means that the Council wanted to minimize the potential for corruption of the initiative process, with the ultimate goals of assuring that only qualified registered electors sign petitions and that their signatures are based on complete and accurate information. In adopting Rule 1607.9, the Board clearly indicated that when these goals have been achieved, the Board need not invalidate otherwise proper signatures because they were collected by disqualified circula-tors. The Board implied that circulation by non-registered voters did not, per se, constitute a corruption of the electoral process.7 That judgment is within the Board’s prerogative.
[521]*521B. When considering Initiative # 7, however, the Board changed its policy. Despite the unequivocal language of its rule the Board rejected the 22,624 valid though illegally obtained signatures, stating that this was necessary “to preserve the integrity of the initiative process.” Board Conclusion of Law 8. The Board stated that Rule 1607.9 only “was intended to cover situations in which a circulator inadvertently was not registered at the time of signature collection or circumstances in which a candidate or proponent of an initiative reasonably believed a circulator was registered, or finally situations in which a small number of signatures is involved.” Board Order at 14.
The problem is that Rule 1607.9 does not specify these limitations. I am unimpressed by the Board’s argument that, in interpreting its own unqualified rule, the Board can redefine it retroactively to mean what perhaps it could say but plainly does not. See United States v. Nixon, 418 U.S. 683, 695-96, 94 S.Ct. 3090, 3100-3101, 41 L.Ed.2d 1039 (1974); K. Davis, 2 Administrative Law Treatise § 7:21 (1979); cf. Junghans v. Department of Human Resources, D.C.App., 289 A.2d 17, 25 n.13 (1972) (“failure of a government body to conform to its own procedural rules may render its action invalid”). I believe the integrity of the democratic process depends on the Board’s faithfully applying its own clear rule, ill-advised or not. For me, therefore, this case turns on the rule. If the Board wants to modify it, the Board has authority to do so — prospectively.
C. In summary, the record reflects that the signatures on the petitions accepted by the Board are genuinely those of qualified registered electors; the Board properly found that the evidence introduced to support the charge that signatures were collected on the basis of misleading and deceptive statements was “meager and inconclusive”; and no one questions the Board’s conclusion that the tax credit proposal is a proper subject for a citizens initiative. The registered voters who signed these petitions presumably did so in good faith, believing the initiative process was functioning properly. Board Rule 1607.9 provides, without exception, that a circulator’s own disqualification shall not invalidate the signatures of qualified registered voters. The question, then, is whether that rule should be interpreted (or voided) so as to deny those who signed petitions the opportunity to present an initiative to the voters, for the sole reason that the circulators responsible for most of the signatures came from outside the District. I conclude not.
III.
In No. 81 — 978, Dixon, et al, have petitioned for review of the three contentions they lost before the Board: the summary statement of the initiative bill was misleading, the petitions were improperly notarized, and the proponents failed to file a timely verified statement of contributors. We consolidated this petition with Dank-man’s petition for review, No. 81-977, in which Dixon, et al., intervened to support the Board’s ruling.
Part IV of Judge HARRIS’ opinion raises the question whether Dixon, et al., have standing to advance the arguments in this court that they lost before the Board. I conclude that they do have standing, and that the questions they have raised are within our scope of review, but that the Board properly rejected their arguments on the merits.
A. Judge HARRIS acknowledges that Dixon, et al., may intervene as of right in No. 81-977 to support the Board’s ruling. D.C.App.R. 15(g);8 see International Un[522]*522ion, United Automobile, Aerospace & Agricultural Implement Workers of America, AFL-CIO, Local 283 v. Scofield, 382 U.S. 205, 210-11, 86 S.Ct. 373, 377, 15 L.Ed.2d 272 (1965) (Scofield ).9 In order to evaluate the proper scope of intervention (i.e., the range of arguments an intervenor is allowed to make), it is important to understand, first, why intervention itself is permitted.
A challenging party who prevails before the agency no longer is aggrieved once the agency issues its order.10 A petition for review, however, puts in jeopardy, once again, the very rights and interests that the newly-prevailing party had sought to protect. If the challenger’s success before the agency were deemed to eliminate the kind of interest required for intervention on appeal, and if the court — after hearing only from the petitioner and the agency — were to reverse the agency’s order, the once-prevailing, now-aggrieved party would have to start a second round of judicial review. Id. at 211-12, 86 S.Ct. at 377-378.
In the present case, for example, if Dixon, et al., were not permitted to intervene in Dankman’s petition for review, this would mean that as soon as the Board, after remand, had certified Initiative # 7 for the ballot, Dixon, et al, would have to petition this court as “challengers” alleging a statutory right to seek “review of the reasonableness” of the Board’s determination. D.C.Code 1978. Supp., § 1-1108(p)(2) (made applicable by D.C.Code 1980 Supp., § 1— U16(o )).11
Such two-stage review would be unfair to the initially-prevailing party, who now would have an extra burden of meeting arguments about stare decisis if not res judicata. See Scofield, supra at 213, 86 S.Ct. at 379. Such an approach, moreover, would waste the time and energy of the [523]*523court, which would have to hear the same case again. See id. at 212-13, 86 S.Ct. at 378-379. In summary:
If the party successful before the Board is not allowed to intervene in the court of appeals and if the court of appeals reverses the Board and returns the case to it for further proceedings, then it is probable that the party who was not allowed to intervene in the first appeal will himself have the right to bring a second appeal. In the interests of judicial efficiency and fairness to the would-be intervenor, the Supreme Court considered it highly desirable to have the court of appeals hear all the parties in one proceeding.
Hodgson v. United Mine Workers of America, 51 F.R.D. 270, 272 (D.D.C.1970) (summarizing Scofield), rev’d on other grounds, Trbovich v. United Mine Workers, 404 U.S. 528, 92 S.Ct. 630, 30 L.Ed.2d 686 (1972). Indeed, the policy favoring intervention by the prevailing party in this jurisdiction is so strong that D.C.App.R. 15(g) permits a “party to the proceeding before the agency” to intervene on appeal as of right, in contrast with the corresponding federal rule that provides only for permissive intervention in the absence of “an applicable statute.” Fed.R.App.P. 15(d).
B. I turn now to the scope of intervention: (1) As prevailing party-intervenors, are Dixon, et al., limited to supporting the Board’s position, or, in addition, may they advance arguments the Board rejected? (2) If they are permitted to present the additional arguments, does it matter whether they make them as “intervenors” in No. 81-977 or as “petitioners” in No. 81-978?
1. The scope of the right to intervene in administrative proceedings is determined by reference to the statutory scheme governing the particular agency and proceeding. See Scofield, supra 382 U.S. at 210, 86 S.Ct. at 377; Brotherhood of Railroad Trainmen v. Baltimore & Ohio Railroad Co., 331 U.S. 519, 529-31, 67 S.Ct. 1387, 1392-1393, 91 L.Ed. 1646 (1947) (statute grants absolute right to intervene in both administrative and judicial forums); 3B J. Moore, supra ¶ 24.06[3.-l]; 9 J. Moore, supra ¶215.07 (2d ed. 1980).12 Thus, while it may be true that an intervenor in support of an agency order normally is limited to arguments that track the agency’s position before the court, that limitation yields when the governing statute suggests a more comprehensive intervenor’s role.
In the present case, the Initiative Procedures Act, D.C.Code 1980 Supp., § 1 — 1116(o), adopts the appeal rights specified in D.C.Code 1978 Supp., § 1 — 1108(p)(2). See note 11 supra. Although this statute does not expressly deal with the scope of the right to intervene, it reflects a policy of equal access to this court by sponsors and challengers of petitions. Cf. Scofield, supra (charged and charging parties alike who prevail at N.L.R.B. have right to intervene in court of appeals review proceeding). More specifically, § 1108(p)(2) provides that “either the challenger or any person named in the challenged petition” may apply for review. In addition, the brief statutory timetable for election challenges, coupled with the requirement that this court must “expedite consideration,” id., manifests a legislative intention that all election issues be resolved promptly, without piecemeal review. These two aspects of the statute compel a conclusion that both the losing-party petitioner and the prevailing-party intervenors are free on appeal to make every argument raised before, and ruled on, by the Board.13
[524]*524If the prevailing-party intervenors did not have this equal, unfettered right of review, the very reasons justifying intervention — fairness and judicial economy— would be undermined. In the first place, Dixon, et al., would be penalized for winning one, instead of none, of their arguments to the agency; for if they had lost on all grounds — and thus had become petitioners — the court would have entertained each alleged error. See note 11 supra; cf. Scofield, supra 382 U.S. at 216, 86 S.Ct. at 380.14
Even more telling, however, is the following illustration. Suppose in the present case, that Dixon, et al., could not advance in this court the arguments they lost before the Board, and that we were to reverse on the basis of Dankman’s arguments. As soon as the case was remanded and the Board prepared to certify the initiative for the ballot, Dixon, et al. could try to obtain reconsideration by the Board and, if they lost, come to this court once again- — this time as petitioners, not intervenors — to challenge the Board ruling on grounds not resolved by the first court review. See D.C.Code 1978 Supp., § 1 — 1108(p)(2); note 11 supra. Thus, if Dixon, et al., were not permitted to advance in the first review proceeding all their arguments that the Board rejected, the statutory policy of equal access to this court, on an expedited basis, would be ignored, and the very reasons justifying intervention in the first place would be subverted. See Part III.A. supra.15
[525]*525Judge HARRIS asserts that this analysis “would afford an intervenor the power effectively to convert agency challenges into renewed litigation between the private parties to the agency proceeding.” Ante at 517. That is an assertion without meaning. As the statute makes clear, Dixon, et al., are party to. the litigation just as much as Dankman or the Board, in contrast with persons of lesser interest who must seek leave of court to intervene under D.C.App.R. 15(g). Furthermore, as Dixon, et al., were prevailing parties before the Board, their very right to intervene on appeal reflects an interest and potential injury sufficient for standing to protect their position in the exceptional context of an election case by using all available legal arguments. They are no less aggrieved before the court than they were before the Board.16
Finally, the prevailing party-intervenors are not in a position to expand the litigation beyond its original scope. They are limited to the arguments presented to, and ruled upon by, the Board; they cannot raise a new question for the first time on appeal. DeLevay v. District of Columbia Rental Accommodations Commission, D.C.App., 411 A.2d 354, 358 (1980).
In summary, because a petition for review of a Board ruling puts the prevailing party’s interests in jeopardy once again, and because D.C.Code 1978 Supp., § 1-1108(p)(2) reflects a legislative intent to provide equal, expedited access to this court for parties affected by the Board’s ruling, I conclude that Dixon, et al., as prevailing party-intervenors, may advance on appeal the arguments the board rejected, as well as accepted.
2. The next question is whether Dixon, et al, have prejudiced their review rights by docketing separately in No. 81— 978 the arguments they lost before the Board, rather than presenting all their arguments in No. 81-977 in which they duly intervened. I conclude not, for we have consolidated the two cases and only one Board order is at issue. Although “ ‘there are two proceedings, separately carried on the docket, they were essentially one so far as any question as to the legality of the Board’s order was concerned.’ ” Scofield, supra 382 U.S. at 213 n.6, 86 S.Ct. at 379 n.6 (quoting Ford Motor Co. v. Labor Board, 305 U.S. 364, 370, 59 S.Ct. 301, 305, 83 L.Ed. 221 (1939)).
Under the Scofield rule, as is generally true of administrative proceedings, “the party supporting a Board order, or the party challenged, may intervene, while a party opposing a Board order or a portion of it may petition for review.” N.L.R.B. v. Oil, Chemical and Atomic Workers International Union, 476 F.2d 1031, 1034 (1st Cir. 1973). Dixon, et al., may have been concerned that this court would characterize their effort for review of contentions the Board rejected as an opposition to a portion of the Board’s “order”. See id. In that case, the court would require that they file a separate petition for review.
As I see it, however, none of Dixon, et al.’s arguments in No. 81-978 reflects an effort to oppose the Board “order” or a [526]*526portion of it.17 Thus, a separate petition was superfluous; intervention would have sufficed. See N.L.R.B. v. General Electric Co., supra at 294. The fact that Dixon, et al, separately docketed the arguments they lost before the Board, however, rather than adding them to No. 81-977, is of no consequence. As long as this court has recognized the unity of the proceeding by consolidating both petitions for review, it would be unfair to say that Dixon, et al.’s, precaution in filing a separate petition, instead of relying solely on intervention, could prejudice their review rights.18
IV.
Having concluded that Dixon, et aL, may raise arguments rejected by the Board, I nonetheless perceive no Board error on any of the grounds alleged. One of these, however, requires discussion.19
Dixon, et a1., claim the petitions were notarized improperly. They assert that the 22,624 signatures obtained by the disqualified circulators should be rejected because Jo Ann Willis, Executive Director and Treasurer of the D.C. Committee for Improved Education to Promote Initiative Seven — in notarizing the circulators’ signatures — conspired with the circulators to represent to the public that they were bona fide residents of the District. They also allege that Willis violated the following proviso in D.C. Code 1973, § 1-501: “no notary public shall be authorized to take acknowledgments, administer oaths, certify papers, or perform any official acts in connection with matters in which he is employed as counsel, attorney, or agent, or in which he may be in any way interested before any of the departments aforesaid.”20
[527]*527The Board concluded, however, “that there was no evidence in the record to show a conspiracy between Jo Ann Willis and others to misrepresent the legal status of the circulators to the signatories to the petitions.” Board Order at 9. The record supports that conclusion. Furthermore, even if a violation of id, § 1-501 would create a violation of the Initiative Procedures Act by circumventing the circulators’ affidavit requirement, I do not agree with Dixon, et al., that the proviso applies to Ms. Willis’ actions before the Board.
As I read the statute, the proviso, by its reference to “the departments aforesaid,” governs only actions of notaries before departments of the United States Government, not actions before departments of the District of Columbia. See note 20 supra. Congress indicated that these governments are separate for purposes of § 1-501 by referring separately, in the second paragraph of the statute, to both the United States Government and the District of Columbia Government. Moreover, in the one case analyzing § 1-501, the court clearly understood the proviso to mean that the statute was to protect against conflicts of interest in practice before federal departments. See Hall’s Safe Co. v. Herring-Hall-Marvin Safe Co. (1), 31 App.D.C. 498 (1908) (holds statute applies to non-District as well as District notaries). The Board, accordingly, did not err in concluding that § 1-501 is inapplicable here.
V.
Because the Board misapplied its own Rule 1607.9, I concur in reversal of the Board’s order. I perceive no other erroneous interpretation of law that would justify Board reconsideration. Although Rule 1607.9 limits the remedies available for illegal circulation, the criminal process is available to pursue anyone who illegally participated in solicitation of signatures. The political process is available to inform the electorate about the tactics employed by the circulators and their sponsors. And the administrative process is available to those who would propose to change the rule for the future.
6. Because the petitions had not then been circulated to voters, this information was not in-eluded on the statement attached to the petition.