OPINION
SHORT, Judge.
Respondent’s driving privileges were cancelled and denied pursuant to Minn.Stat. §§ 171.14 and 171.04(8) (1986) and Minn.R. 7503.1800, subpt. 2 (1987) because he had three alcohol-related driving incidents and a special review in approximately &k years. Respondent petitioned for reinstatement pursuant to Minn.Stat. § 171.19 (1986). The trial court ruled that (1) the Commissioner exceeded his authority by promulgating Minn.R. 7503.1300, subpt. 2, and (2) the challenged provision of the rule was unreasonable. The trial court reinstated respondent’s driving privileges, and the Commissioner of Public Safety appeals.
FACTS
Respondent Darrell Vang has three alcohol-related incidents on his record. His driving license was revoked under the DWI statute (Minn.Stat. § 169.121) for an offense committed December 31, 1980, and then under the implied consent statute (Minn.Stat. § 169.123) for incidents on September 7, 1984 and August 14, 1987. The three incidents occurred over a period of approximately &-k years. After the second incident, respondent was required to undergo a “special review.” 1
As a result of the third alcohol-related incident, respondent was served with a notice and order of revocation for 90 days pursuant to Minn.Stat. § 169.123 (1986 & Supp.1987). The Department of Public Safety also issued respondent a notice of cancellation and denial of his driving privileges pursuant to Minn.Stat. § 171.04(8) (1986) and Minn.R. 7503.1300, subpt. 2 (1987). After the 90 days, respondent applied for reinstatement. He met all the requirements for immediate reinstatement of his license as a result of the revocation pursuant to Minn.Stat. § 169.123. However, he had not met the rehabilitation requirements contained in Minn.R. 7503.1700 resulting from the cancellation and denial of his license pursuant to Minn.Stat. §§ 171.14, 171.04(8) (1986) and Minn.R 7503.1300, subpt. 2.
The Commissioner denied reinstatement of respondent’s driving privileges, and respondent petitioned for reinstatement pursuant to Minn.Stat. § 171.19 (1986). The trial court held that the Commissioner exceeded his statutory authority by promulgating that part of Minn.R. 7503.1300, subpt. 2 (1987) under which respondent’s license was cancelled and denied, and reinstated respondent’s Minnesota driving privileges.
ISSUES
1. Did the Commissioner of Public Safety exceed his statutory authority in promulgating that part of Minn.R. 7503.1300, subpt. 2 (1987) which authorizes cancellation and denial for a person who has incurred three alcohol-related driving incidents and a special review during the course of five or more years?
2. Is the challenged part of Minn.R. 7503.1300 invalid because it is unreasonable?
ANALYSIS
The facts in this case are undisputed and the issues are purely legal ones. This court therefore need not give deference to the trial court decision. See Berge v. Commissioner of Public Safety, 374 N.W.2d 730, 732 (Minn.1985). Further, upon review of the administrative action of [206]*206promulgating rules, an appellate court conducts an independent review without according special deference to review by the trial court. See Minnesota-Dakotas Retail Hardware Association v. State, 279 N.W.2d 360, 363 (Minn.1979).
I.
An administrative regulation is valid only to the extent it is consistent with the statutory authority pursuant to which it is promulgated. Guerrero v. Wagner, 310 Minn. 361, 357, 246 N.W.2d 838, 841 (1976). If a regulation is not consistent with the statute, it is ineffective and does not have the force and effect of law. Sellner Manufacturing Co. v. Commissioner of Taxation, 295 Minn. 71, 74, 202 N.W.2d 886, 888 (1972).
Respondent argues that the rule at issue is inconsistent with Minn.Stat. § 169.121, subd. 4 (Supp.1987), and the Commissioner has thus exceeded his rulemaking authority under Minn.Stat. § 169.128 (1986). The inconsistency, according to respondent, is that the statute requires revocation for three offenses within five years, while the rule permits cancellation and denial for three incidents in more than five years. We reject this argument because (1) it improperly relies on Minn.Stat. § 169.128 as the sole authority for the rule, and (2) it improperly interprets Minn.Stat. § 169.121, subd. 4 as circumscribing the Commissioner’s authority to cancel or deny driving privileges.
Minn.R. 7503.1300, subpt. 2 (1987), provides that:
The commissioner shall cancel and deny the driver’s license or the driving privilege of any person who has incurred three alcohol- or eontrolled-substance-re-lated incidents within the past five years or who has incurred three such incidents and a special review had been conducted prior to the third incident, or who has four or more such incidents on record.
(Emphasis added.)
Minn.Stat. § 169.121, subd. 4 (Supp.1987) provides in pertinent part:
The commissioner of public safety shall revoke the driver’s license of a person convicted of violating this section * * * as follows:
* * * * * *
(c) Third offense in less than five years: not less than one year, together with denial under section 171.04, clause (8), until rehabilitation is established in accordance with standards established by the commissioner;
(d) Fourth or subsequent offense on the record: not less than two years, together with denial under section 171.04, clause (8), until rehabilitation is established in accordance with standards established by the commissioner.
Minn.Stat. § 169.128 (1986) provides that: The commissioner of public safety may promulgate permanent rules to carry out the provisions of sections 169.121 and 169.123 and until December 31, 1985, emergency rules to implement any statutory changes enacted by the 1985 legislature pertaining to issues of implied consent and driving while under the influence. The rules may include forms for notice of intention to revoke, which shall describe clearly the right to a hearing, the procedure for requesting a hearing, and the consequences of failure to request a hearing; forms for revocation and notice of reinstatement of driving privileges as provided in section 169.-1261; and forms for temporary licenses.
A. The Commissioner Has Broad Rule-making Authority.
We do not agree with respondent’s view that the authority to promulgate the rule at issue must be found, if at all, in Minn.Stat. § 169.128. Other statutory provisions conferring rulemaking authority on the Commissioner are also relevant, and persuade us that Minn.R. 7503.1300, subpt. 2 is within the scope of the Commissioner’s statutory authority.
In Minnesota Rules published by the re-visor of statutes, the revisor’s comment on statutory authority for Minn.R. 7503.1300 lists only Minn.Stat. § 169.128.
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OPINION
SHORT, Judge.
Respondent’s driving privileges were cancelled and denied pursuant to Minn.Stat. §§ 171.14 and 171.04(8) (1986) and Minn.R. 7503.1800, subpt. 2 (1987) because he had three alcohol-related driving incidents and a special review in approximately &k years. Respondent petitioned for reinstatement pursuant to Minn.Stat. § 171.19 (1986). The trial court ruled that (1) the Commissioner exceeded his authority by promulgating Minn.R. 7503.1300, subpt. 2, and (2) the challenged provision of the rule was unreasonable. The trial court reinstated respondent’s driving privileges, and the Commissioner of Public Safety appeals.
FACTS
Respondent Darrell Vang has three alcohol-related incidents on his record. His driving license was revoked under the DWI statute (Minn.Stat. § 169.121) for an offense committed December 31, 1980, and then under the implied consent statute (Minn.Stat. § 169.123) for incidents on September 7, 1984 and August 14, 1987. The three incidents occurred over a period of approximately &-k years. After the second incident, respondent was required to undergo a “special review.” 1
As a result of the third alcohol-related incident, respondent was served with a notice and order of revocation for 90 days pursuant to Minn.Stat. § 169.123 (1986 & Supp.1987). The Department of Public Safety also issued respondent a notice of cancellation and denial of his driving privileges pursuant to Minn.Stat. § 171.04(8) (1986) and Minn.R. 7503.1300, subpt. 2 (1987). After the 90 days, respondent applied for reinstatement. He met all the requirements for immediate reinstatement of his license as a result of the revocation pursuant to Minn.Stat. § 169.123. However, he had not met the rehabilitation requirements contained in Minn.R. 7503.1700 resulting from the cancellation and denial of his license pursuant to Minn.Stat. §§ 171.14, 171.04(8) (1986) and Minn.R 7503.1300, subpt. 2.
The Commissioner denied reinstatement of respondent’s driving privileges, and respondent petitioned for reinstatement pursuant to Minn.Stat. § 171.19 (1986). The trial court held that the Commissioner exceeded his statutory authority by promulgating that part of Minn.R. 7503.1300, subpt. 2 (1987) under which respondent’s license was cancelled and denied, and reinstated respondent’s Minnesota driving privileges.
ISSUES
1. Did the Commissioner of Public Safety exceed his statutory authority in promulgating that part of Minn.R. 7503.1300, subpt. 2 (1987) which authorizes cancellation and denial for a person who has incurred three alcohol-related driving incidents and a special review during the course of five or more years?
2. Is the challenged part of Minn.R. 7503.1300 invalid because it is unreasonable?
ANALYSIS
The facts in this case are undisputed and the issues are purely legal ones. This court therefore need not give deference to the trial court decision. See Berge v. Commissioner of Public Safety, 374 N.W.2d 730, 732 (Minn.1985). Further, upon review of the administrative action of [206]*206promulgating rules, an appellate court conducts an independent review without according special deference to review by the trial court. See Minnesota-Dakotas Retail Hardware Association v. State, 279 N.W.2d 360, 363 (Minn.1979).
I.
An administrative regulation is valid only to the extent it is consistent with the statutory authority pursuant to which it is promulgated. Guerrero v. Wagner, 310 Minn. 361, 357, 246 N.W.2d 838, 841 (1976). If a regulation is not consistent with the statute, it is ineffective and does not have the force and effect of law. Sellner Manufacturing Co. v. Commissioner of Taxation, 295 Minn. 71, 74, 202 N.W.2d 886, 888 (1972).
Respondent argues that the rule at issue is inconsistent with Minn.Stat. § 169.121, subd. 4 (Supp.1987), and the Commissioner has thus exceeded his rulemaking authority under Minn.Stat. § 169.128 (1986). The inconsistency, according to respondent, is that the statute requires revocation for three offenses within five years, while the rule permits cancellation and denial for three incidents in more than five years. We reject this argument because (1) it improperly relies on Minn.Stat. § 169.128 as the sole authority for the rule, and (2) it improperly interprets Minn.Stat. § 169.121, subd. 4 as circumscribing the Commissioner’s authority to cancel or deny driving privileges.
Minn.R. 7503.1300, subpt. 2 (1987), provides that:
The commissioner shall cancel and deny the driver’s license or the driving privilege of any person who has incurred three alcohol- or eontrolled-substance-re-lated incidents within the past five years or who has incurred three such incidents and a special review had been conducted prior to the third incident, or who has four or more such incidents on record.
(Emphasis added.)
Minn.Stat. § 169.121, subd. 4 (Supp.1987) provides in pertinent part:
The commissioner of public safety shall revoke the driver’s license of a person convicted of violating this section * * * as follows:
* * * * * *
(c) Third offense in less than five years: not less than one year, together with denial under section 171.04, clause (8), until rehabilitation is established in accordance with standards established by the commissioner;
(d) Fourth or subsequent offense on the record: not less than two years, together with denial under section 171.04, clause (8), until rehabilitation is established in accordance with standards established by the commissioner.
Minn.Stat. § 169.128 (1986) provides that: The commissioner of public safety may promulgate permanent rules to carry out the provisions of sections 169.121 and 169.123 and until December 31, 1985, emergency rules to implement any statutory changes enacted by the 1985 legislature pertaining to issues of implied consent and driving while under the influence. The rules may include forms for notice of intention to revoke, which shall describe clearly the right to a hearing, the procedure for requesting a hearing, and the consequences of failure to request a hearing; forms for revocation and notice of reinstatement of driving privileges as provided in section 169.-1261; and forms for temporary licenses.
A. The Commissioner Has Broad Rule-making Authority.
We do not agree with respondent’s view that the authority to promulgate the rule at issue must be found, if at all, in Minn.Stat. § 169.128. Other statutory provisions conferring rulemaking authority on the Commissioner are also relevant, and persuade us that Minn.R. 7503.1300, subpt. 2 is within the scope of the Commissioner’s statutory authority.
In Minnesota Rules published by the re-visor of statutes, the revisor’s comment on statutory authority for Minn.R. 7503.1300 lists only Minn.Stat. § 169.128. We take the revisor’s comment as informational, but [207]*207not conclusive or binding. Cf. Minn.Stat. § 645.49 (1986). We find additional statutory authority for the rule in Minn.Stat. § 171.015, subds. 1 and 2 and Minn.Stat. § 299A.01, subd. 6 (1986). The Commissioner has broad rulemaking authority and the rule at issue is well within the combined statutory authority set forth in Minn. Stat. § 299A.01, subd. 6, § 171.015, subds. 1 and 2 and § 169.128.
The legislature has delegated responsibility and enforcement of the driver’s license laws to the Commissioner of Public Safety. This area is within the Commissioner’s sphere of authority. Norman v. Commissioner of Public Safety, 404 N.W.2d 315, 317 (Minn.Ct.App.1987). The challenged provision of Rule 7503.1300 did not exceed the Commissioner’s statutory authority.
B. Minn.Stat. § 169.121 does not circumscribe the Commissioner’s authority to cancel or deny driving privileges.
Minn.Stat. § 169.121 requires the Commissioner to revoke a license for convictions under the DWI law in the circumstances described in the statute. Minn. Stat. § 169.121, subd. 4, does not speak to other situations under which the Commissioner is to revoke, such as incidents under the implied consent law. See Minn.Stat. § 169.123, subd. 4. Obviously the legislature did not intend Minn.Stat. § 169.121, subd. 4 to preclude revocation on other grounds or to limit or circumscribe the Commissioner’s authority to cancel or deny driving privileges. Minn.Stat. § 169.121, subd. 4 speaks only to revocations for DWI convictions; it does not speak to revocation for incidents other than DWI convictions, or to cancellation for repeated DWI convictions or other incidents.
Revocation and cancellation are procedurally distinct and are not substantively grounded in identical statutes. See definitions at Minn.R. 7503.0100, subpts. 4 and 9. Cf. Minn.R. 7503.0700-.1200 with Minn.R. 7503.1300-1600. Revocation pursuant to Minn.Stat. § 169.121, subd. 4 is an administrative penalty required upon conviction of driving under the influence of alcohol or controlled substance. See State, Department of Public Safety v. Mulvihill, 303 Minn. 361, 368, 227 N.W.2d 813, 817-18 (1975). It is improper for a court in a criminal proceeding to decide reinstatement of a cancellation or denial of driving privileges. State v. Hanson, 356 N.W.2d 689, 693 (Minn.1984). The distinction between these procedures further supports our conclusion that Minn.Stat. § 169.121, subd. 4 does not limit the authority of the Commissioner to cancel and deny under Minn.Stat. §§ 171.04(8) and 171.14.
We find additional support in the statutory references to the grounds for cancellation and denial. The legislature gave the Commissioner broad authority to cancel or deny in numerous situations that do not necessarily involve DWI convictions. Minn.Stat. § 171.04(8) provides that the department shall not issue a driver’s license to any person when the Commissioner has good cause to believe the operation of a motor vehicle by such person would be inimical to public safety. Minn.Stat. § 171.14 authorizes the Commissioner to cancel a license when the person would not be authorized to receive one under Minn. Stat. § 171.04.
For these reasons, we do not find Minn. R. 7503.1300, subpt, 2 inconsistent with Minn.Stat. § 169.121. The statute speaks to revocation for DWI convictions, while the rule refers to cancellation and denial for incidents. The legislature did not intend the five year time limit for revoking a license to apply to cancellation or denial of a license by the Commissioner.
II.
The trial court also determined that the rule at issue was unreasonable. Where a board or commission has been empowered to make regulations, the law is to be interpreted as though it conferred the power and right to make reasonable regulations. Lee v. Delmont, 228 Minn. 101, 110, 36 N.W.2d 530, 537 (1949).
A rule is reasonable if it is rationally related to the end sought to be achieved. Blocker Outdoor Advertising [208]*208Co. v. Department of Transportation, 347 N.W.2d 88, 91 (Minn.Ct.App.1984). In this case, the purpose of the rule is to remove inebriated drivers from the highways. See Szczech v. Commissioner of Public Safety, 343 N.W.2d 305, 306 (Minn.Ct.App.1984). Laws relating to drunk driving are remedial statutes intended for the protection of the public and are to be liberally construed toward that end. Id.
A rule requiring cancellation and denial of a driver’s license after three alcohol-related driving incidents, when a review has been conducted after the second incident, is reasonable and rationally related to the end of removing inebriated drivers from the highways.
DECISION
The order of the trial court reinstating respondent’s driving privileges is reversed.
REVERSED.
RANDALL, J., dissents.