ERICKSTAD, Chief Justice.
Dan Walter appeals from a district court judgment which affirmed a decision of Thomas W. Nielsen, a hearing officer representing the North Dakota State Highway Commissioner, suspending Walter’s driver’s license for a period of 420 days. We affirm.
Walter, a North Dakota resident, was convicted in North Dakota of being in actual physical control [of a vehicle] under the influence of alcohol in June of 1982. On October 26, 1984, Walter was convicted in Montana of the offense of “Operation of a Motor Vehicle ... with Alcohol Concentration of 0.10 or more (first offense)” in violation of Section 61-8-406, M.C.A.1 Walter asserts that this conviction was a result of a guilty plea and that a condition of the plea was that Walter would be sentenced as a first offender.
As a result of the Montana conviction, Walter was assessed a fine in the amount of $400, received a suspended 10-day jail sentence, and had his driving privileges suspended for a period of six months, the suspension lasting until April 25, 1985. The order of suspension sent to Walter from the Motor Vehicle Division of the State of Montana indicated that a copy of the citation had been forwarded to North Dakota.
On February 26, 1985, the North Dakota State Highway Department sent Walter a notice informing him that his driving privileges in North Dakota would be suspended for a period of 420 days because of the alcohol related conviction in Montana which resulted in an assessment of 63 points for a total accumulation of 71 points on his driver’s license record. Walter requested a hearing on the matter which was subsequently held on August 27, 1985, before a hearing officer representing the North Dakota State Highway Commissioner. The hearing officer issued a decision on September 26, 1985, making the following findings of fact and conclusions of law:
“THE PETITIONER’S DRIVING RECORD WAS REVIEWED AND FOUND TO BE CORRECT. SECTION 39-06-27, N.D.C.C. APPLIES.
“THEREFORE: IT IS HEREBY DETERMINED THAT THE DRIVER’S LI[157]*157CENSE OF THE PETITIONER SHALL BE SUSPENDED FOR 420 DAYS....”
Upon appeal to the district court, the decision of the hearing officer was affirmed and judgment was entered on November 21, 1985.
Walter now appeals to our Court asserting that the hearing officer failed to establish that Walter was convicted of a criminal offense in Montana “which is equivalent” to one of the offenses listed in Section 39-06.1-05, N.D.C.C., as required by Section 39-06-27, N.D.C.C., and questions “[wjhether the Montana statutes under which Walter was convicted constitute an ‘equivalent ordinance,’ as required by N.D. C.C. 39-06-27, 39-06.1-05, and 39-08-01.”2
Walter argues in essence that the hearing officer could not have established that Walter was convicted of a criminal offense “which is equivalent” to Section 39-08-01 which is referred to in 39-06.1-05, subsection 1, because the Montana statute, under which Walter was convicted, was not received in evidence at the hearing. The record of the administrative hearing includes: testimony from Walter and argu-mente of his counsel, a copy of the Montana order of suspension, a copy of the Montana complaint alleging that Walter had violated Montana Code, Section 61-8-406, and stating that Walter “did wrongfully operating [sic ] motor vehicle with BAC of 0.10 or greater,” a copy of the final disposition of the case indicating the penalty imposed in Montana, and a copy of Walter’s driving record abstract from the North Dakota Drivers License Division. A copy of Section 61-8-406, M.C.A., the Montana statute of which Walter was convicted, was not received in evidence during the hearing before the hearing officer.
We note at the outset that the findings of fact and conclusions of law made by the hearing officer are quite sparse and thus are not examples to be followed for compliance with the Administrative Agencies Practice Act, Section 28-32-13, N.D. C.C.3 They are nonetheless adequate, as “we are able to understand the factual basis upon which the trial court reached its conclusions.” Matter of Boschee, 347 N.W.2d 331, 336 (N.D.1984). See also, [158]*158Schadler v. Job Service North Dakota, 361 N.W.2d 254, 258 (N.D.1985).
The fact that the Montana statute was not made a part of the official record does not compel the conclusion that the hearing officer did not review the statute before making his decision. It may be a good practice to receive applicable foreign statutes in evidence at an administrative hearing but we know of no rule or statute that specifically requires that be done, and we have been referred to no such rule or statute.4 In any case, we should not presume that the hearing officer did not review an applicable state statute simply because that statute was not formally submitted and received in evidence or requested l.o be officially noticed.5
The absence of a specific reference to the Montana statute in the hearing officer’s decision can be explained by the fact that Walter did not raise the issue of equivalency during the hearing.6 The main argument made by Walter’s counsel before the hearing officer was that as Montana treated his Montana conviction as a first offense it was a violation of substantive due process for North Dakota to treat that conviction as a second offense. That argument has not been made on appeal to this Court.
While we cannot compliment the hearing officer for his sparse findings, we should [159]*159not be too critical of him for not making findings concerning issues not raised. Under these circumstances, the hearing officer was not required to include in his written decision all statutes or legal authority which may' have influenced his decision, especially as his decision refers to Section 39-06-27, N.D.C.C., which establishes that a conviction of an “equivalent” foreign statute can be used to assess points against a driver’s license, and as the record clearly indicates the section number of the foreign state statute of which Walter was convicted.
For the sake of argument only, let us assume that the hearing officer did not review the applicable Montana statute before making his decision. Making this assumption leads us to Walter’s next argument on this appeal, that the Montana statute, under which Walter was convicted, is not a statute “which is equivalent” as required by Section 39-06-27, N.D.C.C.7 As this is a question of law, it is fully reviewable by this Court. Appeal of Dickinson Nursing Center, 353 N.W.2d 754, 757-58 (N.D.1984). Therefore, the issue which we must resolve is whether or not Section 61-8-406 and related sections of the Montana Code are “equivalent” to Section 39-08-01, N.D.C.C., and related North Dakota statutes.
Walter argues that the statutes are not equivalent because the Montana statute creates a rebuttable presumption based upon the blood alcohol level while North Dakota has a per se statute. In Shinault v. Commonwealth, 228 Va.
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ERICKSTAD, Chief Justice.
Dan Walter appeals from a district court judgment which affirmed a decision of Thomas W. Nielsen, a hearing officer representing the North Dakota State Highway Commissioner, suspending Walter’s driver’s license for a period of 420 days. We affirm.
Walter, a North Dakota resident, was convicted in North Dakota of being in actual physical control [of a vehicle] under the influence of alcohol in June of 1982. On October 26, 1984, Walter was convicted in Montana of the offense of “Operation of a Motor Vehicle ... with Alcohol Concentration of 0.10 or more (first offense)” in violation of Section 61-8-406, M.C.A.1 Walter asserts that this conviction was a result of a guilty plea and that a condition of the plea was that Walter would be sentenced as a first offender.
As a result of the Montana conviction, Walter was assessed a fine in the amount of $400, received a suspended 10-day jail sentence, and had his driving privileges suspended for a period of six months, the suspension lasting until April 25, 1985. The order of suspension sent to Walter from the Motor Vehicle Division of the State of Montana indicated that a copy of the citation had been forwarded to North Dakota.
On February 26, 1985, the North Dakota State Highway Department sent Walter a notice informing him that his driving privileges in North Dakota would be suspended for a period of 420 days because of the alcohol related conviction in Montana which resulted in an assessment of 63 points for a total accumulation of 71 points on his driver’s license record. Walter requested a hearing on the matter which was subsequently held on August 27, 1985, before a hearing officer representing the North Dakota State Highway Commissioner. The hearing officer issued a decision on September 26, 1985, making the following findings of fact and conclusions of law:
“THE PETITIONER’S DRIVING RECORD WAS REVIEWED AND FOUND TO BE CORRECT. SECTION 39-06-27, N.D.C.C. APPLIES.
“THEREFORE: IT IS HEREBY DETERMINED THAT THE DRIVER’S LI[157]*157CENSE OF THE PETITIONER SHALL BE SUSPENDED FOR 420 DAYS....”
Upon appeal to the district court, the decision of the hearing officer was affirmed and judgment was entered on November 21, 1985.
Walter now appeals to our Court asserting that the hearing officer failed to establish that Walter was convicted of a criminal offense in Montana “which is equivalent” to one of the offenses listed in Section 39-06.1-05, N.D.C.C., as required by Section 39-06-27, N.D.C.C., and questions “[wjhether the Montana statutes under which Walter was convicted constitute an ‘equivalent ordinance,’ as required by N.D. C.C. 39-06-27, 39-06.1-05, and 39-08-01.”2
Walter argues in essence that the hearing officer could not have established that Walter was convicted of a criminal offense “which is equivalent” to Section 39-08-01 which is referred to in 39-06.1-05, subsection 1, because the Montana statute, under which Walter was convicted, was not received in evidence at the hearing. The record of the administrative hearing includes: testimony from Walter and argu-mente of his counsel, a copy of the Montana order of suspension, a copy of the Montana complaint alleging that Walter had violated Montana Code, Section 61-8-406, and stating that Walter “did wrongfully operating [sic ] motor vehicle with BAC of 0.10 or greater,” a copy of the final disposition of the case indicating the penalty imposed in Montana, and a copy of Walter’s driving record abstract from the North Dakota Drivers License Division. A copy of Section 61-8-406, M.C.A., the Montana statute of which Walter was convicted, was not received in evidence during the hearing before the hearing officer.
We note at the outset that the findings of fact and conclusions of law made by the hearing officer are quite sparse and thus are not examples to be followed for compliance with the Administrative Agencies Practice Act, Section 28-32-13, N.D. C.C.3 They are nonetheless adequate, as “we are able to understand the factual basis upon which the trial court reached its conclusions.” Matter of Boschee, 347 N.W.2d 331, 336 (N.D.1984). See also, [158]*158Schadler v. Job Service North Dakota, 361 N.W.2d 254, 258 (N.D.1985).
The fact that the Montana statute was not made a part of the official record does not compel the conclusion that the hearing officer did not review the statute before making his decision. It may be a good practice to receive applicable foreign statutes in evidence at an administrative hearing but we know of no rule or statute that specifically requires that be done, and we have been referred to no such rule or statute.4 In any case, we should not presume that the hearing officer did not review an applicable state statute simply because that statute was not formally submitted and received in evidence or requested l.o be officially noticed.5
The absence of a specific reference to the Montana statute in the hearing officer’s decision can be explained by the fact that Walter did not raise the issue of equivalency during the hearing.6 The main argument made by Walter’s counsel before the hearing officer was that as Montana treated his Montana conviction as a first offense it was a violation of substantive due process for North Dakota to treat that conviction as a second offense. That argument has not been made on appeal to this Court.
While we cannot compliment the hearing officer for his sparse findings, we should [159]*159not be too critical of him for not making findings concerning issues not raised. Under these circumstances, the hearing officer was not required to include in his written decision all statutes or legal authority which may' have influenced his decision, especially as his decision refers to Section 39-06-27, N.D.C.C., which establishes that a conviction of an “equivalent” foreign statute can be used to assess points against a driver’s license, and as the record clearly indicates the section number of the foreign state statute of which Walter was convicted.
For the sake of argument only, let us assume that the hearing officer did not review the applicable Montana statute before making his decision. Making this assumption leads us to Walter’s next argument on this appeal, that the Montana statute, under which Walter was convicted, is not a statute “which is equivalent” as required by Section 39-06-27, N.D.C.C.7 As this is a question of law, it is fully reviewable by this Court. Appeal of Dickinson Nursing Center, 353 N.W.2d 754, 757-58 (N.D.1984). Therefore, the issue which we must resolve is whether or not Section 61-8-406 and related sections of the Montana Code are “equivalent” to Section 39-08-01, N.D.C.C., and related North Dakota statutes.
Walter argues that the statutes are not equivalent because the Montana statute creates a rebuttable presumption based upon the blood alcohol level while North Dakota has a per se statute. In Shinault v. Commonwealth, 228 Va. 269, 321 S.E.2d 652 (1984), the only authority Walter cites to support his argument, the Supreme Court of Virginia addressed the issue of whether or not a DUI conviction in the state of North Carolina could be used to enhance the penalty imposed upon a person for a subsequent conviction of Virginia’s DUI statute. Virginia’s enhancement statute provided that a conviction under “the laws of any other state substantially similar to the provisions” of Virginia’s statutes shall be considered a prior conviction. The Virginia court concluded that because the North Carolina statute created a conclusive presumption of intoxication when a person’s blood alcohol concentration was 0.10 percent or greater, when the Virginia statute “merely gives rise to a rebuttable presumption that the person is under the influence of alcohol,” the North Carolina statute was not substantially similar to the Virginia statute.
Assuming that Walter’s assertions regarding presumptions created by the North Dakota and Montana statutes are correct, the situation involved in the instant case is a reverse of that addressed by the Supreme Court of Virginia. In Shinault, the court was faced with a foreign state statute which made it easier to establish the guilt of an accused than did the domestic state statute. In the instant case, the foreign state statute makes it more difficult to establish the guilt of the accused. The instant case also involves a hearing before an administrative agency while Shinault dealt with a criminal conviction. See, Plad-son v. Hjelle, 368 N.W.2d 508, 511 (N.D. 1985). For these reasons, we find Walter’s argument unpersuasive, and Shinault distinguishable.
Walter also asserts that the statutes are not equivalent because they provide for different penalties. The penalties of an offense, however, do not affect the elements which must be established to convict a person of that offense. Accordingly, for the purposes of driving suspensions, we do not believe that the differences in the penalties should be determinative of whether or not the statutes are equivalent. Incidentally, the differences in penalties are not so drastic that treating the Montana [160]*160statute as equivalent would contravene the intent of the North Dakota statute.8
It is not a requirement of 39-06-27 that the foreign statute be identical to the North Dakota statute. Instead, the requirement is that the statutes be equivalent. Upon reviewing the Montana statute and the North Dakota statute, we believe they are equivalent. Both statutes make it unlawful for any person to drive or be in actual physical control of a motor vehicle in public areas if that person has a certain blood alcohol concentration. Had the basic elements of the offenses described in the two statutes been different, or had the penalties been substantially different we might have concluded differently. That, however, is not the situation. We also view it as important that the instant case involves an administrative agency decision as distinguished from a criminal conviction. See, Pladson v. Hjelle, 368 N.W.2d at 511.
Accordingly, we affirm the decision of the district court which affirmed the decision of the hearing officer acting on behalf of the Highway Commissioner.
[161]*161VANDE WALLE, GIERKE and MESCHKE, JJ., concur.