Okubo was asking for a ruling (legal opinion) on existing law. The section of Administrative Rules that you referenced has to do with adopting a new rule, amending an existing rule, or repealing an existing rule. I don’t see where that applies to asking the AG’s office for a decision on what the law says.
Okubo knew that they were supposed to provide the 1961 birth index. She wanted the AG to say that they didn’t have to do that. That would require an additional rule or ruling about the interpretation of the existing rules and law, which is what that section talks about.
What other official procedure would an AG use in order to say that index records required to be made public would not have to be released?