After meeting with the top political adviser to Republican presidential candidate Robert J. Dole (R-Kan.), a California political consulting firm is setting up an "independent" expenditure committee that plans to raise and spend millions of dollars on Sen. Dole's behalf in the West.

Federal election laws permit such "independent expenditures," but only if they are truly independent -- made without any cooperation or consultation with a candidate or his or her representatives.

Lee Stitzenberger, president of the Dolphin Group, a Los Angeles-area consulting group, said yesterday that his firm, which had expressed interest in becoming paid political consultants for the Dole campaign in the West, was invited to a meeting last month by Norman (Skip) Watts, Dole's political director.

During the meeting, "it became clear that they {the Dole campaign} wouldn't be able to run a real media campaign out here because they will have allocated the max by then," Stitzenberger said, referring to the fact that the Dole campaign is spending funds so fast it could reach the national spending ceiling of $27.7 million before the California primary June 6. "So we have started and will be announcing next week an independent expenditure committee."

The option allows Dole backers to, in effect, run a big-state campaign outside the FEC rules, regulations and limits that apply to presidential campaigns that accept public financing.

Stitzenberger said the "option" of setting up an independent expenditure committee was discussed at the meeting and that he asked Watts to send him material on how to form such a committee. He said he had not talked to Watts or anyone in the Dole committee since then.

Scott Morgan, general counsel to the Dole campaign, said last night that the campaign had not violated election rules. He said Watts told him that it was Stitzenberger's idea to have the meeting because the Dolphin Group wanted to be hired by the campaign.

"Toward the end of the discussion they pitched the idea of an independent expenditure committee," Morgan said. "There's nothing a campaign can do if they bring it up." He added that Watts sent Stitzenberger the rules for forming such a group.

Stitzenberger said he plans to announce formation of the committee early next week and will give it a name similar to "Independent Westerners for America."

He said his firm hopes to raise "in the neighborhood of a couple million dollars" in amounts of up to $5,000 per donor, and will spend the money in California and other western states.

"It seems 'Super Tuesday' won't dictate the outcome of the nomination. California and the West will end up being the Super Bowl," he added.

The Dolphin Group was set up by Bill Roberts, who helped run Ronald Reagan's campaign for governor in 1966 with partner Stu Spencer. Stitzenberger said his group worked for the 1982 gubernatorial campaign of George Deukmejian and for the Republican National Committee in several western states in 1984.

Stitzenberger acknowledged it is unusual for professional political consultants to set up "independent expenditure" committees, but said the spending "won't be successful without professional management." He said he also hopes the program will be "economically viable" for his firm.

The Dole campaign already has been the beneficiary of "independent expenditures" in the New Hampshire primary. Thomas C. Foley, the New York business executive who spent more than $150,000 on television commercials there, has said he made his decision without any consultation with the Dole campaign.