大方廣佛華嚴經隨疏演義鈔 80.57

80.57

疏「豈同三乘但用佛聲為法輪等耶」者，揀實異權。而言等者，就佛聲中揀尋常言，如問晴雨、安慰弟子等，亦非法輪；唯取轉法。又要令他斷惑見理，方明法輪。今此乃至數重深玄。一則不論斷不斷等，說即名輪，故經云「如來所轉妙法輪，一切皆是菩提分。若能聞已悟法性，如是之人常見佛。」二者尋常之言亦是法論，如來無有散亂聲，故言不虛發。如《涅槃》說「如來一切語言皆名轉法輪」故。三者能令三界所有聲，聞者皆是如來音故。四者不揀聲與非聲，遍於法界皆法輪體，況復一多交徹相映融即，豈同三乘之法輪哉？

Regarding the commentary's "How could it be like the triyāna, merely taking the Buddha's voice as the Dharma wheel and so forth?" this distinguishes the real from the provisional. As for saying "and so forth," within the Buddha's voice it sets aside ordinary speech, such as asking about clear or rainy weather, comforting disciples, and so forth, which are also not the Dharma wheel; it only takes turning the Dharma. Furthermore, it must cause others to sever delusion and see the principle before it is clarified as the Dharma wheel. Now, here it even reaches multiple layers of profound profundity: 1. Irrespective of whether delusion is severed or not, speech itself is called the wheel; hence the sūtra says: "The wondrous Dharma wheel turned by the Tathāgata / is entirely of the bodhi-factors. / If one can hear it and awaken to dharmatā, / such a person constantly sees the Buddha." 2. Ordinary words are also the Dharma wheel; the Tathāgata has no distracted voice, so his words are not uttered in vain. As the Nirvāṇa [Sūtra] says, "All the Tathāgata's utterances are called turning the Dharma wheel." 3. It can cause all sounds in the three realms to be heard by listeners as the Tathāgata's voice. 4. Without distinguishing between sound and non-sound, pervading the dharmadhātu, everything is the essence of the Dharma wheel. How much more so when the one and the many interpenetrate and mutually reflect in harmonious identity! How could it be identical to the Dharma wheel of the triyāna?