Hello,
I have presented my remarks in the public hearing today. I wanted to forward you the text of my
remarks for inclusion in the record.
Thank You
Administrative Rules for Part 7 Plumbing Code Rules
Rule Set 2019-117 LR
In review of the proposed rule changes, I would like to raise an objection to the deletion of substantial
portions of the administrative section (chapter 1) of the Plumbing Code. These sections identified for
deletion have existing in the model code and MI versions of that code since the promulgation of the
2000 codes. Similar language has also been a part of the MI adopted codes from the formation of PA
230 0f 1972 without being modified by administrative rules. Why is it now that the director has
determined to throw out over 50 years of precedence and claim that these sections of code are in
contradiction to the Act? I ask the director to respond with reasoning for the deletions, and specific
reasoning for each of the following sections identified for deletion from the 2018 International Plumbing
Code.
103.1 to 103.3
104.2
104.5 to 104.7
105.1
105.3 to 105.3.3
106.3
106.3.2
106.3.3
106.5.5
108.3
108.5
109.1
William Hordyk
Plans Examiner
City of Grand Rapids
1120 Monroe Ave, NW
Grand Rapids, MI 49503
(616) 456-3134