Mark Stimac Page 1-2  
Compliant by Design LLC  
Building Code Consulting  
31695 Karolyn Lane  
Fraser, MI 48026  
April 4, 2024  
Tony Williamson  
Bureau of Construction Codes  
P.O. Box 30254, Lansing, MI 48909  
Re: Public Comment on proposed 2021 Michigan Rehabilitation Code for Existing Buildings  
Rules of Public Act 230 of 1972  
Dear Sir:  
I will be unable to attend the public hearing scheduled for 4/4/24. Enclosed are my comments on the  
proposed rules which would adopt and amend the 2021 International Building Code to become the 2021  
Michigan Building Code.  
Rule 554 should be amended as follows  
Section 101.2 should be amended to read:  
101.2 Scope. The provisions of this code shall apply to the repair, alteration, change of occupancy,  
addition, and relocation of existing buildings. A building or portion of a building which has not been  
previously occupied or used for its intended purpose shall comply with the provisions of the Michigan  
building code for new construction. Repairs, alterations, change of occupancy, existing buildings to  
which additions are made, historic buildings, and relocated buildings complying with the provisions of  
the Michigan building code, the Michigan electrical code, the Michigan residential code, the Michigan  
mechanical code, and the Michigan plumbing code shall be considered to be in compliance with this  
code.  
Reason for code change: The second sentence of the language inserted into Section 101.2 by Rule 554 is  
already covered and in conflict with the language that exists in in Section 101.4.1 which is proposed to  
be adopted without amendment. This redundant and conflicting language should be deleted.  
Rule 557  
The definition of "Registered design professional" is intended to be amended to mean an individual who  
is licensed under the occupational code, 1980 PA 299, MCL 339.101 to 339.2919 339.2677.  
There are numerous professions that are licensed under 1980 PA 299. These include barbers,  
accountants, appraisers and others. The correct reference should be to individuals who are licensed  
under article 20 of the occupational code, 1980 PA 299. That is the article that licenses architects,  
engineers and land surveyors who should be the licensed professionals that are submitting plans for  
approval with building permit applications.  
www.compliantbydesignllc.com  
Compliant by Design LLC  
Building Code Consulting  
31695 Karolyn Lane  
Fraser, MI 48026  
I appreciate the opportunity to submit these public comments. I can be reached via email at  
marks@compliantbydesignllc.com.  
Respectfully submitted.  
Mark Stimac, R.A., C.B.O.  
Compliant by Design LLC  
www.compliantbydesignllc.com  
Tracie Pack Page 3  
LARA-BCC-Rules  
From:  
Sent:  
To:  
Tracie Pack <paxnmac@gmail.com>  
Thursday, April 4, 2024 1:58 PM  
LARA-BCC-Rules  
Subject:  
Re: Rehabilitation Code Rules  
CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov  
Good afternoon. I'm recommending that the Bureau of Construction Codes keep the current rehabilitation code rules as  
they are with no amendments.  
Thank you,  
Tracie Pack  
1
William Hordyk  
Page 4  
To Whom it may concern,  
In review of the proposed changes to the Michigan Building Code, I present the following on behalf of  
the Metro Building Inspectors Association of Greater Grand Rapids, and myself.  
General  
‐
In several modifications to rule language there appears a change from a metric  
measurement symbol to a metric word. To be clear, the short forms for metric units (such as  
mm for millimeter) are symbols, not abbreviations. These correct ways to use the Système  
international d’unités, and other related units are set by the international standards that  
define the SI. There is no need to create additional confusion of measurements or additional  
rules that will need to be reviewed in the next promulgation process. Please allow the  
symbol mm to remain where used in the model code.  
Rule 557  
‐
The definition for “Act” should not be written into code language. There are references  
within established rules and draft rules that reference different Public Acts of Michigan,  
such as the Skilled Trades Regulation Act, the Occupation Code, the Adult Foster Care  
Licensing Act, as well as the Stille Derosett‐Hale Single State Construction Act. Where any  
Act is referenced within code language it is, and properly so, identified using it’s full name.  
PA 230 is named the “Stille Derosett‐Hale Single State Construction Act” within the Act. It  
does not need to be redefined in code language that is subordinate to the Act.  
Rule 561  
‐
The current reference to section 410.7 was modified to reference 306.7.2, the correct  
section to reference is 306.7.1  
Thank you for the consideration of these items and honestly (honestly, because inflection can be  
misread in written communication) thank you for your diligence in updating the codes.  
William A Hordyk, MCP  
;