Michigan Office of Administrative Hearings and Rules  
Administrative Rules Division (ARD)  
REGULATORY IMPACT STATEMENT  
and COST-BENEFT ANALYSIS (RIS)  
Agency Information:  
Department name:  
Licensing and Regulatory Affairs  
Bureau name:  
Bureau of Construction Codes  
Name of person filling out RIS:  
Amanda Johnson  
Phone number of person filling out RIS:  
517-241-3408  
E-mail of person filling out RIS:  
Rule Set Information:  
ARD assigned rule set number:  
2019-109 LR  
Title of proposed rule set:  
Building Officials, Plan Reviewers, and Inspector Rules  
Comparison of Rule(s) to Federal/State/Association Standard  
1. Compare the proposed rules to parallel federal rules or standards set by a state or national licensing agency or  
accreditation association, if any exist.  
There are no federal rules or standards that are set by a state or national licensing agency or accreditation association.  
State law mandates the rules, MCL 125.1504(5), states that the director shall add, amend, and rescind rules to update  
the MI Building Officials, Plan Reviewers, and Inspectors rules not less than once every 3 years to coincide with the  
national code change cycle.  
A. Are these rules required by state law or federal mandate?  
The authority these rules were promulgated under, the Building Officials and Inspectors Regulation Act, was  
repealed by the Skilled Trades Act , and so these rule are being rescinded. The Skilled Trades Regulations rules are  
required by state law public 2016, PA 407. There are no federal mandates.  
B. If these rules exceed a federal standard, please identify the federal standard or citation, describe why it is  
necessary that the proposed rules exceed the federal standard or law, and specify the costs and benefits arising out  
of the deviation.  
The authority these rules were promulgated under, the Building Officials and Inspectors Regulation Act, was repealed  
by the Skilled Trades Act , and so these rule are being rescinded. These rules do not exceed a federal standard.  
2. Compare the proposed rules to standards in similarly situated states, based on geographic location, topography,  
natural resources, commonalities, or economic similarities.  
While the current rules are being rescinded, they are being recodified and the proposed rules are less restrictive than  
the bordering state of Wisconsin which requires 24 hours of educational requirements for provisional registration.  
None of the other Great Lake states have educational requirements. Unable to find licensing requirements for Illinois,  
Ohio and Indiana.  
A. If the rules exceed standards in those states, please explain why and specify the costs and benefits arising out of  
the deviation.  
MCL 24.245(3)  
RIS-Page 2  
The rules do not exceed standards in the surrounding states. The authority these rules were promulgated under, the  
Building Officials and Inspectors Regulation Act, was repealed by the Skilled Trades Act , and so these rule are being  
rescinded.  
3. Identify any laws, rules, and other legal requirements that may duplicate, overlap, or conflict with the proposed  
rules.  
There are no laws, rules, or other legal requirements that duplicate, overlap, or conflict with the proposed rules. The  
authority these rules were promulgated under, the Building Officials and Inspectors Regulation Act, was repealed by  
the Skilled Trades Act , and so these rule are being rescinded.  
A. Explain how the rules have been coordinated, to the extent practicable, with other federal, state, and local laws  
applicable to the same activity or subject matter. This section should include a discussion of the efforts undertaken  
by the agency to avoid or minimize duplication.  
There are no federal, state, or local laws applicable to the same activity or subject matter. The authority these rules  
were promulgated under, the Building Officials and Inspectors Regulation Act, was repealed by the Skilled Trades  
Act , and so these rule are being rescinded.  
4. If MCL 24.232(8) applies and the proposed rules are more stringent than the applicable federally mandated  
standard, provide a statement of specific facts that establish the clear and convincing need to adopt the more  
stringent rules.  
There are no federal rules or standards that regulate construction codes. The authority these rules were promulgated  
under, the Building Officials and Inspectors Regulation Act, was repealed by the Skilled Trades Act , and so these rule  
are being rescinded.  
5. If MCL 24.232(9) applies and the proposed rules are more stringent than the applicable federal standard,  
provide either the Michigan statute that specifically authorizes the more stringent rules OR a statement of the  
specific facts that establish the clear and convincing need to adopt the more stringent rules.  
There are no federal rules or standards that regulate construction codes. The authority these rules were promulgated  
under, the Building Officials and Inspectors Regulation Act, was repealed by the Skilled Trades Act , and so these rule  
are being rescinded.  
Purpose and Objectives of the Rule(s)  
6. Identify the behavior and frequency of behavior that the proposed rules are designed to alter.  
The Building Officials and Inspectors Registration Act, 1986 PA 54, MCL 338.2301 to MCL 338.2313, has been  
repealed by the Skilled Trades Act and is outdated. The current rule does not provide uniform licensing, complaint  
investigation, and enforcement provisions for skilled trades licenses. This places a burden on the bureau  
administering these acts and creates an inefficient use of resources. Additionally, many licensees who are cross  
licensed in multiple trades have expressed dissatisfaction with conflicting provisions in separate statutes. The Skilled  
Trades Regulation Act, 2016 PA 407, streamlines the processes for all license types included, while providing for  
modernized provisions, such as electronic communication and third-party continuing education tracking options, and  
specifies violations for unlicensed activity as provided to other regulated professions. While the Skilled Trades  
Regulation Act repealed the five acts that regulated certain skilled trades, this new act includes provisions to regulate  
those same skilled trades. Consequently, the bureau is promulgating a new rule set to regulate these skilled trades, as  
provided under the new act. In addition, the bureau has submitted separate RFRs to rescind the current rules that were  
promulgated under the authority of the five acts that have been repealed.  
A. Estimate the change in the frequency of the targeted behavior expected from the proposed rules.  
The Building Officials and Inspectors rules are being repealed and recodified. The proposed rules will not change the  
frequency of the targeted behavior. The authority these rules were promulgated under, the Building Officials and  
Inspectors Regulation Act, was repealed by the Skilled Trades Act , and so these rule are being rescinded.  
B. Describe the difference between current behavior/practice and desired behavior/practice.  
The current practice is inconsistent whereas the desired practice will be consistent and will regulate the skilled trades  
in one place. The authority these rules were promulgated under, the Building Officials and Inspectors Regulation Act,  
was repealed by the Skilled Trades Act , and so these rule are being rescinded.  
C. What is the desired outcome?  
MCL 24.245(3)  
RIS-Page 3  
The repealed act is outdated and does not provide uniform licensing, complaint investigation, and enforcement  
provisions for skilled trades licenses. This places a burden on the bureau administering these acts and creates an  
inefficient use of resources. The new rule set will provide uniform regulation of the skilled trades, as provided under  
the new Act, 2016 PA 407.  
7. Identify the harm resulting from the behavior that the proposed rules are designed to alter and the likelihood  
that the harm will occur in the absence of the rule.  
The harm will be the continuation of the inconsistencies in the regulation of the license trades. Likewise, the harm is  
the continuation of a lack of uniform regulation. The authority these rules were promulgated under, the Building  
Officials and Inspectors Regulation Act, was repealed by the Skilled Trades Act , and so these rule are being rescinded.  
A. What is the rationale for changing the rules instead of leaving them as currently written?  
The repealed act is outdated and does not provide uniform licensing, complaint investigation, and enforcement  
provisions for the electrical trade. This places a burden on the bureau administering these acts and creates an  
inefficient use of resources. Additionally, many licensees who are cross licensed in multiple trades have expressed  
dissatisfaction with conflicting provisions in separate statutes. The Skilled Trades Regulation Act, 2016 PA 407,  
streamlines the processes for all license types, including while providing for modernized provisions, such as  
electronic communication and third-party continuing education tracking options, and specifies violations for  
unlicensed activity as provided to other regulated professions. The new rule set will regulate the skilled trades as  
provided under the new act.  
8. Describe how the proposed rules protect the health, safety, and welfare of Michigan citizens while promoting a  
regulatory environment in Michigan that is the least burdensome alternative for those required to comply.  
The Building Officials and Inspectors Regulation Act was repealed and will be recodified in the Skilled Trades  
Regulations rules. With repealing the current act it allows the bureau to review and bring some rules up to date so it  
protects the health, safety, and welfare of Michigan citizens, while still promoting a regulatory environment.  
9. Describe any rules in the affected rule set that are obsolete or unnecessary and can be rescinded.  
The rules that are outdated will be obsolete and unnecessary. The authority these rules were promulgated under, the  
Building Officials and Inspectors Regulation Act, was repealed by the Skilled Trades Act , and so these rule are being  
rescinded.  
Fiscal Impact on the Agency  
Fiscal impact is an increase or decrease in expenditures from the current level of expenditures, i.e. hiring additional staff,  
higher contract costs, programming costs, changes in reimbursements rates, etc. over and above what is currently  
expended for that function. It does not include more intangible costs for benefits, such as opportunity costs, the value of  
time saved or lost, etc., unless those issues result in a measurable impact on expenditures.  
10. Please provide the fiscal impact on the agency (an estimate of the cost of rule imposition or potential savings  
for the agency promulgating the rule).  
These rules are being rescinded so there is no fiscal impact on the agency. The authority these rules were  
promulgated under, the Building Officials and Inspectors Regulation Act, was repealed by the Skilled Trades Act ,  
and so these rule are being rescinded.  
11. Describe whether or not an agency appropriation has been made or a funding source provided for any  
expenditures associated with the proposed rules.  
No agency appropriation has been made, nor a funding source provided for any expenditures associated with the  
proposed rules. The authority these rules were promulgated under, the Building Officials and Inspectors Regulation  
Act, was repealed by the Skilled Trades Act , and so these rule are being rescinded.  
12. Describe how the proposed rules are necessary and suitable to accomplish their purpose, in relationship to the  
burden(s) the rules place on individuals. Burdens may include fiscal or administrative burdens, or duplicative  
acts.  
MCL 24.245(3)  
RIS-Page 4  
As stated above in question 6, the repealed act is outdated and does not provide uniform licensing, complaint  
investigation, and enforcement provisions for skilled trades licenses. This places a burden on the bureau  
administering these acts and creates an inefficient use of resources. Additionally, many licensees who are cross  
licensed in multiple trades have expressed dissatisfaction with conflicting provisions in separate statutes. The Skilled  
Trades Regulation Act, 2016 PA 407, streamlines the processes for all license types included, while providing for  
modernized provisions, such as electronic communication and third-party continuing education tracking options, and  
specifies violations for unlicensed activity as provided to other regulated professions. While the Skilled Trades  
Regulation Act repealed the five acts that regulated certain skilled trades, this new act includes provisions to regulate  
those same skilled trades. Consequently, the bureau is promulgating a new rule set to regulate these skilled trades, as  
provided under the new act. In addition, the bureau has submitted separate RFRs to rescind the current rules that  
were promulgated under the authority of the five acts that have been repealed.  
A. Despite the identified burden(s), identify how the requirements in the rules are still needed and reasonable  
compared to the burdens.  
The current building officials, plan reviewers, and inspector rules will be rescinded, and the bureau will promulgate a  
new rule set, the Skilled Trades Regulation rules, that will include the building officials, plan reviewers, and  
inspector rules.  
Impact on Other State or Local Governmental Units  
13. Estimate any increase or decrease in revenues to other state or local governmental units (i.e. cities, counties,  
school districts) as a result of the rule. Estimate the cost increases or reductions for other state or local  
governmental units (i.e. cities, counties, school districts) as a result of the rule. Include the cost of equipment,  
supplies, labor, and increased administrative costs in both the initial imposition of the rule and any ongoing  
monitoring.  
The authority these rules were promulgated under, the Building Officials and Inspectors Regulation Act, was repealed  
by the Skilled Trades Act , and so these rule are being rescinded. There are no increases or decreases in revenues to  
other state or local governmental units as a result of these rules. There are no cost increases or reductions for such  
other state or local governmental units as a result of the rules. No cost of equipment, supplies, labor, or increased  
administrative costs.  
14. Discuss any program, service, duty, or responsibility imposed upon any city, county, town, village, or school  
district by the rules.  
There is no program, service, duty, or responsibility imposed upon any city, county, town, village, or school district  
by these rules. The authority these rules were promulgated under, the Building Officials and Inspectors Regulation  
Act, was repealed by the Skilled Trades Act , and so these rule are being rescinded.  
A. Describe any actions that governmental units must take to be in compliance with the rules. This section should  
include items such as record keeping and reporting requirements or changing operational practices.  
There are no actions that governmental units must take to be in compliance with the rules. The authority these rules  
were promulgated under, the Building Officials and Inspectors Regulation Act, was repealed by the Skilled Trades  
Act , and so these rule are being rescinded.  
15. Describe whether or not an appropriation to state or local governmental units has been made or a funding  
source provided for any additional expenditures associated with the proposed rules.  
No appropriations to state or local governmental units have been made, nor a funding source provided for any  
additional expenditures associated with the proposed rules. The authority these rules were promulgated under, the  
Building Officials and Inspectors Regulation Act, was repealed by the Skilled Trades Act , and so these rule are being  
rescinded.  
Rural Impact  
16. In general, what impact will the rules have on rural areas?  
There will be no impact on rural areas. The authority these rules were promulgated under, the Building Officials and  
Inspectors Regulation Act, was repealed by the Skilled Trades Act , and so these rule are being rescinded.  
A. Describe the types of public or private interests in rural areas that will be affected by the rules.  
MCL 24.245(3)  
RIS-Page 5  
There are no public or private interests in rural areas that will be affected by the rules. The authority these rules were  
promulgated under, the Building Officials and Inspectors Regulation Act, was repealed by the Skilled Trades Act ,  
and so these rule are being rescinded.  
Environmental Impact  
17. Do the proposed rules have any impact on the environment? If yes, please explain.  
The proposed rules will have no impact on the environment. The authority these rules were promulgated under, the  
Building Officials and Inspectors Regulation Act, was repealed by the Skilled Trades Act , and so these rule are being  
rescinded.  
Small Business Impact Statement  
18. Describe whether and how the agency considered exempting small businesses from the proposed rules.  
These rules are being rescinded and recodified in the Skilled Trades rules. The bureau had a four-week period that  
licensees and stakeholders could propose a code change via the rules/code proposal form.  
19. If small businesses are not exempt, describe (a) the manner in which the agency reduced the economic impact  
of the proposed rules on small businesses, including a detailed recitation of the efforts of the agency to comply  
with the mandate to reduce the disproportionate impact of the rules upon small businesses as described below (in  
accordance with MCL 24.240(1)(a-d)), or (b) the reasons such a reduction was not lawful or feasible.  
Small businesses are not anticipated to be adversely affected by the changes. The authority these rules were  
promulgated under, the Building Officials and Inspectors Regulation Act, was repealed by the Skilled Trades Act ,  
and so these rule are being rescinded.  
A. Identify and estimate the number of small businesses affected by the proposed rules and the probable effect on  
small businesses.  
The bureau does not expect that small businesses will be affected by these proposed rules. The authority these rules  
were promulgated under, the Building Officials and Inspectors Regulation Act, was repealed by the Skilled Trades  
Act , and so these rule are being rescinded.  
B. Describe how the agency established differing compliance or reporting requirements or timetables for small  
businesses under the rules after projecting the required reporting, record-keeping, and other administrative costs.  
Because the rules apply to individuals who apply for licensure, it is not practical to establish differing compliance or  
reporting requirements or timetables for small businesses. Small businesses are not expected to be adversely affected  
by these rules. There are no additional reporting, record keeping, or other administrative costs associated with the  
implementation of the proposed rules.  
C. Describe how the agency consolidated or simplified the compliance and reporting requirements for small  
businesses and identify the skills necessary to comply with the reporting requirements.  
The compliance and reporting requirements are unchanged. The authority these rules were promulgated under, the  
Building Officials and Inspectors Regulation Act, was repealed by the Skilled Trades Act , and so these rule are being  
rescinded.  
D. Describe how the agency established performance standards to replace design or operation standards required  
by the proposed rules.  
There are no design or operation standards in the proposed rules. The authority these rules were promulgated under,  
the Building Officials and Inspectors Regulation Act, was repealed by the Skilled Trades Act , and so these rule are  
being rescinded.  
20. Identify any disproportionate impact the proposed rules may have on small businesses because of their size or  
geographic location.  
The Building Officials and Inspectors Act was repealed and the rules will be rescinded and recodified in the Skilled  
Trades Regulation rules. The new rules will have no disproportionate impact on small businesses because of their  
size or geographic location.  
21. Identify the nature of any report and the estimated cost of its preparation by small businesses required to  
comply with the proposed rules.  
MCL 24.245(3)  
RIS-Page 6  
There are no anticipated reports or increased costs to small businesses that are required to comply with the proposed  
rules. The authority these rules were promulgated under, the Building Officials and Inspectors Regulation Act, was  
repealed by the Skilled Trades Act , and so these rule are being rescinded.  
22. Analyze the costs of compliance for all small businesses affected by the proposed rules, including costs of  
equipment, supplies, labor, and increased administrative costs.  
The authority these rules were promulgated under, the Building Officials and Inspectors Regulation Act, was  
repealed by the Skilled Trades Act , and so these rule are being rescinded. Small businesses are not expected to be  
adversely affected by the proposed rules, including costs of equipment, supplies, labor, and increased administrative  
costs.  
23. Identify the nature and estimated cost of any legal, consulting, or accounting services that small businesses  
would incur in complying with the proposed rules.  
There are no legal, consulting, or accounting services costs that small businesses would incur in complying with the  
proposed rules. The authority these rules were promulgated under, the Building Officials and Inspectors Regulation  
Act, was repealed by the Skilled Trades Act, and so these rule are being rescinded.  
24. Estimate the ability of small businesses to absorb the costs without suffering economic harm and without  
adversely affecting competition in the marketplace.  
There are no additional costs or harm anticipated as a result of the Building Officials and Inspectors Act being  
repealed and the Skilled Trades Regulation Act proposed rules. The authority these rules were promulgated under, the  
Building Officials and Inspectors Regulation Act, was repealed by the Skilled Trades Act , and so these rule are being  
rescinded.  
25. Estimate the cost, if any, to the agency of administering or enforcing a rule that exempts or sets lesser  
standards for compliance by small businesses.  
The Building Officials and Inspectors Registration Act has been repealed and the new rules are needed to reflect the  
Skilled Trades Regulation Act. There is no additional cost to the agency for administrating and enforcing the  
proposed rules beyond the current operational costs.  
26. Identify the impact on the public interest of exempting or setting lesser standards of compliance for small  
businesses.  
The Building Officials and Inspectors Act has been repealed and the new rules are needed to reflect the Skilled  
Trades Regulation Act. Small businesses are not exempt from either rule set. Therefore, there is no impact on the  
public interest of exempting or setting lesser standards of compliance for small businesses.  
27. Describe whether and how the agency has involved small businesses in the development of the proposed rules.  
The authority these rules were promulgated under, the Building Officials and Inspectors Regulation Act, was  
repealed by the Skilled Trades Act , and so these rule are being rescinded. The bureau involved small businesses  
through the new Skilled Trades Regulation Act rules review process. An email blast was sent out to stakeholders and  
licensees with a rule/code proposal form giving them four weeks to get any rule changes submitted and an advisory  
meeting was held with stakeholders and licensees invited.  
A. If small businesses were involved in the development of the rules, please identify the business(es).  
The authority these rules were promulgated under, the Building Officials and Inspectors Regulation Act, was  
repealed by the Skilled Trades Act , and so these rule are being rescinded. Licensees and stakeholders that the bureau  
has emails for were involved if they chose to be.  
Cost-Benefit Analysis of Rules (independent of statutory impact)  
28. Estimate the actual statewide compliance costs of the rule amendments on businesses or groups.  
The rules are needed to reflect the Skilled Trades Regulation Act and will not result in any statewide compliance  
costs on businesses or groups. The authority these rules were promulgated under, the Building Officials and  
Inspectors Regulation Act, was repealed by the Skilled Trades Act , and so these rule are being rescinded.  
A. Identify the businesses or groups who will be directly affected by, bear the cost of, or directly benefit from the  
proposed rules.  
Businesses will not be directly affected by the proposed rules. The authority these rules were promulgated under, the  
Building Officials and Inspectors Regulation Act, was repealed by the Skilled Trades Act , and so these rule are being  
rescinded.  
MCL 24.245(3)  
RIS-Page 7  
B. What additional costs will be imposed on businesses and other groups as a result of these proposed rules (i.e.  
new equipment, supplies, labor, accounting, or recordkeeping)? Please identify the types and number of businesses  
and groups. Be sure to quantify how each entity will be affected.  
There will be no additional costs imposed on businesses or other groups as a result of the proposed rules. The  
authority these rules were promulgated under, the Building Officials and Inspectors Regulation Act, was repealed by  
the Skilled Trades Act , and so these rule are being rescinded.  
29. Estimate the actual statewide compliance costs of the proposed rules on individuals (regulated individuals or  
the public). Include the costs of education, training, application fees, examination fees, license fees, new  
equipment, supplies, labor, accounting, or recordkeeping.  
The Building Officials and Inspectors Registration Act was repealed and recodified in the Skilled Trades Regulation  
rules. The proposed rules are not anticipated to increase compliance costs for the public. Individuals who in the past  
have had an application and examination fee will continue to do so. Individuals requesting registration as a plan  
review, inspector, or building official registration will continue to pay an application fee and will now pay an  
examination fee as well.  
A. How many and what category of individuals will be affected by the rules?  
The individuals that would be affected by the rescission of these rules would be building officials and inspectors.  
The authority these rules were promulgated under, the Building Officials and Inspectors Regulation Act, was  
repealed by the Skilled Trades Act , and so these rule are being rescinded.  
B. What qualitative and quantitative impact do the proposed changes in rules have on these individuals?  
The qualitative impact will ensure higher standards for an individual who is licensed in the skilled trades. There is  
no quantitative impact. The authority these rules were promulgated under, the Building Officials and Inspectors  
Regulation Act, was repealed by the Skilled Trades Act , and so these rule are being rescinded.  
30. Quantify any cost reductions to businesses, individuals, groups of individuals, or governmental units as a result  
of the proposed rules.  
There are no expected cost reductions to businesses, individuals, or groups of individuals as a result of the proposed  
rules. The authority these rules were promulgated under, the Building Officials and Inspectors Regulation Act, was  
repealed by the Skilled Trades Act , and so these rule are being rescinded.  
31. Estimate the primary and direct benefits and any secondary or indirect benefits of the proposed rules. Please  
provide both quantitative and qualitative information, as well as your assumptions.  
The authority these rules were promulgated under, the Building Officials and Inspectors Regulation Act, was  
repealed by the Skilled Trades Act , and so these rule are being rescinded. The primary benefit is uniform licensing,  
compliant investigation, and enforcement provisions for skilled trades licensees. The secondary benefit is higher  
quality licensees, citizens in Michigan will be better served, likewise fewer complaints will be investigated by the  
bureau, which reduces staff costs.  
32. Explain how the proposed rules will impact business growth and job creation (or elimination) in Michigan.  
The Building Officials rules are being rescinded and will be recodified in the Skilled Trades Regulation rules. The  
proposed rules are not expected to have any adverse impact on business growth or job creation.  
33. Identify any individuals or businesses who will be disproportionately affected by the rules as a result of their  
industrial sector, segment of the public, business size, or geographic location.  
The authority these rules were promulgated under, the Building Officials and Inspectors Regulation Act, was  
repealed by the Skilled Trades Act , and so these rule are being rescinded. Individuals or businesses will not be  
disproportionately affected by the rules as a result of their industrial sector, segment of the public, business size, or  
geographic location.  
34. Identify the sources the agency relied upon in compiling the regulatory impact statement, including the  
methodology utilized in determining the existence and extent of the impact of the proposed rules and a cost-  
benefit analysis of the proposed rules.  
The bureau relied upon bureau staff and rules/code proposal forms that the bureau received as the form asks for  
justification for the change they are proposing, including determining the existence and extent of the impact of the  
proposed rules and the cost benefit analysis of these proposed rules.  
A. How were estimates made, and what were your assumptions? Include internal and external sources, published  
reports, information provided by associations or organizations, etc., that demonstrate a need for the proposed  
rules.  
MCL 24.245(3)  
RIS-Page 8  
There were neither estimates or assumptions made. The authority these rules were promulgated under, the Building  
Officials and Inspectors Regulation Act, was repealed by the Skilled Trades Act , and so these rule are being  
rescinded.  
Alternative to Regulation  
35. Identify any reasonable alternatives to the proposed rules that would achieve the same or similar goals.  
There are no reasonable alternatives to the proposed rules that have been identified that would achieve the same or  
similar goals. The authority these rules were promulgated under, the Building Officials and Inspectors Regulation  
Act, was repealed by the Skilled Trades Act , and so these rule are being rescinded.  
A. Please include any statutory amendments that may be necessary to achieve such alternatives.  
No statutory amendments are necessary to achieve alternatives. The authority these rules were promulgated under,  
the Building Officials and Inspectors Regulation Act, was repealed by the Skilled Trades Act , and so these rule are  
being rescinded.  
36. Discuss the feasibility of establishing a regulatory program similar to that proposed in the rules that would  
operate through private market-based mechanisms. Please include a discussion of private market-based systems  
utilized by other states.  
The authority these rules were promulgated under, the Building Officials and Inspectors Regulation Act, was  
repealed by the Skilled Trades Act , and so these rule are being rescinded. Establishment of a regulatory program  
operating through private market-based mechanisms similar to the proposed rules would not be feasible, as licensing  
by the bureau is the primary obligation as required under the Act.  
37. Discuss all significant alternatives the agency considered during rule development and why they were not  
incorporated into the rules. This section should include ideas considered both during internal discussions and  
discussions with stakeholders, affected parties, or advisory groups.  
There were no significant alternatives presented for the bureau to consider.  
Additional Information  
38. As required by MCL 24.245b(1)(c), please describe any instructions regarding the method of complying with  
the rules, if applicable.  
This is not applicable as these rules are being rescinded.  
MCL 24.245(3)  
;