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:  
2019-110 LR  
Title of proposed rule set:  
Electrical Administrative Board General 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.  
A. Are these rules required by state law or federal mandate?  
The authority the rules were promulgated under, the Electrical Administrative Act, was repealed by the Skilled Trades  
Act, and so these rules are being rescinded. The Skilled Trades Regulations rules are required by state law 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The authority the rules were promulgated under, the Electrical Administrative Act, was repealed by the Skilled Trades  
Act, and so these rules are being rescinded.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While the current rules are being rescinded, they are being recodified and the proposed rules are less restrictive than  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 states. Ohio is more stringent; the applicant must be a United States citizen or a legal alien who must  
provide proof of being a legal alien; either have been a tradesperson in the type of licensed trade for which the  
application is filed for not less than five (5) years immediately prior to the date the application is filed, currently be a  
registered engineer in this state with three (3) years of business experience in the construction industry in the trade for  
which the engineer is applying to take the examination, or have other experience acceptable to the appropriate section  
of the board; never have been convicted of a disqualifying offense; and carry a minimum $500,000 contractor liability  
coverage. Indiana and Illinois do not have a statewide Electrical licensing system. Electrical contractors in those  
states are licensed at the county or city level. Wisconsin journeyman license requires proof of a minimum of 5 years  
and a 1,000 hours per year of experience and the master license requires a minimum of 1,000 hours per year of  
experience for at least 7 years in electrical construction.  
MCL 24.245(3)  
RIS-Page 2  
A. If the rules exceed standards in those states, please explain why and specify the costs and benefits arising out of  
the deviation.  
The authority the rules were promulgated under, the Electrical Administrative Act, was repealed by the Skilled Trades  
Act, and so these rules are being rescinded. The rules do not exceed standards in the surrounding states.  
3. Identify any laws, rules, and other legal requirements that may duplicate, overlap, or conflict with the proposed  
rules.  
The authority the rules were promulgated under, the Electrical Administrative Act, was repealed by the Skilled Trades  
Act, and so these rules are being rescinded. There are no laws, rules, and or other legal requirements that duplicate,  
overlap, or conflict with the proposed rules.  
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.  
The authority the rules were promulgated under, the Electrical Administrative Act, was repealed by the Skilled Trades  
Act, and so these rules 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.  
The authority the rules were promulgated under, the Electrical Administrative Act, was repealed by the Skilled Trades  
Act, and so these rules are being rescinded. There are no federal rules or standards that regulate construction codes.  
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.  
The authority the rules were promulgated under, the Electrical Administrative Act, was repealed by the Skilled  
Trades Act, and so these rules are being rescinded. There are no federal rules or standards that regulate construction  
codes.  
Purpose and Objectives of the Rule(s)  
6. Identify the behavior and frequency of behavior that the proposed rules are designed to alter.  
The Electrical Administrative Act, 1956 PA 217, MCL 338.881 to 338.892, has been repealed. The Electrical  
Administrative 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 the Electrical Administrative  
Act 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, PA  
407 of 2016, 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. Because the Electrical Administrative Act was  
repealed, the bureau plans to rescind the licensing rules promulgated under the act and create a new rule set to house  
all licensing rules regulation under the Skilled Trades Regulation Act, including the Electrical Administrative Board  
General Rules.  
A. Estimate the change in the frequency of the targeted behavior expected from the proposed rules.  
The Electrical Administrative Act was repealed and the rules are being rescinded and will be recodified in the Skilled  
Trades Regulation rules. The proposed rules will not change the frequency of the targeted behavior.  
B. Describe the difference between current behavior/practice and desired behavior/practice.  
The authority the rules were promulgated under, the Electrical Administrative Act, was repealed by the Skilled Trades  
Act, and so these rules are being rescinded. The current practice is inconsistent whereas the desired practice will be  
consistent and will regulate the skilled trades in one place.  
C. What is the desired outcome?  
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.  
MCL 24.245(3)  
RIS-Page 3  
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 the rules were promulgated under, the Electrical  
Administrative Act, was repealed by the Skilled Trades Act, and so these rules 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 Electrical rules are being rescinded and recodified in the Skilled Trades Regulation rules. The proposed rules will  
be more up to date to protect the health, safety, and welfare of Michigan citizens.  
9. Describe any rules in the affected rule set that are obsolete or unnecessary and can be rescinded.  
The Electrical Administrative Act, 1956 PA 217, MCL 338.881 to 338.892, has been repealed. Because the Electrical  
Administrative act was repealed, the bureau is rescinding the Electrical Administrative Board General Rules and then  
will recodify those rules in a new rule set that will cover all licensing rules regulated under the Skilled Trades  
Regulation Act, including the electrical administrative board rules.  
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 the rules were promulgated  
under, the Electrical Administrative Act, was repealed by the Skilled Trades Act, and so these rules 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.  
The authority the rules were promulgated under, the Electrical Administrative Act, was repealed by the Skilled Trades  
Act, and so these rules are being rescinded. No agency appropriation has been made nor a funding source provided  
for any expenditures associated with the proposed rules.  
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 Electrical Administrative Board General rules will be rescinded, and the bureau will promulgate a new  
rule set, the Skilled Trades Regulation rules, that will include the electrical administrative board 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.  
There are no cost 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. The authority the rules were  
promulgated under, the Electrical Administrative Act, was repealed by the Skilled Trades Act, and so these rules are  
being rescinded.  
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 the rules were promulgated under, the Electrical Administrative Act, was repealed by  
the Skilled Trades Act, and so these rules 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 the rules  
were promulgated under, the Electrical Administrative Act, was repealed by the Skilled Trades Act, and so these rules  
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 the rules were promulgated under, the  
Electrical Administrative Act, was repealed by the Skilled Trades Act, and so these rules are being rescinded.  
Rural Impact  
16. In general, what impact will the rules have on rural areas?  
The authority the rules were promulgated under, the Electrical Administrative Act, was repealed by the Skilled  
Trades Act, and so these rules are being rescinded. There will be no impact on rural areas.  
A. Describe the types of public or private interests in rural areas that will be affected by the rules.  
There are no public or private interests in rural areas that will be affected by the rules.  
MCL 24.245(3)  
RIS-Page 5  
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.  
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 Regulation rule set. The bureau had a four-week  
period that licensees and stakeholders could propose a code change via the rules/code proposal form and the bureau  
held an advisory meeting that all licensees and stakeholders were invited to participate in.  
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.  
The authority the rules were promulgated under, the Electrical Administrative Act, was repealed by the Skilled  
Trades Act, and so these rules are being rescinded. Small businesses are not anticipated to be adversely affected by  
the changes.  
A. Identify and estimate the number of small businesses affected by the proposed rules and the probable effect on  
small businesses.  
The authority the rules were promulgated under, the Electrical Administrative Act, was repealed by the Skilled  
Trades Act, and so these rules are being rescinded. The bureau does not expect that small businesses will be affected  
by these proposed rules.  
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 authority the rules were promulgated under, the Electrical Administrative Act, was repealed by the Skilled  
Trades Act, and so these rules are being rescinded. The compliance and reporting requirements are unchanged.  
D. Describe how the agency established performance standards to replace design or operation standards required  
by the proposed rules.  
The authority the rules were promulgated under, the Electrical Administrative Act, was repealed by the Skilled  
Trades Act, and so these rules are being rescinded. There are no design or operation standards in the proposed rules.  
20. Identify any disproportionate impact the proposed rules may have on small businesses because of their size or  
geographic location.  
The Electrical Administration Act was repealed, which means the Electrical Administrative Board General 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.  
The authority the rules were promulgated under, the Electrical Administrative Act, was repealed by the Skilled  
Trades Act, and so these rules are being rescinded. There are no anticipated reports or increased costs to small  
businesses that are required to comply with the proposed rules.  
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.  
MCL 24.245(3)  
RIS-Page 6  
The authority the rules were promulgated under, the Electrical Administrative Act, was repealed by the Skilled  
Trades Act, and so these rules are being rescinded. Small businesses are not expected to be adversely affected 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.  
The authority the rules were promulgated under, the Electrical Administrative Act, was repealed by the Skilled  
Trades Act, and so these rules are being rescinded. There are no legal, consulting, or accounting services costs that  
small businesses would incur in complying with the proposed rules.  
24. Estimate the ability of small businesses to absorb the costs without suffering economic harm and without  
adversely affecting competition in the marketplace.  
The authority the rules were promulgated under, the Electrical Administrative Act, was repealed by the Skilled  
Trades Act, and so these rules are being rescinded. There are no additional costs or harm anticipated as a result of the  
Electrical Administrative Act being repealed and the Skilled Trades Regulation Act proposed rules.  
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 Electrical Administrative 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 Electrical Administrative 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 the rules were promulgated under, the Electrical Administrative Act, was repealed by the Skilled  
Trades Act, and so these rules 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).  
Licensees and stakeholders that the bureau has emails for were involved if they chose to be. The authority the rules  
were promulgated under, the Electrical Administrative Act, was repealed by the Skilled Trades Act, and so these rules  
are being rescinded.  
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 the rules were promulgated under, the Electrical Administrative Act, was  
repealed by the Skilled Trades Act, and so these rules 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 the rules were promulgated under, the  
Electrical Administrative Act, was repealed by the Skilled Trades Act, and so these rules are being rescinded.  
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 the rules were promulgated under, the Electrical Administrative Act, was repealed by the Skilled Trades  
Act, and so these rules are being rescinded.  
MCL 24.245(3)  
RIS-Page 7  
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 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. The authority the rules were promulgated under, the Electrical Administrative Act, was repealed by the  
Skilled Trades Act, and so these rules are being rescinded.  
A. How many and what category of individuals will be affected by the rules?  
The individuals that would be affected by the rescinding of these rules would be electricians. The authority the rules  
were promulgated under, the Electrical Administrative Act, was repealed by the Skilled Trades Act, and so these rules  
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 the rules were promulgated under, the Electrical Administrative Act, was  
repealed by the Skilled Trades Act, and so these rules 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 the rules were promulgated under, the Electrical Administrative Act, was repealed by the Skilled  
Trades Act, and so these rules 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 primary benefit is uniform licensing, compliant investigation, and enforcement provisions for skilled trades  
licensees. The secondary benefit is higher quality licensee, citizens in Michigan will be better served, likewise fewer  
complaints will be investigated by the bureau, this reduces staff costs. The authority the rules were promulgated  
under, the Electrical Administrative Act, was repealed by the Skilled Trades Act, and so these rules are being  
rescinded.  
32. Explain how the proposed rules will impact business growth and job creation (or elimination) in Michigan.  
The Electrical Administrative rules are being rescinded and recodified in the 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.  
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. The authority the rules were promulgated under, the  
Electrical Administrative Act, was repealed by the Skilled Trades Act, and so these rules are being rescinded.  
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.  
There were neither estimates or assumptions made. The authority the rules were promulgated under, the Electrical  
Administrative Act, was repealed by the Skilled Trades Act, and so these rules are being rescinded.  
Alternative to Regulation  
35. Identify any reasonable alternatives to the proposed rules that would achieve the same or similar goals.  
MCL 24.245(3)  
RIS-Page 8  
There are no reasonable alternatives to the proposed rules that have been identified that would achieve the same or  
similar goals. The authority the rules were promulgated under, the Electrical Administrative Act, was repealed by the  
Skilled Trades Act, and so these rules 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 the rules were promulgated under, the  
Electrical Administrative Act, was repealed by the Skilled Trades Act, and so these rules 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.  
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.  
MCL 24.245(3)  
;