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 MMFLA and MRTMA require the agency to promulgate rules that ensure the safety, security, and integrity of the
operation of marihuana businesses. The statutes also require licensees to comply with standards and requirements for
marihuana businesses. There are costs associated with the statutory requirements implemented through the proposed
rule changes. This is an existing program, so the actual costs are already in place. These rule changes will not
increase or decrease the compliance costs.
A. Identify the businesses or groups who will be directly affected by, bear the cost of, or directly benefit from the
The rule changes apply to applicants and licensees. There could be additional businesses or groups affected by, bear
the cost of, or directly benefit from the proposed rule changes. Examples may be CPAs, lab equipment companies,
surveillance equipment companies, third-party integrators, and point of sale companies.
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.
No additional cost will be imposed on businesses or other groups. Only applicants and licensees are affected by the
proposed rule changes.
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.
There are no compliance costs associated with these rule changes.
A. How many and what category of individuals will be affected by the rules?
All licensees are affected by these proposed rule changes. There are approximately 1,850 licenses currently.
B. What qualitative and quantitative impact do the proposed changes in rules have on these individuals?
This licensed and regulated industry could have an impact on the cost and sale of medical marihuana, and whether
someone chooses to become a medical marihuana patient with adult-use marihuana available.
30. Quantify any cost reductions to businesses, individuals, groups of individuals, or governmental units as a result
of the proposed rules.
The proposed rule changes do not provide any cost reductions to business, individuals, or governmental units.
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.
a) Establish consistent employment requirements and practices across marihuana businesses.
b) Establish parity between the adult-use and medical marihuana business, especially so that those holding equivalent
licenses are able to operate in a compliant fashion.
32. Explain how the proposed rules will impact business growth and job creation (or elimination) in Michigan.
The licensing and regulatory framework that is created will establish a commercial supply and distribution
mechanism for marihuana. The license categories create new businesses in the industry that otherwise were not
licensed or regulated – and will impact business growth and job creation specifically for those interacting with the
licensed marihuana business.
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 proposed rule changes specifically focus on the marihuana industrial sector as they implement aspects of the
regulatory framework as required by the MMFLA and MRTMA. The operation of these businesses impacts the
marihuana customer segment of the public through increased access to marihuana that has been tracked, tested, and
labeled to ensure safety for customers. There is no expected disproportionate effect due to business size or
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.