A. Identify the businesses or groups who will be directly affected by, bear the cost of, or directly benefit from the
The proposed rules benefits farmers by adjusting the nutrient guarantees so farmers can use less fertilizer and pay
less in tonnage fees back to the retailer. There is no limit on usage but the rule requires specific details for nutrients
present and the necessary awareness of what is being used.
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 costs will be imposed on businesses; they will have to do the reporting only once per year instead of
twice. The recordkeeping, accounting, and other tracking remains the same.
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.
No additional statewide compliance costs will be imposed on individuals.
A. How many and what category of individuals will be affected by the rules?
MDARD typically licenses 800 fertilizer manufacturers per year. Additionally, approximately 6,000 specialty
fertilizer & soil conditioner products are registered in Michigan. All these licensees and registrants shouldn’t be
impacted overall with the minimum rule change because Michigan follows AAPFCO standards. This practice is
followed to ease the burden on the fertilizer industry and changing label which can be different from state to state.
Consumers are already purchasing products per AAPFCO standards, so they will not be affected either.
Regarding tonnage changes, only licensed sellers/distributors are affected and will save time/costs of person
responsible for reporting tonnage from twice per year to once per year.
B. What qualitative and quantitative impact do the proposed changes in rules have on these individuals?
The impact is less fertilizer used which reduces the costs and impact on the environment.
30. Quantify any cost reductions to businesses, individuals, groups of individuals, or governmental units as a result
of the proposed rules.
As previously mentioned, approximately 1,400 hours per year are logged by departmental technicians to process
tonnage reports. By reducing to once per year, this number will be reduced by half resulting in thousands of dollars
of savings for employee’s time to process these reports. This should have the same effect on the industry’s
administrative costs to complete and submit these reports. The savings in staff time should allow departmental
technicians to work on reporting delinquencies and correcting errors in the reports. Also, time savings will allow for
better outreach to the industry to complete these reports properly and accurately.
With the proposed minimum guarantees, thousands of dollars overall should be saved for the industry and the
consumer due to less micronutrients being added to meet the higher, minimum guarantees currently in the regulation.
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 benefits are streamlining the tonnage reporting. This new yearly reporting allows for the department and
farmers to directly benefit by decreasing cost and time devoted to the recording and auditing process. The secondary
benefits are the positive impacts on the environment from precision agriculture and less runoff.
32. Explain how the proposed rules will impact business growth and job creation (or elimination) in Michigan.
The proposed rules will not impact business growth. If any, the rule may spur additional expansion of current parties
due to saved costs and allowing for more efficient use of fertilizer. As discussed above, awareness of the fertilizer
and what nutrients are present will also allow for more diversification of plant species to be grown.
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.