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 Professional Licensing  
Name of person filling out RIS:  
Dena Marks  
Phone number of person filling out RIS:  
517-335-3679  
E-mail of person filling out RIS:  
Rule Set Information:  
ARD assigned rule set number:  
2022-23 LR  
Title of proposed rule set:  
Landscape Architects – 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.  
Each state establishes its own requirements with respect to the regulation of this profession, so there are no federal  
rules or standards set by a national or state agency that the proposed rules can be compared to.  
A. Are these rules required by state law or federal mandate?  
The department is required to promulgate rules necessary and appropriate to enable it to fulfill its role pursuant to  
MCL 339.205. MCL 339.2203 requires the director, with the assistance of the ad hoc committee, to adopt rules  
regarding continuing education and continuing competency courses, providing for exceptions to licensure in  
extraordinary cases, and establishing sanction recommendations.  
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 proposed 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.  
The proposed rules are consistent with the standards required in the Michigan Occupational Code, and the rules are  
largely consistent with the requirements in other Great Lakes region states that regulate the profession. All states in  
the Great Lakes region license or register landscape architects.  
A. If the rules exceed standards in those states, please explain why and specify the costs and benefits arising out of  
the deviation.  
The education and experience requirements for licensure or registration and continuing education requirements for  
landscape architects differ from state to state. Overall, the standards in the proposed rules do not exceed those of the  
other states in the Great Lakes region that license or register landscape architects.  
3. Identify any laws, rules, and other legal requirements that may duplicate, overlap, or conflict with the proposed  
rules.  
MCL 24.245(3)  
RIS-Page 2  
There are no other laws, rules, or other legal requirements that may duplicate, overlap, or conflict with these 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.  
No coordination is needed because there are no other applicable laws that regulate the areas addressed in the proposed  
rules.  
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.  
MCL 24.232(8) does not apply.  
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.  
MCL 24.232(9) does not apply.  
Purpose and Objectives of the Rule(s)  
6. Identify the behavior and frequency of behavior that the proposed rules are designed to alter.  
Part 1 General Provisions: The current rule in this part provides definitions for terms used in the rule set. Several  
current rule numbers that should be included in Part 1 of the rules contain rules that pertain to education and  
examination or licensure. The rule numbers will be moved to Part 1, those current rules related to education and  
examination or licensure will be rescinded, and the substance of those rules will be moved to a new rule number  
within the Part of the rules where they should be located to comply with current drafting requirements and for  
organization and clarity. The proposed rules are intended to assist a licensee in complying with the requirements for  
licensure or license renewal.  
Part 2 Education and Examination: The proposed rules in this part identify the approved educational programs and  
examination. The accreditation standards will be updated to assist an applicant in identifying the educational  
programs approved by the department. Several current rule numbers that should be included in Part 2 of the rules  
contain rules that pertain to relicensure, license renewal, and continuing education. Those rules pertaining to  
relicensure, license renewal, and continuing education will be rescinded, and the substance of those rules will be  
moved to new rule numbers within the Parts of the rules where they should be located to comply with current drafting  
requirements and for organization and clarity. The proposed rules are intended to assist a licensee in complying with  
the education and examination requirements for licensure.  
Part 3 Licensure: The proposed rules in this part identify the requirements for licensure, licensure by endorsement,  
and relicensure. The proposed rules do not change the substance of rules currently contained in this rule set. Rather,  
the substance of these rules is currently contained in rule numbers that should be included in either Part 1 or Part 2 of  
the rules. The proposed rules renumbering will comply with current drafting rule requirements and will provide  
organization and clarity within the rule set. The proposed rules are intended to assist a licensee in complying with the  
requirements for licensure.  
Part 4 License Renewal Standards, Continuing Education, Sanctions for Failure to Complete Continuing Education:  
The proposed rules in this part identify standards for license renewal, identify approved continuing education  
providers and activities, and provide sanctions for failure to satisfy continuing education requirements for renewal.  
The proposed rules add the procedure to be used if a licensee is requesting a waiver of the continuing education  
requirements for license renewal. The remainder of the new rules do not change the substance of rules currently  
contained in this rule set. Rather, the substance of these rules is currently contained in rule numbers that should be  
included in either Part 2 or Part 3 of the rules. The proposed rules renumbering will comply with current drafting rule  
requirements and will provide organization and clarity within the rule set. The proposed rules are intended to assist a  
licensee in complying with the requirements for license renewal.  
MCL 24.245(3)  
RIS-Page 3  
A. Estimate the change in the frequency of the targeted behavior expected from the proposed rules.  
Part 1 General Provisions: The current rule in this part provides definitions for terms used in the rule set for better  
reader understanding. It is estimated that reader understanding of the rules will be increased by reorganizing the rules  
contained to comply with current drafting requirements. The frequency of the targeted behavior is not expected to  
change.  
Part 2 Education and Examination: The proposed rules in this part identify the approved education programs and  
examination for licensure. The prior rules contained outdated information, which is updated in the proposed rules.  
The frequency of the targeted behavior will not increase, but the proposed rules will provide better organization,  
greater clarity, up-to-date information, and will comply with current drafting requirements.  
Part 3 Licensure: The proposed rules in this part establish the requirements for initial licensure, licensure by  
endorsement, and relicensure. It is expected that each applicant seeking licensure will be impacted by the new rules,  
but the frequency of use is not expected to change. The proposed rules will also provide better organization and  
greater clarity while complying with current drafting requirements.  
Part 4 License Renewal Standards, Continuing Education, Sanctions for Failure to Complete Continuing Education:  
The proposed rules in this part pertain to license renewal standards, identify approved continuing education providers  
and activities, and establish sanctions if a licensee fails to comply with the continuing education required for license  
renewal. The proposed rules will add the procedure to be used if a licensee is requesting a waiver of the continuing  
education requirements for license renewal. The frequency of use is not expected to change. The proposed rules will  
provide better organization and greater clarity while complying with current drafting requirements.  
B. Describe the difference between current behavior/practice and desired behavior/practice.  
Part 1 General Provisions: This part provides general rules within the rule set. It is estimated that reader  
understanding of the rules will be increased by reorganizing the rules to comply with current drafting requirements.  
Part 2 Education and Examination: The proposed rules in this part identify the approved education programs and  
examination for licensure. The prior rules contained outdated information, which is updated in the proposed rules. It  
is expected that the proposed rules will provide better organization, greater clarity, up-to-date information, and will  
comply with current drafting requirements for greater reader understanding.  
Part 3 Licensure: The proposed rules in this part establish the requirements for initial licensure, licensure by  
endorsement, and relicensure. It is expected that each applicant seeking licensure will be impacted by the new rules,  
but the frequency of use is not expected to change. The proposed rules will also provide better organization and  
greater clarity while complying with current drafting requirements. It is estimated that reader understanding of the  
rules will be increased by reorganizing the rules to comply with current drafting requirements.  
Part 4 License Renewal Standards, Continuing Education, Sanctions for Failure to Complete Continuing Education:  
The proposed rules in this part pertain to license renewal standards, identify approved continuing education providers  
and activities, and establish sanctions if a licensee fails to comply with the continuing education required for license  
renewal. The proposed rules will add the procedure to be used if a licensee is requesting a waiver of the continuing  
education requirements for license renewal. The frequency of use is not expected to change. The proposed rules will  
also provide better organization and greater clarity while complying with current drafting requirements. It is  
estimated that reader understanding of the rules will be increased by reorganizing the rules to comply with current  
drafting requirements.  
C. What is the desired outcome?  
MCL 24.245(3)  
RIS-Page 4  
Part 1 General Provisions: This section will provide the general rules within the rule set. The proposed rules will  
reorganize the rules to comply with current drafting requirements and is intended to provide ease of use and better  
reader understanding.  
Part 2 Education and Examination: The proposed rules in this part identify the approved educational programs and the  
examination required for licensure. The desired outcome is to assist an applicant in determining if his or her  
educational program is approved and to identify the examination he or she must take for licensure and to reorganize the  
rules to comply with current drafting requirements for ease of use and better reader understanding.  
Part 3 Licensure: The proposed rules set out the requirements for initial licensure, licensure by endorsement, and  
relicensure. The desired outcome is to assist an applicant for licensure in meeting the requirements, to reorganize the  
rules to comply with current drafting requirements, and to provide ease of use and better reader understanding of the  
rules.  
Part 4 License Renewal Standards, Continuing Education, Sanctions for Failure to Complete Continuing Education:  
The proposed rules in this part pertain to license renewal standards, identify approved continuing education providers  
and activities, and establish sanctions if a licensee fails to comply with the continuing education required for license  
renewal. The proposed rules will add the procedure to be used if a licensee is requesting a waiver of the continuing  
education requirements for license renewal. The desired outcome is to provide better organization and clarity while  
complying with current drafting requirements and to setting forth the procedure to be followed when seeking a  
continuing education waiver for license renewal.  
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.  
Part 1 General Provisions: Although the likelihood of harm is slight as written, the reorganization in compliance with  
current drafting requirements will ensure ease of use and better reader understanding.  
Part 2 Education and Examination: The potential harm without the proposed rule change is that the licensee’s  
education may not satisfy the requirements for licensure because accreditation standards in the rules are outdated.  
Part 3 Licensure: Although the likelihood of harm is slight as written, the reorganization in compliance with current  
drafting requirements will ensure that the applicant can easily identify the requirements for obtaining a license.  
Part 4 License Renewal Standards, Continuing Education, Sanctions for Failure to Complete Continuing Education:  
The potential harm without the proposed rule change setting out the procedures for applying for a waiver of the  
continuing education requirements for license renewal is that the licensee may fail to apply for the waiver in a timely  
manner or fail to comply with all requirements.  
A. What is the rationale for changing the rules instead of leaving them as currently written?  
Part 1 General Provisions: As written, the rules do not comply with current drafting requirements.  
Part 2 Education and Examination: Updating the information regarding approved educational programs cannot be  
achieved without a rule change.  
Part 3 Licensure: As written, the rules do not comply with current drafting requirements.  
Part 4 License Renewal Standards, Continuing Education, Sanctions for Failure to Complete Continuing Education:  
The current rules do not provide the procedural requirements to apply for a waiver of the continuing education  
requirements necessary for license renewal. This may result in the applicant not being granted the waiver he or she  
seeks.  
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.  
MCL 24.245(3)  
RIS-Page 5  
Part 1 General Provisions: Making administrative rules consistent protects the health, safety, and welfare of Michigan  
citizens by ensuring that the rules are easy to locate and read. The proposed rules do not impose any new burdens.  
Part 2 Education and Examination: Updating the information regarding approved educational programs cannot be  
achieved without a rule change, and the health, safety, and welfare of Michigan citizens are protected by ensuring that  
an applicant’s education is up to the current standards. The proposed rules do not impose any new burden.  
Part 3 Licensure: Making administrative rules consistent protects the health, safety, and welfare of Michigan citizens  
by ensuring that the rules are easy to locate and read. The proposed rules do not impose any new burdens.  
Part 4 License Renewal Standards, Continuing Education, Sanctions for Failure to Complete Continuing Education:  
The current rules will be revised to add the procedure to be followed if a licensee is requesting a waiver of the  
continuing education requirements for license renewal. The health, safety, and welfare of Michigan citizens are  
protected when a licensee stays up to date in his or her profession, or the requirements are waived in compliance with  
statute. There is no new burden imposed on the licensee as a result of the proposed rules.  
9. Describe any rules in the affected rule set that are obsolete or unnecessary and can be rescinded.  
R 339.19004 will be rescinded, and the content of the rule will be amended and relocated to R 339.19011 to comply  
with current drafting rules.  
R 339.19006 will be rescinded, and the content of the rule relocated to R 339.19013 to comply with current drafting  
rules.  
R 339.19008 will be rescinded, and the content of the rule relocated to R 339.19021 to comply with current drafting  
rules.  
R 339.19010 will be rescinded, and the content of the rule relocated to R 339.19022 to comply with current drafting  
rules.  
R 339.19012 will be rescinded, and the content of the rule relocated to R 339.19024 to comply with current drafting  
rules.  
R 339.19014 will be rescinded, and the content of the rule will be amended and relocated to R 339.19031 to comply  
with current drafting rules.  
R 339.19016 will be rescinded, and the content of the rule relocated to R 339.19034 to comply with current drafting  
rules.  
R 339.19018 will be rescinded, and the content of the rule relocated to R 339.19036 to comply with current drafting  
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).  
The proposed rules are not expected to have a fiscal impact on the agency.  
11. Describe whether or not an agency appropriation has been made or a funding source provided for any  
expenditures associated with the proposed rules.  
MCL 24.245(3)  
RIS-Page 6  
No agency appropriation has been made or a funding source provided because there are no 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.  
Part 1 General Provisions: The proposed rules do not place any burden on an individual.  
Part 2 Education and Examination: There is no new cost imposed by the proposed rules in this part. The  
accreditation standards will be updated, but there is no new burden on an individual as a result of the proposed rules.  
Part 3 Licensure: The proposed rules will assist a reader in locating the requirements for licensure. The proposed  
rules do not place any burden on an individual.  
Part 4 License Renewal Standards, Continuing Education, Sanctions for Failure to Complete Continuing Education:  
The proposed rules add the procedure for applying for a waiver of the continuing education requirements needed for  
license renewal. The proposed rules will assist a licensee in making the request, and they do not impose any new  
burden on an individual.  
A. Despite the identified burden(s), identify how the requirements in the rules are still needed and reasonable  
compared to the burdens.  
The proposed rules do not impose any new burdens. To the extent that the current rules impose burdens for  
completing education, examination, and continuing education, the rules are necessary to ensure that an applicant for  
licensure has the appropriate training, can demonstrate a minimum level of competence, and that a licensee remains  
up to date in his or her knowledge and training. There is no less burdensome way to ensure the health, safety, and  
welfare of Michigan citizens.  
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 anticipated increases or reductions for other state or local governmental units as a result of the proposed  
rules.  
14. Discuss any program, service, duty, or responsibility imposed upon any city, county, town, village, or school  
district by the rules.  
There are no anticipated or intended programs, services, duties, or responsibilities imposed on any city, town, village,  
or school district as a result of these proposed rules.  
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 anticipated actions that a governmental unit must take to comply with the proposed rules.  
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 have been made to any governmental units as a result of the proposed rules. No additional  
expenditures are anticipated or intended with the proposed rules.  
Rural Impact  
16. In general, what impact will the rules have on rural areas?  
The proposed rules impose requirements on individual licensees rather than small businesses. Even if a licensee’s  
workplace qualifies as a small business, the department could not exempt the licensee’s business because it would  
create a disparity in the regulation of the profession.  
MCL 24.245(3)  
RIS-Page 7  
A. Describe the types of public or private interests in rural areas that will be affected by the rules.  
The proposed rules will not impact public or private interests in rural areas.  
Environmental Impact  
17. Do the proposed rules have any impact on the environment? If yes, please explain.  
The proposed rules do not have any impact on the environment.  
Small Business Impact Statement  
18. Describe whether and how the agency considered exempting small businesses from the proposed rules.  
The department did not consider exempting small businesses because they are not impacted by the proposed rules.  
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 rules cannot exempt small businesses because the rules do not directly regulate small businesses. The rules  
regulate individual licensees. Further, the Michigan Occupational Code requires landscape architects to be licensed.  
A. Identify and estimate the number of small businesses affected by the proposed rules and the probable effect on  
small businesses.  
There are approximately 685 landscape architects in Michigan.  
A licensee may work in a small business. However, no matter what type of business environment the licensee works  
in, the licensee will have to comply with the proposed rules. The rules do not impact small business differently  
because the impact is to the individual licensee only.  
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.  
The agency did not establish separate compliance or reporting requirements for small businesses. The proposed rules  
will apply to all landscape architect licensees. The rules were drafted to be the least burdensome on all affected  
licensees.  
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 agency did not consolidate or simplify compliance and reporting requirements for small businesses with the  
proposed rules because the proposed rules do not impact small businesses.  
D. Describe how the agency established performance standards to replace design or operation standards required  
by the proposed rules.  
The agency did not establish performance standards to replace design or operation standards required by these rules.  
20. Identify any disproportionate impact the proposed rules may have on small businesses because of their size or  
geographic location.  
The proposed rules do not impact small business. They impact an individual licensee. Therefore, there is no  
disproportionate impact on a small business because of its 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 proposed rules affect individuals applying for licensure and renewal, regardless if they practice in a small  
business. There is no separate cost to a small business.  
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.  
There are no expected costs for equipment, supplies, labor, or administrative costs that a small business would incur  
in complying with the proposed rules.  
The rules impact licensees and not small businesses.  
MCL 24.245(3)  
RIS-Page 8  
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 expected costs for legal, consulting, or accounting services that a small business 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.  
There are no expected costs to a small business that will cause economic harm to a small business or the marketplace  
as a result of the 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 proposed rules impose requirements on individual licensees rather than a small business. Even if a licensee’s  
practice qualifies as a small business, the department could not exempt the licensee’s business because it would  
create disparity in the regulation of the profession.  
Therefore, there is no cost to the agency for administering or enforcing the rules because exempting or setting lesser  
standards of compliance for a small business is not in the best interest of the public.  
26. Identify the impact on the public interest of exempting or setting lesser standards of compliance for small  
businesses.  
The proposed rules impose requirements on individual licensees rather than a small business. Even if a licensee’s  
work qualifies as a small business, the department could not exempt the licensee’s business because it would create a  
disparity in the regulation of the profession. Therefore, exempting or setting lesser standards of compliance for a  
small business is not in the best interest of the public.  
27. Describe whether and how the agency has involved small businesses in the development of the proposed rules.  
No small businesses were involved in the development of the rules.  
A. If small businesses were involved in the development of the rules, please identify the business(es).  
No small businesses were involved in the development of the rules.  
Cost-Benefit Analysis of Rules (independent of statutory impact)  
28. Estimate the actual statewide compliance costs of the rule amendments on businesses or groups.  
There are no estimated compliance costs with these rule amendments on businesses or groups.  
A. Identify the businesses or groups who will be directly affected by, bear the cost of, or directly benefit from the  
proposed rules.  
No businesses or groups will be directly affected or benefitted by the proposed rules. No additional costs will be  
imposed on any businesses or groups.  
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 any businesses or groups.  
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.  
It is estimated that there will be no new compliance costs imposed on an individual to comply with the proposed  
rules.  
A. How many and what category of individuals will be affected by the rules?  
All licensees and applicants are affected by the proposed rules.  
B. What qualitative and quantitative impact do the proposed changes in rules have on these individuals?  
The proposed rules do not impose any new costs on individuals.  
30. Quantify any cost reductions to businesses, individuals, groups of individuals, or governmental units as a result  
of the proposed rules.  
MCL 24.245(3)  
RIS-Page 9  
There are no cost reductions to businesses, individuals, groups of individuals, or governmental units as a result of the  
proposed rules.  
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 proposed rules use clear, concise language, and implement the statutory requirements for licensing. The clear,  
concise language allows the public, applicants, and licensees to better understand the requirements for licensure and  
license renewal. The addition of the procedural requirements for applying for a waiver of the continuing education  
requirements for license renewal will also benefit a licensee who has encountered difficulties in obtaining the  
necessary continuing education for license renewal.  
32. Explain how the proposed rules will impact business growth and job creation (or elimination) in Michigan.  
The rules are not expected to have an impact on business growth, job creation, or job elimination in Michigan.  
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 department does not expect any individuals or businesses to be disproportionately impacted 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.  
Indiana: http://iga.in.gov/legislative/laws/2020/ic/titles/025#25-4-2; http://iac.iga.in.gov/iac//T08040/A00011.PDF?  
Administrative Regulations • Legislative Research Commission  
file=/secure/pacode/data/049/chapter15/chap15toc.html&d=;  
https://www.dos.pa.gov/ProfessionalLicensing/BoardsCommissions/LandscapeArchitects/Documents/Board%  
20Documents/Law.pdf  
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.  
Since the rules are required by statute, no estimates were made.  
Alternative to Regulation  
35. Identify any reasonable alternatives to the proposed rules that would achieve the same or similar goals.  
Since the rules are required by statute, there are no reasonable alternatives to the proposed rules.  
A. Please include any statutory amendments that may be necessary to achieve such alternatives.  
Since the rules are required by statute, a statutory change would be needed to provide an alternative.  
MCL 24.245(3)  
RIS-Page 10  
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.  
Since the rules are required by statute, private market-based systems cannot serve as an alternative. The licensing or  
registration of landscape architects are state functions, and states regulate landscape architects by statute, regulation,  
or both. Private market-based systems are not used for licensing and regulation.  
There are professional organizations that establish criteria for membership, but these organizations would provide the  
public with significantly less protection because membership in many of these organizations is voluntary. This  
means an individual who meets the membership requirements but does not join one of the professional organizations  
would be able to practice, and there would be no way to ensure their competency or hold them accountable.  
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.  
Since the rules are specifically required by statute, there are no alternatives to the proposed rules that the agency  
could consider. The rules are necessary for the administration and enforcement of the licensing process.  
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.  
The instructions for compliance are included in the rules.  
MCL 24.245(3)  
;