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The proposed rules reference federal standards used throughout the MAPCR which impact a wide range of industry
statewide, including but not limited to coating processes, consumer products, and architectural and industrial
maintenance coating manufacturers, that will be directly affected by, bear the cost of, or directly benefit from the
proposed rules.
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.
The proposed rules themselves are references to materials adopted throughout the MAPCR. The rules where these
references are utilized will dictate needs for new equipment, supplies, labor, accounting, and recordkeeping.
Therefore, additional costs from these proposed rules in Part 9 are difficult to quantify. As previously mentioned,
many of the revisions will not result in additional costs for businesses and other groups beyond the small increases in
publication prices to purchase copies, if applicable. The CTG and OTC Model Rule references adopted within these
proposed rules may require businesses to install new control equipment or reformulate their products, adding
additional costs.
Businesses impacted by the proposed rules cover a large variety of source types and categories regulated through the
AQD. However not all will be impacted by additional costs, generally only ones regulated under the CTG and OTC
model rules will see additional costs. An estimated 30% of facilities statewide report VOC emissions, of which only a
subset would be impacted by the CTG and OTC model rules.
27. 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 have small increases in the publication prices for a few existing reference materials and added a
few new reference materials, which cost anywhere from $0.00 to $74.00. These publications may have been
purchased by individuals in the past so it is unknown how many will need to purchase after the promulgation of these
rules.
A. How many and what category of individuals will be affected by the rules?
The proposed rules will affect the category of individuals who must comply with the MAPCR.
B. What qualitative and quantitative impact do the proposed changes in rules have on these individuals?
The proposed changes in rules provide information on how individuals can purchase materials referenced in the
MAPCR, if needed. Publication costs range from $0.00 to $220.00.
28. Quantify any cost reductions to businesses, individuals, groups of individuals, or governmental units as a result
of the proposed rules.
The proposed rules are not expected to have any cost reductions to businesses, individuals, groups of individuals, or
governmental units.
29. 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 of the proposed rules is to update adoption by reference information which supports the
MAPCR. The secondary or indirect benefit of the proposed rules is the increased level of clarity to help support
interpretation of the MAPCR.
30. Explain how the proposed rules will impact business growth and job creation (or elimination) in Michigan.
The proposed rules are expected to have negligible effect on business growth and job creation in Michigan.
31. 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.
There is not expected to be a disproportionate impact on any sector because the standards would apply uniformly to
the entire regulated community in Michigan.
32. 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 agency relied upon statistical analysis to determine averages of the publication price increases and ranges of
document prices resulting from the proposed rules.
MCL 24.245(3)