Michigan Office of Administrative Hearings and Rules  
Administrative Rules Division (ARD)  
MOAHR-Rules@michigan.gov  
REGULATORY IMPACT STATEMENT  
and COST-BENEFIT ANALYSIS (RIS)  
AGENCY INFORMATION:  
Department name:  
State Police  
Bureau name:  
Michigan Commission on Law Enforcement Standards (MCOLES)  
Name of person filling out RIS:  
Joseph Kempa  
Phone number of person filling out RIS:  
517-898-4219  
Email of person filling out RIS:  
KempaJ@michigan.gov  
RULE SET INFORMATION:  
ARD assigned rule set number:  
2025-20 SP  
Title of proposed rule set:  
Law Enforcement Standards and Training  
COMPARISON OF RULE(S) TO FEDERAL/STATE/ASSOCIATION STANDARDS  
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.  
Currently there are no parallel federal standards or accreditation standards that compare to this rule. Texas has  
passed S.B. No. 1852 which mandates that officers receive 16 hours of comparable training on or after 01/01/2024.  
The training mandated under PA 552 of 2018 requires licensed officers receive 8 hours of training.  
A. Are these rules required by state law or federal mandate?  
The Michigan Commission on Law Enforcement Standards (Commission) is required to promulgate this rule  
under §9e(2) of the Michigan commission on law enforcement standards act (MCOLES Act), MCL 28.609e(2).  
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 rule does not have a parallel federal standard and therefore does not exceed any federal rules.  
2. Compare the proposed rules to standards in similarly situated states, based on geographic location,  
topography, natural resources, commonalities, or economic similarities.  
The rule does not appear to have parallel standards in the surrounding states or those states that are similarly  
situated.  
A. If the rules exceed standards in those states, please explain why and specify the costs and benefits  
arising out of the deviation.  
The rule does not have parallel standards in other states and therefore do not deviate from standards in other  
states.  
3. Identify any laws, rules, and other legal requirements that may duplicate, overlap, or conflict with the  
proposed rules.  
There does not appear to be any duplication, overlap, or conflict with other legal requirements.  
MCL 24.245(3)  
RIS-Page 2  
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.  
Section 9e of the MCOLES Act mandates rule promulgation establishing the minimum standards for active  
violence response training. The proposed rule provides that training programs in existence since January 1,  
2020, that were offered to meet the active violence response training requirement, will be reviewed by the  
Commission and evaluated for validation as an authorized in-service law enforcement training that meets the  
statutory mandate.  
PURPOSE AND OBJECTIVES OF THE RULE(S)  
4. Identify the behavior and frequency of behavior that the proposed rules are designed to alter.  
Section 9e of the MCOLES Act requires active violence response training that emphasizes coordinated tactical  
response to rapidly developing incidents in which intentional physical injury or death to a specific population occurs  
through the use of conventional or unconventional weapons and tactic. The rule establishes a mechanism to develop  
in-service training to improve the survivability of civilians and officers during high stress and deadly events, which are  
usually a result of a person or persons seeking to use deadly force while having access to victims to commit mass  
homicide. This training was previously not mandated.  
A. Estimate the change in the frequency of the targeted behavior expected from the proposed rules.  
Section 9e of the MCOLES Act requires an individual seeking to become licensed to complete active violence  
response training. MCL 28.609e(1). It also requires an individual who is licensed to complete the active violence  
response training. MCL 28.609e(3) The frequency of the training is not specified in the proposed rule and varies  
by agency.  
B. Describe the difference between current behavior/practice and desired behavior/practice.  
Prior to enactment of § 9e of the MCOLES Act, there was no mandated in-service training for active violence  
response training. The statute requires all individuals seeking a license and all licensed individuals complete the  
active violence response training. By attending training, the desired outcome is to improve the survivability of  
civilians and officers during high stress and deadly events, which are usually a result of a person or persons  
seeking to use deadly force while having access to victims to commit mass homicide.  
C. What is the desired outcome?  
The desired outcome is that all individuals seeking to become licensed as a law enforcement officer and all  
licensed law enforcement officers in the state of Michigan attend active violence response training to improve  
the survivability of civilians and officers during high stress and deadly events, which are usually a result of a  
person or persons seeking to use deadly force while having access to victims to commit mass homicide. As a  
result, there will be a reduction in casualties.  
5. 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 active violence response training required by § 9e of the MCOLES Act will include, at a minimum, measures to  
improve the survivability of civilians and officers during high stress and deadly events, which are usually a result of a  
person or persons seeking to use deadly force while having access to victims to commit mass homicide.  
A. What is the rationale for changing the rules instead of leaving them as currently written?  
Section 9e of the MCOLES Act mandates rule promulgation to establish minimum standards for active violence  
response training.  
6. 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.  
Nationally the incidents of active violence have increased in frequency. The rule establishes a method for approving  
in-service training that, at a minimum, will include measures to improve the survivability of civilians and officers during  
high stress and deadly events, which are usually a result of a person or persons seeking to use deadly force while  
having access to victims to commit mass homicide. This will protect the health, safety, and welfare of Michigan  
citizens.  
7. Describe any rules in the affected rule set that are obsolete or unnecessary and can be rescinded.  
The rule is being amended to address in-service training programs for active violence response training that has  
previously not been mandated until the amendment of the MCOLES Act adding § 9e.  
MCL 24.245(3)  
RIS-Page 3  
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.  
8. 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 fiscal impact includes additional staff for continued development of evolving training, as well as tracking  
compliance by licensed law enforcement officers or those seeking to become licensed law enforcement officers.  
Additionally, a module would need to be developed in the database used for tracking and reporting of licensed law  
enforcement officer training. Recurring operating expenses, such as empaneling subject matter expert groups,  
instructor training, travel, etc. would be necessary. The estimated one-time cost would be $100,000, and recurring  
costs of $300,000 per year.  
9. Describe whether or not an agency appropriation has been made or a funding source provided for any  
expenditures associated with the proposed rules.  
A one-time appropriation of $1,927,600 was granted in FY 2019 and extended as a work project through the end of  
FY 2023. An additional one-time appropriation of $1,300,000 was included in the FY 2024 budget and has been  
extended as a work project through FY 2028.  
10. 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.  
The proposed rule is necessary to meet the training mandate in § 9e of the MCOLES Act. The burden to meet the  
training mandated by § 9e of the MCOLES Act, if the training is not received, may impact an individual’s status as a  
licensed law enforcement officer. The rule would have additional fiscal impact on local and state law enforcement  
agencies for the costs associated with licensed law enforcement officers attending the training, a potential Headlee  
issue.  
A. Despite the identified burden(s), identify how the requirements in the rules are still needed and  
reasonable compared to the burdens.  
Despite the burden, the proposed rule is necessary to meet the training mandate in § 9e of the MCOLES Act.  
IMPACT ON OTHER STATE OR LOCAL GOVERNMENTAL UNITS  
11. 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.  
The rule would have a fiscal impact on local and state law enforcement agencies for the costs associated with  
licensed law enforcement officers attending the training. This includes salary and wages for officers attending the  
training plus potential overtime salary and wages for position backfill while an officer is at training. As there is no  
requirement for additional training beyond the initial mandate, the fiscal impact of the rule would cease once all  
currently licensed law enforcement officers have attended the training; all subsequently licensed officers will have  
received the training through a basic law enforcement training academy program.  
12. Discuss any program, service, duty, or responsibility imposed upon any city, county, town, village, or school  
district by the rules.  
Section 9e of the MCOLES Act requires an individual seeking a license to become licensed as a law enforcement  
officer to complete active violence response training. Individuals already licensed are also required to complete active  
violence response training. Compliance is technically at the individual level. It is anticipated that governmental units  
employing licensed law enforcement officers will have an interest in ensuring their licensed law enforcement officers  
comply.  
MCL 24.245(3)  
RIS-Page 4  
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.  
Section 9e of the MCOLES Act requires an individual seeking to become licensed as a law enforcement officer  
to complete active violence response training. Individuals already licensed are also required to complete active  
violence response training. Compliance is technically at the individual level. It is anticipated that governmental  
units employing licensed law enforcement officers will have an interest in ensuring their licensed law  
enforcement officers comply.  
13. 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.  
Expenditures for the program and associated rules are through appropriations from the General Fund of the state of  
Michigan.  
RURAL IMPACT  
14. In general, what impact will the rules have on rural areas?  
The training is specific to an individual seeking to become licensed as a law enforcement officer and licensed law  
enforcement officers. Requiring training impacts rural areas because training is traditionally offered in areas with  
higher available resources for law enforcement. The proposed rule does require the Commission to establish a review  
and evaluation procedure to validate programs in existence since January 1, 2020. This is intended to lessen the  
impact on areas with less funding.  
A. Describe the types of public or private interests in rural areas that will be affected by the rules.  
Acts of violence where a person is seeking to use deadly force while having access to victims to commit mass  
homicide have increased nationally. Rural areas are not exempted from these events. The public and private  
interest in providing in-service training that at a minimum will include measures to improve the survivability of  
civilians and officers during high stress and deadly events does not have a geographical boundary.  
ENVIRONMENTAL IMPACT  
15. Do the proposed rules have any impact on the environment? If yes, please explain.  
The rule does not have an anticipated impact on the environment.  
SMALL BUSINESS IMPACT STATEMENT  
16. Describe whether and how the agency considered exempting small businesses from the proposed rules.  
The agency did not consider exempting small businesses from the proposed rule because the training is specific to an  
individual seeking to become licensed as a law enforcement officer and licensed law enforcement officers.  
17. 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 agency did not exempt small businesses from the proposed rule because the training is specific to an individual  
seeking to become licensed as a law enforcement officer and licensed law enforcement officers.  
A. Identify and estimate the number of small businesses affected by the proposed rules and the probable  
effect on small businesses.  
Except for potentially providing a small business with increased protection by having law enforcement officers  
trained in active violence response, small businesses will not be impacted by the proposed rule.  
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.  
MCL 24.245(3)  
RIS-Page 5  
The agency did not establish differing compliance, reporting requirements, or timetables for small businesses  
because they will have no required reporting, record-keeping, or administrative costs as a result of the proposed  
rule change.  
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 or  
identify skills necessary to comply with the reporting requirements because the proposed rule does not create  
compliance or reporting requirements for small businesses.  
D. Describe how the agency established performance standards to replace design or operation standards  
required by the proposed rules.  
The agency has not established performance standards to replace design or operation standards for small  
businesses.  
18. Identify any disproportionate impact the proposed rules may have on small businesses because of their size  
or geographic location.  
The proposed rule has no disproportionate impact on small businesses because of their size or geographical location  
because the training is specific to an individual seeking to become licensed as a law enforcement officer and licensed  
law enforcement officers.  
19. 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 rule has no reporting requirement for small businesses.  
20. 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 small business costs related to the proposed rule.  
21. 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 proposed rule does not involve legal, consulting, or accounting services for small businesses.  
22. Estimate the ability of small businesses to absorb the costs without suffering economic harm and without  
adversely affecting competition in the marketplace.  
Small businesses will have no costs to absorb and thus will not suffer economic harm or affect competition in the  
marketplace.  
23. 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 agency has no estimate of cost for exempting or setting lesser standards for compliance for small businesses.  
The training is specific to individuals seeking a license as a law enforcement officer and licensed law enforcement  
officers.  
24. Identify the impact on the public interest of exempting or setting lesser standards of compliance for small  
businesses.  
There is a strong public interest in having in-service training on active violence response that at a minimum will  
include measures to improve the survivability of civilians and officers during high stress and deadly events which are  
usually a result of a person or persons seeking to use deadly force while having access to victims to commit mass  
homicide. The training is specific to individuals seeking a license as a law enforcement officer and licensed law  
enforcement officers. There are no exemptions or lesser standards for small businesses.  
25. Describe whether and how the agency has involved small businesses in the development of the proposed  
rules.  
The agency did not involve small businesses in the development of the proposed rules because the training is specific  
to individuals seeking a license as a law enforcement officer and licensed law enforcement officers.  
A. If small businesses were involved in the development of the rules, please identify the business(es).  
Small businesses were not involved in the development of the rule.  
COST-BENEFIT ANALYSIS OF RULES (INDEPENDENT OF STATUTORY IMPACT)  
MCL 24.245(3)  
RIS-Page 6  
26. Estimate the actual statewide compliance costs of the rule amendments on businesses or groups.  
The proposed rules do not impose compliance costs to 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.  
The proposed rules do not affect any businesses.  
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 rule does not impose any additional costs to businesses or groups.  
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 training required by the proposed rules will require all licensed officers in the state of Michigan to attend a  
minimum of 8 hours of training. The training is offered for free to licensed officers in the state.  
A. How many and what category of individuals will be affected by the rules?  
The proposed rule affects all persons seeking a license and all licensed law enforcement officers in the state of  
Michigan. Currently there are approximately 18,500 individuals licensed law enforcement officers in the state of  
Michigan.  
B. What qualitative and quantitative impact do the proposed changes in rules have on these individuals?  
The proposed rules would require licensed law enforcement officers, and persons seeking licensure, to attend a  
minimum of 8 hours of instruction in responding to active violence. The intent of the proposed rules is to  
increase knowledge through a combination of classroom and practical exercises to officers potentially tasked  
with responding to an active violence event.  
28. Quantify any cost reductions to businesses, individuals, groups of individuals, or governmental units as a  
result of the proposed rules.  
The proposed rules do not anticipate reduced costs to businesses, individuals, groups of individuals, or government  
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 any assumptions.  
The primary and direct benefits of the proposed rule is having law enforcement officers with in-service training that at  
a minimum will include measures to improve the survivability of civilians and officers during high stress and deadly  
events, which are usually a result of a person or persons seeking to use deadly force while having access to victims to  
commit mass homicide.  
30. Explain how the proposed rules will impact business growth and job creation (or elimination) in Michigan.  
There will be no impact on business growth or job creation (or elimination) because of the proposed rule.  
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.  
Active violence response training can improve the survivability of civilians and officers during high stress and deadly  
events. Individuals and businesses will not be disproportionately affected by the proposed rule because of the  
industrial sector, segment of the public, business size, or geographical location.  
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 proposed rules are directly related to the individual licensed officer status and training requirements. There are no  
anticipated additional financial implications or cost-benefits associated with the rules.  
A. How were estimates made, and what assumptions were made? Include internal and external sources,  
published reports, information provided by associations or organizations, etc., that demonstrate a need  
for the proposed rules.  
Estimates were not incorporated in the regulatory impact statement as no costs by businesses or individuals  
were assumed.  
MCL 24.245(3)  
RIS-Page 7  
ALTERNATIVE TO REGULATION  
33. Identify any reasonable alternatives to the proposed rules that would achieve the same or similar goals.  
No alternatives to the proposed rules have been identified.  
A. Please include any statutory amendments that may be necessary to achieve such alternatives.  
No alternatives to the proposed rules have been identified.  
34. 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.  
The rules under PA 552 of 2018 do not include a provision for private market-based system. The state of Texas does  
rely on a partnership with ALERRT (Advanced Law Enforcement Rapid Response Training Center) at Texas State  
University - San Marcos.  
35. 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.  
The Commission spent a significant amount of time determining the most effective and efficient method of  
implementing the active violence response training mandated in § 9e of the MCOLES Act. While the MCOLES Act  
specifically involves the relationship between the Commission and individuals seeking a to become a law enforcement  
officer and licensed law enforcement officers, we recognized the significant impact this would have on the agencies  
employing the officers.  
With the understanding that agencies employing the licensed law enforcement officers were significantly impacted by  
this mandate, the Commission attempted to minimize this impact by using subject matter experts in the development  
of the standards included in the mandated training. Initially it was anticipated that the active violence response training  
would be limited to officer training being offered regionally at specific locations and dates. However, to minimize the  
impact on local agencies employing licensed law enforcement officers, the Commission decided to add a mechanism  
to review, evaluate, and validate active violence response training programs in existence since January 1, 2020. Once  
validated, the agency can train in their normal training cycle, minimizing labor costs and scheduling issues.  
ADDITIONAL INFORMATION  
36. As required by MCL 24.245b(1)(c), please describe any instructions regarding the method of complying with  
the rules, if applicable.  
Basic law enforcement training academies are required to comply with the rules because the subject matter is part of  
the course of study approved by the Commission for each academy session. Law enforcement agencies can comply  
with the rules by making their licensed law enforcement officers available for the training provided by the Commission  
or by submitting agency-based training for approval by the Commission.  
MCL 24.245(3)  
;