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:

Licensing and Regulatory Affairs

Bureau name:

Bureau of Construction Codes

Name of person filling out RIS:

Daniela Pelachyk

Phone number of person filling out RIS:

517-284-7738

Email of person filling out RIS:

PelachykD@michigan.gov

RULE SET INFORMATION:

ARD assigned rule set number:

2025-58 LR

Title of proposed rule set:

Skilled Trades Regulation Rules

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.

There are no parallel federal rules or standards set by state or national licensing agency or accreditation association

compared to the proposed rules.

A. Are these rules required by state law or federal mandate?

There are no federal requirements or regulations governing the skilled trades regulation rules. These rules are

mandated by state law under the authority of the Skilled Trades Regulation Act, 2016 PA 407, MCL 339.5207,

339.5209, and 339.5907.

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 any federal standard or law.

2. Compare the proposed rules to standards in similarly situated states, based on geographic location,

topography, natural resources, commonalities, or economic similarities.

All 50 states regulate skilled trades differently. Some states regulate at the state level, while others regulate at the

local level, if regulated at all. Michigan also regulates under statute; most other states regulate through boards and

directors. However, states such as California and Texas maintain comparable electrical programs. The bureau

reviewed the proposed rules against standards in similarly situated states (California, Texas, and Wisconsin), based

on regulatory scope of their electrical and plumbing programs.

California – Labor Code, Chapter 4.5 Electrician Certification, Section 108 -108.2.

Texas – Occupations Code, Title 8. Regulation of Environmental and Industrial Trades, Chapter 1305. Electricians,

Sec. 1305.155 Journeyman Electrician.

MCL 24.245(3)

RIS-Page 2

Wisconsin – Administrative Code, SPS 305.93 Journeyman Plumbers.

R 339.5151 Licenses; issuance - The bureau compared California and Texas electrical program, specifically subrule

(5) regarding similar credit towards the 8,000 hours of practical experience.

R 339.5412 Journey plumbing examinations - The bureau compared Wisconsin’s journey license examination portion

and is similar to our program.

A. If the rules exceed standards in those states, please explain why and specify the costs and benefits

arising out of the deviation.

The proposed rules do not generally exceed other states’ standards.

3. Identify any laws, rules, and other legal requirements that may duplicate, overlap, or conflict with the

proposed rules.

There are no laws, rules, or other legal requirements that duplicate, overlap, or conflict with the 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.

There are no federal, state, or local laws applicable to the same activity or subject matter.

PURPOSE AND OBJECTIVES OF THE RULE(S)

4. Identify the behavior and frequency of behavior that the proposed rules are designed to alter.

The general purpose of the proposed rules is to update, streamline, and clarify the regulatory framework governing

skilled trades license-related activities. The proposed rules are intended to establish clear and consistent fees,

experience requirements, and administrative processes for registrations, licenses, and examination applications.

These updates aim to improve regulatory transparency, enhance administrative efficiency, and ensure consistency in

the application and enforcement of skilled trades requirements.

Additional amendments address requirements for continuing education and clarify procedures related to complaint

handling and resolution. The proposed rules also incorporate editorial and administrative updates to improve

readability, eliminate ambiguity, and ensure consistency with current departmental practices.

Furthermore, the proposed rules rescind the boiler rules currently contained in the Skilled Trades Regulation Rules

ruleset (R 339.5201 through R 339.5253). In accordance with statutory authority, the department, in consultation with

the board, is required to promulgate rules governing the safe construction, installation, inspection, alteration,

servicing, operation, and repair of boilers in this state. This rescission is intended to support the transition of boiler-

related provisions into a separate, dedicated ruleset aligned with statutory requirements.

R 339.5114 (4) License examination; minimum grade. – This rule establishes the minimum grade requirement for

license examinations and includes provisions intended to encourage applicants to attend their scheduled exam

sessions. The purpose of this rule is to reduce the number of missed or unused examination slots, which limit

availability for other applicants and create inefficiencies in exam administration. The bureau experiences

approximately two to three instances per examination cycle each month in which scheduled candidates do not

appear. The proposed penalization changes are expected to decrease these occurrences, improve resource

utilization, and increase exam access for other applicants.

R 339.5115 (3) Minimal standards. – This rule is intended to provide clarity regarding expectations between

homeowners and contractors. The purpose of this rule is to ensure that work is completed in a manner consistent with

agreed-upon standards and contracting requirements, thereby reducing misunderstandings related to project scope

and quality. Based on the bureau’s annual complaint data – approximately 116 complaints per year – many disputes

arise from differing expectations between parties. The clarification provided in this rule is expected to reduce the

number of such complaints and improve overall compliance and consumer satisfaction.

MCL 24.245(3)

RIS-Page 3

R 339.5116 (2) & (3) Renewal for licensure application. – This rule establishes the renewal requirements for licensure

to ensure consistency with category of licensure across both the act and the rules. Current renewal provisions differ

from those applied to other skilled trades, creating inconsistency in regulatory treatment. The proposed changes are

intended to align renewal requirements, reduce the fees that licensees are required to pay, and streamline the

administrative process for both applicants and the bureau. The bureau receives approximately 1,290 electrical

apprentice renewal applications after August 31, 2025, and the clarified and aligned renewal framework is expected to

improve processing efficiency and reduce administrative burden for both applicants and the department.

R 339.5309 Mechanical inspector qualifications. – This rule revises the qualifications for mechanical inspectors to

expand opportunities for individuals to obtain registration. The intent of this rule is to reduce the number of required

classifications needed for eligibility, thereby addressing barriers that have limited entry into the mechanical inspection

field. This change is expected to support industry’s needs by increasing the pool of qualified inspectors. The bureau

currently denies approximately 20 applicants per year due to the existing classification requirements; the proposed

revisions are anticipated to lower this number and facilitate a more efficient and accessible pathway to inspector

registration.

A. Estimate the change in the frequency of the targeted behavior expected from the proposed rules.

The anticipated change in the frequency of the targeted behavior expected in R 339.5114 includes a reduction

in missed examination slots as a result of the added language in subrule (4). While the exact decrease is

uncertain, the strengthened penalty provision is expected to improve attendance and reduce the current

average of two to three no-shows per examination cycle each month. This improvement will increase exam

availability and support more efficient use of testing resources.

The anticipated change in the frequency of the targeted behavior expected in R 339.5115 (3) is intended to

clarify expectations between the homeowners and contractors to ensure work is completed in accordance with

agreed-upon standards. Based on the bureau’s annual data – approximately 116 complaints per year – many

disputes stem from differing expectations about project scope and quality. By establishing clearer requirements,

the added language is expected to reduce the frequency of such complaints and improve overall compliance

and consumer satisfaction.

The anticipated change in the frequency of the targeted behavior expected in R 339.5116 (2) and (3) aligns

renewal requirements with those applied to other skilled trades, creating consistency across the act and the

rules. The changes are expected to reduce fees for licensees and streamline the renewal process. The bureau

receives approximately 1,290 electrical apprentice renewal applications after August 31, 2025, and improved

clarity and alignment are expected to reduce processing delays and decrease the frequency of renewal-related

errors or resubmissions.

The anticipated change in the frequency of the targeted behavior expected in R 339.5309 revises the

qualifications for mechanical inspectors to expand access to registration by reducing the number of required

classifications. These changes are intended to address barriers that have limited entry into the field and better

support industry needs. The bureau currently denies approximately 20 applicants per year under the existing

requirements. By simplifying the qualification criteria, the proposed rule is expected to decrease the frequency

of these denials and provide a more accessible and efficient pathway to inspector registration.

B. Describe the difference between current behavior/practice and desired behavior/practice.

The current regulatory structure is inconsistent, while the proposed rules will create consistent license-related

activities and framework by regulating the skilled trades with one consolidated ruleset. The proposed changes

also rescind the boiler code rules (R 339.5201 through R 339.5253) from the Skilled Trades Regulation Rules

ruleset to support the transition of boiler-related provisions into a separate, dedicated ruleset. This change

aligns the bureau’s regulations with statutory requirements and facilitates updates tied to the boiler code cycle.

C. What is the desired outcome?

The desired outcome for the proposed rules is to update, streamline, and clarify the regulatory framework

governing skilled trades licensing activities. Additionally, the rules seek to enhance regulatory consistency by

establishing clear and uniform fees, experience requirements, and application procedures for registrations,

licenses, examinations, and related administrative processes.

MCL 24.245(3)

RIS-Page 4

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 proposed rules are intended to regulate certain occupations in the skilled trades and to regulate persons and

activities related to those occupations by mandating compliance with industries best practices concerning experienced

requirements, application procedures for registrations, licenses, examinations, and related administrative procedures.

A. What is the rationale for changing the rules instead of leaving them as currently written?

The rationale for changing the proposed rules and not leaving them as written is to update the rules and bring

Michigan in line with the industry’s best practices and streamline and clarify the regulatory framework governing

skilled trades license-related activities.

The rules also rescind the boiler rules (R 339.5201 to R 339.5253) to better align with statutory authority.

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.

The proposed rules protect the health, safety, and welfare of Michigan citizens while promoting a regulatory

environment that reflects the least burdensome alternative for those required to comply. They accomplish this by

reducing restrictive licensing requirements and establishing clearer standards, which are expected to lower barriers to

license-related activities, decrease complaints, and improve overall compliance and consumer satisfaction.

7. Describe any rules in the affected rule set that are obsolete or unnecessary and can be rescinded.

The following rules in the affected rule set that are obsolete or unnecessary and can be rescinded are listed below:

R 339.5113, License Classification, is being rescinded, and its provisions are being relocated to R 339.5161 to place

the language in the appropriate section of the ruleset.

R 339.5172 Out-of-state applicant for licensure in this state, is being rescinded because Michigan does not have an

out-of-state applicant licensure, and the provision does not align with existing statutory or regulatory requirements.

The bureau has determined that this rule is unnecessary and was likely included in error. It’s removal with improve

clarity and consistency with the ruleset.

R 339.5201 to R 339.5253, Subpart B. Boiler Inspectors, installers, repairers, operators, and stationary engineers is

being rescinded to support the transition of boiler-related provisions into a separate, dedicated ruleset aligned with

statutory requirements. The new ruleset is being created to eliminate any conflict or duplication with the existing boiler

provisions in the Skilled Trades Regulation 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.

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 bureau does not anticipate any fiscal impact resulting from the proposed rules. The licensure and examination fee

adjustments, which include a 10 percent increase due to inflation, are expected to produce a slight revenue gain of

$5,000 for the bureau.

9. Describe whether or not an agency appropriation has been made or a funding source provided for any

expenditures associated with the proposed rules.

There has been no agency appropriation made for any expenditures associated with the proposed rules; however, in

the skilled trades regulation act is an agency appropriation, which funds the continuous operation of the licensing

operations.

MCL 24.245(3)

RIS-Page 5

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 set supports the department's mission statement to protect individuals and promote business. The

proposed rule set relieves some of the burdens that individuals have had in attempting to become licensed, while still

protecting the skilled trades.

The rule changes are designed to make it easier for individuals to obtain licensure in the skilled trades. By reducing

unnecessary barriers, more people can enter these professions, which supports small business growth and increases

the availability of essential services for Michigan residents. The only added cost for newly eligible applicants is the

standard licensing fees related to applying, testing, and renewing their licenses. Fees are established at rates to offset

the agency’s administrative costs.

The costs for code update courses are a necessary burden as licensed individuals need to remain capable of

ensuring code compliance to protect citizen health, safety, and welfare.

A. Despite the identified burden(s), identify how the requirements in the rules are still needed and

reasonable compared to the burdens.

The proposed rule set supports the department’s mission to protect individuals and promote business. The

revisions reduce certain burdens for those seeking licensure while maintaining the integrity of the skilled trades.

For example, under R 339.5116, the registration fee has been reduced to align with other apprentice fees and

to streamline processes across all trades.

Fee adjustments in R 339.5176 for licenses and examinations are due to inflation. Overall, the proposed rules

provide needed clarification, streamline the experience timeline, help hold no shows accountable, and promote

consistency throughout all trades while protecting the citizens of Michigan.

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 proposed rules do not affect state or local government revenues or costs.

12. Discuss any program, service, duty, or responsibility imposed upon any city, county, town, village, or school

district by the rules.

The proposed rules do not impose any duty or responsibility on any city, county, town, village, or school district

beyond what is already required by law and industry standards.

The act already mandates the regulation of certain occupations in the skilled trades and licensing authority. The

proposed rules do not add new responsibilities at the local government level.

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.

The proposed rules do not require any additional or new responsibilities on behalf of government units to be in

continued compliance with the rule beyond what is already required by law and industry standards.

The act already mandates the regulation of certain occupations in the skilled trades and regulates persons and

activities relative to those occupations. The proposed rules clarify the scope of licensing authority but do not

create new obligations.

MCL 24.245(3)

RIS-Page 6

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.

No, the proposed rules do not require any additional funds for state or local governmental units.

No new staff will be required, and there are no added salary or benefit costs. The rule changes are expected to

reduce restrictive licensing requirements without raising operational expenses.

RURAL IMPACT

14. In general, what impact will the rules have on rural areas?

With the reduction of licensing restrictions, rural areas will be afforded better opportunities to hire qualified inspectors.

A. Describe the types of public or private interests in rural areas that will be affected by the rules.

Residents in rural areas will receive faster service for permitting and inspections.

ENVIRONMENTAL IMPACT

15. 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

16. Describe whether and how the agency considered exempting small businesses from the proposed rules.

The bureau did not consider exempting small businesses because the skilled trades rules are intended to regulate all

licensees consistently, regardless of business size.

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 bureau administers rules related to license related activities, including licensing fees and examination

requirements, in accordance with the Skilled Trades Regulation Act. Small businesses are not expected to be

adversely affected by the proposed changes, as the revisions primarily provide greater clarity and alignment within the

ruleset. The bureau is unable to exempt small businesses from these requirements, as the rules apply uniformly to all

regulated entities. The bureau does not anticipate any negative impact on small businesses as a result of these rule

changes.

A. Identify and estimate the number of small businesses affected by the proposed rules and the probable

effect on small businesses.

The bureau is unable to exempt small businesses from these requirements, as the rules apply uniformly to all

regulated entities. The bureau does not anticipate any negative impact on small businesses as a result of these

rule changes.

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 bureau did not establish differing compliance or reporting requirements or timetables for small businesses

under the rules.

MCL 24.245(3)

RIS-Page 7

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 bureau did not establish differing compliance or reporting requirements or timetables for small businesses

under the rules.

D. Describe how the agency established performance standards to replace design or operation standards

required by the proposed rules.

There are no performance standards to replace design or operation standards required in the proposed rules.

18. Identify any disproportionate impact the proposed rules may have on small businesses because of their size

or geographic location.

There are no disproportionate impacts on small businesses based on size or geographic location.

19. Identify the nature of any report and the estimated cost of its preparation by small businesses required to

comply with the proposed rules.

There are no anticipated reports or increased costs to small businesses that are required to comply with the proposed

rules.

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 costs of compliance for small businesses by the proposed rules, including costs of equipment, supplies,

labor, and increased administrative costs.

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.

There are no expected costs for legal, consulting, or accounting services that small businesses would incur in

complying with the proposed rules.

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 are not expected to absorb any costs based on the proposed rules.

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.

Small businesses are not expected to absorb any costs under the proposed rules. In fact, it would likely be more

costly for the agency to devote staff time to identifying which licensees work for small businesses and enforcing

separate requirements for those individuals.

24. Identify the impact on the public interest of exempting or setting lesser standards of compliance for small

businesses.

The bureau did not identify the impact on the public interest of exempting or setting lesser standards of compliance for

small businesses due to the fact that the bureau administers rules related to license related activities, including

licensing fees and examination requirements, in accordance with the Skilled Trades Regulation Act.

Applying different requirements to small businesses would compromise public safety. These trades follow national

codes, varying standards between small and large businesses could result in inconsistent installations and services in

residential settings, creating potential safety risks. Small businesses are not expected to be adversely affected by the

proposed changes, as the revisions primarily provide greater clarity and alignment within the ruleset.

25. Describe whether and how the agency has involved small businesses in the development of the proposed

rules.

The bureau engaged small businesses in the rules review process. An email notification was distributed to

stakeholders and licensees with a rule and code proposal form, providing four weeks to submit suggested changes. In

addition, the bureau also engaged small businesses and individuals by notifying the skilled trades industry and

licensees (mechanical, plumbing, electrical, boiler) of a public advisory meeting at which individuals and businesses

were able to discuss changes and make comments on the proposed rules.

A. If small businesses were involved in the development of the rules, please identify the business(es).

MCL 24.245(3)

RIS-Page 8

Small businesses were not excluded from participating in the proposed rules; however, the following licensees,

contractors, corporations, building officials, industry representatives, and other individuals were involved:

Michigan Air Conditioning Contractors Association, Mid-City Supply Company, Professional Code Services, City

of Lansing, City of Grand Rapids, and Dean Boiler Inc.

COST-BENEFIT ANALYSIS OF RULES (INDEPENDENT OF STATUTORY IMPACT)

26. Estimate the actual statewide compliance costs of the rule amendments on businesses or groups.

The proposed rules are necessary to align with the Skilled Trades Regulation Act and are consistent with the Cutting

Red Tape Report, which outlines 80 recommendations across LARA to make professional licensing more efficient,

transparent, and accessible. By supporting reforms that reduce barriers to licensure, improve customer experience,

and meet workforce needs, these rules advance both public protection and business growth. They are not expected to

impose any statewide compliance costs on businesses or other affected groups.

A. Identify the businesses or groups who will be directly affected by, bear the cost of, or directly benefit

from the proposed rules.

Individuals will benefit from the proposed rules through reduced restrictions on licensing requirements, which

will lower barriers to entry and expand employment opportunities in the skilled trades. These changes will also

support local governments by increasing the number of licensed professionals available for hire, strengthening

their ability to ensure public safety through proper inspections. Individuals licensed under the Skilled Trades

Regulation Act will bear the costs of licensing and code update courses.

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.

There will be no additional costs imposed on businesses or other groups as a result of the proposed 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 align with the Skilled Trades Regulation Act and are not expected to increase statewide

compliance costs for most individuals, who will continue paying the standard application and licensing fees. The main

new statewide compliance costs involve required code update courses for mechanical contractors, totaling an

estimated $800,000 every three years, and an annual increase of about $20,000 for boiler licensees. Additional

statewide compliance costs for provisional inspector registrations are expected to be minimal, estimated at under

$5,000 per year.

A. How many and what category of individuals will be affected by the rules?

Approximately 73,600 individuals would be affected under the following trades: Boiler, Mechanical, Building

Officials, Plan Reviewers, Inspectors, Electrical, and plumbing.

B. What qualitative and quantitative impact do the proposed changes in rules have on these individuals?

The qualitative impact is fewer licensing restrictions providing more employment opportunities. The quantitative

impact will be affected by the rules is an increase in licenses issued by the department which includes an

estimated $800,000 every three years for mechanical contractors, an annual $20,000 increase for boiler

licensees, and less than $5,000 per year in additional costs for provisional inspector registrations.

28. Quantify any cost reductions to businesses, individuals, groups of individuals, or governmental units as a

result of the proposed rules.

The proposed rules will not result in additional fiscal burden for any of the parties involved. The proposed rules are

intended to alleviate and reduce restrictive requirements on individuals to obtain licensing and late fee decrease in R

339.5116(2).

No cost reductions are anticipated, as individuals, businesses, and other affected groups are required to comply with

the Skilled Trades Regulation Act and must continue to meet its established licensing and regulatory requirements.

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.

MCL 24.245(3)

RIS-Page 9

Direct and indirect qualitative benefits would be to provide more opportunities for individuals to become licensed as

inspectors/plan reviewers. Direct and indirect quantitative benefits would be an increase in licensed individuals and

provide reductions in barriers to licensures, streamlines processes and ensures consistency, and better serves all

affected, through increased employment opportunities and reductions in labor costs.

30. Explain how the proposed rules will impact business growth and job creation (or elimination) in Michigan.

The proposed rules are expected to positively impact business growth and job creation in Michigan, particularly within

Part 10. Updated requirements for building officials, inspectors, and plan reviewers will help increase the pool of

qualified applicants and support the filling of vacancies that currently remain unfilled throughout the state. By

improving access to these positions, the rules are anticipated to strengthen workforce capacity and better meet

industry and community needs.

Those benefiting from the proposed rule set will have clearer direction in how to advance in their careers, creating a

more competitive, yet secure job market through improved licensing processes and more appropriate requirements to

fit the needs of the industries.

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.

The bureau does not expect any individuals or businesses to be disproportionately affected by the proposed rules.

The proposed rules do not include exemptions or reduced standards for any individuals or businesses, as uniform

safety compliance is essential across the industry, regardless of their industrial sector, segment of the public,

business size, or geographic 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 bureau relied upon bureau staff and rules/code proposal forms that the bureau received as the form asks for

justification for the change they are proposing, including determining the existence and extent of the impact of the

proposed rules and the cost benefit analysis of these proposed rules.

The bureau relied on input from bureau staff and on the rule and code proposal forms submitted during the review

process, which require stakeholders to justify proposed changes and explain anticipated impacts and cost benefit

considerations. The bureau also relied on the Cutting the Red Tape Report, which provides recommendations to

improve efficiency, transparency, and accessibility in professional licensing. Together, this information helped the

bureau evaluate the need for and potential effects of the proposed rules.

Cutting Red Tape Report in Michigan –

https://www.michigan.gov/lara/news-releases/2025/02/27/cutting-red-tape-in-michigan

The bureau also compared the following proposed rules to standards in similarly situated states (California, Texas,

and Wisconsin) based on similar regulatory scope:

California – Labor Code, Chapter 4.5 Electrician Certification, Section 108 -108.2

https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=LAB&division=1.&title=

art=&chapter=4.5.&article

Texas – Occupations Code, Title 8. Regulation of Environmental and Industrial Trades, Chapter 1305. Electricians,

Sec. 1305.155 Journeyman Electrician

https://statutes.capitol.texas.gov/?tab=1&code=OC&chapter=OC.1305&artSec=

Wisconsin – Administrative Code, SPS 305.93 Journeyman plumbers

https://docs.legis.wisconsin.gov/code/admin_code/sps/safety_and_buildings_and_environment/301_319/305/ix/93

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 developed using current licensing totals and projected costs from comparable programs and

assuming consistent application levels in future years. In addition to considering statutory requirements and

MCL 24.245(3)

RIS-Page 10

public input, the bureau relied on information provided by licensees, contractors, corporations, building officials,

industry representatives, and other participants in the public advisory meeting, including the Michigan Air

Conditioning Contractors Association, Mid-City Supply Company, Professional Code Services, the City of

Lansing, the City of Grand Rapids, Dean Boiler Inc., and Historical Boilers.

ALTERNATIVE TO REGULATION

33. Identify any reasonable alternatives to the proposed rules that would achieve the same or similar goals.

No reasonable alternatives to the proposed rules have been identified that would achieve the same or similar goals.

A. Please include any statutory amendments that may be necessary to achieve such alternatives.

There are no statutory amendments that may be necessary to achieve such alternatives in the proposed rules.

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.

Establishment of a regulatory program operating through private market-based mechanisms similar to the proposed

rules would not be feasible, as licensing by the bureau is the primary obligation as required under the Skilled Trades

Regulation Act. Licensing regulation nationwide is government-based and there are no known private market-based

systems utilized.

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.

Significant alternatives the bureau considered in the rule development were reverting back to existing rule language

regarding required minimum hours of continuing education for electricians based on conversations with the general

public and national organization members.

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.

There are no instructions regarding the method of complying with the proposed rules.

MCL 24.245(3)