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  
Bureau name:  
Automotive Related Businesses  
Name of person filling out RIS:  
Colleen Tulloch-Brown  
Phone number of person filling out RIS:  
517-245-3237  
Email of person filling out RIS:  
tulloch-brownc@michigan.gov  
RULE SET INFORMATION:  
ARD assigned rule set number:  
2025-66 ST  
Title of proposed rule set:  
Breath Alcohol and Ignition Interlock Devices  
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 a state or national licensing agency or accreditation  
association.  
A. Are these rules required by state law or federal mandate?  
MCL 257.625k mandates rule promulgation.  
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 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 State of Washington approves ignition interlock devices and publishes a list of approved ignition interlock  
manufacturers. The processes are similar.  
A. If the rules exceed standards in those states, please explain why and specify the costs and benefits  
arising out of the deviation.  
The rules do not exceed standards in other states.  
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 may duplicate, overlap or conflict with the proposed rules.  
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.  
There is no other 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 rules are not intended to affect behavior and frequency of behavior.  
A. Estimate the change in the frequency of the targeted behavior expected from the proposed rules.  
The rules do not affect any change in the frequency of behavior.  
B. Describe the difference between current behavior/practice and desired behavior/practice.  
There is no difference between current behavior/practice and desired behavior/practice.  
C. What is the desired outcome?  
The amendment to the rules is to update the correct area of the Department that oversees the process and to  
correct spelling errors.  
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.  
There is no harm resulting from behavior that the proposed rules are designed to alter.  
A. What is the rationale for changing the rules instead of leaving them as currently written?  
The rationale is to update the correct area of the Department that oversees the process and to correct spelling  
errors.  
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 rules provide definitions and a process for approval of ignition interlock devices and ignition interlock devices  
used by Michigan citizens. A process to approve ignition interlock devices and manufacturers is to ensure only  
approved devices are used by individuals required to operate with an ignition interlock device. The proposed rules  
are to correct typographical errors in the existing rules and update the responsible area of the department. There is  
no burden to any business, agency or individual.  
7. Describe any rules in the affected rule set that are obsolete or unnecessary and can be rescinded.  
There are no rules in the rule set that are obsolete or unnecessary.  
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).  
There is no fiscal impact on the agency.  
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 is not an agency appropriation that has been made or a funding source provided.  
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 rules do not place a burden on individuals.  
MCL 24.245(3)  
RIS-Page 3  
A. Despite the identified burden(s), identify how the requirements in the rules are still needed and  
reasonable compared to the burdens.  
The rules do not have identified burdens.  
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.  
There is no increase or decrease in revenues to other state or local government units. There are no cost increases or  
reductions to other state or local government units.  
12. Discuss any program, service, duty, or responsibility imposed upon any city, county, town, village, or school  
district by the rules.  
There is no program, service, duty, or responsibility imposed on any city, county, town, village, or school district.  
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.  
No action by government units needs to be taken.  
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 appropriation has been made, and no funding source has been provided.  
RURAL IMPACT  
14. In general, what impact will the rules have on rural areas?  
The rules will not impact rural areas.  
A. Describe the types of public or private interests in rural areas that will be affected by the rules.  
There are no public or private interests in rural areas that will be affected.  
ENVIRONMENTAL IMPACT  
15. Do the proposed rules have any impact on the environment? If yes, please explain.  
The 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 rules do not affect small businesses.  
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 rules do not affect small businesses.  
A. Identify and estimate the number of small businesses affected by the proposed rules and the probable  
effect on small businesses.  
The rules do not affect small businesses.  
MCL 24.245(3)  
RIS-Page 4  
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 rules do not affect small businesses.  
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 rules do not affect small businesses.  
D. Describe how the agency established performance standards to replace design or operation standards  
required by the proposed rules.  
The rules do not replace design or operations standards.  
18. Identify any disproportionate impact the proposed rules may have on small businesses because of their size  
or geographic location.  
The rules do not have a disproportionate impact on small businesses.  
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 rules do not require any report or cost by 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 is no cost of compliance for small businesses.  
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 is no cost to 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.  
There is no cost to small businesses.  
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.  
There is no associated cost.  
24. Identify the impact on the public interest of exempting or setting lesser standards of compliance for small  
businesses.  
There is no impact on small businesses.  
25. Describe whether and how the agency has involved small businesses in the development of the proposed  
rules.  
The rules do not impact small businesses.  
A. If small businesses were involved in the development of the rules, please identify the business(es).  
There were no small businesses involved in the development of the rules.  
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 rules do not impose any 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.  
There are no businesses or groups that will be directly affected by or 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 rules do not impose any additional costs.  
MCL 24.245(3)  
RIS-Page 5  
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.  
There are no actual statewide compliance costs of the proposed rules.  
A. How many and what category of individuals will be affected by the rules?  
The rules do not impact individuals.  
B. What qualitative and quantitative impact do the proposed changes in rules have on these individuals?  
The rules do not impact individuals.  
28. Quantify any cost reductions to businesses, individuals, groups of individuals, or governmental units as a  
result of the proposed rules.  
The rules do not have any cost reductions.  
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 rules provide guidance regarding the approval of ignition interlock devices and ignition interlock manufacturers in  
Michigan.  
30. Explain how the proposed rules will impact business growth and job creation (or elimination) in Michigan.  
The rules do not impact business growth, job creation or elimination.  
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 are no individuals or businesses who will be disproportionately affected by the rules.  
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.  
https://wsp.wa.gov/interlock  
The only changes to the proposed rules are to correct typographical errors that exist in the current version and update  
the responsible area of the Department.  
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.  
The rules are current Department practice. There were no estimates made.  
ALTERNATIVE TO REGULATION  
33. Identify any reasonable alternatives to the proposed rules that would achieve the same or similar goals.  
There are no reasonable alternatives to the proposed rules that would achieve the same or similar goals.  
A. Please include any statutory amendments that may be necessary to achieve such alternatives.  
No statutory amendments are necessary.  
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.  
Private market-based mechanisms are not feasible. The Michigan Department of State is responsible for approving  
ignition interlock devices and manufacturers.  
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.  
No alternatives were considered.  
ADDITIONAL INFORMATION  
MCL 24.245(3)  
RIS-Page 6  
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 rules.  
MCL 24.245(3)  
;