STATE OF MICHIGAN  
DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS  
LANSING  
GRETCHEN WHITMER  
GOVERNOR  
MARLON I. BROWN, DPA  
DIRECTOR  
March 3, 2026  
Sent Via Email  
Dale Shaw  
Regulatory Affairs Officer  
Michigan Department of Environment, Great Lakes, and Energy  
Ms. Dale Shaw:  
On October 1, 2025, the Department of Environment, Great Lakes, and Energy (EGLE)  
submitted a Request to Withdraw with Permission the rule set entitled “Sewerage Systems”  
(2024-52 EQ). The Joint Committee on Administrative Rules (JCAR) granted EGLES request  
on October 1, 2025.  
Pursuant to section 45c(3) of the Administrative Procedures Act of 1969, 1969 PA 306, MCL  
24.245c, MOAHR reviewed the rules as changed and has determined that the regulatory impact  
or the impact on small businesses of the rules as changed would not be more burdensome than  
the regulatory impact or the impact on small businesses of the rule as originally proposed.  
Therefore, a second public hearing is not required.  
The changes to the “Sewerage Systemsrule set include clarifying the definitions of “combined  
sewer system” and “retention treatment basin”; adding references to “collection system,”  
“treatment,” “treatment works,” and “treatment facility” throughout the rules; adding “retain and”  
to the description of class RTB; changing “shall” to “must”; adding a subrule to align the  
proposed collection system certification requirements with existing wastewater treatment plant  
certification requirements; correcting a web address; changing “this” to “the”; and changing  
“rules” to “rule.These changes result in no impact on the burden placed on regulated  
individuals or entities.  
There are also changes that reduce licensing requirements for operator certification by  
removing college education requirements, removing a requirement for active participation in not  
less than 4 discharge events, removing an examination requirement, and increasing a timeline  
for department notification from 90 days to 2 years. MOAHR has determined that the regulatory  
impact and the impact on small businesses would not be more burdensome as a result of all of  
these changes, as the changes reduce the regulatory impact on regulated individuals and  
entities by making licensure less burdensome to obtain.  
Please contact our office with any questions regarding this determination.  
Sincerely,  
MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES  
611 W. OTTAWA • P.O. BOX 30695 • LANSING, MICHIGAN 48909-8195  
www.michigan.gov/lara PHONE: (517) 335-2484 • FAX: (517) 335-6696  
LARA is an equal opportunity employer/program.  
Emily Leik  
Departmental Specialist, Administrative Rules Division  
Michigan Office of Administrative Hearings and Rules  
cc: Suzanne Sonneborn, Executive Director, MOAHR  
STATE OF MICHIGAN  
DEPARTMENT OF  
ENVIRONMENT, GREAT LAKES, AND ENERGY  
INFORMATION MANAGEMENT DIVISION  
GRETCHEN WHITMER  
PHILLIP D. ROOS  
GOVERNOR  
DIRECTOR  
February 26, 2026  
VIA EMAIL  
Michigan Department of Licensing and Regulatory Affairs  
Michigan Office of Administrative Hearings and Rules  
Administrative Rules Division  
611 West Ottawa Street  
Lansing, Michigan 48933  
Dear Administrative Rules Division:  
SUBJECT: Review of Proposed Changed Rules; Sewerage Systems, 2024-052 EQ  
On July 30, 2025, the Michigan Office of Administrative Hearings and Rules’  
Administrative Rules Division submitted the 2024-052 EQ Sewerage Systems rules to  
the Joint Committee on Administrative Rules (JCAR). On September 3, 2025, JCAR  
held a committee meeting to discuss the 2024-052 EQ rule set. During that meeting,  
JCAR asked the Michigan Department of Environment, Great Lakes, and Energy  
(EGLE) several questions, including why certain municipalities and communities were  
not involved in the stakeholder process.  
After further internal discussion and consideration, EGLE requested to withdraw the  
rules from JCAR, with permission, to expand stakeholder involvement and input. JCAR  
granted this withdrawal with permission on October 1, 2025.  
In response to JCAR’s questions and comments, EGLE held a public webinar on  
November 20, 2025, which was advertised to over 66,000 individuals via GovDelivery.  
More than 1,000 individuals registered for the webinar, and approximately 700 attended.  
During the webinar, EGLE announced that anyone interested in participating in the  
expanded stakeholder group should contact [email protected] by  
December 12, 2025.  
EGLE subsequently held two expanded stakeholder meetings on January 8, 2026, and  
February 5, 2026, to further discuss the proposed rules. As a result of these meetings,  
EGLE made the following edits to the rules:  
Impact Key:  
M Edit makes the rule more burdensome  
L Edit makes the rule less burdensome  
C Edit is neutral or used for clarification purposes  
DEBORAH A. STABENOW BUILDING  
525 WEST ALLEGAN STREET  
P.O. BOX 30457 LANSING, MICHIGAN 48909-7957  
Michigan.gov/EGLE 800-662-9278  
SUBJECT: Review of Proposed Changed Rules; Sewerage Systems, 2024-052 EQ  
Page 2  
February 26, 2026  
Rule Number and Citation  
Changed  
Agency Rationale for Rule Change and  
Description of Change(s)  
Impact  
1.  
2.  
R 299.2903(d)  
Removed “to a publicly owned treatment works for  
treatment prior to discharge to surface waters”  
from the definition of combined sewer system for  
clarification.  
Added references to and collection system,” “or  
collection system,and “treatment” to ensure  
facility classification and operator certification  
requirements apply to collection systems as well  
C
R 299.2903(h), R 299.2903(m),  
R 299.2903(p), R 299.2911(1),  
R 299.2911(6), R 299.2912(1),  
R 299.2916, R 299.2920(2),  
C
C
R 299.2922(1)(c), R 299.2922(3), as treatment systems. These additions also clarify  
R 299.2924(1), R 299.2926(1),  
R 299.2952(1), and  
R 299.2952(2)  
the distinction between collection systems and  
treatment facilities under the current rules.  
3.  
4.  
R 299.2903(m)  
Changed “collect” to “retain”; and “overflows” to  
“domestic and industrial wastes and stormwater” in  
the definition of retention treatment basin for  
clarification.  
Added “and collection system” to include the  
proposed operator certification and facility  
classification requirements.  
Added “retain and” to description of class RTB for  
accuracy.  
Updated treatment worksto treatment facilityfor  
consistency and clarification per removal of  
R 299.2903(o).  
Part 2. Treatment Facility  
Classification and Operator  
Certification  
C
C
C
L
5.  
6.  
R 299.2911(5)  
R 299.2916  
7.  
R 299.2918(h)(ii)  
Removed “and actively participated in not less than  
4 discharge events.”  
SUBJECT: Review of Proposed Changed Rules; Sewerage Systems, 2024-052 EQ  
Page 3  
February 26, 2026  
Rule Number and Citation  
Changed  
Agency Rationale for Rule Change and  
Description of Change(s)  
Impact  
8.  
R 299.2918(i), R 299.2918(j),  
R 299.2918(k), and R 299.2918(l)  
Class C1  
o Removed college education requirement and  
sequential licensing requirement.  
o Added high school requirement (assumed in  
previous draft).  
o Work experience is now the only  
requirement.  
Class C2  
o Removed college education requirement and  
sequential licensing requirement.  
o Added high school requirement (assumed in  
previous draft).  
o Work experience is now the only  
requirement.  
Class C3  
L
o Removed sequential licensing requirement.  
Class C4  
o Added high school requirement (assumed in  
previous draft).  
o Work experience changed from 6 months to  
one year for consistency with other  
classification requirements.  
Removing college education and sequential  
licensing requirements reduces the burden on the  
regulated community while maintaining appropriate  
standards through work experience and high  
school education requirements.  
9.  
R 299.2925(17)  
Added subrule to align proposed collection system  
certification requirements with existing wastewater  
treatment plant certification requirements.  
Changed “shall” to “must” for correction and  
consistency.  
C
C
10. R 299.2925a(1)  
SUBJECT: Review of Proposed Changed Rules; Sewerage Systems, 2024-052 EQ  
Page 4  
February 26, 2026  
Rule Number and Citation  
Changed  
Agency Rationale for Rule Change and  
Description of Change(s)  
Impact  
11. R 299.2925a(1)(c),  
Revised section to allow site-specific, restricted  
certification for operators working in collection  
systems without examination, provided the  
outlined certification experience requirements  
are met.  
R 299.2925a(2),  
R 299.2925a(2)(a),  
R 299.2925a(2)(b), and  
R 299.2925a(3)  
Added subrule clarifying that certification  
renewal requirements must be met, even for  
site-specific restricted certifications.  
Removed the “strike-through” from (1) when  
adding (2) and (3).  
L
Increased the timeline for department  
notification from 90 days to two years.  
Removing the examination requirement reduces  
burden on the regulated community.  
12. R 299.2935(2)  
13. R 299.2953 and R 299.2959(2)  
Corrected Ten States Standards webpage link.  
Changed “this” back to “the” for “waters of the  
state” for accuracy. Using “this” changes the  
context of the statement and is incorrect.  
Changed “rules” to “rule” for consistency.  
C
C
C
14. R 299.2960  
EGLE believes these proposed changes, resulting from the expanded stakeholder  
process, will lessen the regulatory impact and the impact on small businesses. We  
respectfully request that, following your review of the proposed changes, you issue a  
formal determination regarding whether these edits reduce regulatory impact and the  
impact on small businesses.  
Thank you for your time and attention to this matter. We greatly appreciate your  
consideration and look forward to receiving your determination. Should you have any  
questions or require additional information, please do not hesitate to contact me at  
517-599-8365 or [email protected].  
Sincerely,  
/c/ Dale Shaw  
Dale Shaw  
EGLE Regulatory Affairs Officer  
Enclosure  
SUBJECT: Review of Proposed Changed Rules; Sewerage Systems, 2024-052 EQ  
Page 5  
February 26, 2026  
cc/enc: Phillip D. Roos, Director, EGLE  
Aaron B. Keatley, Chief Deputy Director, EGLE  
Travis Boeskool, Senior Deputy Director, EGLE  
Ann Larson, Deputy Director, EGLE  
Dylan Gebhard, Legislative Liaison, EGLE  
Brad Pagratis, EGLE  
Jerrod Sanders, EGLE  
Christine Alexander, EGLE  
Alyssa Sarver, EGLE  
Archived: Monday, May 5, 2025 9:53:34 AM  
Mail received time: Tue, 29 Apr 2025 14:24:09  
Sent: Tue, 29 Apr 2025 10:25:27  
Subject: Public Comment Pertaining to Part 41 Rule Changes  
Importance: Normal  
Sensitivity: None  
\cbpat2\qcCAUTION: This is an External email. Please send suspicious emails to [email protected]  
Good Morning -  
Thank you for the presentation on the forthcoming changes to EGLE's Sewerage System Rule. On behalf of the City of Rochester Hills  
we are submitting the following questions / comments to be included as part of the public comment record.  
1) Under R 299.2918 Rule 18 (2) states additional education or experience of an applicant may be substituted by the department for  
meeting the minimum qualifications prescribed in subrule (1) of this Rule. Will there be more elaboration on what will be acceptable  
education/experience substitutes for some of the more stringent requirements for C1 and C2 licenses? Specifically, the college degree  
requirement in an engineering or science related field.  
2) The City has concerns with the college degree requirement as none of our operators have college degrees specifically in  
engineering or science, but they have decades of years of experience, hold other required state licenses, and are more than capable  
of running our collections system and have been doing so for years. We would like for there to be consideration towards an alternate  
option for meeting this requirement that does not require going back to college.  
3) This bullet is more of a statement, but we would like to point out that those employees that do have degrees in engineering or  
science are typically not running the collections system, so do not have the years of experience required in operating the system.  
Similarly those who have experience with operating the system do not typically have college degrees in engineering or science.  
Therefore it is hard for any one person to meet the requirements of a C1 or C2 license.  
4) Will there be any training/prep courses or practice tests/problems available for the individual licenses?  
5) Will more than one licensee be required (i.e. a primary and secondary) similar to how the S licenses operate?  
6) Will any other college degrees be accepted? In our specific situation, would a business degree be acceptable to meet the college  
degree requirement?  
Thank you again for this opportunity to voice our comments.  
Please feel free to reach out if you would like to discuss further.