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FAQ: Part 41, Sewerage systems, Administrative Rules update

On April 29, 2026, new rules were put in place for collection systems and RTB facilities. Collection system, or sewer system, means the network of pipes, drains, manholes, pumps, and related equipment that the public uses to carry household and industrial wastewater to a treatment plant. It serves more than one privately owned property. RTB means a treatment facility that holds and cleans wastewater and stormwater from a combined sewer system during storms. It operates according to the rules in its discharge permit. These rules explain how systems are classified and what certifications operators need.

This FAQ includes questions from public webinars held over the past few years. Most of the questions are related to the new classifications and certification requirements; additional questions about the rule changes are also included.

More webinars and presentations will be offered as the rules are implemented. The Michigan Department of Environment, Great Lakes, and Energy, EGLE also plans to work with an expanded group of stakeholders to support exam development and will continue working with partners like the Michigan Water Environment Association and Michigan Rural Water Association to offer training during the implementation process.

Learn more about the full rulemaking process. You can also find the rulemaking documents and read the final version of the updated rules.

Content updated: August 17, 2026

Collection systems

  • What is a contributing municipality?

    It is a city, village, township, local government, or any public serving system that sends wastewater to a treatment plant owned by another unit of government.

  • Do the new collection system and RTB certification rules affect other wastewater treatment operator certifications?

    No. These rules do not affect other wastewater treatment certifications. If you already have a wastewater treatment certification and work in a collection system or RTB, you may qualify for restricted certifications or exams once your system is classified.

  • Are mobile home communities included in the collection system rules if they discharge to a treatment plant?

    No. Mobile home communities are private systems and are not included.

  • Are condominium associations or other private systems included if they discharge to a treatment plant?

    Yes. Any public serving system (e.g., serve more than 1 individually owned real property) that serves more than 150 people is subject to the classification and certification requirements.

  • Do the new rules create a collection system permit?

    No. The rules only require classification of systems and operator certification. If a permit is developed, it will go through a public review process.

  • If my system is part of a utility authority, who can be the certified operator?

    Anyone employed by or contracted by the system owner can be designated as the certified operator.

  • Can more than one person be certified at each system?

    Yes. Only one certified operator is required but having more than one is encouraged. Backup operators are not required.

  • How many certified operators are needed for each classified system?

    Only one certified operator is required after EGLE formally classifies the system.

  • How will EGLE classify each system?

    EGLE will review each system based on criteria in the rules and will notify each community of its classification.

  • When will my system be classified?

    The earliest classifications will start in mid- to late 2028. Systems will be prioritized based on size and compliance status. This process will take several years.

  • How will restricted certifications work?

    After a system is classified, operators have two years to apply for restricted certification. Operators qualify if they already hold any wastewater certification and work in the system, or if they meet the required experience as stated in the rules. Restricted certifications only apply to the system where the operator currently works. If they move to a new system, they must take the exam.

  • Will EGLE accept reciprocity from other states?

    Yes, if the other state also accepts Michigan’s certifications.

  • When can I get certified for a collection system?

    You can apply after EGLE has classified your system.

  • How long do I have to get certified after a facility has been classified?

    Each system has two years to meet the certification requirement. This can be met either by restricted certification or by someone taking and passing an examination.

  • If I am a certified drinking water operator and become a certified collection system operator, do I need to earn separate continuing education credits (CECs) to renew the collection system certificate?

    Yes. Drinking water and collection system programs have different rules. You must earn the full number of credits required for collection system certification renewal.

Retention treatment basin (RTB)

  • Do the new RTB certification requirements affect other wastewater certifications?

    No. The RTB operator certification requirements do not affect the other wastewater treatment plant operator certifications. If you are a certified wastewater treatment plant operator who works at an RTB, you may be able to earn a restricted certification or qualify for an RTB exam after your system has been classified.

  • Can more than one person be certified at an RTB facility?

    Yes. Facilities are encouraged to have more than one certified operator on staff.

  • If my NPDES Permit contains multiple RTB facilities, how many RTB certified operators are needed?

    One certified operator is required for each permitted facility, but the same operator can be responsible for more than one RTB.

  • If my NPDES Permit contains a wastewater treatment plant and one or more RTB facilities, which licenses are required?

    One certified operator is needed for the treatment plant and one for the RTB. The same person can be assigned to multiple facilities if they hold all required certifications.

  • How will RTB reclassification work?

    EGLE will send a formal letter stating that a facility has been reclassified from Class D to Class RTB.

  • When will RTB facilities be reclassified?

    EGLE plans to complete reclassification within two years of the new rules, no later than April 29, 2028. Reclassification will begin once RTB exams are announced.

  • How long do I have to get a site-specific restricted certificate after classification?

    Facility owners have 90 days after EGLE’s notice to identify Class D or higher operators who qualify for a site-specific RTB certification. Operators without a Class D license, but who meet exam requirements, may take the RTB exam any time after reclassification.

  • How do restricted RTB certifications work?

    Once a facility is reclassified, the owner identifies staff with Class D licenses to receive a site-specific RTB certification. This certification has the same education requirements as a regular RTB certification but only applies to that facility.

  • Can I still qualify for a Class D exam if I work in an RTB?

    No. Now that a classification exists for RTBs, operators can only qualify for that exam. Moving forward, an operator must work in a wastewater treatment plant to qualify for the Class D.

Privately owned systems subject to Part 41

  • How will the addition of Rule 35(4) impact wastewater construction permitting requirements for privately owned sewer or sewerage systems subject to Part 41?

    The addition of Rule 35(4) requirements applies to private owned systems. These systems include non-governmentally owned systems that serve the public (e.g., serve more than 1 individually owned real property). The requirements generally include:

    1. Proof of recording of documentation for the continued O&M of the wastewater system across all parcels, which is normally recorded on the deeds of all properties in the condominium,
    2. A resolution and agreement from the local unit of government (LUG) accepting or not accepting responsibility for the wastewater system should the private owner fail to properly operate or maintain the system,
    3. Should the LUG refuse to accept responsibility, the private owner must establish an escrow or letter of credit payable to EGLE for the continued operation and maintenance in the amount of the greater of $20,000 or 20% of the replacement cost, not to exceed $100,000, and
    4. An asset management plan for the continued operation, maintenance and funding of the wastewater system.
    Note: Similar, existing requirements have been required for wastewater construction permitting for privately owned systems per EGLE policy WRD-010
  • When will the requirements of Rule 35(4) be implemented?

    EGLE intends to implement Rule 35(4) in early 2027.