What is a “whole house gut rehabilitation project” for RRP purposes? What RRP requirements, if any, apply during a whole house gut-rehabilitation project? If target housing has, at some point after 1978, been gut-rehabbed, would the RRP Rule apply to subsequent renovations on the property?
The phrase “gut rehabilitation” may have different meanings across the construction industry. EPA, however, used the phrase “whole house gut rehabilitation” in a very limited sense to describe only those activities that demolish and rebuild a structure to a point where it is effectively new construction. At a minimum, these activities include the removal and replacement of all interior and exterior painted surfaces, including windows. The term should not be confused with a comprehensive renovation as described in FQ 23002-23415.
If an activity meets these narrow criteria (i.e., if a firm demolishes and rebuilds a structure to the extent that it is effectively new construction), then the activity is not a renovation for purposes of the RRP Rule and therefore not subject to any RRP requirements.
If, after 1978, target housing has been demolished and rebuilt to the extent that it is effectively new construction, subsequent renovations on the property would also not be subject to the RRP Rule. In other words, if target housing has been demolished and rebuilt to the extent that it is effectively new construction, it is no longer target housing. Conversely, if only a portion of the target housing has undergone a post-1978 modification (e.g., an overhaul of a kitchen or bathroom), then a subsequent renovation would still be covered under the RRP Rule.