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On Feb. 4, the broad-based “Commercial Properties Coalition,” which includes NAR and many other real estate and development groups, sent the latest in a series of comment letters to EPA regarding lead paint issues. This letter addresses a nationwide questionnaire in which the agency proposes to survey building owners, tenants and contractors regarding renovation and remodeling practices in commercial buildings.
The Feb. 4 letter “commended EPA for recognizing that it has significant data gaps to fill before it can determine whether to regulate [renovation and remodeling activities in public and commercial buildings] and, if so, what type of regulation may be warranted.” The coalition went on to caution that EPA’s proposed survey process appears to assume that lead paint hazards exist in commercial buildings. The coalition has also brought the agency to task for failing to gather relevant data from the nation’s largest commercial building owner and tenant – namely, the federal government.
In framing its proposed information collection request, the coalition asserted, “EPA is asking the wrong questions at this juncture. . . As a threshold matter, EPA must determine whether a lead hazard exists in [public and commercial buildings]. Routine maintenance and repair, painting, and other renovations are conducted on a regular basis in the public and commercial building stock. The critical question is not whether these activities are performed, but whether they create lead hazards.”
EPA will now consider these comments and may refine its survey process and instruments as a result. Through the coalition, NAR will continue to monitor developments to ensure that any federal rules on building retrofits and renovations are based on sound science, and fairly parse regulatory burdens and data obligations on building owners and managers in both the public and private sectors.