[MassHistPres] Fw: EPA NLIC Inquiry

[Garrett Laws]

WOW! Someone forgot to read their 101 economics books regarding supply and
demand! Talk about theoretically twisting the application of an idea!

Cheers,
Garrett

The Copper & Slate Company
Fine Roofing and Exterior Finish Carpentry
238B Calvary Street, Waltham, MA 02453
(781) 893-1916

http://picasaweb.google.com/copperandslate


On Sun, Apr 11, 2010 at 4:08 PM, jade <jade at crocker.com> wrote:

>  i sent an inquiry to the EPA hotline (see my question below) in the hopes
> of gettng clarification on whether or not the new lead regulations apply to
> ALL residences or just those where children under the age of 6 are living or
> frequently visiting ...
>
> below is the response i received...it doesn't even address my inquiry but
> it did make my head spin.....
>
> jade mortimer
> heartwood window restoration
>
>
> ----- Original Message -----
> *From:* Joanna <epahotline at abvi-goodwill.com>
> *To:* JADE MORTIMER <jade at crocker.com>
> *Sent:* Sunday, April 11, 2010 2:10 PM
> *Subject:* EPA NLIC Inquiry
>
> Good Afternoon Jade,
>
> thank you for contacting the National Lead Information Center concerning
> whether the new regulation (RRP) apply to all residences.
>
> In the scenario where someone buys a home but no one lives in it before
> it's sold, the owner does not have to comply with RRP if the owner does
> his/her own renovations.  This work is considered do-it-yourself work.
> If the homeowner is going to rent the home before it is sold the he/she
> would be covered by the rule.
>
> For your second question, landlords are being compensated for work they
> perform in their properties because they are collecting rent.  Rent payments
> are considered compensation for renovations.  Below is a comment on the RRP
> rule and EPA's response which discussed this issue.
> let me know if you have any questions about this.
>
> Comment:   One commenter (0417) argued that EPA should define
> compensation to expressly include
> rent payments. The commenter noted that confusion over this issue in the
> past led EPA to issue interpretive guidance for the Pre-Renovation Education
> Rule on this topic. Another commenter
> (ATL-0002) suggested that EPA define „compensation“ and questioned whether
> cash under the table would be considered compensation.
>
> EPA response: EPA views the term „compensation“ in much the same way as the
> IRS does.
> Compensation includes cash, checks, wire transfers, and services. Cash
> „under the table“ is certainly compensation. As stated in the 1999
> Pre-Renovation Education Rule guidance referenced by the commenter, EPA also
> interprets the term „compensation“
> to cover rent
> payments by tenants, so do-it-yourself renovations performed by landlords
> in rental property they own are covered by the final RRP rule. EPA does not
> believe that a definition of compensation is necessary, given that
> renovation contractors and landlords have been responsible for implementing
> the Pre-Renovation Education Rule for a number of years. The guidance
> referred to by the commenter, combined with the discussions of the issue in
> the preamble to the proposed rule should be sufficient to inform landlords
> of their obligations.
>
> For further information there are a number of informational documents
> available on our website (www.epa.gov/lead) under the additional resources
> link. If you have any further questions please feel free to contact us at
> 1-800-424-LEAD.
>
> Sincerely,
>
> Joanna,
> NLIC Information Specialist
>
> i continue to find conflicting information reqarding this issue:  do the
> new regulations apply to all residences built prior to 1978 regardless if
> there are children under 6 living or visiting on a regular basis?
> EmailAddress:jade at crocker.com <EmailAddress%3Ajade at crocker.com>
> Name:jade
> Organization: heartwood window restoration
> PhoneNumber:413-339-4298
> ---------
>
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