Must notifications for common area renovations always be provided to every unit in a multifamily housing complex?

Answer:  Not necessarily. When renovations are to be performed in common areas of multi-family housing (i.e., those portions of the property generally accessible to all residents/users), the RRP Rule requires that each “affected unit” be notified in writing. See 745.84(b)(2). As a general matter, all units in the housing are “affected unit(s)” and therefore must be provided with notice of a common area renovation.

However, in a minority of cases, certain areas of a property that meet the definition of common area may in fact be used almost exclusively by an identifiable subset of tenants. For example, a common area inside one building of a multi-building apartment complex is likely to be used exclusively by tenants of only that building. See FQ 23002-19756. If a renovation is to be performed on such a common area, EPA believes it appropriate to provide notice only to the truly affected units: the subset of tenant users.

Firms may notify residents/users either by distributing written notice to each affected unit or by posting informational signs. Signs must be posted while the renovation is ongoing and they must describe the general nature and locations of the renovation and the anticipated completion date. These signs must be posted in areas where they are likely to be seen by the occupants of all of the affected units. The signs must be accompanied by a posted copy of the pamphlet or information on how interested occupants can review a copy of the pamphlet or obtain a copy from the renovation firm at no cost to occupants.

Question Number: 23002-32355

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