Respondent is a renovation company performing renovations in target housing regulated by the Renovation, Repair and Painting (RRP) Rule. For a renovation conducted in Manhattan, New York, the company failed to obtain initial EPA firm certification; failed to obtain written acknowledgement from owner that owner received Renovate Right pamphlet, failed to contain the work area to prevent spread of dust/debris, and failed to establish and maintain records documenting compliance with RRP. EPA is seeking a penalty and the Respondent's return to compliance. Due to the fact that Respondent qualified based on income for EPA's Graduated Penalty Policy pilot, penalty was substantially reduced from initial proposed penalty.