Does the minor maintenance exception mean that if I drill 1-inch holes in a painted surface to blow insulation into an enclosed wall cavity, I could drill 864 holes in the interior or 2880 holes on the exterior before I had to comply with the RRP Rule? Or does it mean that the work is covered by the RRP Rule once I insulate more than 6 square feet of interior wall area (basically 1 hole) or more than 20 square feet of exterior wall area?

The exception is based on the area of paint disrupted, which in this example is based on the combined areas of the holes drilled in the wall.

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