Construction vs. Non-Construction
Construction Project
For SCRC purposes, a construction project includes the building, alteration, renovation, or substantial improvement of physical or technological infrastructure, including installation of fixed equipment that becomes part of the facility. Examples include new facilities, major renovations, water/sewer systems, broadband and telecommunications infrastructure, and other permanent improvements to real property.
Non-Construction Project
A non-construction project includes all other eligible activities such as planning, workforce development, technical assistance, equipment purchases not affixed to property, and routine maintenance or minor repairs that do not materially extend the useful life or increase the value of facilities.
Reference Chart
This reference chart is designed to provide a clear comparison of what qualifies as a construction project versus a non-construction project under SCRC guidance. It is intended for use by State Program Managers, Local Development Districts, and Commission staff to ensure consistency and compliance.
* These activities may also qualify for non-construction activities if attached to a project that is only designed for planning and development with no actual construction occurring within the project period.
Guidance considerations of Construction Projects
Construction encompasses activities related to the creation or substantial improvement of physical or technological infrastructure. This includes:
- New Construction: Building new facilities or structures (e.g., community centers, health clinics, broadband networks, water/sewer systems).
- Modernization, Alteration, or Renovation: Significant improvements to existing structures or systems to extend their useful life or adapt them for new purposes (e.g., replacing roofs, upgrading HVAC/electrical, adding water/sewer capacity, major accessibility modifications).
- Installation of Fixed Equipment: Permanent equipment affixed to facilities, such as laboratory systems, medical equipment, or broadband hardware, where removal would impair the building’s utility.
- Associated Required Activities: When working on a construction project, all required architectural and engineering services, permitting, environmental/historic preservation compliance, and bid solicitation directly tied to a construction project are eligible to be considered construction.
Technology infrastructure is expressly included. Broadband expansion, telecommunications towers, data centers, and similar permanent systems are considered construction when involving physical buildout or installation.
Guidance considerations of Non-Construction Projects
Non-construction activities are those that do not involve building or substantially improving facilities or infrastructure. These include:
- Programmatic Investments: Workforce training, entrepreneurship support, technical assistance, and other capacity-building programs.
- Planning & Studies: Feasibility analyses, environmental studies, and program design activities not tied to physical buildout.
- Routine Maintenance & Minor Repairs:Activities that preserve efficient operation but do not extend the facility’s useful life or increase its value (e.g., painting, patching, small-scale cosmetic updates).
- Personal Property & Equipment Purchases: Standalone equipment, software, vehicles, or furnishings not permanently affixed to real property.
- Associated Required Architectural, Engineering, or Permitting: When working on a planning and development for a project, all required architectural and engineering services, permitting, environmental/historic preservation compliance, and bid solicitation that will be directly tied to a construction project can be considered non-construction if no actual construction occurs within the set defined portion of the project.
- Other Administrative or Operational Activities: Salaries, outreach, and other costs unrelated to construction.