2026-06-27 Comment response to the published Request for information

My name is Janet Thome, and I am President of Tiny House Alliance USA, a national nonprofit organization dedicated to advancing safe, affordable, and attainable housing through tiny houses. For more than a decade, I have worked with builders, code officials, engineers, educators, nonprofit organizations, and government agencies to improve opportunities for affordable homeownership through smaller housing. I appreciate the opportunity to provide comments on the U.S. Department of Energy's Request for Information regarding the methodology used to assess the affordability and consumer impacts of building energy codes. As our nation continues to face a housing affordability crisis, I believe it is important that these evaluations recognize the unique role that tiny houses, starter homes, and other smaller housing types play in expanding homeownership opportunities. One housing type has been almost entirely overlooked in these discussions—tiny houses on wheels. Although they represent one of the most affordable paths to homeownership for many Americans, they are rarely considered when evaluating the impacts of building energy code requirements. Because of their small size and lower construction cost, additional code requirements can have a disproportionately greater impact on affordability than they do for larger homes. DOE's methodology should recognize tiny houses on wheels as a distinct housing type when assessing the consumer impacts of future building energy codes. Tiny Houses and Small Homes Are Part of the Affordable Housing Solution Tiny houses and other small homes provide attainable homeownership for first-time buyers, seniors, veterans, young families, essential workers, and individuals seeking to downsize. As housing costs continue to rise, these smaller housing options have become an increasingly important part of addressing the nation's housing shortage. Construction Costs Have a Greater Impact on Small Homes Energy code requirements do not affect all housing equally. A fixed increase in construction costs represents a much larger percentage of the total cost of a tiny house or starter home than it does for a larger residence. Requirements that may appear modest on a larger home can significantly affect the affordability of smaller housing. Consumer Choice Many consumers intentionally choose a smaller home because it better fits their financial needs and lifestyle. Building codes should preserve opportunities for consumers to select housing that balances affordability, efficiency, and personal priorities. Encourage Innovation Tiny houses have become a source of innovation in efficient design, material use, and space utilization. Energy policies should encourage innovation rather than create barriers that disproportionately affect emerging forms of affordable housing. Measuring Consumer Impact DOE's evaluation methodology should include the impact of energy code changes on: Tiny houses. Starter homes. Small cottages. Accessory dwelling units (ADUs). Manufactured homes. Workforce housing. First-time homebuyers. Seniors and veterans. Small builders and nonprofit housing organizations. The smaller the home, the greater the impact of each additional construction requirement. DOE's affordability analyses should recognize that a fixed increase in construction costs does not affect all homes equally. Tiny houses and starter homes deserve separate consideration because they represent one of America's most attainable paths to homeownership. I am attaching additional documents. Thank you for your consideration, Janet Thome President Tiny House Alliance USA