2026-06-28 Comment response to the published Request for information

The International Code Council is a one stop shop, single firm monopoly operating in plain sight with vertical and horizontal agreements. They have consolidated, unchecked power with little oversight and they have locked every aspect of housing in a closed loop system from conception to placement. There needs to be a complete investigation in who they are,their family of services, how they operate, their agreements with others, their acquisitions, and how they have created an illegal tying agreement with the entire nation. Everyone is tied to their model, so they cannot object, because it is their bread and butter. ICC is not suppose to police or enforce their own codes and standards, but they do and they co-brand their standards with trade associations, who lobby for them. The International Code Council Is Tied To Congress Through The National Institute Of Building Sciences ( NIBS) The Story Of NIBS We were created by act of Congress in 1974 to be the nation’s authoritative source of findings and recommendations that impact and improve the built environment for the American people.  At the National Institute of Building Sciences (NIBS), we connect research, policy, and practical application to advance innovation in the built environment. Our mission is to create a safer, more resilient, and technologically advanced infrastructure that serves American communities and strengthens our nation’s future. From shaping industry standards to guiding digital transformation, we empower building professionals, policymakers, and owners to make informed decisions that enhance sustainability, efficiency, and resilience. We convene experts across sectors to develop solutions that ensure construction, infrastructure, and disaster preparedness keep pace with evolving challenges. Through initiatives such as the Digital Technology Council (DTC) and the Facility Management & Operations Council (FMOC), NIBS is at the forefront of advancing best practices. We help develop and refine standards, including NBIMS, NCS, and ANSI/ASHRAE/NIBS SPC 224, to support industry-wide adoption of data-centric approaches and emerging technologies.  We are stewards of the Whole Building Design Guide and the SF Tool, and we keep these comprehensive resources, which guide public buildings and infrastructure, freely available to the public. Building American Innovation isn’t just our tagline—it’s our commitment. We foster collaboration between government, industry, and academia to drive forward-thinking strategies for resilient communities. Because at NIBS, we don’t just build structures, we build solutions. Source Board of Directors The National Institute of Building Sciences Board of Directors is comprised of up to 21 members. The President of the United States, with the advice and consent of the Senate, appoints six members to represent the public interest. The remaining 15 members are elected from the nation’s building community and include both public interest representatives and industry voices. A majority of Board members are required by the authorizing legislation to be in the public interest category. Individuals With Ties To Both ICC And NIBS Dominic Sims: Previous ICC CEO Is On The Board Of NIBS John ( JC) Hudgison: Senior F Board Member Of ICC and a Board Member of NIBS Ryan Colker : Vice President, Innovation with the International Code Council, where he leads the Energy, Resilience and Innovation Center of Focus. He also serves as Executive Director of the Alliance for National & Community Resilience (ANCR), a national coalition working to provide communities with the tools necessary to holistically assess and improve their resilience. Prior to joining ICC, Colker served as Vice President with the National Institute of Building Sciences, where he directed the Consultative Council and served as staff director of the Council on Finance, Insurance and Real Estate; the National Council on Building Codes and Standards; the Off-Site Construction Council and NIBS’ STEM Education Program. If you do a cost analysis of the price of housing since the ICC was formed, you will see that the cost of housing increased and coincided with the salaries of ICC executives and their lobbying expenses. See Supportive Documents Original Song About ICC Written By Janet Thome Every City Is Crying The Housing Blues Verse 1 Every city crying the housing blues Every city crying the housing blues Hard working people drowning in dues Everyone’s too tired to ask who’s making the rules The new face of homeless Is the working poor With no roof over their head Chorus No one is connecting the threads Few men dare to tread Can’t speak up — they’re in the loop With the corporate suits See Attached: Entire Lyrics Thank you for your consideration, Janet Thome President Tiny House Alliance USA