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

Energy Department Analysis Finds Proposed International Building Codes Would Cost Americans $9.2 Billion Annually Focusing on a excerpt from the press release- “This analysis shows how unnecessary regulations and ineffective building codes have drastically increased housing costs with little to no benefit for homeowners or communities,” said Assistant Secretary of Energy (EERE) Audrey Robertson. “An average payback period of 11 years—as long as 22 years in some cases—for new residential building codes is unacceptable. Standard-setting bodies should take note: we prioritize the American homeowner and will not allow erroneous building requirements to push homeownership out of reach.” Standard Developers and standard development needs to be reformed and investigated. ICC has no firewall between their identity as a standard developer, the standards they develop, and their services. ANSI is their oversight, but they do not address technical matters, or their inappropriate behavior, unless you go through the ANSI process to remove them as an approved standard developer. Standards must comply with the ANSI Essential Requirements, but there are crucial missing provisions including. No conflict of interest policy. ICC allows their employees to bully interested parties and has an overreach in their influence. No provision on preemption. No safeguards if the standard developer also can benefit from the standard. Interested parties must pay ICC and ANSI for appeals. ICC does NOT answer 99% of complaints. ICC vote stacks the committee so their agenda is ushered out. ICC violates every single antitrust law including vote stacking, tying and bundling agreements, boycotting competitive standards, creating joint ventures to restrict trade, and more. They do not create standards because of industry need, they create them to dominate industries and be in control of the direction of industries, such as tiny houses and off-site construction. ICC duplicates other standards in violation of both ANSI and the WTO Coherence Duplication. I want to share an excerpt from an ASPE article: May 2024 Professional Engineer's Perspective: Duplicating Standards Is Not Good For The Industry ''Unfortunately, I recently learned of the misapplication of the ANSI Essential Requirements by the International Code Council (ICC) for strictly competitive reasons. While (as mentioned in my previous article), ICC follows a Governmental Process for their I-Codes, where only governmental members are afforded a vote, they also create some standards via an ANSI-accredited process. Unfortunately, they seem to be ignoring some ANSI Essential Requirements in the process for at least one of these standards. Furthermore, I have also learned that ICC has filed Notice of Intent for three additional standards that conflict with existing ANSI-accredited standards, further suggesting that ICC refuses to participate in the betterment of the industry but rather creates confusion for competitive reasons, which jeopardizes health and safety. ICC 815: Preventing Industry Participation I have learned that ICC is requiring their volunteers to sign a non-disclosure agreement (NDA) to participate in their processes, such as for ICC 815. An NDA should not be a prerequisite to participate in an open consensus process for the formulation of an industry standard, especially one that obviously duplicates other efforts. Volunteers should be able to participate, collaborate, and share of information without fear of a lawsuit by ICC.'' Link to article https://aspe.org/pipeline/may-2024-professional-engineers-perspective-duplicating-standards-is-not-good-for-the-industry/ There is no where for an interested party to go to when the processes and procedures are violated besides ICC. There should be an unbiased 3rd party agency that does not benefit financially that a person could go to, with ICC paying for that service, if there is proof complaints are not answered. They have a disregard for preemption and even overturn their own policies when it is convenient for them, such as overturning their own appeals board regarding the IECC. Thank you for recognizing that housing is a consumer choice. Affordability is very relative and we have a crisis with no end in sight, but with a closer look, part of the root cause is ICC. Thank you for your consideration, Janet Thome President Tiny House Alliance USA