2026-07-05 Comment response to the published Request for information

On Feb. 16, 2026, DOE sent ICC a letter that was shared in the DOE June 26, 2026 press release that stated- ''DOE opposes building energy efficiency codes that conflict with federal energy efficiency standards.'' ICC has a complete and utter disregard for federal preemption, including energy, transportation law, and HUD preemption and I am submitting documentation to support this. ICC is an ANSI accredited standard developer, but ANSI does NOT have a provision on preemption. This is my response I received from ANSI in regards to preemption; ''ANSI does not have a formal position statement on preemption. The underlying expectation of all American National Standards (ANS) related work is that it is consistent with U.S. law. ANSI’s role in standards development is limited to procedural compliance issues as defined in the ANSI Essential Requirements. Appeals are similarly limited by the ANSI Essential Requirements and the standards developer’s ANSI-accredited procedures. And of course, use of ANS is voluntary. There is a provision in the ANSI Essential Requirements that provides for the ANSI Board of Standards Review (BSR) to decide not to approve a standard as an ANS if there is sufficient evidence that demonstrates that a proposed or approved ANS is contrary to the public interest, contains unfair provisions or is unsuitable for national use. Any such concerns should be raised during the standards development process, if it is ongoing.'' Sincerely, Anne Anne Caldas acaldas@ansi.org Standard development should be reformed to address preemption and many other gaps. I have been involved in the ICC 1215 Tiny House committee that became hijacked by the arbitrary Small Residential Unit rebranding tool that ICC created for market control to be in their pay to play system and there is complete disrespect for federal preemption. I am including links to blog posts regarding preemption that include my letters to ICC and their replies, not all my supportive documents were compatible. ICC has posted their preemption replies to me on their website without my inquiries or supportive documents and have taken my words out of context. ICC likes to use the strategy of silence, which is a contradiction since ICCNTA is suggesting that the committee avoid federal domains, and AVOID motor vehicle classification. ICCNTA is a IPIA DAPIA agency approved by the federal government and it is disturbing that they are suggesting to find a work around federal laws. The ICC 1215 is unenforceable and creates an obstacle to transportation and HUD preemption. https://www.tinyhouseallianceusa.org/icc-1215-disregards-hud-preemption/ https://www.tinyhouseallianceusa.org/the-overreach-of-iccnta-in-icc1215/ https://www.tinyhouseallianceusa.org/icc-1215-promotes-independent-carrier-system-ghost-trailer/ https://www.tinyhouseallianceusa.org/icc-board-continues-to-disregard-motor-vehicle-preemption/ https://www.tinyhouseallianceusa.org/icc-1215-chassis-silence-or-regulatory-coverup/ Thank you for fighting for more choices for Americans and for recognizing that building codes are being weaponized in a housing crisis by ICC. Janet Thome President Tiny House Alliance USA