Comment Submitted by Tiny House Alliance USA

Re: Docket HUD-2026-0794 – Revising the Definition of ‘‘Manufactured Home’’ to Lower Housing Costs Comment on MHCC Proposed Revised Standards and Modular Industry Input The MHCC received several comment letters from modular building manufacturers and a modular building association in advance of the meeting. The letters generally opposed the draft changes citing concerns that the distinction between their products and manufactured homes could become less clear. This opposition is ironic and warrants careful examination. The modular industry, through MOD X and affiliated groups, has been actively assisting ICC and NIBS via HUD-funded programs that work to blur precisely those distinctions. This is evident in two key HUD publications: Offsite Construction for Housing: Research Roadmap (U.S. Department of Housing and Urban Development, Office of Policy Development and Research, 2023). This report, developed with a Project Technical Committee chaired by MOD X in partnership with NIBS, includes the direct recommendation under regulatory priorities: “HUD Code — Investigate the relative merits of the HUD Code versus ICC codes for potential regulation of manufactured housing.” It further highlights obstacles in the ICC Evaluation Service (ICC-ES) process for new offsite products and pathways to streamline ICC-aligned approvals. HUD’s Past, Present, and Future Role in Accelerating U.S. Offsite Construction for Housing: A Comparative Study and Action Plan (2024–2025/2026). This follow-on work advances harmonization, housing system certification, performance-based codes, and greater integration across methods under ICC-influenced frameworks. Together with chassis-related changes and recent HUD provisions, the pattern points toward moving manufactured housing under the broader ICC umbrella (ICC codes, ICC/MBI standards, and ICC-ES evaluations), justified by the need to eliminate “two different industries.” While framed as a logical evolution, this appears to be a deliberate, planned transition that will not serve the long-term interests of housing affordability, innovation, or consumer choice. The HUD Code has provided a distinct, preemptive federal framework. Shifting toward ICC dominance risks higher costs, reduced competition, and capture by standards development entities. I urge HUD to preserve the unique role and protections of the HUD Code, fully assess the competitive implications of these partnerships and recommendations, and ensure any definition revisions do not facilitate a de facto takeover. Janet Thome President Tiny House Alliance USA