2026-07-10 Comment response to the published Request for information

This administration is bringing back consumer choice, which is being erased by ICC. There needs to be an investigation into the relationship with the International Code Council, and all the different organizations that have rebranded factory built housing to off-site construction that is creating another locked pay to play system with ICC. ICC is tied to Congress through the National Institute Of Building Science (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. Attached Is The ICC/NIBS Connection The ICC Board of Directors, during its duly held July 27, 2018 meeting, unanimously approved a proposed standards project in cooperation with the National Institute of Building Sciences (NIBS) and the Modular Building Institute (MBI) to explore and develop a portfolio of standards and guidance tools to support the off-site construction industry. The ICC Off- Site Construction Standards https://www.iccsafe.org/advocacy/safety-toolkits/offsite-construction/ If you do a search there are multiple off-site construction organizations that are tied to the 2 Modular trade associations with the same executives and ties to ICC. NIBS Press Release:Apr 09, 2026 HUD‑Supported Breakthrough Regional Pilots Summit Charts a Scalable Path Forward for Offsite Construction and Housing Supply. WASHINGTON, April 9, 2026 /PRNewswire/ -- The National Institute of Building Sciences (NIBS) and its strategic partner MOD X convened for the US Department of Housing and Urban Development (HUD) Breakthrough Regional Pilots Summit on April 7, 2026, at the NIBS offices in Washington, DC. The summit brought together six state/regional groups pioneering offsite-construction housing programs, along with federal and industry leaders, to share lessons and strategies to advance offsite construction as a critical approach to increasing housing supply nationwide. MOD X MOD X is a research-based advisory group and international knowledge exchange network integrating academic, industry, government, and related non-profit sectors (quadruple helix) in the prefabricated and volumetric modular offsite construction industry. If you research the website, you will see the ICC, modular trade groups, and NIBS. https://www.modx.network/about Offsite Construction for Housing: Research Roadmap PREPARED FOR: U.S. Department of Housing and Urban Development Office of Policy Development and Research Professor Ryan E. Smith Founding Partner, MOD X Director, School of Design and Construction, Washington State University https://www.huduser.gov/portal//portal/sites/default/files/pdf/Offsite-Construction-for-Housing-Research-Roadmap.pdf Ryan is the founding past chair and current board member of the National Institute of Building Sciences, Offsite Construction Council, a fellow of the Modular Building Institute and a Senior Research Fellow in the Centre for Offsite Construction + Innovative Structures at Edinburgh Napier University in the UK. https://www.modx.network/team The report is another tie to ICC. Alarming Goal Under Key Takeaway 7 Key Takeaway 7: Learn Globally, Act Locally This report identifies the need for lessons from abroad in nearly every topical area. There is a need for comparative research projects about international offsite construction programs that bring together industry, academia, and government to improve housing for everyone. The list of research needs for offsite construction in this report is intended for the offsite construction industry broadly. There are some projects, however, for which HUD is uniquely situated to address within its interests and capacity. The text below outlines research recommendations specifically for HUD to enact as projects, partnerships, and initiatives. HUD Code HUD Code: Investigate the relative merits of the HUD Code versus the ICC codes for potential regulation of manufactured housing. New Products: Research the obstacles of the current ICC-Evaluation Service (ES) process to develop mechanisms to foster new product development in offsite construction for the housing sector There Are Already Concerns That A Manufactured Home Is Becoming More Like An IRC Home This combined effort between HUD, ICC, Mod X, and NIBS is promoting favoritism to ICC, including the certification and accreditation and ICC-Evaluation Services and adding to the ICC Closed System. Janet Thome Tiny House Alliance USA