2026-07-23 Comment response to the published Request for information

I begin with Assistant Secretary Audrey Robertson’s statement: “Proud to fight for Americans and expose the weaponization of building codes pricing Americans out of homeownership… These ‘codes’ are not about safety or baseline efficiency—they are tools that force Americans to build homes and live lives according to liberal extremists. Unelected and unaccountable ‘boards’ are forcing the electrification of your stoves and hot water heaters, mandating inefficient heat pumps, requiring unnecessary building insulation, forcing solar hookups and EV charging… and they are just getting started. Now the ICC is trying to force Biden’s Building Codes on every American in 2027! Currently adopted state energy codes have driven up the cost of new construction by $70 billion since 2006. The 2024 IECC codes, if adopted by all U.S. states, would further drive up new construction costs by $57 billion compared to current state codes. We will not stop until this corruption is exposed! We have shared the data. We have offered another path. But they have said no… so now we fight! These are the people making American homes unaffordable. President Trump and Secretary Wright will not rest until homes are affordable again.” — Audrey Robertson, Assistant Secretary of Energy I support this statement. My detailed reports document the interlocking system of ICC, NIBS, and RESNET. Here is a concise overview. Organizations. ICC weaponizes more than just building codes and federal funding is assisting them. ICC – Writes the model codes most jurisdictions adopt and controls product evaluation (ICC-ES), accreditation (IAS), and related services. RESNET – Runs the HERS energy-rating system; co-brands standards with ICC; accredited by IAS (an ICC subsidiary). NIBS – Congressionally chartered institute that receives large federal contracts and has produced HUD-funded reports promoting ICC systems. Key Overlapping Leaders Dominic Sims – Former ICC CEO; NIBS Board John “JC” Hudgison – ICC Board; NIBS Board Ryan M. Colker – ICC VP; former NIBS chair Mark Johnson – ICC COO; RESNET Board President Funding Snapshot NIBS – $300 million (FY2008–2026) ICC – $4.3 million (FY2008–2025) RESNET – $306,000 (FY2009–2022) HUD specifically funded reports that elevate ICC codes and ICC-ES while ignoring competitors. Antitrust & Litigation Concerns This structure creates a closed compliance marketplace. Builders and manufacturers are funneled into ICC/RESNET pathways. Independent options face barriers. ICC has sued platforms such as UpCodes for making evaluation reports searchable. RESNET has sued over the once-generic term “HERS”—a public concept created with DOE/NREL funding in the 1980s and written into the 1992 Energy Policy Act. These lawsuits raise costs and chill lower-cost alternatives. Impact on Housing The result is higher construction costs, reduced competition, and exclusion of affordable solutions such as tiny homes and modular housing. State energy codes have already added an estimated $70 billion since 2006; full 2024 IECC adoption would add another $57 billion. I urge DOE and the DOJ to examine this interlocking system, the federal funds that support it, and its impact on American homeownership. My full reports provide the detailed records and source documentation. I have a report on ICC, but it cannot be uploaded. Please see all reports - ICC RESNET NIBS Roadmap To Dominance https://www.tinyhouseallianceusa.org/icc-resnet-nibs-roadmap-to-dominance/ Respectfully, Janet Thome President, Tiny House Alliance USA