2026-05-04 Updating and Improving the Methodology for Assessing Affordability and Cost Effectiveness of Building Energy Codes; Request for information

Janet Thome, President of Tiny House Alliance USA, supports the DOE's action to improve methodology for assessing building energy code costs. She argues that current codes and the interlocking relationships between organizations like the ICC, NIBS, and RESNET create a "closed compliance marketplace" that drives up construction costs and excludes affordable housing options like tiny homes.

Janet Thome, representing the Tiny House Alliance USA, expresses concerns regarding corruption and market dominance by the International Code Council (ICC) and HUD. She supports the DOE's objective of reducing regulatory burden and costs in new construction, specifically highlighting the need to investigate the influence of the ICC on housing policy.

The Tiny House Alliance USA, represented by its president, requests that the DOE and DOJ investigate the "ICC-RESNET Interlocked Building Energy Requirements Ecosystem" for antitrust concerns. The commenter argues that this interconnected relationship between the International Code Council and the Residential Energy Services Network creates barriers to market entry, suppresses competition, and increases construction costs for consumers.

Janet Thome, representing the Tiny House Alliance USA, provides a detailed technical argument regarding federal preemption and the classification of tiny houses on wheels. The comment focuses on the interplay between HUD, NHTSA, and ICC standards rather than directly addressing the DOE's methodology for assessing building energy code affordability.

Janet Thome, President of Tiny House Alliance USA, argues that tiny houses on wheels are a viable, low-energy housing solution that is currently suppressed by building codes and manufacturers. She advocates for code changes that would allow these homes to be regulated and financed more easily to improve housing affordability and provide alternatives to nursing homes.

Janet Thome, President of the Tiny House Alliance USA, supports the DOE's effort to improve its methodology for assessing building energy code affordability. She specifically advocates for including smaller housing types, such as tiny houses and ADUs, in the DOE's prototype models to ensure a more accurate representation of the current housing market.

Janet Thome, President of the Tiny House Alliance USA, advocates for the Department of Energy to adopt a whole-building performance approach for assessing tiny houses. She argues that this method is more appropriate than prescriptive component requirements because it accounts for the unique design of small homes, encourages innovation, and preserves affordability.

The commenter advocates for the use of tiny houses and factory-built housing as viable, energy-efficient, and affordable alternatives to traditional site-built construction. They argue that these models can address housing shortages for low-income individuals and provide a more efficient building process with lower costs and reduced regulatory burdens.