There was an OSMTH 1215 meeting yesterday and we had the opportunity to discuss the CAH ( Committee Action Hearing ). A code proposal called RB42-25 was presented at the hearing that referenced the ICC/THIA standard and many opponents spoke up against the Small Residential Unit.
For More History: Code Proposal Disapproved Referencing ICC Standard At CAH
Direct Link To The Hearing: A 10 minute Video.
The voting committee members seemed unfazed to the opposition of the Small Residential Unit and stated some reasons for the Small Residential Unit.
- They feel that a tiny house needs to be larger than 400 square feet, to be ADA compliant.
- They described once again, how multiple units could be connected on one chassis, which they have continuously described, but the method is not written in the standard. ( A Duplex, Or Triplex)
- At other times they have said the term tiny house is inflammatory, or it is associated with homeless shelters, and the term was falsely blamed for the disapproval of two ICC standards -ICC/MBI 1200 and 1205 in the 2024 IBC hearing to justify the need to use the term Small Residential Unit.
- They did discuss that perhaps they should lower the square footage of the Small Residential Unit to maybe 800 square feet from 1200 square feet.
I honestly feel that the goal of the Small Residential Unit is to replace manufactured homes.
It is not a bad idea, except it does not belong in a tiny house standard.
Manufactured homes still face old unfair stigmas of trailer parks, and Modular homes do not have that stigma.
I feel that ICC wants to bring more business to their subsidiaries, including ICCNTA, which certifies both manufactured homes, and modular homes, and they developed a standard called ICC/MBI 1205 Standard Off-Site Construction: Inspection and Regulatory Compliance which has been referenced in a current code proposal that will reference this standard and other 1200 series in both the IRC and IBC in the 2027 code cycle.
I later found out that 2 building officials on the committee were proponents of the code proposal that referenced the 1200 series. That was a huge conflict of interest that was not disclosed and shows they could not be impartial. I asked for a certification workgroup for one year and it was denied. They finally threw the discussion in another work group, but we were never allowed a good discussion about it, without being told we had to use the provisions of ICC/MBI 1205 for certification.
ICC tried to FORCE this voluntary standard - ICC/MBI 1205 on the tiny house industry as 'requirements', which I successfully fought, with the help of others, although they still won, because it will just be bundled with this standard.
What was also disturbing, is that David Tompos Sr. circulated a document to the entire committee and me, and created a group boycott of a competitive standard, which is the criteria that one of the third parties of the committee meet for personnel requirements. This company certifies every single manufacturer on the committee. But they did not stand up for it.
Note: ICC/MBI 1205 is currently being removed as a mandatory provision as we go through public comments.
How will A Small Scale Artisan Tiny House Builder Compete With A Large Scale Small Residential Unit Manufacturer?
They cannot compete in price.
I just looked at the financial report of a large manufacturer that builds Manufactured Homes, Modular, and Park Models. They have an umbrella name, and they are the parent company of many other manufacturers.
In the last few years, they invested over 100 million in acquisitions, over 100 million in expansion for their plants, over 300 million to their shareholders, with over 300 million left in cash. They also own subsidiaries for mortgages and insurance.
At this time, there is legislation to remove the mandatory requirement for a permanent chassis on a manufactured home and there are new allowances for duplexes, and triplexes on a HUD manufactured home, and if you notice, there is a lot of marketing of HUD labeled homes that are marketed as tiny homes or a line of small cottages.
These large manufacturers of Small Residential Units ( They Are Just Not Using The Name Yet) that are spending millions of dollars as described above will be pitted against the small tiny house artisan builders that will not be able to compete in pricing.
I cannot tell you how many times the committee members have brought up having multiple tiny homes connected on one chassis in the meetings, that is why I feel the Small Residential Unit is destined to replace manufactured homes, so the regulatory compliance is under the ICC umbrella.
I am certainly not opposed to a a duplex or a triplex, but we need to crawl before we walk, and we have not successfully achieved the first step of achieving recognition of tiny houses on wheels as a viable solution with chassis provisions in the code.
That was the intent of the standard, and the goal has become lost with the complete takeover of the Small Residential Unit.
Duplexes and triplexes will also come with their unique issues, including zoning and parking requirements.
Manufactured Homes Will Have An Edge Over Modular Homes
When the requirement of the permanent chassis is removed from the manufactured home, there will be massive competition occur between manufactured homes and modular homes, because manufactured homes preempt building codes, so they will have an edge over Modular Homes, and this is why I feel ICC wants to stay ahead of this, and create the Small Residential Unit with duplexes, and triplexes, as a competitive housing type to manufactured homes to keep the regulatory compliance under ICC.
Is The Tiny House Industry Going To Repeat History From The 70's Recession That Hit The Mobile Home Industry With A Decline In Sales?
Blame for the industry’s troubles often centers on the HUD Code, which was stricter in both requirements and enforcement than previous mobile home regulations. Arthur Bernhardt gestures towards this in “Building Tomorrow,” a long-term study of the mobile home industry published in 1980:
The dramatic shakeout of the 1973-1975 recession resulted in an industry where the “surviving” firms are financially sophisticated. Increasing government intervention has forced these “survivors” to develop new staff and expertise in dealing with the new regulatory red tape.
…The irony seems to be that consumerism and government have raised entry barriers to the point that new competition is discouraged from entry and production costs are significantly higher.
And Allan Wallis makes similar claims in “Wheel Estate,” a history of the mobile home industry published in 1991:
In previous recessions, small manufacturers would go out of business and larger manufacturers would close some of their branch plants until the economy turned around.
Coming out of this recession, however, small manufacturers were faced with a new set of regulations and a complicated design approval and inspection system. Instead of spot-checking units, every unit being manufactured now had to be inspected in the plant.
For a small firm turning out just a few units a week, the cost of filing drawings for approval and paying an inspector to come for a factory visit might mean the difference between being competitive or out of the market.
More than ever we need to alert the tiny house industry about the Small Residential Unit takeover of tiny houses to preserve the progress we have made.
Thank you for signing, sharing, and for chipping in for more shares. Please keep sharing and join me to protect the interests of owner builders, and small artisan Tiny Houses builders and owner builders that are the heart of the tiny house industry.
Thank you,
Janet Thome President
Tiny House Alliance USA
janet@tinyhouseallianceusa.org