ICC Denies Motor Vehicle Classification By ICC Board Of Directors
I sent a complaint to ICC regarding of ICC 1215 – Design, Construction and Regulation of Small Residential Units and Tiny Houses for Permanent Occupancy.
My complaint was regarding that the ICC 1215 standard was overriding federal standards on the chassis. I received a reply from ICC on Dec. 9, 2025 that I did not agree with. I sent them a rebuttal to their answer on Dec. 17, 2025.
Summary Of My Rebuttal
I am sending a rebuttal to the Dec. 9, 2025 letter from ICC regarding my complaint that ICC 1215 is overriding federal laws regarding the chassis, and a formal new complaint that my comments in the reason section were partially edited and omitted in the first draft that’s currently being reviewed. . I have some new points that I respectfully ask you to consider. I am including the ICC 1215 committee and interested parties that have been involved in the chassis discussion, and ANSI.
The Transportation section of ICC/THIA 1215 unlawfully treats a trailer chassis as if it exists in a regulatory vacuum. By rebranding a trailer as a “temporary carrier system” and carving out an exemption, the standard attempts to obscure the existence of a noncompliant “ghost trailer” and create an alternate compliance pathway outside federal motor vehicle law.
A trailer’s legal identity is fixed by statute and is not fluid. Motor vehicle safety standards cannot be reclassified, waived, or displaced by a building or private consensus standard. Silence or omission cannot defeat federal preemption where Congress has occupied the field.
State Of Colorado: Code Of Colorado Regulations DOLA
In Colorado, a “tiny home” for state regulation (DOLA) means a dwelling under 400 sq. ft. (excluding lofts) on a permanent chassis.
DOLA also defines the chassis as;“Vehicle Chassis” means the base frame of a single-family dwelling, designed and constructed for long-term occupancy that supports the home’s construction and transportation, and includes axles, wheels, GVWR a VIN.
Samuel W. Albrecht is a voting member of ICC 1215 and the Colorado Director Of Office Of Regulatory Oversight in the Division of Housing and could offer crucial input on this debate.
The state of Colorado clearly acknowledges the duo nature that a tiny home on wheels must follow for compliance for both vehicles and structures and integrates the path.
ICC 1215 Acknowledges DOT Authority
‘’One cannot invoke DOT authority while simultaneously claiming that a tiny house on a trailer is not a motor vehicle. Those positions are legally incompatible. ‘’
Most Critically, The Standard Itself Invokes DOT compliance—Thereby Conceding Vehicle Status
DOT does not regulate buildings.
DOT regulates motor vehicles.
Once DOT is invoked, the full federal transportation framework applies, including NHTSA, FMVSS, and certification requirements. Invoking DOT ends the debate.
Below Is My Rebuttal And The Dec. 9, 2025 Reply From ICC
Dec. 9, 2025 Reply To Janet Thome
ICC 1215 Meeting Notes Work Group 3
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Dec. 17, 2025
