The Unfinished Breakthrough
On May 21, 2026, Dr. Ivan Rupnik, PhD, testified before the House Select Committee on Small Business at a hearing titled “Building the Future: How Small Home Builders are Closing America’s Housing Gap,” chaired by Chairman Williams. His written testimony, titled “The Unfinished Breakthrough,” made one central recommendation: that Congress direct the National Institute of Building Sciences (NIBS) to begin developing a national housing system certification framework under authority Rupnik states Congress granted NIBS in 1974 — a framework he described as requiring no new appropriations and no new authority, only congressional direction to exercise a fifty-two-year-old mandate.
About Dr Ivan Rupnik
Dr. Rupnik identifies himself as an architect, researcher, and Founding Partner of MOD X (also referred to in his testimony as “MOD X Advisory”), and as Professor of Architecture at Northeastern University.
He describes MOD X as a firm that “has directly supported HUD’s offsite construction research since 2022 and advises industry and government on topics related to accelerating industrialized housing delivery in the United States.”
He also discloses, in his testimony’s endnotes, that MOD X currently advises JPI, a large multifamily developer whose internal, non-independently-verified operational data — including a projected 58 percent time-savings figure — supplies much of the testimony’s most concrete quantitative evidence for certification’s benefits.
What The Testimony Leaped Over
The testimony states plainly: “No housing system certification framework currently exists in the United States.”
But the federal history Rupnik invokes does not end with Operation Breakthrough. Operation Breakthrough included Project LEAP and the standards-development work that produced ASTM E541. Operation Breakthrough addressed the evaluation and certification of housing systems and producers, while Project LEAP addressed the competence of the laboratories and agencies performing systems analysis, testing, inspection, and compliance assurance. NBS and NCSBCS then transferred the LEAP research to ASTM, where Committee E32 produced ASTM E541 by consensus in 1975.
That distinction matters. ASTM E541 is not identical to the broader system-level certification framework Rupnik is proposing; it is the agency-qualification layer beneath such a framework. Yet it represents a substantial part of the certification infrastructure that grew out of the same federal building-regulatory work surrounding Operation Breakthrough.
ASTM E541 remains active today as ASTM E541-22 and is cited in the current federal manufactured-housing regulation at 24 C.F.R. § 3282.358, and is documented in multiple state industrialized-building programs, including Virginia and Utah. The testimony does not mention Project LEAP, ASTM E541, or this existing infrastructure anywhere.
The Two HUD Publications Cited
Rupnik’s testimony rests almost entirely on two reports he co-authored, both published by HUD’s Office of Policy Development and Research:
Dr. Ivan Rupnik, PhD Written Testimony
Before House Select Committee on Small Business May 21, 2026
Operation Breakthrough Project Leap And ASTME541
NBSIR 75-642 (1975): Project Summaries of the Center for Building Technology. The contemporaneous project record places Operation Breakthrough, the Coordinated Evaluation System (CES), and Project LEAP within the Center’s Standards and Codes program while the LEAP criteria were still moving through ASTM.
NBS Special Publication 473 (1977): Research and Innovation in the Building Regulatory Process. It publishes Otis M. Mader’s September 1976 NIBS keynote, ‘The National Institute of Building Sciences-A Progress Report,’ describing the newly created NIBS, its proposed national role in performance criteria, evaluation and prequalification, and its still-unfinished startup status.
NBS Special Publication 552 (1979): Research and Innovation in the Building Regulatory Process. Gene A. Rowland’s retrospective account supplies the fuller LEAP history: the 1970 NCSBCS request, LEAP’s January 1971 launch, transfer of the LEAP reports to ASTM, and ASTM E541’s 1975 consensus result.
Core Finding
Operation Breakthrough was not limited to the evaluation of housing systems themselves. Within the same federal building-regulatory effort, Project LEAP addressed the qualification of the laboratories and agencies responsible for systems analysis, testing, inspection, and compliance assurance. NBS and NCSBCS then transferred the LEAP research to ASTM, where Committee E32 produced ASTM E541 by consensus in 1975.
Janet Thome Response To His Testimony
Why Do I Care?
I care because we have a housing crisis with no end in sight and I feel what is being proposed here will raise the cost of housing. ASTME541 was accidentally withdrawn in 2019 and I advocated for its reinstatement and it was published in 2022. The first HUD publication, HUD’s Off-Site Construction Research Roadmap exclusively promoted the International Code Council framework, including ICC/MBI 1200 and 1205 standards, ICC-ES evaluation reports and funds were spent to investigate the relative merits of the HUD Code versus ICC codes for potential regulation of manufactured housing.
Below is an anonymous report from a third party in regards to the cost increase to change to ICC/MBI 1205.
Anonymous Third Party Comments And The Acquisition Of NTA , Now Referred To As ICCNTA
ASTME541 State Adoptions
The International Code Council Weaponization Of Certification
First Virginia Memo That Left Out ASTME541
At My Request- Virginia Issued A New Memo That Included ASTME541
Does HUD's Own Research Roadmap Describe a Hub And Spoke Structure?
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August 6, 2026
Author’s Statement and Disclaimer
I was a proponent who spearheaded the tiny-house effort within ASTM, working collaboratively to establish the E06.26 Tiny Houses Subcommittee under the Committee on Performance of Buildings. I currently serve as Membership Secretary for the subcommittee.
Disclaimer: I do not represent ASTM International, and the views, findings, and conclusions expressed in this document are my own, based on my own experience, experience, public information and independent research. This submission is made in my individual capacity as President of Tiny House Alliance USA, in support of transparency, lawful compliance, and open participation in standards development.