The ICC 1215 Committee Is Missing The Expertise From The Transportation Sector
I have sent a request for a new PINS to ICC regarding the ICC 1215 standard. The voting committee does not include representation from any of these transportation-related stakeholder groups despite the standard’s expansion into matters affecting chassis design, transportation use, motor vehicle equipment, registration, titling, and taxation. Tax assessors possess expertise regarding how these units are taxed as both personal property and real property. Transportation stakeholders possess expertise regarding the manufacture, transportation, inspection, certification, registration, and regulation of wheeled structures. Skip to related blog posts at the end of this article for more context of the issue.
What Is A PINS?
ANSI PINS (Project Initiation Notification System) is the mandatory notification mechanism used by ANSI-Accredited Standards Developers (ASD) to announce the commencement of a new American National Standard (ANS) project or a substantial revision to an existing one.
ANSI Essential Requirements
ANSI Essential Requirements
2.5.1 Project Initiation Notification System (PINS)
At the initiation of a project to develop or revise an American National Standard, notification shall be transmitted to ANSI using the Project Initiation Notification System (PINS) form, or its equivalent, for announcement in Standards Action. Comments received in connection with a PINS announcement shall be handled in accordance with these procedures.
A statement shall be submitted and published as part of the PINS announcement that shall include:
- an explanation of the need for the project, including, if it is the case, a statement of intent to submit the standard for consideration as an ISO, IEC or ISO/IEC JTC-1 standard; and
- identification of the stakeholders (e.g., telecom, consumer, medical, environmental, etc.) likely to be directly impacted by the standard; and
- the interest categories that will or are expected to comprise the consensus body.
If the response to sub-section (b) changes substantively as the standard is developed, a revised PINS shall be submitted and published.
Basis Of My Request
The May 16, 2025 PINS failed to include stakeholders from the transportation sector that not only will be affected by ICC 1215, but could offer much needed expertise to the drafting of the standard.
Stakeholders that were not identified include HUD, DOT, NHTSA, SAE, FMCSA, state troopers, chassis fabricators, mechanical engineers, trailer manufacturers, manufacturers of motor vehicle equipment, motor carrier operators, freight companies, dealers, titling and registration authorities, and tax assessors.
All previous PINS notifications have acknowledged stakeholders from the viewpoint of the tiny house as a building only. As ICC 1215 has been drafted, however, the standard has expanded into areas involving permanent chassis, wheeled structures, transportation-related design considerations, inspection, certification, taxation, and regulatory compliance.
These subjects directly impact stakeholder groups that were not identified in the PINS. They also require expertise from disciplines that were not recognized as stakeholders during project initiation.
The omission of these stakeholders is significant because ICC 1215 now addresses subjects for which these stakeholders possess specialized expertise, including transportation, chassis design, motor vehicle equipment, registration,regulatory compliance, and taxation.
The voting committee does not include representation from any of these transportation-related stakeholder groups despite the standard’s expansion into matters affecting chassis design, transportation use, motor vehicle equipment, registration, titling, and taxation. Tax assessors possess expertise regarding how these units are taxed as both personal property and real property. Transportation stakeholders possess expertise regarding the manufacture, transportation, inspection, certification, registration, and regulation of wheeled structures.
My Letter To ICC
ICC 1215 Has A Huge Responsibility
The ICC 1215 committee has a huge responsibility to follow laws and to write provisions that will guide the manufacturers accurately which I feel they are not doing. I have sent a third preemption inquiry regarding motor vehicle preemption to the ICC CEO. I have been tracking all the modular wrecks that are coming off the trailers because they are not legal and this is a very serious subject.
Preemption Inquiry To ICC
Motor Vehicle Safety Act
Related Blog Posts
ICC 1215 Promotes ‘Independent Carrier System’ Ghost Trailer
The ICC 1215 standard has a transportation section that is promoting a type of trailer that they have named ”independent carrier system ” and they have given it an exemption from DOT requirements. There are more and more documented wrecks of this type of trailer. The image above shows that the modular fell of the trailer. They are not even using the term trailer, though that is exactly what it is. I have nicknamed the trailer the ‘Ghost Trailer’, because it is never in the NHTSA/DOT system.
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ICC Board Continues To Disregard Motor Vehicle Preemption
The International Code Council (ICC) has published its official response on a second preemption inquiry that I submitted regarding the ICC/THIA Standard 1215 on the Design, Construction, Inspection and Regulation of Tiny Houses for Permanent Occupancy. What’s missing is the document that prompted it—my preemption inquiry outlining the federal legal conflicts at issue. Scroll down for an all correspondence and an executive summary and a short video explainer.
My First Preemption Inquiry
During the development of ICC/THIA 1215, Design, Construction and Regulation of Small Residential Units and Tiny Houses for Permanent Occupancy, questions of federal preemption are unavoidable. The standard reaches into areas governed by United States federal motor-vehicle and transportation law, making transparency and careful legal review essential. In that context, I submitted a written complaint raising federal preemption concerns and providing supporting documentation. What followed raised serious concerns—not about disagreement, but about how the preemption process and public record were handled.
Learn More
May 31, 2026
