Guest Post Mike Spooner
Mike Spooner, sent a PINS complaint to Karl Aittemini, the ICC Director Of Standards. He is a tiny home dweller who built his own beautiful tiny home. For context, please read the Petition first.
Subject: PINS Concern Regarding ICC 1215
”I am submitting this comment in response to the revised PINS from May 16th, 2025 for ICC/THIA 1215-202x: Design, Construction, Inspection and Regulation of Small Residential Units and Tiny Houses for Permanent Occupancy.
The revised scope — covering residential units up to 1,200 sq ft — appears to duplicate and potentially conflict with existing ICC and federal standards, including:
IRC, which already applies to homes of all sizes off-chassis
HUD Manufactured Housing Code, which covers homes on chassis over 400 sq ft
ICC 1200/1205, which apply to off-site construction
In particular, including homes well over 400 sq ft could:
Dilute the effectiveness of the standard for truly small homes on chassis under 400 sq ft, which are currently not covered by an existing standard.
Create confusion for jurisdictions and inspectors already tasked with navigating IRC, HUD, and modular guidelines.
Overburden small builders and owner-builders, who are a primary stakeholder for tiny houses.
Tiny homes under 400 sq ft present significantly lower structural and life safety risks than larger homes. This has important implications for:
Regulatory burden (allowing a lighter regulatory touch)
Affordability & housing access Owner-builder and small-scale builder feasibility
Transport-ability on a chassis
Reduced utilities requirements
Greater design flexibility within the prescriptive code
In addition, “Tiny House” is an established and defined term within the IRC Tiny House Appendix. In contrast, the term “Small Residential Unit” (SRU) is a brand new term, encompassing a wider range of building types and stakeholders. The original intent of ICC 1215 appeared to be to provide a permanent chassis option specifically for structures already covered by the Tiny House Appendix, addressing a gap not covered by off-site or modular standards like ICC 1200 and 1205. Expanding the scope to include all SRUs up to 1,200 sq ft blurs the lines between these distinct groups, risks stakeholder confusion, and duplicates coverage already provided by existing ICC codes and federal standards.
I suggest that ICC 1215 either:
Limit its scope to homes 400 sq ft and under, or
Clearly divide the standard into separate tiers or sections, so that smaller homes are not subject to the same requirements as larger SRUs.
This will preserve the purpose, clarity, and usefulness of the standard — especially for jurisdictions and owner-builders seeking a practical, code-aligned pathway. ”
One Day Left To Sign The Petition
