The Colorado Tiny House Bill Regarding Section 5-17-2 Rules

[Janet Thome]

Once again I want to thank those that were on the call yesterday and your amazing openness to letting us participate and help you mold this bill.

In that same spirit of openness, I want to invite your participation when our ASTM committee is granted, which is hopefully only weeks away.

I have some thoughts on the section below from the bill.

Regarding Section 5-17-2 Rules

Rules promulgated by the board must include provisions 18 imposing requirements reasonably consistent with recognized and 19 accepted standards adopted by the American National Standards Institute ( ANSI), the International Code Council.

ANSI is not itself a standards developing organization. Rather, the Institute provides a framework for fair standards development and quality conformity assessment systems and continually works to safeguard their integrity. And as a neutral venue for coordination of standards-based solutions, the Institute brings together private- and public-sector experts and stakeholders to initiate collaborative standardization activities that respond to national priorities.
ANSI facilitates the development of American National Standards (ANS) by accrediting the procedures of standards developing organizations (SDOs) and approving their documents as American National Standards (ANS). This process serves and protects the public interest since standards developers accredited by ANSI – and the ANS they develop – must meet the Institute’s requirements for openness,
balance, consensus, and due process and adhere to ANSI's neutral oversight, assuring that all interested parties have an opportunity to participate in a standard’s development.
ANSI’s Roles

My  Thoughts

Above is a statement directly from the ANSI website, explaining their roles in standards development. The bill states adopted by the American National Standards Institute (ANSI). With all due respect, ANSI does not adopt standards, in the simplest of summaries, they oversee the standard developers such as ASTM, ICC,  and NFPA. 

ASTM Was Not Included?

I received a letter of support from Cathy Kipp that urged ASTM to grant the tiny house industry a committee, so I was surprised when ASTM was not listed as a standard developer on the tiny house bill. In my letter of support, I listed that I have been cultivating relationships with both NFPA and ICC.

ASTM is one of the largest ANSI Accredited Standard Developers in the world. We are not going to be developing one standard, and we are done, we will be developing and maintaining the tiny house standards indefinitely. Some of the ASTM committees are over 100 years old.

ASTM Cannabis Committee

Cannabis is an industry, very similar to the tiny house industry, and they now have 75 standards in development including cultivation, testing, security. labels, child-proof caps, lab work, etc... and the committee was invited to the federal hearings on cannabis.  I think people can really trust the safety of this product now if, for instance, they use this for a child that has seizures.

National Uniformity

The tiny house industry needs uniformity as I think you are well aware of.  I hope you will give us a few weeks, to get our approval for our committee. I have negotiated with ASTM for over a year, and have gathered the experts to develop the standards.

The last thing we need is one state doing one thing, and another state with a  whole new set of rules that will not be accepted in another. That is already what is going on.

The tiny house bill in Maine was a great success, but it promotes RV standards, which the tiny house industry needs to separate from. RVIA lobbies against state tiny house bills, mainly because of the nature of their industry, the liability in housing, and to get separated from HUD regulations.  I invited Nick with RVIA to participate with us, to find friendly solutions to the bill, instead of disrupting the bill somewhere down the line.

Thank you very much,

On Tue, Jan 25, 2022 at 4:58 PM Janet Thome <ja...@tinyhouseallianceusa.org> wrote:

Thank you for the call today.

I thought this would be helpful in our discussions.

Manufactured Home Procedural and Enforcement Regulations; Clarifying the Exemption for Manufacture of Recreational Vehicles

HUD Response: HUD respectfully disagrees with the various fundamental premises and conclusions of these commenters about secondary effects. Initially, as stated in this preamble, HUD is not regulating use of manufactured homes or RVs. More specifically, how individuals decide to use their manufactured home or RV unit after purchase—and, in some cases, after receiving a Manufacturer's Notice about the unit's compliance with RV standards—is beyond the scope of this final rule. The regulation of use and occupancy of RVs is the purview of state and local authorities, not HUD.

https://www.federalregister.gov/documents/2018/11/16/2018-24950/manufactured-home-procedural-and-enforcement-regulations-clarifying-the-exemption-for-manufacture-of

On Mon, Jan 24, 2022 at 2:24 PM Eric Fried <fri...@co.larimer.co.us> wrote:

Yes, Jennifer Cram no longer works for Larimer County, having taken a new planning job in Michigan. Please delete her from the distribution list for future posts on this thread.

Thank you for your email, Ms. Thome, and I am glad you feel this proposed bill would help us all achieve our shared goals of housing affordability, public health and life safety. I look forward to discussing this more with you on Wednesday.

	Eric Fried Chief Building Official
	Community Development Department Building Division 200 W Oak St., Suite 3100 Fort Collins, CO 80521  Phone: (970) 498-7705 | Fax: 498-7667 www.larimer.org/building

Community Development Offices will be closed Friday, January 28, 2022 

The Larimer County Community Development Department (Building, Planning, Code Compliance, Community Information Resource Technicians) will be closed to customers on January 28, 2022 to enable staff to improve our systems and handouts to better serve customers.  Building inspections will take place as usual, and the Online Customer Portal will still be available.  Permitting, staff on call, and other community development services will not be available.  Thank you for your understanding about any short-term inconvenience this may cause, and we will respond to your requests as soon as possible after the 28th. 

On Mon, Jan 24, 2022 at 3:13 PM Janet Thome <ja...@tinyhouseallianceusa.org> wrote:

I just received a bounce back to this email- cra...@co.larimer.co.us

On Mon, Jan 24, 2022 at 2:11 PM Janet Thome <ja...@tinyhouseallianceusa.org> wrote:

Greetings,

This is Janet Thome, the President of Tiny House Alliance USA. I have also been leading the exploratory initiative with ASTM International to develop global standards for tiny houses. Thank you so much for inviting us to the stakeholder's call on Wednesday. It is very exciting. I will be there, as well as a few others, including Bob Gorleski, the Vice President Of The Manufactured Structures Division for PFS TECO.

I just had a meeting today with ASTM International with the new business development team in charge of our tiny house initiative. They introduced me to the permanent staff member that will be assigned to our tiny house committee today and they told me the secretary of COTCO, ( Committees On Technical Committees Operations) has our proposal and will be introducing our initiative to the rest of the COTCO board, hopefully within the next 2 weeks. COTCO is the governing board that grants new committees.  ASTM International has 140 technical committees already.

After their review, we will have one more final approval with the ASTM International board.  The new business development team hopes we will have final approval, no later than the end of February, but hopefully mid-February. They also feel very positive regarding our approval.

Our tiny house committee will develop and maintain standards specific to tiny houses indefinitely. Attached is my letter of support for the Colorado bill, more about our ASTM Tiny House Initiative, and an additional and separate initiative regarding creating a DATA Plate and database for tiny houses that are manufactured which would be a great help to what you have proposed in the Colorado bill. I introduced you to an organization called IBTS, which is the single source for manufactured home data used to identify whether a home was built according to the HUD Manufactured Home Construction and Safety Standards (HUD code) that could develop a DATA Plate and database for tiny houses.

What Is A TinyHouse?  Tiny House On A Foundation

The most accepted definition for a tiny house pertaining to a tiny house on a foundation resulted after Appendix Q Tiny House was approved for inclusion of the 2018 IRC building code

to provide regulations and standards for tiny houses on a foundation.

Appendix Q Tiny House relaxes various requirements in the body of the code as they apply to tiny houses that are 400 square feet or less.

 

Attention is specifically paid to features such as compact stairs, including handrails and headroom, ladders, reduced ceiling heights in lofts, and guard and emergency escape and rescue opening requirements of lofts.

The International Residential Code is a comprehensive, stand-alone residential code that creates minimum regulations for one-and two-family dwellings of three stories or less.

The IRC brings together all building, plumbing, mechanical, fuel, gas, energy, and electrical for provisions for one-and two-family residences.  Appendix Q was adopted to the IRC building code standards through the ICC Code Development Process.

Jurisdictions may use Appendix Q as a model code to adopt, reference, or amend. Builders or even jurisdictions that have not adopted the 2018 IRC or the Appendix, can seek approval ”on a project basis through the alternative materials and designs provision” in the IRC.-David Eisenberg,  co-author of The Strawbale House Book.

https://www.tinyhouseallianceusa.org/appendix-q/

I have personally been following the adoption process of Appendix Q Tiny House and more than half of the country has adopted it, it has been very well received.

What Is A Tiny House On Wheels?

There is no clear definition of what a tiny house on wheels is because of our lack of standards. ''Tiny Houses On Wheels'' is a marketing term, and most often builders use RV standards.

How Is A Travel Trailer Or A Park Model A Tiny Home?

At this time, there is not one unified industry standard that is recognized for tiny homes on wheels and each jurisdiction, bank, insurance agency, etc… could have a different definition and requirements, including size and if they are allowed as a dwelling. 

Most tiny home builders are building RVs built to the NFPA 1192 Standard or the Park Model Standard, ANSI 119.5  for the ability to have them certified and registered,  to get a Vin number and title.

These standards address all safe health, life, and fire precautions.

The builders most always exceed the minimum requirements of these standards and build to 2 X 4 and 2 X 6 construction, increase insulation values, have 25-year roof warranties, increase truss loads when applicable, and use superior quality materials.

The beauty of tiny homes is they are custom built to order and can be built for all seasons with a focus on durability and longevity. They can also be built to any added requirements of the jurisdiction. 

Colorado DATA Base For Tiny Houses

There is no accurate data on how many tiny houses already exist in Colorado, or how many will be manufactured by June 2024, but we would be happy to create a team to devise some methods to help you with the data collecting.

Warm Regards,

Janet Thome Founder And President

Tiny House Alliance USA

501( c) 3 Nonprofit  Public Charity

The Future Of Tiny Is Now!

509 345 2013: Cell 509 770 1694

ja...@tinyhouseallianceusa.org

Tiny House Alliance USA 

On Mon, Jan 24, 2022 at 1:02 PM Miskell - DOLA, Maulid <maulid....@state.co.us> wrote:

Good afternoon. 

As the state agency identified in potentially overseeing a program regulating tiny homes in CO, can you or somebody else from the Tiny House Alliance USA or any other tiny home association share a definition for a tiny home? 

Also, can you provide an estimate of how many tiny homes already exist in CO and will be in place by June 30, 2023, and how many you anticipate will be produced for CO between July 1, 2023 and June 30, 2024, so we can get an idea of the workload it may take to effectively implement such a program?

Last but not least, is there an update on developing ASTM tiny home (house) standards? 

Thank you!

Mo

Maulid Miskell

Director

Office of Regulatory Oversight

Building Codes & Standards Section

Mobile Home Park Oversight Program

P 303.864.7833  |  F 303.864.7857 

1313 Sherman Street #320,  Denver, Colorado 80203

maulid....@state.co.us  |  www.colorado.gov/dola 

Under the Colorado Open Records Act (CORA), all messages sent by or to me on this state-owned e-mail account may be subject to public disclosure.

On Tue, Oct 12, 2021 at 8:10 PM Janet Thome <ja...@tinyhouseallianceusa.org> wrote:

Sorry, I saw that the document did not open.

On Tue, Oct 12, 2021 at 6:58 PM Janet Thome <ja...@tinyhouseallianceusa.org> wrote:

Thank you for including me in the email Joe. Our next ASTM call to discuss our Tiny House Standards Initiative is Nov. 8h, 2021. Please let me know if you would like to be on the call, and I will have Lissy Velez from the new business development team, send you an invitation.

Attached is our proposal that will be submitted to COTCO ( Committee On Technical Committees Operations), the governing board of ASTM that grants new committees. We have been in discussion with the new business development team to prepare us to hopefully be granted a committee specific to tiny houses.

I am also attaching the latest update.

I also was on a  recent Podcast that covers a lot of ground, if you wanted to listen to it.

Podcast

https://www.tinyhouseallianceusa.org/ethan-waldman-interviews-janet-thome-on-podcast/

These Are The Benefits Of The Tiny House Industry Being Granted A Committee Specific For Tiny Houses

1) Tiny Houses Will Be Granted A New  ASTM Committee To Develop And Maintain The Standards For Our Own Industry
2) The Committee Will Go On Indefinitely
3) We Elect Our Own Officers 
4) We Write Our Own Bylaws
5) We Select The Subcommittees Which Divide The Standards Development
6) We Elect The Officers For The Subcommittees
7) We Select The Task Groups- They Are The Ones That Have The Expertise To Write The Standards
8) We Select The Standards That Need To Be Developed
9) One Subcommittee Does Not Hold Up Another Committee For Publication Of A Standard
10) An ASTM Standard Can Be Adopted By An Authority Having Jurisdiction Immediately After Publication -No Waiting For An I-Code Cycle Change Or For A State To Adopt A Certain Year Of The IRC building Code.
11) ASTM Standards Can Be Amended Immediately After Publication
12) 150 Countries Can Participate
13) Through The Guidance Of ASTM, Our Committee Must Follow The ANSI Essential Requirements for Due Process That Include Openness, Lack Of Dominance, Balance, Coordination, Harmonization, Considerations And Views, Consensus Vote, Appeals, Compliance, And Written Procedures
14) There Are No Costs That We Incur To Develop The Standards For Publication. Except To Join As A Member Of ASTM At A Cost  Of $75.00 A Year.
15) Together We Will Create Conformity, Without Borders, Uniting For Our Common Goals, Developing A Common Language That Will Integrate The Authority Having Jurisdiction, The Consumer. And The Manufacturers And Builders, Addressing All Life, Health, Fire, And Road Safety, And To Forge The Path That Tiny Houses Are A Viable Housing Solution That Is The Answer To Affordable And Attainable Housing
16) All Our Welcome! No One Can Be Left Out
17) Through The ASTM Process, Standards Will Be Cleansed Of Personal Interests, No One Individual, Company, Organization, Country, Sector Of An Industry, Or Trade Association Can Be The '' Loudest Voice" In The Room Or Dominant The Standards Development. Everyone Matters And Has A Voice And A  Vote
18) We Will Change The Face Of Affordable Housing And Will Broaden Homeownership Globally

Thank you for your support! We would appreciate letters of endorsement to be granted a new committee and as many participants on the call, that can make it. We will possibly be voting on the next call.

Warm Regards,

Janet Thome Founder And President

Tiny House Alliance USA

501( c) 3 Nonprofit  Public Charity

The Future Of Tiny Is Now!

509 345 2013: Cell 509 770 1694

ja...@tinyhouseallianceusa.org

 

Tiny House Alliance USA 

 

 

On Tue, Oct 12, 2021 at 5:21 PM Joe Callantine <j...@lifesizetinycommunities.com> wrote:

Good evening Eric. Thank you for including me in this email.

As someone who's actively involved in community development for tiny homes as well as the ASTM Initiative, I appreciate individuals, like everyone here, looking for ways to incorporate tiny homes sooner rather than later.

The attachments you sent are great examples for getting the ball rolling for tiny homes. To your point however, they only work within that Authority having Jurisdiction.

ASTM is the way forward on a national scale, in my humble opinion. I would encourage each and every one of you to become a stakeholder in the process as we move forward. There is nothing formal at this time.

I have included Janet Thome, President of the Tiny House Alliance USA in this email for those interested in participating in the initiative. She will be able to provide further assistance on how you can get involved. Having the support and involvement of City and County Officials is certainly requested.

I make myself available for emails and phone calls for anyone who has specific questions.

Together, we'll Bring Tiny... home!

With humble gratitude,

Joe Callantine
President/CEO
Life Size: Tiny Communities
Bringing Tiny… home ™
720-460-9467

This communication is confidential and may contain proprietary or sensitive material or be otherwise protected to the extent that it exists under law regarding any type of privileged arrangement or communication between parties. Further distribution/ reproduction may be additionally restricted or encumbered please let the sender know in the event you received this distribution in error.

On 10/12/2021 4:53 PM, Eric Fried wrote:

I am looping Maulid Miskell of the Colorado Division of Housing, Tiny House trade associations and others into this conversation. Is there an ASTM standard under development for Tiny Houses, is it still in the discussion stage, or is nothing formal started yet? 

I ask because I had a meeting today with Mr. Miskell, his staff member Bruce Eisenhauer, Larimer County Commissioner Jody Shadduck-McNally and Daphne Gervais of Colorado Counties Inc. The question of a nationally recognized, appropriate Tiny House standard came up. It would be very difficult/impractical for CODOH to develop its own standard, which would only apply in CO anyway, and Tiny House owners who wanted to move to another state would be out of luck in terms of compliance. A national standard from a standards development agency like ASTM, ANSI or NFPA would be much better. If there is no national standard, the fallback could be to build Tiny Houses meant for residential not recreational occupancy to an existing standard, either the IRC or HUD standard. Those intended for recreational occupancy can already be built to the ANSI RV or Recreational Park Trailer standard.

What do you think about this question of Tiny House residential standards? I would like to move this conversation forward as we consider changes in state law and/or rules to ensure the safety of Tiny Homes while trying to make their use outside of RV Parks and on a semi-permanent basis more possible.

	Eric Fried Chief Building Official
	Community Development Department Building Division 200 W Oak St., Suite 3100 Fort Collins, CO 80521  Phone: (970) 498-7705 | Fax: 498-7667 www.larimer.org/building

On Fri, Aug 27, 2021 at 8:02 PM Joe Callantine <j...@lifesizetinycommunities.com> wrote:

Absolutely no worries Eric. I’m certain there’s a lot going on in your world. Especially with all of the construction going on.

 

I agree with you on Delta County. What I took from it is that tiny homes on wheels would be considered single family detached so long as they are attached to permanent infrastructure. I.e. well, septic, and power.

 

As you pointed out, Eric, there is obviously some regulatory gray area around tiny homes. Many of us participating in the ASTM Initiative understand this and believe that ASTM would be a more well-rounded approach to a construction, health and safety approach to tiny homes. They are a bit of a hybrid structure and don’t exactly fit into the boxes of ICC, etc.

 

Myself and the President of the Tiny House Alliance USA is working with ASTM to put together a potential virtual meeting with Colorado based stakeholders and ASTM on how we could collaborate. Once again, Colorado could serve as a pioneer in setting standards in a new industry.

 

If you’d be so inclined, Eric, could you write a letter of support toward the ASTM Initiative, from your perspective as a Chief Building Official?

 

Attached is Cathy and Chris’ letters for an example.

 

I look forward to connecting with you in the very near future on bringing tiny… home!

 

With humble gratitude,

Joe Callantine
President/CEO

Life Size: Tiny Communities

Bringing Tiny… home ™
720-460-9467

This communication is confidential and may contain proprietary or sensitive material or be otherwise protected to the extent that it exists under law regarding any type of privileged arrangement or communication between parties.  Further distribution/ reproduction may be additionally restricted or encumbered please let the sender know in the event you received this distribution in error.

 

From: Eric Fried <fri...@co.larimer.co.us>
Sent: Friday, August 27, 2021 7:48 PM
To: Joe Callantine <j...@lifesizetinycommunities.com>
Cc: Cathy Kipp <cathy...@gmail.com>
Subject: Re: Tiny Homes

 

Sorry for the delay. It's been an interesting week.

 

I read this all over with great interest, especially the ASTM standard in development, which I believe is the real long-term solution. 

 

El Paso's Land Use Code allows Tiny Homes not per the ANSI standard if a Colorado Engineer approves the structural elements. Who checks the wiring, plumbing, gas pipe, gas venting, fireplace etc etc? The state Division of Housing claims jurisdiction over prefabricated homes coming to a site. The state Electrical and Plumbing Boards say without approved inspections of construction, you may not hook up to utilities, but that is allowed by El Paso County. I don't want to get them or the state in trouble, but only one of two things can be true here: either the state is not enforcing its own rules and allowing El Paso to violate them, or the state lacks the authority to truly enforce the rules they have put forth. Revised state legislation and rulemaking could hopefully solve that problem.

 

Maine's state law is also of interest, but I suspect their overall regulatory structure for housing, both prefab and site-built, differs significantly from Colorado's. I read the Lyons and Walsenburg ordinances as well. Delta County's Land Use Code was too long for me to sift through. 

 

A virtual meeting of a broader group of interested parties, stakeholders, subject matter experts, state legislators and staff, and city, county, and state officials would be great for us all to gain clarity and coordination in moving forward with the best solution.

 

	Eric Fried Chief Building Official
	Community Development Department Building Division 200 W Oak St., Suite 3100 Fort Collins, CO 80521  Phone: (970) 498-7705 | Fax: 498-7667 www.larimer.org/building

 

 

 

 

On Wed, Aug 25, 2021 at 5:57 PM Joe Callantine <j...@lifesizetinycommunities.com> wrote:

Good evening Cathy and Eric!

 

Thank you, Cathy, for the introduction!

 

There are likely many places where Eric and I can overlap in regards to tiny homes.

 

A little about me: I am an electrician by trade, turned entrepreneur after I found out about the regulatory issues that surround the placement and legality of tiny homes. I built my own tiny home and like many looking an affordable housing option; found that I can’t just place it anywhere and live. I launched LSTC to serve as a vehicle to develop tiny home specific communities by working with cities and counties so that we can truly have an attainable option to the current housing market. We are currently in process of getting Bonsai Village up and running in El Paso County. We’ve even been in the news a couple times!

 

https://www.thedenverchannel.com/news/local-news/loveland-tiny-home-festival-attracts-buyers-seeking-cheaper-smaller-options

https://www.kktv.com/2021/08/02/tiny-homes-may-be-welcome-near-colorado-springs-soon/

 

Along with what we’re doing locally, myself and LSTC are working with a group of 100 other people from around the world to engage ASTM to help further legitimize the tiny home industry by fixing the lack of standards. Because of having no standards in place, it’s been the “Wild, Wild, West”. Which has prevented the wide spread adoption of tiny homes. Since ASTM is a global leader in standards development, myself and many others feel that this would be an excellent way forward for DIY-ers, like myself, big and small builders. Colorado, alone, is home to nearly 20 small tiny home builders. Each of which employ anywhere from 5 to 20 employees.

 

You’ve likely read Mr. Kennedy’s letter of support addressed to ASTM on how a standard like this would help to ensure the quality of construction and safety of these structures and how it would be of huge benefit to the housing market. If either of you or any of your colleagues would be willing to write a similar letter in support of this initiative, it would be greatly appreciated.

 

After having a phone conversation with Cathy, I’d like to attach some documents from the State of Maine, who recently passed legislation legalizing tiny homes on wheels anywhere single family zoning exists. As well as a few local examples from Colorado jurisdictions.

 

Beyond this, I’ve talked with the person driving the ASTM Initiative, and she suggested the possibility of a potential virtual group meeting between ASTM and those involved in the creation of this new bill for Colorado.

 

I hope to continue to be a resource for you as this progresses. Together we’ll Bring Tiny… home!

 

With humble gratitude,

Joe Callantine
President/CEO

Life Size: Tiny Communities

Bringing Tiny… home ™
720-460-9467

This communication is confidential and may contain proprietary or sensitive material or be otherwise protected to the extent that it exists under law regarding any type of privileged arrangement or communication between parties.  Further distribution/ reproduction may be additionally restricted or encumbered please let the sender know in the event you received this distribution in error.

 

From: Cathy Kipp <cathy...@gmail.com>
Sent: Wednesday, August 25, 2021 3:22 PM
To: j...@lifesizetinycommunities.com; Eric Fried <fri...@co.larimer.co.us>
Subject: Tiny Homes

 

Hi Joe and Eric,

 

Joe, I got your name from my colleague Representative Chris Kennedy as someone who has been working in support ASTM standards for Tiny Homes.

 

Eric Fried is our Chief Building Official here in Larimer County and has been working on the tiny home issue for quite some time with an interest in ensuring we have a safe way for people to live legally in tiny homes on wheels in Colorado.

 

I have filed a bill request to work on this issue (and will hopefully have a bill drafter assigned soon). But I thought I should connect the two of you to see if there are any ideas you might find useful to share with each other - and potentially going forward as we work on this legislation.

 

Regards,

Cathy

_____________________________________________________________

Representative Cathy Kipp

She/Her/Hers

Colorado House of Representatives for House District 52

Cell: 970-219-5267  Legislative office: 303-866-4569

200 East Colfax, Room 635, Denver, CO  80203

--

Warm Regards,

Janet Thome Founder And President

Tiny House Alliance USA

501( c) 3 Nonprofit  Public Charity

The Future Of Tiny Is Now!

509 345 2013: Cell 509 770 1694

ja...@tinyhouseallianceusa.org

Tiny House Alliance USA 

Founder Of Tiny Portable Cedar Cabins

--

Warm Regards,

Janet Thome Founder And President

Tiny House Alliance USA

501( c) 3 Nonprofit  Public Charity

The Future Of Tiny Is Now!

509 345 2013: Cell 509 770 1694

ja...@tinyhouseallianceusa.org

Tiny House Alliance USA 

Founder Of Tiny Portable Cedar Cabins

--

Warm Regards,

Janet Thome Founder And President

Tiny House Alliance USA

501( c) 3 Nonprofit  Public Charity

The Future Of Tiny Is Now!

509 345 2013: Cell 509 770 1694

ja...@tinyhouseallianceusa.org

Tiny House Alliance USA 

Founder Of Tiny Portable Cedar Cabins

--

Warm Regards,

Janet Thome Founder And President

Tiny House Alliance USA

501( c) 3 Nonprofit  Public Charity

The Future Of Tiny Is Now!

509 345 2013: Cell 509 770 1694

ja...@tinyhouseallianceusa.org

Tiny House Alliance USA 

Founder Of Tiny Portable Cedar Cabins

--

Warm Regards,

Janet Thome Founder And President

Tiny House Alliance USA

501( c) 3 Nonprofit  Public Charity

The Future Of Tiny Is Now!

509 345 2013: Cell 509 770 1694

ja...@tinyhouseallianceusa.org

Tiny House Alliance USA 

Founder Of Tiny Portable Cedar Cabins

--

Warm Regards,

Janet Thome Founder And President

Tiny House Alliance USA

501( c) 3 Nonprofit  Public Charity

The Future Of Tiny Is Now!

509 345 2013: Cell 509 770 1694

ja...@tinyhouseallianceusa.org

Tiny House Alliance USA 

Founder Of Tiny Portable Cedar Cabins

[Janet Thome]

I had an afterthought after my last email to regarding 

Regarding Section 5-17-2 Rules

Rules promulgated by the board must include provisions 18 imposing requirements reasonably consistent with recognized and 19 accepted standards adopted by the American National Standards Institute ( ANSI), the International Code Council.

Did you mean approved by ANSI, instead of adopted?

Thanks!

[Eric Fried]

The current language (page 10, line 15) references "recognized and accepted standards" adopted by ANSI, ICC, NFPA etc. ANSI was added to the list but otherwise the language is existing. I agree the wording should be tweaked since ANSI does not develop  standards per se, but helps by accrediting the procedures used by the actual standards-developing organizations.   

	Eric Fried Chief Building Official
	Community Development Department Building Division 200 W Oak St., Suite 3100 Fort Collins, CO 80521  Phone: (970) 498-7705 | Fax: 498-7667 www.larimer.org/building

Community Development Offices will be closed Friday, January 28, 2022 

The Larimer County Community Development Department (Building, Planning, Code Compliance, Community Information Resource Technicians) will be closed to customers on January 28, 2022 to enable staff to improve our systems and handouts to better serve customers.  Building inspections will take place as usual, and the Online Customer Portal will still be available.  Permitting, staff on call, and other community development services will not be available.  Thank you for your understanding about any short-term inconvenience this may cause, and we will respond to your requests as soon as possible after the 28th. 

[Janet Thome]

Thank you for clarifying, I appreciate it.

[Eric Fried]

Or maybe we take out ANSI (which has the RV/Park Model RV stabdard) and put in ASTM, which is writing (we hope) a Tiny Home standard?

	Eric Fried Chief Building Official
	Community Development Department Building Division 200 W Oak St., Suite 3100 Fort Collins, CO 80521  Phone: (970) 498-7705 | Fax: 498-7667 www.larimer.org/building

Community Development Offices will be closed Friday, January 28, 2022 

The Larimer County Community Development Department (Building, Planning, Code Compliance, Community Information Resource Technicians) will be closed to customers on January 28, 2022 to enable staff to improve our systems and handouts to better serve customers.  Building inspections will take place as usual, and the Online Customer Portal will still be available.  Permitting, staff on call, and other community development services will not be available.  Thank you for your understanding about any short-term inconvenience this may cause, and we will respond to your requests as soon as possible after the 28th. 

[Janet Thome]

That would be great to include ASTM.  And yes, we hope we get final approval, though as I mentioned we are going through all the final steps of being approved, we are just following the protocol. At our last organizational meeting, our final vote for approval was 53 to 7, to request a new committee with ASTM.

I am not sure if everyone has seen the proposal, which is attached.  The beauty of how the ASTM committees are set up is we will elect officers, write bylaws, chose the subcommittees, elect the officers for those committees, and will have the task groups to do the heavy lifting to develop the standards. One committee does not hold up another committee.

The first standard that will probably be published will be a standard for tiny houses on wheels. The most needed.

I am also very excited about our Certification Committee, which will be completely in line with what the states require. We are very blessed to have third-party agencies participating with us that have over 30 years experience in the manufactured housing, Modular Construction, RV, and Park Model Industry, and also understand standards development.

The third-party agencies could possibly be involved to help you to inspect the ''As-Built Tiny Homes''

Looking forward to our call. Thank You!

[Janet Thome]

Thank you so much for a great meeting yesterday! I am including Nick, with RVIA in this email.

I am grateful that you saw the wisdom in eliminating the RV residence term.

Could we please try and find a consensus with the advisory board and the potential ASTM Tiny House Committee in regards to tiny house terms before making changes?

We have gathered stakeholders from Canada, Australia, New Zealand, Italy, China, and the potential is the participation of 150 countries to develop tiny house standards.

Movable Tiny Homes Uses RV Standards

It was suggested last night from Byron with the Tiny Home Industry Association that we change the term tiny house on wheels to movable tiny homes.

I respectfully disagree with changing the term because the term movable tiny homes are defined in ordinances that use NFPA 1192 and ANSI 119.5, which are RV and Park Model Standards, such as in LA.

LA Department Of Building Safety

Permitting Movable Tiny Houses As ADUs

Movable Tiny House Correction Sheet

As an industry, we all need to create the new terms, utilizing the consensus process, because we are creating a new classification, separated finally from all other industries.

RV Language

I so appreciate the attitude of Cathy, Mo, and Eric, to still want to find a solution to the tiny houses that are already built, not wanting people to be kicked out of their terms, and understanding the urgent need for housing.

I  spoke to Nick after our call, and he said, which he can verify, that he does not care if RVs are hooked up to utilities, just do not call them a residence. It comes down to terminology.

Extended Stay Permit

To handle all the tiny houses and RVs that are being lived in as a residence, that are going to be built before 2023 for your registry, how about creating an extended stay permit that needs to be renewed so often? This would be an incentive for them to join the registry. The permit extends their stay beyond 30 days, and it is not called a residence and would have all your requirements for the extended stay.

New Draft

Could I please have a copy of the new draft? Thank you!

[Miskell - DOLA, Maulid]

Agreed. I thought last night was a great discussion as well.

My two cents for what it's worth: I don't think the term is what really matters--in our draft it is simply "tiny home"--I think what really matters is how it is actually defined and to make sure it is distinct from park models, RVs, manufactures homes, and modular homes. Some states use the term "small home", the IRC Appendix Q uses "tiny house". Whatever the term, what matters is what that entity or jurisdiction has included in the definition for the term it will use for its purposes. 

Mo

Maulid Miskell

Director

Office of Regulatory Oversight

Building Codes & Standards Section

Mobile Home Park Oversight Program

P 303.864.7833  |  F 303.864.7857 

1313 Sherman Street #320,  Denver, Colorado 80203

maulid....@state.co.us  |  www.colorado.gov/dola 

Under the Colorado Open Records Act (CORA), all messages sent by or to me on this state-owned e-mail account may be subject to public disclosure.

[Janet Thome]

Adding my 2 cents to your cents, 😀

I personally have been following the adoption process of Appendix Q Tiny House, and I spoke to many states, and so many were happy that there was something official for tiny houses on a foundation, and the AHJ, the jurisdiction,  the builder, and consumer became integrated because there was finally uniformity, a term, and a definition.

The reason I feel like our terms and definitions are so important is because as we separate our industry from the Modular, Manufactured Home, and RV Industry, we have to clearly define what a tiny home on wheels is, so it is no longer left to interpretation, the grey areas are closed, and to deal with all those questions that were asked last night that we are already working on including

Registration

Titles

Regulations for manufacturers to obtain a WMI #

Regulations for dealers

When is a tiny home on wheels personal property?

When is a tiny home on wheels real property?

The ability to obtain financing

I like it that your bill is broad, I was just concerned that a stakeholder mentioned the change to movable tiny homes. 

The clearer our terms, and definitions, which is why we are developing tiny house standards for uniformity, the less work for the AHJ. All over the world, they are dealing with what is a tiny house, and do you accept them? I would love to trade that time spent for the allowance of them, and the AHJ giving out permits!

Insurance

By the way, insurance for tiny houses is now a buyer's market. Companies cover owner-occupied, tenant occupied, airbnbs, off-grid,  and transport. I think that adds to the safety of the home and for communities.

Thank you all again, I so appreciate your knowledge and spirit in developing the bill.

[Janet Thome]

Hello,

I wanted to introduce everyone to Rick Gagliano, the founder of Pins Foundation and the owner of the patents for Diamond Pier Foundations and Ground Frame.

https://www.tinyhouseallianceusa.org/diamond-pier-foundation-for-tiny-houses/4

Rick is an ASTM Tiny House stakeholder and was on the call last night, but he was having trouble getting on, so did not add his contact.

The Seattle Block Project has used Diamond Pier Foundations for their very small tiny homes under 200 square feet and there was a case study in Lynnwood, Wa where they allowed a park model to remove the axles and wheels to be placed on a Diamond Pier Foundation.

Ground Frames is the other Pins Foundation product that could be used for tiny houses, including tiny houses on wheels.

I think Rick can confirm, that these types of foundations, could be temporary, or permanent, where both wheels and axles could stay on.

I was excited when Eric mentioned this on the call regarding a foundation for tiny houses or RVs, so they could legally be hooked up to utilities because we have this concept in our ASTM Tiny House Proposal.

What is exciting is a tiny house could be mobile, permanent, and mobile again.

We will be filming an installation very soon that I will share with you.

You can reach Rick at at 253 405 9787

ri...@pinfoundations.com

Ground Frame

Diamond Pier Foundations

[Cathy Kipp]

Thanks so much, Janet! I will add him to our stakeholder list.

Best,

Cathy

_____________________________________________________________

Representative Cathy Kipp

She/Her/Hers

Colorado House of Representatives for House District 52

Cell: 970-219-5267  Legislative office: 303-866-4569

200 East Colfax, Room 635, Denver, CO  80203

[Janet Thome]

Thank you

[Janet Thome]

Good Morning,

Would it be possible to schedule one or two more calls with the stakeholders? I understand you will appoint an advisory council for a lot of the decisions, but perhaps we can discuss this in broad terms. The main question is how can we keep this affordable, so tiny houses can be a solution for attainable housing?  If calls are not possible. Could a FAQ be created?

Advisory Council

How are the members selected for the advisory council? Can we nominate anyone?

First Call On As-Built  Tiny Houses

• Addressing the registry
• The path for permitting
  
• Possible temporary foundations
  
• Cost of hooking up to utilities
  
• Incentives to join the registry
• Will there be different rules in RV, Mobile Home Parks, Tiny House Communities?
  

The Colorado State Manufactured Tiny House Program ( Not Sure Of Your New Title)

• Costs Are First And Foremost On Everyone's Mind
  
• Would The State Consider Pre-Approved Plans? 
• Would The State Consider Self-Certification for builders that have pre-approved plans for certain models that are not custom after they have established a relationship with the state, and are in compliance, and have proven themself for so many builds? 
• Process for out-of-state builders shipping into Colorado.
  

Thank you for your consideration,

[Eric Fried]

The bill is being redrafted to accommodate some changes based on discussions at the stakeholder meetings. It would be best to wait for the new bill language, which we will send out, see if it answers all/some of the questions, then schedule any additional phone calls or meetings as needed. At least that is my opinion. 

	Eric Fried Chief Building Official
	Community Development Department Building Division 200 W Oak St., Suite 3100 Fort Collins, CO 80521  Phone: (970) 498-7705 | Fax: 498-7667 www.larimer.org/building

The 2021 Building Codes will take effect in Larimer County on March 1! See https://www.larimer.org/building/2021-building-codes-are-coming for details.

[Janet Thome]

Thank you very much.

[Cathy Kipp]

Yes. Agreed. We will get you the updated draft as soon as we have it. Always happy to talk more after that.

Thanks!

Best,

Cathy

_____________________________________________________________

Representative Cathy Kipp

She/Her/Hers

Colorado House of Representatives for House District 52

Cell: 970-219-5267  Legislative office: 303-866-4569

200 East Colfax, Room 635, Denver, CO  80203

[Janet Thome]

Appreciate all of you so much!!! It is so refreshing because we have spent years with planners, code officials, and the NIMBY group acting like tiny houses on wheels is equivalent to Godzilla😀 coming down the road!

Thank You!

[Janet Thome]

Tiny House Trailers

With our potential new  ASTM Tiny House Committee, we have proposed to develop standards for tiny house trailers.  There have been several instances where a tiny house trailer did not have enough axles, so the tiny house could not be moved. There are no true standards specific for tiny house trailers at this time.  We need to address all the regulations for selling, purchasing, registration, taxation, and altering the trailer.

There is an organization called the National Association Of Trailer Manufacturers( NATM) that is bringing uniformity to manufacturers for consumer safety.

They guide their members on how to get a world manufactured (WMI) # at SAE International and then register at the DMV.

NATM

https://www.natm.com/

SAE International

Since 1981, global automotive manufacturers have utilized a complex numbering system called a Vehicle Identification Number (VIN) that uniquely describes a vehicle. This number provides a coded description of the vehicle including manufacturer, year of production, place of production, and vehicle characteristics. Because of our unique position within the mobility industry, SAE International is contracted by the National Highway Traffic Safety Administration (NHTSA), to assign a selected portion of the VIN, specifically called the World Manufacturers Identifier (WMI).

https://www.sae.org/standardsdev/groundvehicle/vin.htm

Federal Law:  Would This Require A Second Label? One For The Trailer, One For The Tiny House

Federal Laws If You Alter A Motor Vehicle: Code Of Federal Regulations Alterer means a person who alters by addition, substitution, or removal of components (other than readily attachable components) a certified vehicle before the first purchase of the vehicle other than for resale.https://ecfr.federalregister.gov/current/title-49/subtitle-B/chapter-V/part-567 (edited)

It was suggested to me that perhaps to follow the federal law, if a trailer is altered, or added to, such as a tiny home being built on it, it possibly might need a second label. No one is doing this, but as we embrace regulations, this is something I want to address.

There are a lot of tiny house trailers being manufactured, and then sold to manufacturers who build on the trailers

There are also builders who build both the trailer and tiny home

There are builders who are building tiny homes, using old manufactured home axles.

Would love your thoughts on the federal law and potential second label.

Thank you

On Wed, Feb 2, 2022 at 5:58 PM Jody Shadduck-McNally <shad...@co.larimer.co.us> wrote:

Thank you Representative Kipp, Eric, and Maulid for your continued work on this legislation and for your continued engagement of stakeholders.

Gratefully,

	Jody Shadduck-McNally Larimer County Commissioner, District 3
	Commissioner's Office 200 W Oak St, Fort Collins, 80521 | 2nd Floor W: (970) 498-7003| M: (970) 939-0558 jshadduc...@larimer.orgl | www.larimer.org

[Janet Thome]

Greetings,

I just heard from Lissy Velez, the program manager that has been in charge of our ASTM Tiny House Standards Initiative and she said that the ballot has gone to COTCO, with a return date of Feb. 18th, 2022.

COTCO ( Committees on Technical Committees Operations) is the governing board that grants new committees.

Thank You!

On Fri, Feb 4, 2022 at 6:06 AM Janet Thome <ja...@tinyhouseallianceusa.org> wrote:

In our discussions with the ASTM stakeholders., we have discussed the potential of developing 2 standards for tiny houses on wheels.

# I Meant For The Road- Personal Property

Potential Size- 8.6' wide up to 34' in length that could be pulled by a truck and registered at the DMV.

# 2 Real Property Very Important For Financing

The tiny house could be up to 400 square feet, but is built and transported to the permanent location and it would be real property. It could be on wheels, a carrier system, or a retractable trailer, frame on or off.

Same Construction Standards

In my opinion, it would be wise that both types are built to the same construction standards, utilizing the zone maps for climate requirements, so the jurisdiction does not question if the first type of tiny house is safe and suitable for their climate and could go through a procedure to become real property in the future.

Procedure To Change To Real Property

Snohomish, Wa. has a great example

Are park model trailers real property?

 When a 'park model' has substantially lost its identity as a mobile unit by virtue of being permanently sited in location and placed on a foundation of either posts or blocks with connections with sewer, water, or other utilities for the operation of installed fixtures and appliances the "park model" meets the definition of "real property".  RCW 82.50.530

https://snohomishcountywa.gov/Faq.aspx?QID=286