Report on the Viability and Disaster Resilience of Mobile ...

Report on the Viability and Disaster Resilience of Mobile Home Ownership and Parks

DECEMBER 2013

Acknowledgments

This report was prepared by Paul Luciano, MPH, Dan Baker, PhD, Kelly Hamshaw, MS, Nolan Riegler, JD and the Department of Housing and Community Development of the Agency of Commerce and Community Development.

Table of Contents

Introduction Executive Summary

5

Municipal Bylaws and Processes Affecting

7

Mobile Home Park Development

55

Recommendations

55

PART I: A Disaster Resilience Plan for Mobile Homes

Mobile Home Innovations and Replacements

56

and Mobile Home Parks in Vermont

11

Permanent Structures as Mobile

Defining and Assessing Risk Flood Risk Infrastructure Risk

Home Replacement

56

11

Cottage Zoning as an Alternative to

12

Mobile Home Parks

57

14

Next Step Network

58

Financial Risk

15

Recommendations

59

Recommendations Parcel Identification

15

Park Infrastructure and Maintenance

59

17

Background

59

Process Recommendations

17

MHP Habitability Requirements

59

22

Comparison with other Jurisdictions

60

Relocation and Acquisition Recommendations

23

Licensing and Registration

61

27

Conclusion

61

Planning for Disasters and Seizing Opportunity

28

Recommendations

62

Emergency Planning for Park Communities

28

Initiatives

31

PART III: Challenges and Recommendations

63

Anchoring Mobile Homes and Fuel Tanks Recommendations

31

33

Historic and Current Challenges

63

Response and Recovery Guidance for Action During and After a Disaster

34

Recommendations

Improving Disaster Resilience

64 64

34

Improving Mobile Home Park Viability

65

Recommendations

37

Appendices

67

PART II: Policy Challenges and Opportunities 39

Mobile Home Financing

39

Vermont and the National Mobile

Home Financing Landscape

39

Recent Vermont Policy Changes

44

Conclusion

45

Recommendations

45

Barriers to Mobile Home Park Purchase and

Development

46

Historic Survey of Mobile Home Park

Development in Vermont

46

Alternatives to Privately Owned

Mobile Home Developments

48

Appendix 1: FEMA Resources

69

Appendix 2: Sample MHP Risk

Assessment Data--MHPs Impacted

by Tropical Storm Irene

72

Appendix 3: Local Mobile Home Financing

Options

73

Appendix 4: Detailed Summary of Cross

Jurisdictional Research

75

Appendix 5: DHCD Mobile Home

Condemnation Report

82

Appendix 6: List of Sources for Part II

of the Report

87

Appendix 7: List of Abbreviations

89

3

Introduction

Mobile homes and mobile home parks have long been important components of Vermont's affordable housing landscape. The US Census Bureau reports 22,3171 mobile homes in the state and the majority of those homes are located on privately-owned or rented property while one- third are located within Vermont's 246 mobile home parks. Increasingly, park closures, sales, infrastructure challenges, and flooding events have demonstrated the vulnerability of this housing stock. Typically, owners of mobile homes and residents of parks have fewer resources with which to manage these dislocations. The Department of Housing and Community Development (DHCD) administers the state's mobile home park laws which serve to protect residents from unjustified rent increases and loss of their homes as a result of the sale or closure of a park. It also conducts an annual survey of parks, and has adopted rules for the warranty of habitability. In Tropical Storm Irene's devastating aftermath, DHCD expanded its work on mobile home park issues to include disaster resilience and began collaborating with the University of Vermont (UVM), which was already engaged in this work.

In 2012, the Vermont General Assembly passed and Governor Peter Shumlin enacted Act 137 which directs the Department to engage in a study to:

1. Develop strategies for improving the resilience of parks to disasters and determine those most vulnerable to natural hazards and other risks;

2. Identify barriers to mobile home ownership;

3. Recommend actions for encouraging resident owned cooperatives or non-profit ownership

to address loss of parks due to sale, closure, or natural disaster

4. Assess potential alternatives to the conventional mobile home that may be more affordable when considering energy, water, sewer, and other costs

5. Propose effective mechanisms for adequate maintenance and safety of park roads and public spaces.

To address these questions, the Department engaged a group of consultants to assist it in the required research. Combined, Paul Luciano, MPH, Dan Baker, PhD, Kelly Hamshaw, MS and Nolan Riegler, JD have extensive experience in disaster recovery, planning and mobile home issues. This report lays out the results of their work as well as recommendations for improving the resilience and viability of mobile home and park ownership. Taken in whole, or in part, DHCD recommends they serve as the basis of efforts to improve the stability of this important segment of the state's affordable housing.

1. U.S. Census Bureau. (2010). American Community Survey 5-Year Estimates for Vermont. Tables D02, DP 03, & HP03.

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