Manufactured Housing Strategy Action Plan Final ReportManufactured Housing
Strategy Action Plan:
Final Report
Q3 2019 – Q4 2021
Report date: March 11, 2022
| Contents
I.Introduction
II.Completed/Ongoing Action Item by Guiding Principle
2.Accountability
3.Affordability
6.Community
9.Viability
III.Potential Future Actions
| Manufactured Housing Strategy Action Plan: Final Report
Introduction
The Manufactured Housing Strategy Action Plan is a city-focused work plan in effect from
Strategy adoption (September 1, 2019) through the end of 2021. Completion of each action
item depended on funding, staffing and annual council prioritization. In 2020, the Action Plan
was revised due to COVID-19 impacts, particularly reduced staffing. Despite these impacts,
nearly all action items were completed, continued or set in motion. This final report
summarizes outcomes of the Strategy categorized by the Manufactured Housing Strategy’s
Guiding Principles for Decision Making: Accountability, Affordability, Community and Viability.
Guiding Principles for Decision Making:
-Accountability
-Affordability
-Community
-Viability
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Completed/Ongoing Action Items by Guiding Principle
Guiding Principle: Accountability
Agreements, ordinances and requirements will have clearly defined and practical enforcement
mechanisms accessible to the affected parties, especially to residents of manufactured home
communities.
Mobile Home Park Oversight Program. House Bill 19-1309, “Mobile Home Park Act
Oversight”, enacted in 2019 and supported by the city, established a Mobile Home Park
Oversight Program. Prior to this law, courts provided the primary means to settle
landlord-tenant disputes. Overall, park owners have greater access to attorneys and can
better bear such a cost compared to homeowners. The new program began operating in
May 2020. It supports the resolution of disputes between homeowners and park owners
through investigations, determinations and, when violations continue, enforcement.
Operating costs are supported by a low annual licensing fee; in 2021, the cost was less
than $30 per leased space, up to half of which could be passed along to homeowners.
Concerns have arisen related to the pace of case resolution, but staffing increases are
planned to address these concerns.
Guide to Navigating Landlord-tenant Regulations in Manufactured Home Communities
in Boulder. This guide was prepared to help landlords (park owners and staff) and
tenants (homeowners and home renters) in manufactured home communities
understand and comply with city regulations. This easy-to-read document is available in
English and Spanish and provides contact information for registering a complaint. A
second navigation guide walks home sellers, homebuyers, park staff, realtors, etc.,
through the city’s requirements when manufactured homes are bought and sold. This
guide is also available in English and Spanish.
City staff workload assessment. Manufactured home owners expressed challenges
navigating city resources, especially related to landlord-tenant disputes regulated by the
city. Workloads were assessed while preparing city code updates and developing the
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navigation guide (see above), which is expected to reduce demands on staff. The Human
Rights Program Manager role was identified to investigate landlord-tenant complaints
that fall under the “Mobile Homes” code chapter. Other key city resources available to
homeowners in these communities include:
o General questions: Inquire Boulder
o Zoning and permitting questions: plandevelop@bouldercolorado.gov or (303)
441-1880
o Emergency Response Connectors: Leaders from manufactured home
communities who work in collaboration with city staff to share information and
resources as well as surface emerging issues related to the COVID-19 pandemic
response and recovery.
City code updates. In addition to establishing new requirements, Ordinance No. 8383
adjusted enforcement of landlord-tenant regulations in the “Mobile Homes” chapter of
the city code based on staff and homeowner experience with enforcement under the
previous code. Ordinance No. 8432 updated code protections specific to buying and
selling manufactured homes.
Guiding Principle: Affordability
Manufactured housing will continue to serve as an affordable market-rate homeownership
opportunity. Programs and policies will be pursued to stabilize rent increases, reduce costs for
home repairs, reduce home replacement costs, and reduce energy and water costs of and
consumption by households in manufactured housing.
Support state legislation that would enable lot/pad rent stabilization. The city is
supporting House Bill 22-1287. Protections For Mobile Home Park Residents, which,
among other resident protections, would stabilize lot rents.
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Local pad rent stabilization analysis. In the Strategy engagement process, rising pad rent
was the most common concern of homeowners. City staff concluded that due to vague
language in the State Statue on Rent Control, it is unclear whether regulating rents on
mobile home pads by a municipality is permissible. Local pad rent stabilization could be
struck down in the courts. Voluntary stabilization of pad rents was explored with
individual communities. The action plan included a proposal to support state legislation
to enable local stabilization of pad rents.
Ponderosa solar garden pilot. Nationally, manufactured home owners spend twice as
much per square foot on energy costs compared to owners of traditional single-family
detached homes. Energy costs will only become more burdensome with increased
weather extremes. In 2021, the city completed construction of a community solar
garden dedicated to income -qualified residents of the Ponderosa Mobile Home Park.
Subscribed households receive discounts on their electric bills. The city’s Energy Impact
Offset Fund was used for this project. The city is investing in other local solar gardens to
expand the benefit of solar energy to more low-income households in Boulder.
Opportunity to purchase. Boulder Valley Comprehensive Plan Policy 7.08 commits the
city to “encourage the preservation of existing mobile home parks…including increasing
opportunities for resident-owned parks”. In 2020, the city supported House Bill 20-1201,
Mobile Home Park Residents Opportunity to Purchase, which was enacted. This bill
provides homeowners in a manufactured home community that is for sale or pending a
change of use with the opportunity to make an offer to buy the property.
Zero Energy Modular (ZEM) factory. The city is partnering with Habitat for Humanity and
the Boulder Valley School District to pursue the development of a zero energy modular
factory at the school district’s central campus. Initially, homes built in this factory will
provide a replacement for interested households in Ponderosa. Fewer on-site
construction impacts and greater energy efficiency are two significant benefits for an
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existing lower-income community like Ponderosa. Eventually, the factory can help
address significant regional demand for affordable housing.
Home repair education and services. A broad array of programs and resources exist to
help low-income owners of manufactured housing maintain their homes. The city funds
a Mobile Home Repair Program that provides grants for up to $10,000 for emergency
and weatherization repairs. In 2020 and 2021, the city-sponsored EcoArts Connections
to train manufactured home owners on Do-It-Yourself home repairs as well as overview
programs to complete safety and energy efficiency improvements, address accessibility
needs, pay energy bills, provide efficient lighting kits, and support emergency repairs.
Solar and efficiency programs. The city has partnered with Boulder County and Energy
Outreach Colorado to support weatherization and electrification of homes through the
Colorado Affordable Residential Energy (CARE) Program. Funding is provided from the
city’s Climate Action Plan (CAP) tax. Where the home is being converted to all electric,
the city is providing a no-cost solar garden subscription to offset increase electricity
costs. While only a limited number of manufactured homes have underground so far,
expanding the impact of this program is a priority for both the city and Boulder County.
Explore state funding for home repair, replacement and disposal. Homeowners who
wish to replace an existing home often cannot afford the cost to dispose of the home,
temporarily live elsewhere until the home is properly installed and connected to utilities
and finance a new home. State funds had been made available for this potential use,
however, due to acute need, they were primarily directed to emergency rental
assistance.
Chattel loan products. According to a 2014 report by the Consumer Finance Protection
Bureau, more than two thirds of loans – both real property and chattel – used to finance
the purchase of manufactured homes could be considered subprime. In Colorado, the
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Impact Development Fund provides an improved chattel loan product as compared to
what is available on the market. In 2021 Fannie Mae published its Duty to Serve Plan
and Freddie Mac, also subject to a Duty to Serve, has published its 2022-2024
Underserve Markets Plan. These federal solutions are expected to expand lending
options for homes in manufactured home communities without further city efforts.
Guiding Principle: Community
Manufactured housing will continue to meet the needs of diverse populations, especially
vulnerable community members. Programs and resources will be employed to support the needs
of MHC residents.
Web resources. The Manufactured Home Community Resources webpage provides a
single point for manufactured home owners, park owners and other parties to access
city information and resources specific to these communities.
Lodging costs during prolonged service disruption. To reduce the financial burden of
infrastructure failure on manufactured home owners and likelihood that households
stay in unsanitary conditions, House Bill 20-1196, “Mobile Home Park Act Updates”,
which was supported by the city and has been enacted, includes a provision that park
owners must pay lodging costs during a prolonged service disruption.
Utility bill transparency. To improve water bill transparency for owners of mobile
homes, House Bill 20-1196 (see “Lodging costs” above), requires managers in
communities where water is charged separately from rent to provide a monthly water
bill showing the amount owed by the homeowner, the total amount owed by all
homeowners in the park, the methodologies used to determine the amount billed to
each homeowner, and, if management purchases the water from a provider, the total
amount paid by management to the provider.
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Landlord-tenant communication. To facilitate effective communication between
landlords and tenants, House Bill 20-1196 (see “Lodging costs” above) requires that an
emergency contact number is posted in common areas of the park and communicated
in rental agreements and in each version of the rules and regulations. Ordinance No.
8383, which updated the city’s regulation of landlord-tenant matters in manufactured
home communities, requires the following information be provided:
o Language access notice. A notice that the city has language access supports
available must be included with the lease, the rules and regulations and any
other notices required by the lease.
o New tenant information. New tenants must be given information on the
previous five years of rent increases, the amount for late payments or
dishonored checks, restrictions on pet occupancy and fees required for
recreational facilities or other amenities.
o Change of lot dimensions. Tenants should be notified of changes to their lot
dimensions 60 days in advance, when possible.
Rent receipt requirements. New local regulations require rent receipts are issued,
especially when a tenant pays with cash or money order or when a tenant has received
a notice of nonpayment of rent. These new rules are meant to reduce the risk of
payment theft and eviction.
Eviction Prevention and Rental Assistance Services Program (EPRAS). Tenants of
manufactured home communities can use this city program, implemented in 2021,
which provides assistance paying rent and legal services.
Human services in manufactured home communities. In January 2020, a human services
fair was held for Ponderosa, bringing together a variety of community resources under
one roof. This event was well attended and could serve as a model for other
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communities, particularly if adapted for COVID-19 safety. Since the pandemic began, the
Emergency Response Connectors (ERC) program has included at least one bilingual and
bicultural individual from each manufactured home community who meet with city staff
weekly. ERCs provide information on COVID-19 and other community resources to their
community and problem solves emerging issues for their neighbors. All three market-
rate manufactured home communities (Boulder Meadows, Orchard Grove and Vista
Village) collaborated with the city to provide on-site COVID-19 testing and vaccine
clinics.
Monthly connection meetings. Throughout the COVID-19 pandemic, Housing and
Human Services staff have met monthly with market rate and affordable rental housing
providers, including park owners and managers, rental assistance providers and the
courts through to coordinate rental assistance resource access, reduce eviction risk and
share information.
Mobile home park resident capacity building consultant. The city has worked with a
mobile home park resident capacity building consultant since 2015. This consultant has
focused on building individual and collective self-advocacy for those living in
manufactured home communities, through leadership trainings, Know Your Rights
trainings, training leaders to help neighbors to meet their daily needs. This consultant
has also focused on supporting improved relationships between park managers and
residents.
Health Equity Services. The city's Health Equity Fund provides funding for community-
based programs aimed at removing barriers to health and wellness and increasing
health equity for Boulder community members including those who live in
manufactured housing communities. Programs include the Rec on Wheelz program
which brings physical activities to youth in Boulder Meadows, Orchard Grove,
Ponderosa and Vista Village; and a wide range of food access, nutrition, physical fitness
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and health service access for mobile home park residents. This fund also supported
replacement of water infrastructure in Ponderosa and the north side of Mapleton.
Racial equity planning. In 2021, the city adopted a Racial Equity Plan focused on
eliminating systemic and institutional racism in its policies and practices using a racial
equity instrument. Because of the diverse nature of households in Boulder’s
manufactured home communities, this tool is important to the Strategy. The
Manufactured Housing Strategy was one of the first projects to use an inclusive
engagement approach to maximize participation by diverse community members.
During the COVID-19 pandemic, a rapid response racial equity tool helped reduce
unintended impacts on racial equity in Boulder resulting from cuts to activities, changing
policies and budget reductions. A 2020 complaint of noncompliance with outdoor
lighting standards in Boulder Meadows required city enforcement of lighting standards.
Recognizing the disproportionate impacts of enforcement in Boulder Meadows,
additional education and an extended compliance period were provided, and a program
was developed to assist low-income homeowners in Boulder Meadows with the cost of
compliance and technical assistance with lighting upgrades. The Racial Equity
Instrument will continue to be applied through 2030.
Guiding Principle: Viability
Existing and new manufactured homes and the communities in which they are located will be
safe, well-maintained and modernized, especially to become more energy efficient. Both for-
profit and nonprofit communities must be able to perform well enough financially to cover
current and capital expenses and provide a reasonable return on investment.
Opportunity to purchase. In Resident Owned Communities (ROCs), tenants and the
landlord are one in the same and interests are more aligned. Alignment of interests is
considered one of the most effective ways to promote long-term viability of both
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manufactured homes and communities. See Opportunity to Purchase discussed above
under Affordability.
Regulation of infrastructure maintenance. City-supported House Bill 20-1196, which was
enacted, clarified landlords’ responsibility to maintain and repair water, sewer and
other utility service lines or related connections and established new related duties.
Regulation of general community maintenance. City-supported House Bill 20-1196,
which was enacted, requires management maintain and repair park common areas,
ensuring accessibility by individuals with impaired mobility; maintain roads and
sidewalks, including snow removal; and maintain lot grades and pads to avoid damage
to homes and water accumulation.
Review of code constraints to infrastructure upgrades. All of Boulder’s manufactured
home communities are legally nonconforming. Because these communities were built
prior to the 1985 adoption of the Mobile Home (MH) zone, in some ways they all
deviate from zoning and building standards. City staff prepared a memo reviewing how
development review staff and applicants navigated code requirements and non-
displacement objectives when infrastructure was replaced in Mapleton Mobile Home
Park and in Ponderosa.
Zero Energy Modular (ZEM) factory. This housing option is expected to advance housing
viability in Ponderosa with a modernized, energy-efficient option that enables housing
replacement without the loss of units to separation requirements. See discussion above
under Affordability.
Solar and efficiency programs. See discussion above under Affordability.
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Home repair education and services. Home repair education and resources can extend
the life of manufactured homes, especially for lower-income households with limited
financial resources. See discussion above in Affordability.
Potential Future Actions
The following action items either (a) are in process, (b) were in the adopted Action Plan but did
not advance due to COVID-19 impacts on staffing, or (c) were identified as potential future
actions on the Action Plan.
Develop infrastructure services disruption resource. Create a reference plan for all
manufactured housing communities to use during a water or sanitary sewer service
interruption.
Principle(s): Viability How to Advance: Seeking to incorporate into 2022 work plan.
Partner with park owners on utility system replacements.
• Explore funding for utility system replacement in exchange for pad rent stabilization.
• Consider publicly maintained utilities in future Resident Owned Communities.
Principle(s): Viability How to Advance: Prioritize in a future work plan.
Parcel analysis to assess feasibility of new manufactured home communities.
Principle(s): Affordability, Viability How to Advance: Prioritize in a future work plan.
Explore updates to the city’s Mobile Home zone. Potential changes could enable new
communities in additional zones, advance city values (i.e., permeability), facilitate homeowner-
driven home replacement, enable new housing options while avoiding gentrification.
Principle(s): Affordability, Viability How to Advance: Prioritize in a future work plan.
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