1) George Allen

2) Arthur Hamlin

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The July/August issue of Shelterforce featured credible though biased observations and opinions about manufactured homes. (See article.) Journalistic balance suggests interviews with manufactured housing (MH) industry spokespersons should have been included to compare with the tenant activists quoted.

Some corrections:

Contemporary manufactured homes not only appreciate when sited on privately-owned homesites, but can also do so in landlease communities under two stringent conditions: new homes are maintained in pristine condition over time, and are sited in well-located and well-cared for MH communities, again, over time.

On the question of relocating a manufactured home, Rosenbloom misses a key solution to the stated problem: amelioration of local regulatory barriers to all forms of affordable housing. That's where Shelterforce devotees should be concentrating more attention, rather than browbeating businesspeople willing to risk capital developing, renovating, and managing multifamily residential rental housing.

Rosenbloom writes, "Some park owners continue to discriminate against children..." For the record, former homesite renters who've banded together to purchase their land and become a resident-owned community are the most commonly guilty of this practice.

Faulty wiring and wood stoves and chemicals hazardous to asthmatics are as prevalent in old and new stick-built homes as they are in older mobile homes. Be fair.

The following unsubstantiated statement defames all property owners/managers through guilt by association: "Park owners, like many landlords, are also known to cut corners when they do make repairs." Certified Property Managers, Accredited Community Managers, and a host of other property management training and certification programs are, and have been, in effect for years to address just such conduct.

Which specific FEMA study states "no mobile home can withstand even a medium-grade tornado"? I'd like to know, as a consultant to the MH Industry who studies every report available.

And this statement is generally, if not patently, false: "mobile home parks tend to be located on the cheapest portion of the park owner's land."(emphasis added) Actually, properly entitled, appropriate raw land for MH community use is so difficult to come by that when available, developers use every bit of it. So potentially valuable has this type of development become that companies have been formed of late to option appropriate raw land, get it zoned properly, and then market it to the highest bidder.

Lastly, a far more comprehensive landlord-tenant program than Vermont's has existed, for decades, in Florida, under Chapter 723. Florida MH community residents enjoy as many, if not more, protections than just about anywhere else in the U.S. and Canada. Plus, the state is home to the nation's largest tenant organization, the FMO, and has a healthy resident-owned community base.

Phil Rosenbloom replies:

While new mobile homes, "maintained in pristine condition," and located in sites which are "well-located and well-cared for," may appreciate in value, the fact remains that it's extremely difficult for a person of moderate means to meet those conditions, which Mr. Allen himself acknowledges are "stringent." 

As for safety concerns, with the decision to purchase a landlease community comes certain responsibilities to the tenants, including maintenance of a safe, healthy environment. Many owners meet those responsibilities, it's true. But many don't. And focusing on "local regulatory barriers" will not change the fact that some parks lack safety lighting or adequate sewage systems. 

FEMA's Building Performance Assessment Team study of the 1999 Oklahoma and Kansas tornadoes can or requested at 1-800-480-2520 (publication number FEMA-342 Item 9-1035). Mr. Allen is correct that the language "no mobile home can withstand even a medium grade tornado" does not appear in the study; it was meant as a summation. The study does state that mobile home codes are only designed for "extreme thunderstorm winds" and that "In general, manufactured housing did not resist wind forces as well as conventional site-built detached single-family dwellings for inflow winds of violent and strong tornadoes and vortex winds from all tornadoes. This primarily was because of inadequate resistance to uplift and overturning provided by anchorage and tie-downs used in the foundations."

To the Editor:

We were pleased to see Phil Rosenbloom's article. Protecting and improving mobile home parks has been a priority in Vermont for several years. Mobile homes represent approximately 10 percent of all housing units in Vermont and roughly 40 percent of them are located in mobile home parks. 

Unfortunately, the article misinterpreted Vermont's lot rent increase mediation law. First, mobile home park residents have the right to request mediation of an increase if increase is more than a percentage determined each year by the Department - 3.3 percent in 2000. Vermont law does not allow more than one increase per year. Second, the owner does not have to obtain pre-approval from the residents, but must provide justification if a majority of the park's residents petition for mediation. There is no cap on the amount a park owner can propose for an increase or charge in total. If a dispute over an increase is not resolved by mediation, the residents can sue the park owner in Superior Court and let a judge determine whether or not the increase is "clearly excessive" as defined by law.

If a mobile home park owner raises the lot rent to recover the cost of a major capital improvement to the mobile home park, a "Capital Improvement Surcharge" allows the owner to pass along the cost of any major repairs or replacements to the residents, but the surcharge expires once the cost has been recouped and the lot rent must be reduced to its previous level.

This past spring, as a result of nearly two years of collaboration among five state agencies, Vermont enacted further mobile home park legislation that promises to improve water and wastewater problems in its mobile home parks. Two-thirds of the state's 267 mobile home parks were built before our major environmental, land use, and mobile home park laws were enacted in the early 1970's. Those parks were grandfathered from the state's permitting requirements and have avoided any state oversight concerning construction or repairs of water and septic systems. Many of Vermont's mobile home parks were built on soils completely unsuitable for an on-site septic system, or in dangerous flood zones. Under the new legislation - which has the support of residents' advocates and the Vermont Manufactured Housing Association, which represents park owners - mobile home parks with failed water or wastewater systems lose their grandfather status and fall under the jurisdiction of the Agency of Natural Resources.

Vermont has also committed millions of dollars in federal block grant and HOME funds, plus Vermont Housing and Conservation Trust fund money, to thirty-three mobile home parks that have been purchased by nonprofit housing agencies on behalf of the residents since 1988.

Thank you for taking up the issues facing mobile home park residents.

Sincerely yours,

Contacts

• Bruce Savage, Manufactured Housing Institute, 703-558-0400.
• Danny Ghorbanni, Manufactured Housing Association for Regulatory Reform, 202-783-4087. 
• Vermont Department of Housing and Community Affairs: www.dhca.state.vt.us (click on "housing division.")