Regulatory Barriers to

Manufactured

Housing Placement

in Urban Communities

U.S. Department of Housing and Urban Development | Office of Policy Development and Research
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Regulatory Barr iers to

Manufactured

Housing Placemen t

in Urb an Communities

Casey J. Dawkins 

C. Theodore Koebel

Marilyn Cavell

Steve Hullibarger, The Home Team

David B. Hattis, Building Technology Incorporated

Howard Weissman, Institute for Building Technology & Safety (IBTS)

Prepared for 

U.S. Department of Housing and Urban Development

Office of Policy Development and Research

Prepared by 

Center for Housing Research

Virginia Tech

Blacksburg, Virginia

January, 2011
Acknowledgments 

The authors gratefully acknowledge the contributions of Mr. John Davis of The Institute for 

Building Technology and Safety and his support staff. Mr. Davis was instrumental in conducting 

research on state and local zoning codes pertaining to manufactured housing and coordinating 

the case study efforts. In addition, the authors recognize and appreciate the contributions of 

colleagues Dr. Arthur C. Nelson and Dr. Rosemary Goss in conducting research for this study as 

well as graduate research assistants Sara Breakiron, Mary Fisher, Yun Sang Lee, and Richa 

Walia. The authors also gratefully acknowledge the help and guidance provided by Mr. Edwin 

A. Stromberg and Dr. Regina C. Gray of the Partnership for Advancing Technology in Housing 

of the U.S. Department of Housing and Urban Development. 

Disclaimer 

The statements and conclusions contained in this report are those of the authors and do not 

necessarily reflect the views or policies of the U.S. Department of Housing and Urban 

Development or the U.S. Government. The authors have made every effort to verify the accuracy 

and appropriateness of the report’s content. However, no guarantee of the accuracy or 

completeness of the information or acceptability for compliance with any industry standard or 

mandatory requirement of any code, law, or regulation is either offered or implied. The products 

and systems described in the report are included only as examples of some available choices. No 

endorsement, recommendation, or evaluation of these products or their use is given or implied. 
FOREWORD 


One of HUD's highest priorities is to support and promote sustainable communities. This 

involves investing in communities that are inclusive, economically viable, safe, and healthy. A 

central part of this mission is to expand housing opportunities that are affordable, energy 

efficient, and provide access to a range of valuable community services. While HUD actively 

nnd vigorously supports the provision of affordable housing in sustainable communities, HUD 

itself does not actually build such housing. The actual gatekeepers for the approval and 

development of affordable housing are state and local governments. These governments, 

through their regulation of the housing development process, influence the type and amount of 

such housing that gets built, where it gets built, the pace of its development, and the cost and 

type of infrastructure used to support it. 

Regrettably, when these policies or practices restrict the development of affordable housing in 

communities, such policies and practices become regulatory barriers that restrict the opportunity 

of hard-working American families to live in the communities where they work or where they 

would like to live. 

An integral part of the mission to promote sustainable communities is identifying and addressing 

state and local regulatory barriers to affordable housing. As part of this effort, PD&R 

commissioned this report, Regulatory Barriers to Manufactured Housing, by Virginia 

Polytechnic Institute (Virginia Tech). Manufactured housing is an option that is little used in 

metropolitan communities although it appears to provide quality and cost advantages over sitebuilt housing. This study examines the scope and severity of state and local regulatory barriers 

(such as local zoning, subdivision ordinances, and architectural design standards) to 

manufactured housing placement within entitlement communities in the Community 

Development Block Grant Program, and makes suggestions on how communities can address 

these barriers. 

The analysis finds that key barriers to the placement of manufactured housing are regulatory, 

with permitting requirements, fire codes, zoning codes, subdivision regulations, and architectural 

design standards all impeding placement. Market factors such as land cost are also significant. 

The authors also highlight the role that planners can play in reducing these barriers, particularly 

those arising in part due to the stigma associated with manufactured housing. By pinpointing 

barriers that can need~!ly restrict such housing or increase costs, this report can serve as a 

guide for communities to overcome their own regulatory barriers and, importantly, contribute to 

their becoming more sustainable. 

RapJ/#.:P

Assi'stant Secretary for 

Policy Development and Research 
TABLE OF CONTENTS 

LIST OF EXHIBITS .................................................................................................................. vii
 

Figures...................................................................................................................................... vii 

Tables ......................................................................................................................................viii 

Maps.......................................................................................................................................... ix 

EXECUTIVE SUMMARY ......................................................................................................... xi
 

INTRODUCTION......................................................................................................................... 1
 

BACKGROUND ........................................................................................................................... 3
 

REGULATORY BARRIERS AND THE SUPPLY OF MANUFACTURED HOUSING .... 9
 

Regional Trends in Manufactured Housing Supply.............................................................. 9 

The Scope and Influence of State Manufactured Housing Statutes................................... 12 

Survey of Local Regulatory Barriers and Placement of HUD-Code Homes..................... 17 

Description of Survey........................................................................................................... 17 

Survey Results ...................................................................................................................... 18 

Regulatory Barriers and the Supply of New Manufactured Homes.................................. 27 

Estimating the Supply of Manufactured Housing.............................................................. 28 

The Data ............................................................................................................................... 29 

Results Using the By-Right Zoning Indicator of Regulatory Restrictiveness ................... 32 

Results Using the Measures of Perceived Regulatory Barriers ......................................... 36 

Summary of Major Findings from the Empirical Analysis ................................................ 40 

Regional Trends in Shipment Activity................................................................................. 41 

The Impact of State Manufactured Housing Statutes........................................................ 41 

Analysis of Local Regulatory Barriers................................................................................ 41 

CASE STUDIES.......................................................................................................................... 43
 

Introduction............................................................................................................................. 43
 

Lessons Learned from the Case Studies ............................................................................... 43 

Oakland, California Case Study............................................................................................ 45 

Introduction.......................................................................................................................... 45 

City Background .................................................................................................................. 47 

Manufactured Housing Characteristics............................................................................. 48 

Terrain and Lot Characteristics......................................................................................... 49 

Manufactured Homes in Oakland....................................................................................... 50 

Neighborhood Areas of Greatest Manufactured Home Activity ...................................... 50 

Architectural Context........................................................................................................ 52
 

Description of Oakland’s Manufactured Homes .............................................................. 52 

Physical Configuration (Singles / Doubles / Triples / Number of stories) ................... 52 

Foundations .................................................................................................................. 55 

Exterior Designs/Architectural Modifications.............................................................. 57 

Manufactured Housing Regulations................................................................................... 59 

City Ordinances ................................................................................................................ 59 

State Legislation................................................................................................................ 60 

Special Considerations...................................................................................................... 60 

Impact of Regulatory Changes on Volume of Development............................................ 61 

Housing Price/Home Equity Effects................................................................................. 61 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities iii
 
Developers’ Market Pricing Advantage ....................................................................... 61 

Homeownership and Growing Family Wealth ............................................................. 62 

Views of Manufactured Home Participants........................................................................ 63 

Developers / Entrepreneurs............................................................................................... 63 

Builder / Investors and Rental Property Owners .............................................................. 64 

Nonprofit Housing Corporations ...................................................................................... 66 

Manufacturers ................................................................................................................... 69 

Conclusions and Benefits .................................................................................................... 69 

State of Washington Case Study............................................................................................ 71 

Introduction.......................................................................................................................... 71 

Washington Background ..................................................................................................... 71 

Manufactured Housing Characteristics............................................................................. 72 

Regulatory Impact of Manufactured Homes ...................................................................... 73 

Regulatory Reform History 1977–2003............................................................................ 73 

2004 Landmark Legislation .............................................................................................. 75 

Manufacturer Acquisition Program.............................................................................. 76 

Exemplary Developments Demonstrate the Benefits of Manufactured Housing.......... 76 

Conclusions .......................................................................................................................... 83 

Pima County, Arizona Case Study........................................................................................ 84 

Introduction.......................................................................................................................... 84 

County Background ............................................................................................................. 84 

Demographic Characteristics............................................................................................ 85 

Manufactured Housing Characteristics............................................................................. 86 

Manufactured Homes .......................................................................................................... 86 

Manufactured Home Production in Arizona and Surrounding States .............................. 86 

Manufactured Home Sales in Arizona.............................................................................. 87 

Manufactured Homes in Pima County.............................................................................. 87 

Manufactured Housing Regulations................................................................................... 88 

Tucson Regulations........................................................................................................... 88
 

Pima County Regulations ................................................................................................. 88 

Changing Pima County Regulations................................................................................. 89 

Conclusions .......................................................................................................................... 93 

Owensboro, Kentucky (Doe Ridge Subdivision) Case Study.............................................. 95 

Introduction.......................................................................................................................... 95 

City Background .................................................................................................................. 96 

Demographic Characteristics............................................................................................ 96 

Manufactured Housing Characteristics............................................................................. 97 

Manufactured Homes in Doe Ridge.................................................................................... 99 

Description of Doe Ridge Manufactured Homes.............................................................. 99 

Physical Configuration (Singles / Doubles / Triples / Number of Stories)................... 99 

Exterior Designs ........................................................................................................... 99 

Existing Homes Similar to Manufactured Housing........................................................ 102 

Architectural Context.................................................................................................. 102 

Site-built Homes in the Doe Ridge Development........................................................ 102 

Impact of Manufactured Home Regulations .................................................................... 104 

Market and Non-regulatory Impacts................................................................................. 104 

iv Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
Conclusions ........................................................................................................................ 105 

CONCLUSION ......................................................................................................................... 107
 

Overall Summary of Results................................................................................................ 107 

Recommendations................................................................................................................. 109 

APPENDIXES........................................................................................................................... A-1
 

Appendix A: Impact of Regulations on Manufactured Housing Survey......................... A-1 

Appendix B: Supporting Documents for Case Studies...................................................... B-1 

Appendix B–1: Oakland, California ................................................................................. B-1

Appendix B–1.1: Oakland, California, City Ordinance 10004....................................... B-1 

Appendix B–1.2: Oakland, California, City Ordinance 10092....................................... B-3 

Appendix B–2: Washington Manufactured Housing Association Brochure.................. B-4 

Appendix B–3: Pima County, Arizona: Ordinance 9443, City of Tucson....................... B-6 

Appendix B–4: Owensboro, Kentucky............................................................................... B-8 

Appendix B–4.1: Owensboro Messenger Inquirer Article on Doe Ridge ...................... B-8 

Appendix B–4.2: Owensboro, Kentucky Metropolitan Zoning Ordinance, Article 8.. B-10 

Appendix B–4.3: Owensboro Metropolitan Zoning Ordinance Article 14 .................. B-11 

Appendix B–4.4: Kentucky Legislation KRS 100.348................................................. B-14 

REFERENCES.......................................................................................................................... R-1
 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities v
 

LIST OF EXHIBITS 

Figures 

Figure 1.1: Manufactured Housing Shipments, 2000 to 2005...................................................... 10 

Figure 1.2: Manufactured Housing Shipments by Type of State Statute ..................................... 17 

Figure 2.1: Single-section, Single-family Manufactured Home................................................... 46 

Figure 2.2: Multi-section Single-family Manufactured Home ..................................................... 46 

Figure 2.3: Single-section HUD-Code Home............................................................................... 53 

Figure 2.4: Two-section HUD-Code Home.................................................................................. 54 

Figure 2.5: Tri-section HUD-Code Home Located in the Hills.................................................... 55 

Figure 2.6: Foundation for a Two-story Manufactured Home ..................................................... 56 

Figure 2.7: Foundation for a Manufactured Home Duplex .......................................................... 56 

Figure 2.8: Garage Abutting Front of Manufactured Home ......................................................... 57 

Figure 2.9: Early Attempt to Get Rid of the “Singlewide” Look by Extending Roof.................. 58 

Figure 2.10: Carpenter Built Front Porch and Detailing on Manufactured Home ....................... 58 

Figure 2.11: A Tract Style Manufactured Home (Montclair Area).............................................. 59 

Figure 2.12: Two-story Manufactured Home ............................................................................... 64 

Figure 2.13: Four-section, Two-story HUD-Code Home............................................................. 65 

Figure 2.14: Nonprofit Developed Single-family HUD-Code Home with Factory Built Porch.. 66 

Figure 2.15: Crane Installation of HUD-Code Home................................................................... 67 

Figure 2.16: Two-family HUD-Code Home Developed by a Nonprofit Organization................ 68 

Figure 3.1: Manufactured Home in Laurel Oaks, Lacey, Washington......................................... 77 

Figure 3.2: Manufactured Home in Azalea Gardens, Graham, Washington................................ 77 

Figure 3.3: Manufactured Home in Lake Wilderness Villa, Maple Valley, Washington ............ 78 

Figure 3.4: Manufactured Home in HarvestGate, Puyallup, Washington .................................... 78 

Figure 3.5: Manufactured Home in Sierra Estates, Yakima, Washington.................................... 79 

Figure 3.6: Manufactured Home in Sunny Creek, Spokane, Washington.................................... 79 

Figure 3.7: Manufactured Home in Thomas Place, Everett, Washington .................................... 80 

Figure 3.8: Duplex, Two-story Manufactured Home in Noji Gardens, Seattle, Washington....... 81 

Figure 3.9: Manufactured Home on Infill Site in Olympia, Washington ..................................... 82 

Figure 3.10: Manufactured Home on Infill Site in Pasco, Washington........................................ 82 

Figure 4.1: Typical Manufactured Home in Rural Pima County.................................................. 90 

Figure 4.2: Manufactured Home Located in Subdivision in Rural Pima County With Exterior 

Stucco, Tile Roof, and Garage ................................................................................................. 91 

Figure 4.3: Conventional Looking Manufactured Home in Subdivision in Rural Pima County . 91 

Figure 4.4: Manufactured Home in Rural Pima County That Would Easily Fit Into A Suburban 

or Urban Area........................................................................................................................... 92 

Figure 4.5: Manufactured Home in Rural Pima County Displaying On-site Architectural 

Modifications ........................................................................................................................... 92 

Figure 4.6: Manufactured Home Located Within Tucson City Limits in a Small Infill 

Subdivision Exemplifying Santa Fe Architecture.................................................................... 93 

Figure 5.1: Manufactured Home With Post-production Porch, Vinyl Decorative Column, and 

Roof Vents (attributed to steeper pitch)................................................................................. 100 

Figure 5.2: Manufactured Home With Post-production Porch................................................... 100 

Figure 5.3: Manufactured Home With Post-production Porch and Attached Garage ................ 101 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities vii 
Figure 5.4: Manufactured Home With Attached Garage............................................................ 101 

Figure 5.5: Manufactured Home With Three Site-built Homes in the Background................... 102 

Figure 5.6: One-story Site-built Home Under Construction with Attached Garage................... 102 

Figure 5.7: One-story Site-built Home With Double Attached Garage...................................... 103 

Figure 5.8: One-story Site-built Home With Brick and Single Attached Garage ...................... 103 

Tables 

Table 1.1: Change in Manufactured (Mobile) Home Status by Region, 1999 to 2003 ................ 12 

Table 1.2: Summary of State Manufactured Housing Statutes for the 50 States and the District of 

Columbia.................................................................................................................................. 13 

Table 1.3: Summary of State Regulatory Inclusion Index............................................................ 15 

Table 1.4: State-by-State Summary of the Strength of Manufactured Housing Statutes ............. 16 

Table 1.5: Number of Respondents by Units Placed in the Past Five Years................................ 18 

Table 1.6: Zoning Regulations in Jurisdictions With Units Placed in the Past Five Years.......... 19 

Table 1.7: New Parks Approved by Zoning Regulation............................................................... 20 

Table 1.8: Potential Barriers to HUD-Code Homes ..................................................................... 21 

Table 1.9: HUD-Code Units (None/Some) by Selected Barriers ................................................. 22 

.................................................................................................................................................. 23 

Table 1.10: Survey Responses With One or More HUD-Code Units Placed in the Past Five Years
 

Table 1.11: Units Placed by Zoning Restriction........................................................................... 23 

Table 1.12: Units Placed by New Parks Approved....................................................................... 24 

Table 1.13: Units Placed by Percent in HUD-Code Parks............................................................ 24 

Table 1.14: Units Placed by Percent Infill.................................................................................... 25 

Table 1.15: Units Placed by Percent of Units in Single-family Zones ......................................... 25 

Table 1.16: Units Placed by Promotion Through Incentives........................................................ 26 

Table 1.17: Number of HUD-Code Units by Selected Barriers ................................................... 27 

Table 1.18: Descriptive Statistics for Variables in Regression Analysis...................................... 32 

Table 1.19: Regression Results, By-Right Zoning Indicator of Regulatory Restrictiveness........ 33 

Table 1.20: Generalized Ordered Logit Regression Results, MH Units Placement Scale ........... 34 

Table 1.21: Summary of MH Shipment Models........................................................................... 36 

Table 1.22: Summary of MH Loan Models.................................................................................. 38 

Table 1.23: Summary of Logit Models......................................................................................... 39 

Table 1.24: Summary of Generalized Ordered Logit Models ...................................................... 40 

Table 2.1: Comparison of Manufactured Homes with All Housing Units in Oakland................. 49 

Table 2.2: Distribution of Oakland’s 259 Manufactured Homes by Zip Code ............................ 51 

Table 3.1: Population of Washington’s Five Largest Cities......................................................... 71 

Table 3.2: Comparison of Manufactured Homes With All Housing Units in Washington.......... 72 

Table 3.3: Manufactured Home Shipments to Washington Retailers 1977 to 2006 .................... 73 

Table 4.1: Comparison of Manufactured Homes With All Housing Units in Pima County ........ 86 

Table 4.2: Shipments of Manufactured Homes to Arizona Retailers ........................................... 87 

Table 4.3: Zoning Specifications for Installation of Manufactured Homes ................................. 88 

Table 5.1: Comparison of Manufactured Housing With All Housing Units in Owensboro......... 98 

viii Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
Maps 

Map 1.1: Geographic Distribution of Manufactured Housing Plants........................................... 11 

Map 2.1: Location of Oakland, California.................................................................................... 47 

Map 2.2: Oakland Neighborhood Areas ....................................................................................... 50 

Map 2.3: Oakland Zip Code Areas ............................................................................................... 51 

Map 4.1: Pima County, Arizona ................................................................................................... 85 

Map 5.1: Owensboro, Kentucky ................................................................................................... 96 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities ix
 

EXECUTIVE SUMMARY 

Manufactured housing units (built under the HUD Code or Manufactured Home Construction 

and Safety Standards in the controlled environment of a manufacturing plant and transported in 

one or more sections on a permanent chassis) provide an important source of affordable housing 

within the United States. After adjusting for land costs, the per square foot cost of HUD-Code 

housing is less than half of standard, site-built housing. With the increased use of multi-section 

units and recent innovations in manufactured housing building technology, particularly 

integrated floor and chassis systems, many manufactured housing units are now virtually 

indistinguishable from conventional site-built units. 

Despite the affordability advantages of manufactured housing, local zoning, subdivision 

ordinances, architectural design standards, and other requirements often limit the number of 

locations within which manufactured housing can be placed, impose additional onsite installation 

standards and other design requirements which do not pertain to site-built units, and in some 

cases, prohibit the use of manufactured housing units altogether. 

This study examines the scope and severity of state and local regulatory barriers to manufactured 

housing placement within CDBG-eligible communities. Toward that end, three analytical 

approaches are employed: 

•	 An examination of regional trends in manufactured housing shipment activity using 

shipments data collected by IBTS. 

•	 An analysis of the impact of state statutes defining permissible regulations for local 

governments using IBTS shipments data along with the results of a content analysis of all 

states’ manufactured housing statutes. 

•	 An analysis of the impact of local regulatory barriers on placement of manufactured 

housing using a variety of secondary data sources paired with information obtained from 

a survey of local officials in CDBG-eligible jurisdictions. 

The following are the major findings from the statistical analysis: 

•	 Over the 2000 to 2005 period, there were significant regional differences in manufactured 

housing shipment activity. The South continued to attract the largest share of shipments, 

although this share declined somewhat since 2000. The relative decline in shipments to 

Southern states was accompanied by a relative decline in retention of the existing stock of 

units. The Midwest also saw declining shares of shipments over the 2000 to 2005 period, 

while the Northeast and West saw consistently low levels of shipment activity. 

•	 Almost all states address the regulation of manufactured housing in some way, and more 

than half of states require localities to allow HUD-Code units somewhere within local 

jurisdictions. The majority of states do not address additional local regulations governing 

design, installation, lot improvements, or placement on site. 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities xi 
•	 Categorizing states by the degree to which states promote the use of manufactured 

housing by local governments, those that most strongly promoted HUD-Code usage 

captured the highest share of shipments over the 2000 to 2005 period. Furthermore, the 

gap between strong states and other states has grown over time. This suggests that state 

requirements to enact accommodating local standards appear to be having an influence on 

shipment activity at least at the state level. 

•	 Regulatory barriers play a larger role in limiting the placement of manufactured housing 

than in limiting the sale or shipment of manufactured housing units. By-right zoning 

(allowed under present zoning code) does not significantly impact shipments or sales, and 

few perceived regulatory barriers impede HUD-Code shipments or sales at statistically 

significant levels. Manufactured housing placements, on the other hand, are influenced by 

a variety of regulatory barriers, including the lack of by-right zoning, burdensome fees, 

permits, snow load standards, fire codes, zoning codes, subdivision regulations, 

architectural design standards, and environmental regulations. 

•	 Regulatory barriers are associated more with whether jurisdictions have any HUD-Code 

units, while market conditions play a greater role in determining the total number of units 

placed in a community, given that units are allowed. Market factors shown to have a 

statistically significant impact on placements include regional location, population 

density, median family income, the existing inventory of manufactured housing units, and 

proximity to manufactured housing plants. This finding suggests that while regulatory 

barriers are important impediments to the placement of manufactured units, such barriers 

are not the only constraint. Regulatory constraints interact with market conditions and 

local perceptions of manufactured housing to influence manufactured housing supply. 

•	 This study’s analysis of HUD-Code placements in urban communities suggests that the 

best approach to increasing the supply of HUD-Code homes would be to promote the use 

of manufactured housing in HUD-Code parks and infill in traditional subdivisions, along 

with allowing by-right placement in new single-family subdivisions. Jurisdictions 

approving new parks were twice as likely to have more than 50 units placed in the past 

five years than those not approving new parks. Communities with the highest placements 

of HUD-Code units were those with a mix of placements among HUD-Code parks, as 

infill in traditional subdivisions or in new subdivisions. However, jurisdictions with byright regulations were less likely to approve new parks than those requiring special 

permits or restricting units to special districts. These findings suggest that to promote the 

supply of HUD-Code homes, regulations protecting by-right use in traditional singlefamily districts and infill locations should not be viewed as replacing regulations 

allowing the development of subdivisions devoted to manufactured housing. 

To augment the survey and statistical analysis, four case studies were conducted on communities 

reported to have success in regulatory reforms and the urban placement of HUD-Code homes: 

Oakland (California), state of Washington, Pima County (Arizona), and Owensboro (Kentucky). 

Oakland is one of the premier success stories of the use of manufactured housing in urban infill. 

Washington recently passed state legislation enabling broader use of manufactured housing after 

a near three-decade-long advocacy effort and the success of several well-publicized subdivisions 

xii Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
featuring manufactured housing. The Pima County case illustrates the complexities of placing 

manufactured units in the expanding suburbs of a high-growth urban area. Owensboro illustrates 

the ongoing challenges of developing and marketing manufactured housing even within a state 

with a long reliance on manufactured housing in rural areas and a record of state legislative 

support. The prominent findings from the case studies include: 

•	 Built-out urban areas can promote affordable redevelopment using manufactured housing 

on vacant infill lots, as illustrated by Oakland, particularly in cities with the potential to 

capture an important share of the moderate priced housing market. 

•	 Using manufactured housing reduces the time required to enclose and secure the unit 

from theft or vandalism, potentially adding to the cost-savings particularly when used as 

infill. 

•	 Successful manufactured housing based affordable housing strategies require strong 

community support, institutional mechanisms for delivering manufactured housing units, 

along with sustained political leadership. Communities must also be familiar with the 

technical constraints to transporting and securing units onsite. 

•	 Manufactured housing needs to be priced competitively. When price advantages are 

achieved, developers can increase their profit margin or achieve a rapid sale. 

•	 The support of financial and other housing market institutions influences the promotion 

of manufactured housing. 

•	 The difficulty of financing units under traditional construction loans can impede the 

placement of units. 

•	 The manufactured housing industry’s supply chain (manufacturer-dealer-installer-buyer) 

affects timely placement of units. 

•	 Although more units can be placed through the development of manufactured housing 

subdivisions, acceptance (public, governmental, and market) in high growth suburban 

areas will be difficult, but not impossible, as illustrated in Pima. 

•	 Within a high growth area, infill might prove more successful within older cities where 

infill lots are often small and open areas are minimal than within suburban areas. 

•	 The potential in lower-cost, lower-growth communities, such as Owensboro, might 

remain with the rural fringe urban areas more than with urban subdivisions and infill 

unless greater competitive advantages and public support can be gained. 

•	 The greater potential for developing new manufactured housing subdivisions outside of 

cities could create a higher volume of units, but many of these subdivisions would be in 

strictly rural jurisdictions. 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities xiii 
 

•	 Prominent successes and local initiatives, such as found in several manufactured housing 

subdivisions in the state of Washington, can help promote statewide legislative reform. 

•	 The nonprofit affordable housing sector could be an important ally in promoting 

manufactured housing within urban communities, but the city/suburb, infill and new 

subdivision mix will depend on local market conditions that create greater competitive 

advantage for manufactured housing. 

•	 Local nonprofit housing organizations should investigate opportunities provided by 

national nonprofit organizations to support manufactured housing initiatives within urban 

communities. CFED (Corporation for Enterprise Development) promotes manufactured 

housing through an initiative called I’M HOME, or Innovations in Manufactured Homes. 

Offering grants to nonprofit organizations throughout the nation and across the rural, 

suburban, and urban spectrum, CFED reports that only a few of the 39 organizations 

receiving their support promoted or developed manufactured housing within urban areas. 

Together, these findings suggest that if HUD-Code homes are to be considered viable affordable 

housing options in urban communities, steps must be taken to remove the barriers that currently 

exist to placing such units. The following are offered as recommendations for achieving this 

goal: 

•	 Since local regulations influence manufactured housing placement through a variety of 

channels, local regulators should seek to ensure that the overall permitting system is 

supportive of manufactured housing placement. Regulations protecting by-right use in 

traditional single-family districts and infill locations should not be viewed as replacing 

regulations allowing the development of subdivisions and parks devoted exclusively to 

manufactured housing. Similarly, states wishing to have the most significant impact on 

reducing local regulatory barriers should focus on minimizing the cumulative effect of all 

local regulations, rather than on requiring specific local provisions such as design 

requirements and by-right allowances. 

•	 Regulatory reforms will help to alleviate some constraints to placing manufactured 

housing units, but market conditions will ultimately determine if manufactured housing is 

viable locally. Residents must be willing to pay for manufactured housing units, and 

financing must be available to those seeking to purchase a manufactured home. 

Furthermore, the manufactured housing industry’s supply chain (manufacturer-dealerbuyer), and the difficulty of financing units under traditional construction loans until they 

are secured onsite, can impede the placement of units. 

•	 Built-out urban areas can promote affordable redevelopment using manufactured housing 

on vacant infill lots, particularly in cities with the potential to capture an important share 

of the moderate priced housing market. Using manufactured housing also reduces the 

time required to enclose and secure the unit from theft or vandalism, potentially adding to 

the cost-savings particularly when used as infill. 

xiv Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
•	 Manufactured housing may not be a viable affordable housing alternative for all 

communities. Although more units can be placed through the development of 

manufactured housing subdivisions, acceptance (public, governmental, and market) in 

high growth suburban areas will be difficult, but not impossible. Infill in older cities 

within high-growth metropolitan markets might prove more fruitful. 

•	 Urban areas where placement of manufactured housing has been successful are models 

for other communities. For example, Oakland, California capitalized on state regulatory 

reforms to introduce manufactured housing on infill lots. Without a forward thinking or 

motivating leader (in the case of Oakland, a progressive city council), regulatory reform 

will not in itself promote manufactured housing. 

•	 Efforts should be taken to familiarize nonprofit housing producers with the unique 

aspects of the manufactured housing supply chain, in addition to the role of regulations 

and local market conditions in influencing the viability of manufactured housing as an 

affordable housing alternative. 

•	 Research on this topic is severely limited by the paucity of jurisdiction-level data on 

manufactured housing supply. Shipments are only provided in state-level aggregate form, 

and placements at the local level are not provided by any publicly-available sources. 

Furthermore, information on important aspects of the supply chain, particularly supplierto-dealer relationships, is nonexistent. Collection of these data would help to generate 

additional research on the manufactured housing industry and provide local planners with 

a useful source of information for analyzing the impacts of local regulatory measures. 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities xv 

INTRODUCTION 

In 1974, Congress enacted the Manufactured Home Construction and Safety Standards (HUD 

Code) Act, the nation’s first set of uniform standards governing the construction of manufactured 

homes. The call for a uniform set of standards came from several sources (Manufactured 

Housing Institute, 2004): 

•	 Since many manufactured housing units are shipped across state borders, individual 

plants often had limited information about which state building codes would apply at the 

location where the units would ultimately be placed. This effectively placed limits on the 

number of possible shipment locations, because the cost of tailoring each individual unit 

to the building code requirements of particular states was cost prohibitive. 

•	 Many states were not successful in tailoring state codes to address the health and safety 

issues unique to manufactured housing. 

•	 Since factory built housing offered a promising technological solution to the affordable 

housing crisis, given that the units could be constructed at a much lower cost by taking 

advantages of the economies of scale resulting from mass production, Congress sought to 

promote its use on a national scale. 

Implemented in 1976, the HUD Code preempted state and local building codes governing the 

construction of manufactured housing units. While this effectively eliminated the state-level 

uncertainties surrounding the standards to which units would be constructed, the HUD Code does 

not address local standards governing the placement of individual units onsite. Local zoning, 

subdivision ordinances, architectural design standards, and other requirements often limit both 

the number of locations within which manufactured housing can be placed, impose additional 

onsite installation standards and other design requirements which do not pertain to site-built 

units, and in some cases, prohibit the use of manufactured housing units altogether. 

While this problem has not gone unnoticed, particularly among affordable housing policy 

advocates, little is known about the impact of regulatory restrictions on the actual placement of 

HUD-Code units within communities. The purpose of this report is to eliminate this gap in 

current knowledge and provide information on the extent to which local regulations constitute 

regulatory barriers to the placement of manufactured housing within CDBG-eligible urban 

communities. CDBG-eligible communities are taken as the relevant unit of analysis because 

these communities constitute the universe of communities to which HUD programs pertain. 

Furthermore, urban communities have received scant attention in this literature, given that 

manufactured housing is typically viewed to be a more rural housing option. Since utilizing 

manufactured housing constitutes an important way to minimize capital costs in the face of high 

land costs, it stands to reason that this option may also be attractive in urban communities, if 

regulatory environments are supportive of its use. 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 1 
To shed light on this issue, this report addresses the following research objectives: 

1.	 Determine the type, incidence, and scope of regulatory barriers that local governments 

use to prohibit or restrict the use of manufactured (HUD Code) housing in their 

communities. 

2.	 Provide alternative estimates, based on varying assumptions, of the impact that such 

barriers have had on the placement of manufactured housing in these communities. 

3.	 Make suggestions and recommendations on steps that states and localities could take to 

eliminate or mitigate the identified barriers. 

4.	 Prepare case studies of community efforts that provide a so-called level playing field for 

manufactured housing. 

The report begins with a brief literature review that emphasizes recent literature examining the 

impact of regulatory barriers to the placement of manufactured housing. A section on regulatory 

barriers follows examining empirical evidence on the connection between regulatory 

characteristics and manufactured housing supply. Then four qualitative case studies illustrate a 

range from state to local efforts spanning public, for-profit, and nonprofit development. The case 

studies provide a detailed description of how regulations impact the development of 

manufactured housing within urban areas. In particular, the case study of Oakland, California 

traces infill development throughout the city over a 27 year period following regulatory reform 

of state statutes regarding manufactured housing. The report concludes with a summary of the 

major findings and a discussion of the policy implications of this report. 

2 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
BACKGROUND 

Manufactured housing accounted for more than one sixth of the growth in the owner-occupied 

housing stock between 1993 and 1999 (Apgar et al. 2002). However, the market share of 

manufactured housing declined significantly after 2000. Based on Census Bureau reports of 

housing starts and manufactured home placements, as well as IBTS data on manufactured home 

shipments between 2000 and 2003, manufactured housing fell from 23% of total single-family 

production (starts and placements) in 2000 to only 8% in 2003 and then remained at or below 8% 

through 2007. 

Since the cost of constructing a new manufactured home has been estimated at less than two 

thirds the cost of the average site-built single-family home (HUD 1998), the average sales price 

of new manufactured homes is considerably lower than the average price of the new site-built 

single-family home. Estimates of new home sales suggest that in 2002, the average sale price for 

new manufactured housing units was less than one third the average sale price of new site-built 

single-family homes excluding land (Manufactured Housing Institute 2004). The average sales 

price for manufactured homes in 2007 was $63,400 overall and $83,700 for double-wide units, 

exclusive of land costs. The average sales price for new single-family homes at $311,600, 

inclusive of land, was 272% more than for double-wide units. Even if one-third of the singlefamily unit price is subtracted for land, the remaining price is still 146% above that for the 

average double-wide manufactured unit. Adjusting for both land and unit size, the per square 

foot cost of site-built units was 128% higher than manufactured units in 2005 (Manufactured 

Housing Institute 2006). 

With the increased use of multi-section units and recent innovations in manufactured housing 

building technology, particularly integrated floor and chassis systems, many manufactured 

housing units are now virtually indistinguishable from conventional site-built units. Furthermore, 

an increasing number of units are now being placed on conventional owned lots, as opposed to 

being sited on rented lots within mobile home parks. In Michigan, for example, approximately 

one half of all manufactured homes purchased were placed on privately owned lots (Mrozowski 

2002). Although demonstration programs (such as the Next-Gen and the Urban Design projects) 

generally report positive results, research to date has not addressed whether these design 

improvements have resulted in greater acceptance of manufactured housing in urban 

communities. 

Evidence suggests that residents of manufactured homes view their homes to be of a quality that 

is comparable to site-built homes. Boehm (1995) finds that residents of manufactured homes 

perceive their homes to be of higher quality than similar rental units and of lower cost than 

traditional owned units. This quality-cost advantage points to a potentially significant market 

demand for manufactured units if regulatory barriers are reduced. Evidence from the 2003 

National American Housing Survey indicates that the incidence of severe physical problems in 

manufactured housing is both rare and comparable to other housing units. While residents of 

1.5% of manufactured housing units reported severe physical problems with their unit, this was 

only slightly higher than the percentage for all owner-occupied units (1.3%) and slightly less 

than the percentage for total occupied units (1.9%). For these reasons, Genz (2001) argues that 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 3 
advocates should rethink the importance of manufactured housing toward the nation’s affordable 

housing objectives. 

Perhaps the most significant barrier to the siting of new manufactured homes in metropolitan 

areas is the presence of zoning codes which restrict the size, design, and location of 

manufactured units. These barriers likely explain the fact that in Michigan, for example, 80 

percent of rural manufactured homes are sited on private lots, while 80 percent of urban 

manufactured homes are sited within traditional mobile home parks (Mrozowski 2002). Typical 

regulatory barriers include restrictions on building types which effectively rule out the most 

common types of manufactured homes and zoning requirements which limit the locations where 

manufactured housing units are considered allowable uses (Sanders 1998). As an example, the 

most affordable manufactured homes are not constructed to meet steep roof pitch requirements 

because steep pitches often make units more expensive to purchase, set-up, and difficult to 

transport due to height restrictions on highways (Hart et al. 2002). Although modular and even 

traditional site-built single-family homes are often subject to many of the same requirements, 

communities often place more stringent regulations on manufactured units due to the negative 

perceptions of manufactured housing held by many community residents chiefly relating to 

impact on conventional housing values. Yet, Wubneh and Shen (2001) show such adverse 

impacts often are not present and through site-planning potentially adverse effects can be 

reduced. 

The following categorizes the most common types of regulatory barriers typically faced by 

developers and manufactured home producers: 

•	 Exclusion of by-right (allowed under present zoning code) use in single-family zoning 

classifications. 

o	 Restriction of by-right use to mobile home parks and subdivisions. 

o	 Restriction of by-right use to agricultural and rural zones. 

o	 Prohibition of manufactured housing for replacement or infill use in existing 

single-family neighborhoods. 

•	 Siting requirements. 

o	 Lot size restrictions which limit the density of manufactured housing units. 

o	 Minimum acreage or number of parcels for manufactured home community 

development. 

•	 Design standards. 

o	 Exterior siding requirements. 

o	 Roof structure requirements regarding roof pitch. 

o	 Roof material requirements. 

o	 Minimum floor area requirements. 

o	 Minimum width requirements. 

o	 Foundation requirements. 

•	 Landscaping requirements. 

o	 Landscape buffer requirements. 

4 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
o	 Parking requirements. 

o	 Street width requirements. 

o	 Common open space requirements. 

•	 Public facility requirements. 

o	 Utility and public facility level of service standards that are higher than those for 

average site-built single-family homes. 

•	 Regulatory review requirements. 

o	 Consideration of mobile or manufactured homes as “special uses” which are 

subject to additional regulatory review. 

o	 Inflexible zoning categories which impose rezoning requirements on those 

wishing to site manufactured homes. 

•	 Restrictions on use of HUD-code units as affordable housing in community development 

projects. 

o Prohibition on manufactured housing within infill or redevelopment projects. 

•	 Classification as personal property for tax purposes. 

The existing literature points to several factors which motivate local government adoption of 

these and other manufactured housing regulatory barriers (Bean 2004): 

•	 General prejudice against all forms of low-cost housing (Beamish et al. 2001). 

•	 The perception that manufactured home residents constitute a transient population with 

weak ties to the community (Atiles 1995; Beamish et al. 2001). 

•	 The low aesthetic appeal of the traditional trailer park community design (Gann 2001). 

•	 Perceptions that manufactured housing is substandard and unsafe (Advisory Commission 

on Regulatory Barriers to Affordable Housing 1991). 

•	 The perception that manufactured housing appreciates more slowly than traditional sitebuilt homes and negatively influences adjacent housing prices. 

Evidence suggests that nearly all of these claims are unwarranted and not based on empirical 

reality. For example, despite the common perception that manufactured homes are moved on a 

more regular basis, the reality is that few manufactured homes are ever moved from their initial 

setup sites. Bean (2004) estimated that less than 5% of units are moved. American Housing 

Survey data from 1999 to 2003, reported later in Table 1.1., indicate that 7% of units were 

moved during this period. Other evidence from the American Housing Survey suggests that the 

incidence of severe structural problems is no more frequent among manufactured housing 

residents than it is among all owner-occupants. Regarding differences in home price 

appreciation, manufactured homes sited on owned lots exhibit appreciation rates that are 

comparable to those of site-built homes (Consumers Union 2003). Furthermore, several studies 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 5 
find no evidence of any impact of manufactured homes on the sales prices of adjacent properties 

(Apgar et al. 2002; Warner and Scheuer 1993; Stephenson and Shen 1997; Hegji and Mitchell 

2000). Despite this evidence, community residents continue to harbor stereotypes against 

manufactured housing and will likely continue to appeal to local government officials to impose 

regulatory restrictions on such housing. 

Sanders (1998) is the only author to examine the extent and severity of local manufactured 

housing regulatory barriers nationwide. The report is based on 475 respondents to a 1996 survey 

of 1,172 communities conducted by the American Planning Association. This survey found that 

while almost all communities permit manufactured homes in residential districts, permit 

manufactured homes on individual lots, and permit manufactured homes by right (allow units to 

be placed without additional administrative review or approval), considerably fewer allow 

manufactured homes in the most restrictive residential districts or in all residential districts. 

Furthermore, only 29 percent of communities had regulations that treated site-built homes and 

manufactured homes comparably. Sanders’ findings, however, require careful interpretation. 

Permitting manufactured housing in residential districts “by right” does not necessarily mean that 

manufactured housing is a by-right use comparable to site-built housing. Reviews of state 

statutes indicate a range of by-right use of manufactured housing in single-family zoning 

districts, with 22 states providing some by-right use but only eight states treating manufactured 

housing on an equal basis as site-built. 

States play an important role in ignoring, enabling, mitigating, or banning local regulatory 

barriers to the use of manufactured housing. The National Association of Home Builders 

(NAHB) Research Center (2000), Sanders (1996), and Bredin (2000) provide some information 

on the degree to which states limit the authority of local governments to enact regulations which 

restrict the placement of manufactured housing. Additionally, a review of the Manufactured 

Housing Institute’s (MHI) current Summary of State Laws and Court Decisions Regarding the 

Zoning, Placement and Tax Treatment of Manufactured Housing shed further light. There is 

clearly a continuum of inclusion with respect to state-level manufactured housing regulations 

ranging from equal treatment (compared to site-built single-family houses) in single-family 

residential zones to no state legislation impeding exclusion of manufactured housing. 

Several studies have examined the impact of various types of land use regulations on housing 

market outcomes (Nelson et al. 2004; Quigley and Rosenthal 2004). In general, these studies find 

that while land use regulations do, in some cases, constrain the supply of affordable housing, the 

impact of such constraints varies considerably with the nature of local housing market 

characteristics including factors affecting regional housing demand, housing supply and demand 

elasticities, and the ownership structure of local land markets. 

Although many studies to date focus on the equilibrium housing price impacts of regulatory 

barriers, two recent studies focus directly on the supply side of the housing market. Thorson 

(1997) examines the factors affecting new building permit issuance in a sample of Illinois towns 

and finds that after controlling for other factors affecting housing supply, a change to a more 

restrictive local zoning classification (that is “downzoning”) lead to long-run reductions in the 

number of new housing units permitted. Somerville and Mayer (2003) rely on data from the 

American Housing Survey to examine the impact of government land use regulations on the loss 

6 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
of units from the affordable housing stock over time. The authors find that when new 

construction is constrained, either through lower supply elasticities or through mandated and 

self-imposed regulatory barriers and covenants, than affordable housing units are more likely to 

filter up and become unaffordable over time, controlling for unit and local housing market 

characteristics. 

Green (1999) traces the effects of six land use indicators, one of which is the permitting of 

mobile homes, in 37 Milwaukee suburbs and finds that a mobile home prohibition increased 

home prices between 7.1 and 8.5 percent (the highest impact among the six land use variables 

studies). He found that both the exclusion of mobile homes and the imposition of street width 

minima significantly reduce the proportion of modestly priced homes. 

Curiously, the regulation that has received the most attention among those analyzing the 

manufactured housing market is rent control. Due to the separation of land and unit ownership in 

most manufactured home markets, rent controls imposed on mobile home park landlords can 

have the unintended effect of raising the price of new manufactured homes. This occurs because 

the lower land rents are capitalized into the price of housing. Hirsch (1988) examines the impact 

of such rent control provisions on the sales price of mobile homes in California and finds that 

mobile home sales prices are about 32 percent higher in communities which have imposed rent 

control on mobile home pad rents. Similar results are reported by Mason and Quigley (2004). 

Hirsch and Rufolo (1999) examine the supply-side impacts of such restrictions and find that rent 

control restrictions have reduced the shipments of manufactured housing units to California by 

between 200 and 300 units per year. 

Less is known about the impacts of other market and regulatory conditions on the manufactured 

housing market. Research on local housing markets has identified several variables that should 

be considered in research on barriers to manufactured housing: land values, distance from the 

central city, state water pollution control regulations, and local zoning ordinances (Field 1972; 

Hart et al. 2002); the proximity to amenities and negative externalities of zones allowing 

manufactured housing (Stephenson and Shen 1999); and the percent of owner-occupied housing, 

housing prices, rents, and the percent of affordably-priced homes (Green 1999). In addition, 

macro-economic characteristics such as interest rate levels and availability of capital have 

influenced recent trends in manufactured housing. 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 7 

REGULATORY BARRIERS AND THE SUPPLY OF MANUFACTURED HOUSING: 

RESULTS OF EMPIRICAL ASSESSMENTS OF IMPACTS 

To determine if local regulations impede the placement of HUD-Code units, it is important to 

control for other factors which also influence manufactured housing supply, such as regional 

variations and overall market conditions. It is also important to recognize that local jurisdictions 

influence the placement of manufactured housing units through a variety of different regulatory 

and fiscal policy instruments, as suggested previously. This section addresses these issues using 

a multi-pronged analytical approach: 

1.	 An examination of regional trends in manufactured housing shipment activity. 

2.	 An analysis of the impact of state statutes defining permissible regulations for local 

governments. 

3.	 An analysis of the implementation and impacts of local regulatory barriers on placement 

of manufactured housing, controlling for local and regional market conditions. 

Regional Trends in Manufactured Housing Supply 

This section provides an overview of manufactured housing shipment activity nationwide and 

within different regions of the country. Figure 1.1 displays data on the total number of units 

shipped to each U.S. region and across the entire U.S. between 2000 and 2005. In this table, a 

manufactured housing “unit” refers to either a single-wide or multi-sectional unit. As such, 

shipment totals reflect the sum of these two unit types. 

As mentioned in the previous section, manufactured housing shipments in the U.S. declined 

between 2000 and 2003. Shipments then leveled off in 2003 only to rebound slightly during the 

following years but without increasing market share. Over this period, the Northeast and West 

saw little change in shipment activity, with the Northeast consistently underperforming relative 

to other regions. The Midwest, on the other hand, saw declining shares of overall shipment 

activity. The South accounted for the largest share of shipments, with a trend that largely mirrors 

the national trend. Possible explanations for these regional differences in shipment activity 

include regional differences in preferences for manufactured housing, regional differences in 

land costs, and regional differences in climatic conditions such as snow and wind levels which 

influence the durability of manufactured housing units over time. 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 9 
0 

100000 

200000 

300000 

400000 

500000 

600000 

2000 2001 2002 2003 2004 2005 

Year 

Shipments 

Northeast 

Midwest 

South 

West 

U.S. 

Figure 1.1: Manufactured Housing Shipments, 2000 to 2005 

Map 1.1 provides additional detail on the supply-side determinants of the trend displayed above. 

As the map indicates, manufactured housing plants (production facilities) are also concentrated 

in the South. Given that shipments from plants entail significant transfer and transportation costs, 

it is generally more cost-effective to ship units over a relatively shorter distance; hence, one 

would expect to find higher numbers of shipments in areas that are more proximate to production 

facilities. Furthermore, road noise and vibration degrade the structural integrity of manufactured 

housing units over long distances. Interestingly, despite a relatively high share of plants within 

portions of the Midwest, this region has seen relative declines in shipments over the most recent 

period. 

10 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
Map 1.1: Geographic Distribution of Manufactured Housing Plants 

To gain a slightly different perspective on these regional trends, Table 1.1 below examines recent 

trends in the existing stock of manufactured housing units. This table relies on data from the 

1999 through 2003 waves of the national sample of the American Housing Survey (the most 

recent years for which data were available for this type of analysis) to explain, for those units 

present in the 1999 wave, the proportion of units that remained in the stock versus being moved, 

demolished, converted to site-built, or converted to something else by region. 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 11 
Table 1.1: Change in Manufactured (Mobile) Home Status by Region, 1999 to 2003 

MANUFACTURED HOME REGION 

STATUS Northeast Midwest South West All Regions 

Unit Remained 81.92% 81.14% 76.82% 83.78% 79.40% 

Unit Moved 4.23% 6.41% 8.88% 3.78% 7.04% 

Unit Demolished 0.38% 1.65% 1.66% 0.36% 1.30% 

Unit Converted to Site-built 6.92% 4.58% 5.43% 4.50% 5.23% 

Other 6.54% 6.23% 7.22% 7.57% 7.04% 

Source: 1999 and 2003 National American Housing Survey. Unweighted percentages displayed. 

As this table suggests, almost all units in the sample remained in place over the period under 

investigation. Across regions, the South saw the largest net loss of existing units. Of those that 

did not remain in place, almost all units in the South were moved to another location. Recall that 

the South also saw the largest declines in shipment activity over this same period. Since existing 

manufactured housing units and new units are likely close substitutes, particularly given the 

standardization of such units under the HUD Code, one would expect to find a high degree of 

correlation between regional trends in the existing stock and regional trends in the shipment of 

new units. Further research is needed to understand the factors contributing to the relative 

dampening of manufactured housing supply within the South over the 2000 to 2003 period, 

however. 

The Scope and Influence of State Manufactured Housing Statutes 

The analysis of the influence of regulations on manufactured housing supply begins with an 

examination of state statutes which address the regulation of manufactured housing by local 

governments. Given that manufactured housing offers a technological solution to the affordable 

housing dilemma, many state policymakers have enacted provisions requiring localities to place 

manufactured housing on a level regulatory playing field with site-built housing. For example, 

Section 17–27–105.5 of the Utah Code states that “manufactured homes, which comply with the 

HUD Code, may not be excluded from any single-family residential zone or area where a sitebuilt home would be permitted, as long as the home complies with all zoning and deed 

restrictions on the property.” Other states require that manufactured homes be treated similarly to 

other site-built homes, but allow local governments to specify certain restrictions on architectural 

elements, placement on site, and exterior design and materials. For example, California 

Government Code 65852.3 states that “permanently sited manufactured homes built to the HUD 

Code may not be excluded from lots zoned for single-family dwellings, and are subject to the 

same rules as site-built homes, except for architectural requirements concerning the 

manufactured home’s roof overhand, roofing materials, and siding materials.” Others, such as 

Colorado, also include minimum unit size requirements in their definition of state-compliant 

manufactured homes (Manufactured Housing Institute 2005). 

At the other extreme are states that do not address manufactured housing at all in their state 

statutes, other than with respect to real property issues or taxation (that is Alabama, Alaska, 

Louisiana, North Dakota, Oklahoma, and Wyoming). Some even go so far as to enact state-level 

provisions which may have the effect of excluding manufactured housing units as a preferred 

12 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
 

 

 

 

 

 

 

residential option. For example, Section 3 of the Kentucky Revised Statutes states that “any local 

government may adopt and enforce as part of its zoning regulations, compatibility standards 

governing the placement of qualified manufactured homes in residential zones ... Compatibility 

standards shall be adopted, amended, and enforced in the same manner as other zoning 

regulations and shall be in addition to any zoning regulations that are generally applicable to 

single-family residences. The compatibility standards shall be designed to ensure that when a 

qualified manufactured home is placed within a residential zone it is compatible, in terms of 

assessed value, with existing housing located within a one-eighth mile or less radius from the 

proposed location of the qualified manufactured home” (Manufactured Housing Institute 2005). 

To determine how states are addressing manufactured housing in their statutes, a content analysis 

was performed on all state statutes (and the District of Columbia) addressing any issue related to 

manufactured housing. For each state, the presence of a statute governing manufactured housing, 

the definition of manufactured housing (that is, Is manufactured housing defined more 

restrictively than the HUD Code specifies?), the treatment of manufactured housing as real 

property, the treatment of manufactured housing in local zoning regulations, and the treatment of 

additional local regulations governing design, installation, lot improvements, and/or placement 

on-site were examined. Table 1.2 summarizes the results of this analysis. 

Table 1.2: Summary of Manufactured Housing Statutes for the 50 States and the District of Columbia 

ISSUE TREATMENT OF ISSUE 

STATES* 

N Percent 

Presence of state MH

 Statute 

Statute not present 11 21.57% 

Statute present 40 78.43% 

Coverage of MH in state 

 Statute 

No state statute 11 21.57% 

Statute pertains to HUD-Code homes which meet certain requirements 9 17.65% 

Statute pertains to any HUD-Code home 31 60.78% 

Treatment of MH

 as real property 

State does not address this issue 19 37.25% 

MH classified as real property 32 62.75% 

Treatment of MH in 

 zoning classifications 

State does not address this issue 24 47.06% 

State requires local governments to allow MH somewhere 7 13.73% 

State requires local governments to allow MH in all residential districts 20 39.22% 

Regulations governing 

 design, installation, 

 improvements, and 

 placement on site 

State specifies quantitative standards which apply only to MH 7 13.73% 

State does not address this issue 26 50.98% 

State enables local standards but encourages fair treatment of MH 18 35.29% 

*Including the District of Columbia. 

As the above table indicates, 40 states (78%) address the regulation of manufactured housing in 

some way. Of those 40, 31 (77.5%) define manufactured housing as any HUD-Code compliant 

unit, and the other nine states qualify those definitions with additional items, including minimum 

square footage, placement on a foundation, architectural features, and so forth. Thirty-one states 

(62.8%) define manufactured housing as real property rather than personal property. This 

designation facilitates the placement of manufactured housing units by allowing homeowners to 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 13 
pursue mortgage-based financing for such homes. This designation also allows homeowners to 

qualify for federal and state income tax deductions received by other residential property owners. 

Regarding the treatment of local regulations in state statutes, more than half of states (52.9%) 

require localities to allow HUD-Code units somewhere within local jurisdictions. The majority 

of states do not address additional local regulations governing design, installation, lot 

improvements, and/or placement on site, however. 

To determine the degree to which states are permissive or restrictive with respect to 

manufactured housing provisions, the information from the state-level content analysis was used 

to construct a state-level regulatory inclusion index reflecting the extent to which states 

encourage local governments to include rather than exclude manufactured housing from their 

jurisdictions. For those states addressing manufactured housing in state law, the index is simply 

the sum of three different measures of the intensity of state laws addressing real property 

designation, treatment of manufactured housing in local zoning statutes, and local design 

regulations governing manufactured housing (states are penalized if design requirements are 

required to be exclusively applied only to manufactured housing). This sum is weighted by the 

degree to which each of these issues pertains specifically to HUD-Code homes. 

The formula used to calculate this index is described below. The index equals 0 if the state does 

not address manufactured housing in the state’s statutes. If state statutes address manufactured 

housing, the value of the index is the sum of the values for three regulatory barrier measures (Q2, 

Q3 and Q4) times two (* symbolizes multiplication) if the statute(s) pertain to any HUD-Code 

home or times one if additional requirements are imposed. The index can range from 0 (no state 

statutes pertaining to manufactured housing) to 8 if the statutes apply to all HUD-Code homes 

without additional qualification and all of the following additive conditions apply: if classified as 

real property when on a permanent foundation (1), if local governments required to allow HUDCode housing in all residential zoning districts (2), and if local standards promote consistent 

treatment with other housing types (1). The highest index weight is given when states require 

localities to allow HUD-Code housing, without additional qualification, in all residential districts 

(4 points). The other two “inclusionary” practices (treating as real property and encouraging fair 

treatment when standards are imposed), if applied to all HUD-Code units without additional 

qualification, add 2 points for each. 

State Regulatory Inclusion Index (INDEX) = Q0*{Q1*(Q2 + Q3 + Q4)} 

Where: 

Q0 = 1 if state addresses manufactured housing in state statute; 0 otherwise. 

Q1 = 1 if state statute pertains to any HUD-Code home which also meets other 

requirements (minimum size, siding material, and so forth); 2 if state statute 

pertains to any HUD-Code home; 0 otherwise. 

Q2 = 1 if manufactured housing on a permanent foundation is classified as real property 

(possibly subject to conditions regarding ownership of land,); 0 otherwise. 

14 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
 

 

 

Q3 = 1 if state statute requires local governments to allow HUD-Code housing 

somewhere in the jurisdiction; 2 if state statute requires local governments to allow 

HUD-Code housing in all residential zoning districts; 0 otherwise. 

Q4 = -1 if state statute specifies quantitative standards which apply only to manufactured 

housing; 1 if state statute enables local standards, primarily to ensure consistency 

with other single-family units, but encourages fair treatment of manufactured 

housing; 0 otherwise. 

* = multiplication. 

Table 1.3 below displays the frequency distribution of INDEX. To facilitate the analysis of the 

state regulatory inclusion index, states were further classified into “weak” states (INDEX value = 

0), “moderate” states (INDEX value ranges from 1 to 3), and “strong” states (INDEX value 

ranges from 4 to 8). Table 1.4 displays the states that fall within each of these ranges. Categories 

were chosen according to natural breaks in the frequency distribution and to ensure a roughly 

equivalent number of states within each category. 

Table 1.3: Summary of State Regulatory Inclusion Index 

INDEX VALUE FREQUENCY PERCENT SUMMARY GROUPING 

0 15 29.4% Weak 

1 1 2.0% Moderate 

2 12 23.5% Moderate 

3 2 3.9% Moderate 

4 9 17.6% Strong 

5 0 0.0% Strong 

6 5 9.8% Strong 

7 0 0.0% Strong 

8 7 13.7% Strong 

Total 51 100% 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 15 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table 1.4: State-by-State* Summary of the Strength of Manufactured Housing Statutes 

PROTECTION OF 

MANUFACTURED HOUSING STATE 

Weak (Index = 0) Alabama Massachusetts 

Alaska North Dakota 

Delaware Oklahoma 

Washington DC Pennsylvania 

Georgia Rhode Island 

Hawaii Texas 

Kentucky Wyoming 

Louisiana 

Moderate (Index Range: 1–3) Arizona Oregon 

Colorado South Carolina 

Maryland South Dakota 

Missouri Vermont 

Montana Virginia 

New Mexico West Virginia 

New York Wisconsin 

North Carolina 

Strong (Index Range: 4–8) Arkansas Minnesota 

California Mississippi 

Connecticut Nebraska 

Florida Nevada 

Idaho New Hampshire 

Illinois New Jersey 

Indiana Ohio 

Iowa Tennessee 

Kansas Utah 

Maine Washington 

Michigan 

*Including the District of Columbia. 

Figure 1.2 examines the total number of units shipped again, only this time, differentiating the 

destination of shipment flows by type of state statute. As Figure 1.2 suggests, states classified 

into the weak and moderate categories of the state regulatory inclusion index have seen 

increasingly lower shares of manufactured housing shipments over the 2000 to 2005 period, with 

weak states exhibiting a slight increase over moderate states spanning the most recent two years 

of the analysis period. The most dramatic trend evident from this graph, however, is the 

significantly higher number of shipments captured by strong states over the analysis period. Not 

only were shipments in strong states much higher than in other states, the gap between strong 

states and other states has been growing over time. A separate analysis of shipment trends by 

each value of INDEX reveals that while no single value of INDEX dominates these results, the 

increase in shipments between 2003 and 2005 is larger for higher values of INDEX within the 

strong state category. At the state level, this suggests that requirements to enact accommodating 

local standards appear to be having an influence on local shipment activity. To determine if the 

16 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
impacts are observed at a level below the state, local regulations and their impacts on 

manufactured housing supply are investigated. 

0 

20000 

40000 

60000 

80000 

100000 

120000 

140000 

160000 

180000 

200000 

2000 2001 2002 2003 2004 2005 

Year 

Shipments 

Weak State Statute 

Moderate State Statute 

Strong State Statute 

Figure 1.2: Manufactured Housing Shipments by Type of State Statute 

Survey of Local Regulatory Barriers and Placement of HUD-Code Homes 

Description of Survey 

A survey instrument was designed to gauge an understanding of how regulations and specific 

barriers affect the placement of manufactured homes in urban communities. The survey 

instrument was a short questionnaire intended to be received by mail and self administered by 

the recipient (see Appendix A). The recipients were part of a universe that consisted of 1,839 

CDBG-eligible communities across the nation (contact information was successfully obtained for 

1,736 of the CDBG-eligible jurisdictions). Recipients were primarily local planning directors or 

other officials with knowledge of local regulations as they relate to manufactured housing (in 

order to get the respondent with the best knowledge of local code practices, the recipient was 

given the option to pass the questionnaire to a person he or she believed was better suited to 

answer questions on coding regulations related to manufactured housing). 

The survey was administered using a modified Dillman technique for mailed surveys, a 

technique that often generates response rates of over 50% when the survey content is of direct 

interest to the recipient. The survey process began by mailing the survey instrument along with a 

personalized cover letter and a postage-paid, pre-addressed return envelope to the community 

representative. Two weeks after the first mailing, a postcard reminder was sent. If no response 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 17 
had been received within a few weeks following the reminder, a second and final survey 

instrument along with a cover letter encouraging the recipient to reply was sent. The Dillman 

technique resulted in a final response rate of 55 percent. A total of 940 completed surveys were 

returned (eleven surveys were returned as undeliverable, so these were subtracted from the 1,736 

surveys mailed to community representatives when calculating the response rate). 

Survey Results 

The survey was designed to identify the jurisdiction’s regulatory practices regarding 

manufactured (HUD-Code) homes, whether any incentives are provided for the use of HUDCode homes, the number of new homes placed in the past five years, and the distribution in 

placements among designated parks, subdivisions, infill, or single-family zone districts. 

Nearly one-third of the total respondents reported that no or probably no units were placed in the 

past five years (Table 1.5). A majority (n=558, 59.4%) reported that new HUD-Code units had 

been placed in this time span, with another 5.7% (n=54) indicating that units probably had been 

placed. 

Of the 612 respondents who reported that new HUD-Code units were or probably were placed in 

their jurisdictions in the past five years, 572 were able to indicate the number of units placed 

(using five intervals of 10 units each and then 51–99 units and 100+ units). One-fifth had only 

1–10 units and one-fourth had between 11–50 units. One hundred and forty-five respondents 

reported HUD-Code placements of 51 or more units, and nearly all of these had 100 or more 

units. 

The median number of units placed over the past five years was less than 10, or fewer than 2 

units per year. The distribution of units suggests that communities separate into three primary 

categories: those with no units placed, those with only a few units placed, and those that manage 

to place a large number of units. 

Table 1.5: Number of Respondents by Units Placed in the Past Five Years 

UNITS PLACED FREQUENCY PERCENT 

None 291 31.0% 

1–10 191 20.3% 

11–20 105 11.2% 

21–30 67 7.1% 

31–40 29 3.1% 

41–50 35 3.7% 

51–99 36 3.8% 

100+ 109 11.6% 

Total Non-missing 863 91.8% 

Missing 77 8.2% 

Total 940 100.0% 

Additional evidence from the survey indicates that many of the jurisdictions without any units 

placed in the past five years are not entirely exclusionary of HUD-Code homes. The majority 

18 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
(159 or 58.0%) of the 291 respondents who answered that there were no (or probably no) HUDCode homes placed in the past five years reported that their jurisdictions do allow HUD-Code 

homes to be used. These respondents classified their jurisdiction’s regulatory approach as one of 

the following: 

•	 Allowing HUD-Code homes as a by right use in single-family zones (n=73, 46.8%). 

•	 Allowing HUD-Code homes in single-family zones on a temporary basis or with special 

or conditional use permits (n=16, 10.3%). 

•	 Restricting HUD-Code homes to designated mobile home parks, communities, or 

subdivisions (n=67, 42.9%). 

Extreme exclusion of HUD-Code homes was fairly rare among the respondent communities. 

Only 115 respondents (12.2% of the total respondents to the survey) indicated that their 

jurisdictions never (n=74) or rarely (n=41) allow HUD-Code homes to be used. 

The 612 respondents indicating that HUD-Code homes were placed in their jurisdictions in the 

past five years were asked about their jurisdiction’s regulations controlling the placement of 

these homes (Table 1.6). Since these regulatory controls are not mutually exclusive, respondents 

were asked to respond about each type of regulation. Nearly 40 percent of these jurisdictions 

restrict HUD-Code homes to special zoning categories such as mobile home parks, communities, 

or subdivisions. One-fifth requires a special or conditional use permit for HUD-Code homes to 

be placed or located in single-family zones. But a majority of these jurisdictions allow HUDCode homes as a by-right use in single-family zones either under the same rules as other housing 

or if design standards are met. The substantial overlap between the “design standards” and “same 

rules” responses indicates that communities allowing HUD-Code homes as a by-right use in 

single-family zones do so by requiring them to meet design standards and to meet the rules 

applied to other homes. 

Table 1.6: Zoning Regulations in Jurisdictions With Units Placed in the Past Five Years 

ZONING REGULATION YES NO OTHER NO 

RESPONSE TOTAL N 

Restrict to mobile-home parks 38.9% 56.0% 0.2% 4.9% 100.0% 612 

Require a permit for use in single- 

 family zones 20.9% 68.5% 3.4% 7.2% 100.0% 612 

Allow as a by-right use in single- 

 family zones if design standards are

 met 

58.3% 34.2% 0.5% 7.0% 100.0% 612 

Allow as a by-right use in single- 

 family zones under same rules as

 other housing 

56.5% 35.0% 0.7% 7.8% 100.0% 612 

Respondents answering that design standards are applied to HUD-Code homes were asked if the 

planning staff or building department have any discretion in the administration of these design 

standards. Seventy-one percent indicated that they have no discretion and the design standards 

are fixed and clear. Seventy-four percent indicated that the standards are easily met and 18.4 

percent said that the standards significantly affect unit costs. 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 19 
Among communities with some units placed in the past five years, 104 (17.0%) approved new 

mobile home parks, communities, or subdivisions for HUD-Code homes in that time span. Sixtyfive of these approved only one such community and another 21 approved two communities, but 

18 had approved three or more communities. The approval of new HUD-Code parks or 

subdivisions could dramatically expand the placement of units, perhaps even more so than the 

seemingly less exclusionary acceptance of HUD-Code units as a by-right use in single-family 

zones. Jurisdictions with by-right regulations were less likely to approve new parks than those 

requiring special permits or restricting units to special districts (Table 1.7). Although the 

association is statistically significant, it only increases the probability of approving new parks 

from 15 percent to 20 percent. 

Table 1.7: New Parks Approved by Zoning Regulation 

ZONING NEW PARKS APPROVED 

REGULATION Yes No Total N 

By right 14.8% 85.2% 100.0% 311 

Permit 20.4% 79.6% 100.0% 284 

Total 17.5% 82.5% 100.0% 595 

N 104 491 595 

Sig. .05 

All of the respondents were asked to rate a list of potential barriers to HUD-Code homes. Almost 

all of the items are regulatory barriers, while three are market characteristics that could limit the 

placement of HUD-Code homes (high land cost, not much land, and insufficient demand). The 

approval of new HUD-Code subdivisions was also included as a barrier, since the supply of land 

in such subdivisions could influence placements. None of the respondents identified any these 

barriers as “not applicable” so that category is not shown in Table 1.8. The respondents 

overwhelmingly felt that almost all of the potential barriers listed were either not barriers or were 

minor barriers, or apparently did not know and skipped the item. Few respondents (below 10%) 

thought any of the barriers listed would prevent HUD-Code homes from being placed in their 

communities. Items were more likely to be classified as “significant barriers” to placing HUDCode homes than as preventing these units. The high cost of land category was selected most 

frequently as a significant or preventive barrier (42.4%), followed by citizen opposition (36.1%), 

no new parks (35.6%), zoning codes (33.4%), and not much land (31.1%), but these were always 

minority opinions. Fees, permits, wind codes, snow load standards, fire codes, and environmental 

regulations were the most likely items to be identified as “not a barrier” or a “minor barrier”. 

20 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
Table 1.8: Potential Barriers to HUD-Code Homes 

POTENTIAL BARRIERS NOT A 

BARRIER 

MINOR 

BARRIER 

SIGNIFICANT 

BARRIER 

PREVENT 

HUD-CODE 

HOMES 

NO 

RESPONSE 

Fees 67.3% 17.6% 2.5% 0.5% 12.1% 

Permits 66.4% 19.0% 5.1% 1.5% 8.0% 

Deed restrictions/covenants 33.5% 19.6% 20.4% 6.4% 20.1% 

Wind standards 53.7% 23.1% 7.4% 1.1% 14.7% 

Snow load standards 50.5% 16.3% 2.7% 0.8% 29.7% 

Fire codes 62.6% 20.0% 5.6% 0.7% 11.1% 

Zoning codes 34.2% 28.7% 24.2% 9.2% 3.7% 

Subdivision regulations 46.6% 24.1% 14.4% 6.0% 8.9% 

Architectural design standards 39.0% 24.7% 10.2% 3.1% 23.0% 

Citizen opposition 22.2% 31.6% 31.3% 4.8% 10.1% 

Environmental regulations 64.4% 13.3% 2.7% 0.5% 19.1% 

Historic district regulations 31.8% 16.1% 16.2% 9.9% 26.0% 

High land costs 26.5% 22.0% 38.0% 4.4% 9.1% 

Not much land (built-out) 35.9% 20.0% 27.3% 3.8% 13.0% 

No new HUD-Code parks,

 communities, or subdivisions approved 27.0% 14.6% 28.4% 7.2% 22.8% 

Insufficient demand for HUDCode homes 37.8% 20.7% 18.2% 3.6% 19.7% 

The relationship among zoning regulations, barriers and whether jurisdictions had no or some 

units placed in the past five years is shown in Table 1.9. Zoning regulations do not appear to be 

associated clearly with whether units were placed in the community. Although jurisdictions with 

by-right regulations and not requiring special permits for using HUD-Code units in single-family 

zones had a slightly higher probability of having some units placed, the differences were 

insufficient to significant. (Statistically significant associations are identified by italics in Table 

1.9.) This could reflect the complexity of regulatory barriers rather than the absence of barriers, a 

caution suggested by the association of the respondents’ ratings of barriers with whether no or 

some units were placed. 

In jurisdictions where zoning was rated as a significant barrier, the probability of units having 

been placed was significantly lower than in jurisdictions where zoning was rated as a minor 

barrier (dropping from 77.5% to 53.9%). In jurisdictions where respondents rated subdivision 

covenants, architecture design standards, citizen opposition, high land costs, not much land, no 

new parks approved, and insufficient demand as significant barriers, there were similar 

statistically significant negative impacts on HUD-Code units being placed. The largest impact 

was associated with insufficient demand, which was the only factor associated with a lower than 

40% likelihood of some units being placed. 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 21 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table 1.9: HUD-Code Units (None/Some) by Selected Barriers 

BARRIERS NO UNITS SOME UNITS N 

Statistically Significant Associations 

Zoning (.000) 798 

Not a barrier 28.7% 77.5% 516 

 Significant barrier 46.1% 53.9% 282 

Subdivision regulations (.000) 740 

Not a barrier 22.5% 76.2% 571 

 Significant barrier 46.1% 55.0% 169 

Architectural design standards (.000) 624 

Not a barrier 24.2% 75.8% 513 

 Significant barrier 55.0% 45.0% 111 

Citizen opposition (.000) 727 

Not a barrier 21.4% 78.6% 429 

 Significant barrier 41.9% 58.1% 298 

High land costs (.000) 747 

Not a barrier 20.3% 79.7% 225 

 Significant barrier 41.1% 58.9% 522 

Not much land—Built out (.000) 707 

Not a barrier 19.7% 80.3% 446 

 Significant barrier 47.1% 52.9% 261 

No new HUD-Code parks approved 

(.000) 622 

Not a barrier 18.2% 81.8% 329 

 Significant barrier 46.8% 53.2% 293 

Insufficient demand (.000) 647 

Not a barrier 18.4% 81.6% 467 

 Significant barrier 62.8% 37.2% 180 

Not Statistically Significant 

Units allowed in single-family zones 711 

 By right 18.3% 81.7% 360 

 By permit/park 22.2% 77.8% 351 

Requires special use permit in single- 

 family districts 669 

Yes 23.8% 76.2% 193 

No 19.5% 80.5% 476 

Deed restrictions 636 

Not a barrier 28.7% 71.3% 422 

 Significant barrier 24.3% 75.7% 214 

Historic district regulations 598 

Not a barrier 27.6% 72.4% 388 

 Significant barrier 30.5% 69.5% 210 

22 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
 

 

 

 

It bears noting that except for insufficient demand, when barriers rated as significant were 

associated with reduced percentages of placing units, a majority of the impacted jurisdictions still 

had some units placed. 

Local regulations and other potential barriers could also affect the number as well as the 

likelihood of units being placed. Given the bi-modal distribution of units placed, the categories 

were reduced to the four shown in Table 1.10 for the purpose of cross-tabulating the number of 

units with various potential barriers. These results are limited to the 572 respondents reporting 

the number of units placed in the past five years. Since respondents did not answer every 

question, the number of respondents (Frequency) for each category is shown in the table. 

Table 1.10: Survey Responses With One or More HUD-Code 

Units Placed in the Past Five Years
 

UNITS 

PLACED FREQUENCY PERCENT 

1–10 191 33.4% 

11–30 172 30.1% 

31–50 64 11.2% 

51+ 145 25.3% 

Total 572 100% 

As with the earlier comparison of the association of by-right and permit-park regulations with the 

likelihood of having no or some units placed, there was no association between these regulation 

approaches and the number of units placed (Table 1.11). 

Table 1.11: Units Placed by Zoning Restriction 

UNITS ZONING RESTRICTION 

PLACED By-right Permit or in Park Total 

1–10 34.4% 33.0% 191 

11–30 32.3% 26.7% 168 

31–50 8.2% 14.7% 64 

51+ 25.2% 25.6% 144 

Total 100.0% 100.0% 

N 294 273 567 

Not Sig. 

As suggested earlier, the approval of new HUD-Code parks or subdivisions appears to 

dramatically increase the placement of units (Table 1.12). Jurisdictions approving new parks 

were twice as likely to have more than 50 units placed in the past five years than those not 

approving new parks. As shown in Table 1.7 previously, by-right jurisdictions were slightly less 

likely to approve parks than jurisdictions restricting units with special permits or park locations 

(15% to 20%). 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 23 
 

 

 

Table 1.12: Units Placed by New Parks Approved 

UNITS 

PLACED YES NO TOTAL 

1–10 10.9% 38.5% 191 

11–30 27.7% 30.8% 172 

31–50 15.8% 10.0% 63 

51+ 45.5% 20.7% 143 

Total 100.0% 100.0% 

N 101 468 569 

Sig. .000 

Table 1.13 provides additional support to viewing new HUD-Code park development as a means 

of promoting manufactured housing. The table provides the distribution for the number of HUDCode units placed in the past five years according to the percent of units placed in HUD-Code 

parks. Communities where the percent of units placed in HUD-Code parks is very low (<25%) 

are more likely than others of having only 1–10 units placed (43.7%) and much less likely of 

having 51 or more units placed (15.8%). But the relationship between HUD-Code parks and 

units placed is not linear. Communities where placements are heavily concentrated in HUDCode parks (90% or more) have the second highest percent (26.5) of placing only a few units (1– 

10) and the second lowest percent (30.1) of placing a large number of units (51+). The 

communities with higher levels of HUD-Code placements are those with more balance between 

placements in HUD-Code parks and in traditional subdivisions as infill or an alternative to sitebuilt homes. 

Table 1.13: Units Placed by Percent in HUD-Code Parks 

UNITS 

PLACED 

PERCENT IN HUD-CODE PARKS 

0–24% 25–49% 50–74% 75–89% 90%+ Total N 

1–10 43.7% 18.5% 10.5% 13.3% 26.5% 31.7% 151 

11–30 33.5% 25.9% 36.8% 30.0% 24.7% 30.0% 143 

31–50 7.0% 11.1% 13.2% 20.0% 18.7% 12.6% 60 

51+ 15.8% 44.4% 39.5% 36.7% 30.1% 25.6% 122 

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 476 

N 215 27 38 30 166 476 

Sig. .000 

24 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
 

 

 

 

 

Table 1.14 provides the complementary perspective in terms of the percent of units placed as 

infill units. Again, a higher number of units placed (in any location) is associated with 

communities achieving a balance between infill and other locations (particularly parks). 

Table 1.14: Units Placed by Percent Infill 

UNITS 

PLACED 

PERCENT INFILL 

0–24% 25–49% 50–74% 75–89% 90%+ Total N 

1–10 33.8% 14.3% 20.8% 26.7% 44.8% 32.0% 151 

11–30 28.6% 46.9% 41.7% 30.0% 39.7% 32.6% 154 

31–50 13.5% 8.2% 8.3% 13.3% 8.6% 12.1% 57 

51+ 24.1% 30.6% 29.2% 30.0% 6.9% 23.3% 110 

Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 472 

N 311 49 24 30 58 472 

Sig. .05 

Table 1.15 shows that although this mix can include placements in single-family zones (aside 

from infill), very few communities (only 35 of those responding) had 25 percent or more of their 

new HUD-Code units placed in single-family zones. These communities were more likely to 

reach the 51+ placement level, but the association between units placed and the percent placed in 

single-family zones is not statistically significant. This suggests that the best approach to 

increasing the supply of HUD-Code homes emphasizes parks and infill somewhat more so than 

placement in single-family zones. 

Table 1.15: Units Placed by Percent of Units in Single-family Zones 

UNITS PLACED 

PERCENT IN SINGLE-FAMILY ZONES 

0–24% 25+% Total N 

1–10 31.2% 20.0% 30.2% 127 

11–30 31.9% 37.1% 32.4% 136 

31–50 12.7% 5.7% 12.1% 51 

51+ 24.2% 37.1% 25.2% 106 

Total 100.0% 100.0% 100.0% 420 

N 385 35 420 

Not Sig. 

Survey respondents were also asked if their communities promoted the use of HUD-Code homes 

through any special incentives (Table 1.16). Although only 11 responded that they provide 

incentives, mostly through targeting redevelopment and infill (n=9) and with the use of CDBG, 

HOME or other federal funds (n=7), these communities were substantially more likely to have 

had 51+ units placed in the past five years (63.6%) compared with those not providing incentives 

(25.2% from Table 1.15). The success of these 11 communities suggests the benefit of promoting 

the use of HUD-Code homes with the resources provided in other HUD programs. 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 25 
 

Table 1.16: Units Placed by Promotion Through Incentives 

UNITS PLACED 

PROMOTES HUD-CODE HOMES WITH INCENTIVES 

Yes No Total N 

1–10 27.3% 33.4% 33.3% 190 

11–30 9.1% 30.5% 30.1% 172 

31–50 0.0% 11.4% 11.2% 64 

51+ 63.6% 24.6% 25.4% 145 

Total 100.0% 100.0% 100.0% 571 

N 11 560 571 

Sig. .05 

Only two of the respondents’ ratings of potential barriers to HUD-Code units were statistically 

associated with the number of units placed (Table 1.17): not much land (built out) and 

insufficient demand. Both of these are market barriers rather than regulatory barriers. It would 

appear that regulatory barriers are associated more with whether jurisdictions have no or any 

HUD-Code units, while market barriers might have a greater role in determining the number of 

units that are placed in a community. 

26 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table 1.17: Number of HUD-Code Units by Selected Barriers 

SELECTED BARRIERS 

NUMBER OF HUD-CODE UNITS 

1–10 11–30 31–50 51+ Total N 

Statistically Significant Associations 

Not much land—Built out (.000) 

Not a barrier 28.2% 32.4% 12.0% 27.4% 100.0% 358 

Significant barrier 47.8% 25.4% 8.7% 18.1% 100.0% 138 

Insufficient demand (.000) 

Not a barrier 30.2% 31.0% 13.1% 25.7% 100.0% 381 

Significant barrier 56.7% 23.9% 4.5% 14.9% 100.0% 67 

Not Statistically Significant 

Zoning (Not sig.) 

Not a barrier 33.8% 30.8% 10.0% 25.5% 100.0% 400 

Significant barrier 34.2% 28.9% 14.5% 22.4% 100.0% 152 

Subdivision regulations (Not sig.) 

Not a barrier 32.4% 29.9% 10.8% 26.9% 100.0% 435 

Significant barrier 37.6% 34.4% 11.8% 16.1% 100.0% 93 

Architectural design standards (Not sig.) 

Not a barrier 33.2% 32.1% 9.8% 24.9% 100.0% 389 

Significant barrier 40.0% 28.0% 6.0% 26.0% 100.0% 50 

Citizen opposition (Not sig.) 

Not a barrier 31.8% 30.0% 10.4% 27.9% 100.0% 337 

Significant barrier 32.9% 32.4% 13.3% 21.4% 100.0% 173 

Historic district regulations (Not sig.) 

Not a barrier 30.6% 32.4% 10.3% 26.7% 100.0% 281 

Significant barrier 39.0% 28.1% 9.6% 23.3% 100.0% 146 

High land costs (Not sig.) 

Not a barrier 31.5% 33.8% 12.7% 22.0% 100.0% 314 

Significant barrier 34.6% 26.0% 9.1% 30.3% 100.0% 208 

No new HUD-Code parks approved (Not sig.) 

Not a barrier 32.0% 28.6% 13.4% 26.0% 100.0% 269 

Significant barrier 34.6% 28.8% 10.3% 26.3% 100.0% 156 

The examination of bi-variate associations as done in this section can help point to potential 

relationships that influence the placement of HUD-Code homes, but can also mask 

interrelationships between several variables and measures not included in the survey. The 

multivariate models presented in the next section on the impact of regulatory barriers on the 

supply of new manufactured homes provide more exacting and thorough tests of the associations 

suggested so far. 

Regulatory Barriers and the Supply of New Manufactured Homes 

This section describes the approach to estimating the impact of local regulatory barriers on the 

supply of new manufactured homes. A general discussion of the empirical issues that arise when 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 27 
estimating such a model precedes a discussion of the data used in the analysis and an 

examination of the results. 

Estimating the Supply of Manufactured Housing 

Empirical models of housing supply typically model the number of new residential housing starts 

as a function of variables influencing the price and cost of producing housing. In a dynamic 

model of housing supply, the flow of new construction in a given time period depends on the 

sensitivity of construction activity to changes in the price of housing. If the supply of housing is 

inelastic (that is, insensitive to price changes), producers respond to economic shocks with a 

considerable lag, leaving a short-run gap between actual and equilibrium quantities of housing. 

This type of model has come to be known as the “stock adjustment model” of housing supply 

and has been widely used to estimate housing supply elasticities (DiPasquale and Wheaton 

1994). 

Several unique features of the manufactured housing market complicate any attempt to 

empirically estimate the supply of this housing type. Unlike traditional site-built homes, 

manufactured units are constructed off-site, often transported to a dealer where sales are 

conducted, and finally placed on-site following a sale. This feature of the manufactured housing 

market has implications for both the measure of housing supply and the exogenous factors which 

likely influence housing supply. Regarding the measure of housing supply itself, publiclyavailable sources such as the U.S. Census of Construction provide information on shipments 

from plants to dealers and ultimately placements on site, but this information is only available as 

state-level aggregates. Neither shipment nor placements information are publicly available at the 

jurisdiction-level. 

A second important distinction between manufactured housing and single-family homes is the 

difference in the cost of supplying units. Since almost all of the costs associated with 

constructing a single-family home are incurred on site, in the form on labor, land, and materials, 

it is relatively straightforward to estimate regional construction cost indices which vary as a 

function of these inputs. Costs are more complicated in a model of manufactured housing supply, 

however, because on-site labor requirements are minimal, land costs are typically lower given 

that manufactured homes tend to be constructed in rural areas, and almost all material costs are 

incurred off-site. Furthermore, an important additional cost of producing manufactured housing 

units is the cost of transporting units from the plant to the final dealer or home site. Given these 

idiosyncrasies, regional construction cost indices such as those available from Means or McGraw 

Hill are less accurate measures of the true costs facing manufactured housing producers. 

A final distinction that is particularly relevant for this analysis is the difference in the manner in 

which regulations typically treat manufactured housing relative to single-family units. 

Traditional site-built single-family residential units are easy to identify and define, and almost all 

zoning ordinances are designed with the explicit purpose of protecting this housing type from 

incompatible land use interactions. Such is not the case with manufactured housing. 

Manufactured housing units are defined in a variety of ways within zoning ordinances and are 

usually treated differently from single-family homes. Furthermore, approval of manufactured 

housing units often involves a different review process that is administrative in some cases and 

28 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
legislative in others. These subtleties must be carefully considered when quantifying the impact 

of zoning ordinances on the supply of manufactured homes. 

In the empirical analysis that follows, the basic reduced-form housing supply model developed 

by DiPasquale and Wheaton (1994) is modified to incorporate these factors. Given the 

difficulties associated with acquiring information on the number of manufactured home 

placements within individual communities, the supply of units is measured using a variety of 

proxy variables. The supply of units is modeled as a function of relevant supply determinants 

identified in the literature, including regional controls, population density (a proxy for land 

costs), and the number of manufacturing plants within 500 miles (a proxy for shipment costs 

from the manufactured housing plant to the final site). Demand-side price influences include 

median family income and the value of manufactured homes relative to single-family homes. 

Since adjustments to the stock in the form of new supply occur only through modifications to the 

existing stock plus the number of new units added through shipments, both of these factors are 

included as exogenous controls to capture the influence of the stock adjustment process. Finally, 

a measure of regulatory barriers is incorporated to capture the influence of regulatory constraints 

on the number of new units supplied. The next section describes the data employed to measure 

each of these variables. 

The Data 

This analysis is conducted for a sample of CDBG-eligible communities, using the most recent 

CDBG eligibility criteria. This sample selection criterion has three advantages: (1) it defines a 

sample of communities for which federal housing and urban development policy has been 

established, thus making the communities a relevant object of federal policy analysis; and (2) the 

sample criteria ensure that the communities are roughly homogeneous in terms of population 

size, geography, and metropolitan designation; and (3) since almost all studies of manufactured 

housing focus on rural communities, this sample selection criterion provides new information on 

an understudied dimension of the manufactured housing market. There were a total of 1,839 

communities that were deemed CDBG-eligible for inclusion in the sample. 

The data used in this analysis are derived from a variety of sources. Three different sources were 

relied on to construct four different measures of manufactured housing supply. First, data were 

obtained on the flow of new manufactured housing shipments from data collected by the Institute 

of Building Technology and Safety (IBTS) for the HUD-Code inspection program. These data, 

available upon contractual arrangement with IBTS, are available at the local jurisdiction-level 

where homes are shipped for all years between 2000 and 2005. The shipments measure is used 

both as a dependent variable, to determine if regulations influence shipments from plants, and as 

an independent variable (lagged to avoid endogeneity concerns) in models explaining 

placements, given that placements are likely to adjust in response to the existing supply of 

manufactured homes which also include inventories built up through shipments. 

Since homes may be placed in a variety of locations once shipped, separate measures of housing 

supply that reflect the actual number of units placed were identified. The first proxy for 

placements is the total number of manufactured home sales (loans) as reported in the Home 

Mortgage Disclosure Act (HMDA) data. These data were made available in 2004 for the first 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 29 
time, so data were pooled from 2004 and 2005 to construct a two-year count of manufactured 

home sales. Although sales totals reflect both the number of existing units sold as well as the 

number of newly-placed units sold, placements and total sales are probably highly correlated at 

the jurisdiction-level. In communities with few existing units, nearly all sales would reflect new 

placements. If communities with more existing sales are also more favorably disposed to 

approving new units, the total sales and new placements would be correlated. 

The final chosen measure of manufactured housing supply is taken from the survey described in 

the previous section. Two supply measures were constructed from the responses to this survey. 

The first measure is a dummy variable equal to 1 if the respondent responds “yes” or “probably 

yes” to the question, “In the past five years has your jurisdiction approved the placement or 

location of any new HUD-Code homes?” The second supply measure is an ordinal scale that 

identifies the number of units placed, based on responses to the question, “Approximately how 

many HUD-Code homes have been placed or located in your jurisdiction in the past five years?” 

Since the assumption was made that due to limited recall, respondents would only be able to 

identify actual unit totals within particular ranges, the categories for this variable include the 

following ranges: 0, 1–10, 11–20, 21–30, 31–40, 41–50, 51–99, 100+. Since some categories 

had limited response ranges, a few categories were combined to estimate the regression model 

described in the next section, given that the model requires a sufficient number of responses per 

category to estimate the relevant regression coefficients. The final category ranges, after 

combining categories with low response rates, include the following: 0, 1–20, 21–50, 50+. 

Since each of these supply measures has unique advantages and disadvantages, all measures 

were examined to determine the robustness of results to different measures of supply. One could 

argue that shipments should be relatively insensitive to regulatory characteristics, given that 

knowledge of regulations at the plant level is likely minimal, and local dealers can simply avoid 

restrictive local regulations by placing units in adjacent less-restrictive communities. For this 

reason, it is also useful to examine actual measures of placements. The HMDA proxy is an 

indirect measure, but it also reflects the supply of existing units as well as the turnover rate in 

units due to mobility. As a result, it is at best an indirect proxy for placements. The most direct 

measures of placements are the ones constructed from responses to the survey questions 

described above, although the accuracy of these data are limited by the recall ability of local 

respondents and should be interpreted with this caution in mind. 

The measure of regulatory barriers is also obtained from the manufactured housing survey 

described above. Using this source, two types of regulatory barriers variables were constructed: 

•	 By-Right Zoning Indicator: This variable is equal to 1 if respondents placing 

manufactured homes during the last five years answered “yes” when asked if the 

following best describes the jurisdiction’s regulations on HUD-Code homes: “HUD-Code 

homes are allowed as a by right use in single-family zones, but there have been no 

requests to locate HUD-Code homes in the past five years.” This variable is also equal to 

1 if those not placing manufactured homes answered “yes” to the question “Does your 

jurisdiction allow HUD-Code homes as a by right use in one or more single-family zones 

if design standards are met?” The variable is equal to 0 otherwise. 

30 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
•	 Measures of Perceived Regulatory Barriers: The question, “For your jurisdiction, please 

rate the following potential barriers to HUD-Code homes:” was used to construct a vector 

of variables. Each variable in the vector is equal to 1 if a given issue is seemed a 

“significant barrier” or worse and 0 otherwise. The issues posed for consideration by 

respondents include: fees, permits, deed restrictions/covenants, wind standards, snow 

load standards, fire codes, zoning codes, subdivision regulations, architectural design 

standards, citizen opposition, environmental regulations, historic district regulations, high 

land costs, not much land (built-out), no new manufactured housing communities 

approved, insufficient demand for manufactured housing. 

Each of these measures provides different information on the content of local regulations. The 

by-right zoning indicator is an objective measure of actual regulatory requirements, but it does 

not capture the extent to which the regulation, as implemented in practice, actually constrains the 

supply of manufactured units. The measures of perceived regulatory barriers are employed for 

this purpose, with the caveat that these measures reflect the subjective interpretation of 

respondents. 

In addition to the data obtained from the survey, several independent variables were included 

from the 2000 U.S. Census of Population and Housing and the 2004 Census Population 

Estimates, including regional dummy variables, population density, population growth rate 

between 2000 and 2004, median family income in 2000, the total number of existing 

manufactured housing units in 2000, and the median value of manufactured homes relative to the 

median value of single-family homes. 

The final independent variable is the number of manufactured housing plants within 500 miles of 

each CDBG-eligible community. The 500 mile radius was chosen both to reflect the reasonable 

distance that a home could be shipped in a single day and to ensure sufficient variability in the 

count variable. To measure the proximity between each community in the sample and nearby 

manufactured housing plants, Arc-GIS was employed to construct 500 mile circles around the 

centroid of each CDBG-eligible community allowing the number of manufactured housing 

plants that fell within each circle to be counted. The data on the location of manufactured 

housing plants were provided by IBTS. 

Out of the initial universe of 1,839 CDBG-eligible communities, 940 responded to the regulatory 

barriers survey. Of these, several communities did not respond to all questions used in the 

analysis and had to be dropped from the final sample. Furthermore, manufactured housing 

shipments data were not available for some communities in the sample. While the final sample 

size used in the regression analysis varies from model to model, the final sample sizes generally 

range from 547 to 843, which is sufficiently large to ensure efficient estimates of the regression 

parameter coefficients. Table 1.18 below provides descriptive statistics for all variables used in 

the regression analysis, including the sample sizes associated with each variable. 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 31 
 

 

Table 1.18: Descriptive Statistics for Variables in Regression Analysis 

VARIABLES 

DESCRIPTIVE STATISTICS 

N Mean Std. Dev. Min Max 

MH shipments, 2000–05 843 393.686 684.089 0.000 8233.000 

Total MH loans, 2004–05 843 128.668 247.847 0.000 3519.000 

MH units placed 818 0.681 0.466 0.000 1.000 

(Recoded) MH placements scale 843 2.047 1.052 1.000 4.000 

Northeast region 843 0.108 0.310 0.000 1.000 

Midwest region 843 0.281 0.450 0.000 1.000 

South region 843 0.364 0.481 0.000 1.000 

Population density 830 2756.609 2485.024 11.300 26403.810 

Population growth rate, 2000–04 843 4.134 9.195 -18.744 90.947 

Median family income (2000 $s) 843 46167.780 13339.980 21677.000 109455.000 

Total existing MH units, 2000 843 897.263 1962.430 0.000 30984.000 

Median value MH homes / Median value SF homes 843 0.303 0.256 0.000 2.818 

Number of MH plants within 500 miles 843 11.275 12.974 0.000 54.000 

MH is treated as a by-right use in SF zones 843 0.437 0.496 0.000 1.000 

Fees are significant MH barrier 682 0.034 0.181 0.000 1.000 

Permits are significant MH barrier 712 0.067 0.251 0.000 1.000 

Deed restrictions/covenants are significant MH barrier 617 0.358 0.480 0.000 1.000 

Wind standards are significant MH barrier 663 0.109 0.311 0.000 1.000 

Snow load standards are significant MH barrier 547 0.051 0.221 0.000 1.000 

Fire codes are significant MH barrier 683 0.078 0.268 0.000 1.000 

Zoning codes are significant MH barrier 767 0.347 0.476 0.000 1.000 

Subdivision regulations are significant MH barrier 715 0.227 0.419 0.000 1.000 

Architectural design standards are significant MH 

barrier 611 0.185 0.389 0.000 1.000 

Citizen opposition is significant MH barrier 696 0.409 0.492 0.000 1.000 

Environmental regulations are significant MH barrier 624 0.035 0.185 0.000 1.000 

Historic district regulations are significant MH barrier 587 0.365 0.482 0.000 1.000 

High land costs are significant MH barrier 713 0.452 0.498 0.000 1.000 

Not much land (built-out) is significant MH barrier 678 0.344 0.475 0.000 1.000 

No new MH communities approved is significant MH 

barrier 599 0.457 0.499 0.000 1.000 

Insufficient demand is significant MH barrier 624 0.271 0.445 0.000 1.000 

Results Using the By-Right Zoning Indicator of Regulatory Restrictiveness 

The discussion begins with the results from models which rely on the by-right zoning indicator 

of regulatory restrictiveness. This variable was included along with the others described above in 

models which rely on the four separate measures of manufactured housing supply described 

above as the relevant dependent variables. The results of these regressions are displayed in 

Tables 1.19 and 1.20. The models employing the shipments variable and manufactured home 

sales variable as dependent variables were estimated using ordinary least squares (OLS), and the 

models employing the binary indicator of placements as a dependent variable were estimated 

using logit regressions. Since the manufactured housing placements scale is measured on an 

32 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

ordinal scale, this model is estimated using a generalized ordered logit model. Ordered logit 

models account for the ordinal nature of the data, as opposed to ordinary least squares, which 

treats the dependent variable as a continuous measure. Generalized ordered logit models are 

employed for two reasons. First, the models provide separate coefficients for each level of the 

dependent variable which allows for determining if regulatory barriers have an impact on 

placements beyond the 0–1 threshold. Second, Chi-Square tests (not reported for brevity) 

soundly reject the proportional odds restriction placed on the usual ordered logit model in favor 

of the generalized model which relaxes this restriction. 

Table 1.19: Regression Results, By-Right Zoning Indicator of Regulatory Restrictiveness 

MEASURE OF MH SUPPLY SHIPMENTS LOANS UNITS PLACED 

Independent Variables Coefficient Significance Coefficient Significance Coefficient Odds 

Ratio 

Significance 

Constant 431.161 *** -44.659 * 3.431 

Northeast region -61.022 -2.923 -1.398 0.247 *** 

Midwest region -51.497 -6.685 -0.839 0.432 *** 

South region 339.263 *** 35.496 ** -0.858 0.424 *** 

MH shipments, 2000–05 0.098 *** 2.2E-04 1.0002 

Population density -0.019 ** 0.002 -3.1E-04 0.9997 *** 

Population growth rate, 2000–04 -0.221 -0.354 -0.007 0.993 

Median family income (2000 $s) -0.005 *** 0.001 ** -4.1E-05 0.99996 *** 

Total existing MH units, 2000 0.139 *** 0.084 *** 2.3E-04 1.0002 ** 

Median value MH homes / 

Median value SF homes -61.342 -1.245 -3.1E-04 0.9997 

Number of MH plants within 

500 miles 3.277 ** -0.042 0.004 1.004 

MH is treated as a by-right use in 

SF zones -3.046 5.765 1.356 3.882 *** 

R-squared 0.2814 0.675 0.1966 

N 830 830 807 

*** p < .01; ** p < .05; * p < .10 

NOTE: Shipment and loans models rely on OLS; Units placed models employ logistic regression. 

R-squared for logit models refers to the pseudo R-squared.
 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 33 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table 1.20: Generalized Ordered Logit Regression Results, MH Units Placement Scale 

PLACEMENT SCALE MEASURE OF MH SUPPLY 

Outcome Category Independent Variables Coefficient Odds 

Ratio 

Significance 

At least 1 MH unit placed in 

last 5 years 

Constant 3.007 

Northeast region -1.233 0.292 *** 

Midwest region -0.907 0.404 *** 

South region -0.647 0.524 ** 

MH shipments, 2000–05 1.6E-05 1.00002 

Population density -2.9E-04 0.9997 *** 

Population growth rate, 2000–04 -0.002 0.998 

Median family income (2000 $s) -4.1E-05 0.99996 *** 

Total existing MH units, 2000 1.5E-04 1.0002 * 

Median value MH homes / Median value SF homes -0.174 0.840 

Number of MH plants within 500 miles 0.006 1.006 

MH is treated as a by-right use in SF zones 1.596 4.935 *** 

More than 20 MH units placed 

in last 5 years 

Constant 0.437 

Northeast region -1.697 0.183 *** 

Midwest region -1.343 0.261 *** 

South region -0.680 0.507 *** 

MH shipments, 2000–05 2.5E-04 1.0002 * 

Population density -2.8E-04 0.9997 *** 

Population growth rate, 2000–04 -0.020 0.981 ** 

Median family income (2000 $s) -1.2E-05 0.99999 

Total existing MH units, 2000 3.7E-04 1.0004 *** 

Median value MH homes / Median value SF homes -0.562 0.570 

Number of MH plants within 500 miles 0.011 1.011 * 

MH is treated as a by-right use in SF zones 0.555 1.742 *** 

More than 50 MH units placed 

in last 5 years 

Constant -1.948 

Northeast region -1.089 0.337 

Midwest region -1.388 0.250 *** 

South region -0.212 0.809 

MH shipments, 2000–05 2.2E-04 1.0002 

Population density -2.4E-04 0.9998 *** 

Population growth rate, 2000–04 -0.004 0.996 

Median family income (2000 $s) 1.4E-05 1.00001 

Total existing MH units, 2000 3.6E-04 1.0004 *** 

Median value MH homes / Median value SF homes -1.511 0.221 * 

Number of MH plants within 500 miles 0.020 1.020 ** 

MH is treated as a by-right use in SF zones 0.526 1.693 ** 

Pseudo R-squared 0.158 

N 830 

*** p < .01; ** p < .05; * p < .10 

34 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
 

The sample sizes in these models range from 807 to 830, and the R-squared measures range from 

.158 to .675. Although .158 is on the low end of an acceptable measure of fit, this measure along 

with the goodness of fit measure for the logit model are based on Pseudo-R-squared measures 

calculated for maximum likelihood estimation. These measures tend to be a bit lower than the 

actual R-squared measures reported for ordinary least squares (OLS) models. 

As might be expected, the results suggest that the determinants of manufactured housing supply 

are sensitive to the measure of supply employed. When measuring the supply in terms of the 

number of shipments or manufactured housing loans, the South captures a larger share of 

manufactured housing units. However, when placements are taken as the measure of supply, 

supply is higher in the West. One explanation for this apparently contradictory finding is that the 

South exhibits a larger inventory of unplaced units and a larger number of existing manufactured 

housing sales relative to sales of new units. Further analysis is needed to determine if this theory 

is correct. 

When the flow of units is taken as an independent variable explaining the number of recent sales 

and units placed, flows have a strong impact on sales, but only influence placements within a 

relatively moderate (20+ unit) range. This suggests that inventory shortages do not constrain unit 

placements unless the shortages are moderately large. 

Several community characteristics influence manufactured housing supply. Population density is 

negatively associated with manufactured housing supply in three of the four models. This implies 

that on average, manufactured housing is a more feasible option in more suburban CDBGeligible jurisdictions where density is low, likely due to the relatively lower land costs in those 

areas and possibly higher demand for this housing type. In all models but the manufactured 

housing sales model, median family income is negatively associated with manufactured housing 

supply, as might be expected given that manufactured housing units typically sell for lower 

prices than equivalent site-built homes. The positive impact of income on manufactured housing 

loans possibly reflects the influence of income on total home loans, which are likely also higher 

in areas with higher income. In all cases, manufactured housing supply is positively associated 

with a higher existing supply of manufactured housing. This suggests that manufactured housing 

does not follow the traditional stock adjustment process that typically characterizes the supply of 

site-built homes. In the case of manufactured housing, the existing stock is more likely an 

indicator of community-level tastes for manufactured housing, as well as the historical regulatory 

stance of the community in allowing the placement of such units. Interestingly, the relative price 

of manufactured housing does not influence supply until a higher (50+) placements threshold is 

reached. Beyond this threshold, higher prices are equated with lower levels of supply. It is 

possible that this estimate reflects the endogeneity of housing prices in the model (that is, 

increased housing supply is associated with relatively lower prices rather than the reverse). 

Finally, proximity to manufactured housing plants influences the number of shipments but does 

not influence other measures of housing supply. This is somewhat expected, given that shipment 

costs likely have a much larger impact on the flow of homes rather than the stock of homes sold 

and placed at any given time. 

Regarding the influence of the policy variable of interest, allowing manufactured housing as a by 

right use in single-family zones has no influence on shipments or sales. This is somewhat 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 35 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

expected, given that shipments are largely influenced by inventory adjustment considerations for 

a given level of demand, while sales reflect the turnover in existing units as well as the number 

of new units sold. By-right zoning for manufactured housing is shown to have a positive impact 

on the probability of a new unit being placed, however. Also, comparing the logit and the 

generalized ordered logit models, the impact is largest at the 0–1 threshold. The relative impact 

of by-right allowances on the odds of placing one unit or more is three times higher than the odds 

of placing more than 20 units. Above the 50 unit threshold, the impact of by-right allowances 

diminishes in magnitude even further, although it is still statistically significant. This result 

suggests that by-right zoning of manufactured housing units has a larger impact on the likelihood 

of a small number of units being placed. At higher numbers of placements, other local economic 

factors become more important in determining the supply of manufactured housing units. 

Results Using the Measures of Perceived Regulatory Barriers 

The models discussed in this section rely on the vector of perceived regulatory barriers indices 

described above. Separate models are estimated for each different regulatory barriers indicator, 

given that each is likely highly correlated. The discussion focuses on a comparison of the relative 

influence of the regulatory barriers coefficients for each different measure of manufactured 

housing supply. The section begins with a discussion of the regulatory barriers coefficients from 

models employing the number of shipments as the dependent variable (Table 1.21). 

Table 1.21: Summary of MH Shipment Models 

REGULATORY BARRIERS 

STATISTICS 

N R-squared Coefficient Significance 

Fees 673 0.283 -142.619 

Permits 703 0.282 -79.351 

Deed restrictions/covenants 609 0.287 -21.452 

Wind standards 654 0.289 -138.197 * 

Snow load standards 538 0.275 155.520 

Fire codes 674 0.250 -138.243 

Zoning codes 758 0.272 -18.768 

Subdivision regulations 706 0.289 -125.938 ** 

Architectural design standards 603 0.283 -64.432 

Citizen opposition 688 0.275 53.979 

Environmental regulations 616 0.284 -201.085 

Historic district regulations 579 0.293 56.570 

High land costs 704 0.287 -50.282 

Not much land (built-out) 671 0.292 -62.906 

No new MH communities approved 592 0.291 3.168 

Insufficient demand for MH 616 0.241 -36.028 

*** p < .01; ** p < .05; * p < .10 

The R-squared measures range from .24 to .29, which is comparable to the shipment model 

described above. Some of the models presented in this section tend to have lower sample sizes 

due to the relatively higher number of missing responses to the perceived regulatory barriers 

questions. 

36 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
Regarding the impact of regulatory barriers, only wind standards and subdivision regulations 

have a statistically significant negative impact on the number of shipments to localities. Of the 

two, it is possible that the significance of wind standards reflects regional variation given that 

some regions are much more wind-prone than others. It is rather expected to find that regulatory 

barriers have a limited impact on shipments for reasons discussed above. It is not clear why the 

only factor of importance would be subdivision regulations, however. Perhaps this regulatory 

feature is more difficult for dealers to avoid by placing in neighboring jurisdictions given that 

subdivision regulations are likely similar from jurisdiction to jurisdiction. 

Turning now to a summary of the regression coefficients from models employing the number of 

manufactured housing loans as the dependent variable, the R-squared values are again much 

higher. This is likely due to the inclusion of the flow variable as a determinant of sales. In these 

models, one regulatory barrier (snow load standards) is shown to have an unexpectedly positive 

and statistically significant influence on manufactured home sales. There are two possible 

explanations for this unexpected finding. First, as with wind load standards, this variable could 

be capturing unobserved regional characteristics associated with snow-prone areas. However, 

one would expect that this would bias this coefficient in the negative direction and not the 

positive direction since nearly all snow-prone regions of the country tend to exhibit much lower 

levels of manufactured housing activity. It is also possible that in snow-prone areas the absence 

of standards simply renders manufactured housing an infeasible housing option. Further research 

is needed to understand this unexpected finding. 

The other statistically significant coefficients do display expected signs, however. Burdensome 

zoning codes, architectural design standards, and lack of buildable land all serve to reduce the 

number of manufactured housing sales within a community (Table 1.22). Of these factors, 

burdensome architectural design standards have the largest dampening effect on sales, possible 

suggesting that such standards reduce the cost effectiveness and affordability of this housing 

option in many communities. 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 37 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table 1.22: Summary of MH Loan Models 

REGULATORY BARRIERS 

STATISTICS 

N R-squared Coefficient Significance 

Fees 673 0.671 0.809 

Permits 703 0.669 13.967 

Deed restrictions/covenants 609 0.675 1.467 

Wind standards 654 0.661 -20.656 

Snow load standards 538 0.759 40.033 ** 

Fire codes 674 0.746 -6.151 

Zoning codes 758 0.669 -32.254 *** 

Subdivision regulations 706 0.678 -4.915 

Architectural design standards 603 0.674 -38.353 ** 

Citizen opposition 688 0.668 -4.748 

Environmental regulations 616 0.649 17.872 

Historic district regulations 579 0.673 -4.640 

High land costs 704 0.664 -18.257 

Not much land (built-out) 671 0.662 -28.264 ** 

No new MH communities approved 592 0.662 2.396 

Insufficient demand for MH 616 0.745 -1.773 

*** p < .01; ** p < .05; * p < .10 

Table 1.23 displays a summary of the odds ratios (impact of each independent variable on the 

odds of observing a value of “1” on the outcome variable of interest) from logit models 

predicting the probability that a single manufactured housing unit or more will be placed within a 

given community. The pseudo R-squared values for these models range from .12 to .22, which is 

comparable to the logit model estimated in the previous section. 

38 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
 

 

 

 

 

 

Table 1.23: Summary of Logit Models 

REGULATORY BARRIERS 

STATISTICS 

N Pseudo R-squared Odds Ratio Significance 

Fees 673 0.137 0.369 ** 

Permits 703 0.147 0.205 *** 

Deed restrictions/covenants 609 0.129 1.241 

Wind standards 654 0.124 0.775 

Snow load standards 538 0.162 0.381 ** 

Fire codes 674 0.131 0.289 *** 

Zoning codes 758 0.165 0.349 *** 

Subdivision regulations 706 0.147 0.345 *** 

Architectural design standards 603 0.174 0.334 *** 

Citizen opposition 688 0.165 0.358 *** 

Environmental regulations 616 0.141 0.395 * 

Historic district regulations 579 0.134 0.850 

High land costs 704 0.164 0.536 *** 

Not much land (built-out) 671 0.169 0.382 *** 

No new MH communities approved 592 0.179 0.324 *** 

Insufficient demand for MH 616 0.217 0.185 *** 

*** p < .01; ** p < .05; * p < .10 

When relying on an actual measure of placements as the dependent variable, almost all 

regulatory barriers were found to exhibit a statistically significant impact on the probability that a 

unit will be placed. Recalling that odds ratios above 1 indicate that a given variable increases the 

odds that a unit will be placed, while odds ratios below 1 suggest the opposite, burdensome fees, 

permits, snow load standards, fire codes, zoning codes, subdivision regulations, architectural 

design standards, citizen opposition, environmental regulations, high land costs, not much land, 

no new manufactured housing communities approved, and insufficient demand for manufactured 

housing all were found to reduce the odds of unit placement. Of these factors, insignificant 

demand for manufactured housing has the largest negative impact on the odds of unit placement. 

Among regulatory factors, the overall permitting system, when perceived to be burdensome, has 

the largest negative impact on unit placement. All statistically significant impacts are quite large 

in magnitude, however. 

Table 1.24 displays a summary of the results from generalized ordered logit models predicting 

the conditional probability that a community receives a number of placements that falls within a 

higher category on the manufactured housing scale relative to the next lowest category. Again, 

the results from Chi-Square tests (not shown for brevity) suggest that the generalized ordered 

logit model is superior to the basic ordered logit model which relies on the proportional odds 

assumption. The pseudo R-squared values for these models range from .10 to .13, which is 

slightly lower but comparable to the ordered logit model described in the previous section. 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 39 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table 1.24: Summary of Generalized Ordered Logit Models 

REGULATORY BARRIERS 

MODEL 

SUMMARY 

IMPACT OF REGULATORY BARRIER PRESENCE 

ON ODDS OF PLACING 

N Pseudo 

R-squared 

>0 MH Units >20 MH Units >50 MH Units 

Odds 

Ratio 

Significance Odds 

Ratio 

Significance Odds 

Ratio 

Significance 

Fees 673 0.111 0.506 0.979 1.901 

Permits 703 0.110 0.287 *** 0.414 ** 0.229 * 

Deed restrictions/covenants 609 0.105 1.272 1.259 1.547 * 

Wind standards 654 0.105 0.735 0.632 0.561 

Snow load standards 538 0.112 0.421 * 0.392 1.125 

Fire codes 674 0.104 0.358 *** 0.612 1.012 

Zoning codes 758 0.119 0.415 *** 0.601 *** 0.535 ** 

Subdivision regulations 706 0.113 0.456 *** 0.487 *** 0.326 *** 

Architectural design standards 603 0.120 0.397 *** 0.560 ** 0.867 

Citizen opposition 688 0.115 0.474 *** 0.492 *** 0.442 *** 

Environmental regulations 616 0.110 0.621 1.618 2.482 

Historic district regulations 579 0.115 0.913 0.752 1.003 

High land costs 704 0.116 0.593 *** 0.785 0.913 

Not much land (built-out) 671 0.124 0.583 *** 0.388 *** 0.278 *** 

No new MH communities 

approved 592 0.128 0.406 *** 0.546 *** 0.746 

Insufficient demand for MH 616 0.160 0.264 *** 0.174 *** 0.252 *** 

*** p < .01; ** p < .05; * p < .10 

These models present a more nuanced view of the impact of regulatory barriers, because they 

describe how barriers influence the number of units across the distribution of the placements. 

Again, insufficient demand has the largest dampening effect on unit placement. This effect is 

rather consistent across all categories of units placed. The built-out nature of the community has 

an increasing effect over the distribution of units placed. This is somewhat expected, given that 

the land scarcity constraint is likely higher for large-scale developments compared to smaller 

scale developments. Among the regulatory influences, the overall permitting system again was 

found to exhibit the largest impact at lower levels of units placed. The effect of permits exhibits a 

more nonlinear trend across the distribution of units placed, however, with the influence 

diminishing rather significantly over moderate levels of units placed. Snow load standards, fire 

codes, zoning regulations, and architectural design standards exhibit effects that either become 

statistically insignificant at higher levels or diminish in magnitude. Such is not the case with 

subdivision regulations, which exhibit larger impacts at higher levels of units placed. An 

unexpected finding is that deed restrictions and covenants actually increase the odds of a higher 

number of units being placed, although this effect is only statistically significant at the .10 level. 

Summary of Major Findings from the Empirical Analysis 

State and local regulatory barriers to placement of manufactured housing were analyzed through 

three approaches: 

1. An examination of regional trends in manufactured housing shipment activity. 

40 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
2.	 An analysis of the impact of state statutes defining permissible regulations for local 

governments. 

3.	 An analysis of the impact of local regulatory barriers on placement of manufactured 

housing. 

The following summarizes the major findings from each of these three analyses. 

Regional Trends in Shipment Activity 

Over the 2000 to 2005 period, there were significant regional differences in manufactured 

housing shipment activity. The South continued to attract the largest share of shipments, 

although this share declined somewhat since 2000. The relative decline in shipments to southern 

states was accompanied by a relative decline in retention of the existing stock of units. The 

Midwest also saw declining shares of shipments over the 2000–05 period while the Northeast 

and West saw consistently low levels of shipment activity. 

The Impact of State Manufactured Housing Statutes 

Almost all states address the regulation of manufactured housing, and more than half of states 

require localities to allow HUD-Code units somewhere within local jurisdictions. The majority 

of states do not address additional local regulations governing design, installation, lot 

improvements, and/or placement on site, however. 

Categorizing states by the degree to which states promote the use of manufactured housing by 

local governments, those that most strongly promoted HUD-Code usage captured the highest 

share of shipments over the 2000 to 2005 period. Furthermore, the gap between strong states and 

other states has grown over time. At the state level, this suggests that requirements to enact 

accommodating local standards appear to be having an influence on local shipment activity. 

Analysis of Local Regulatory Barriers 

Communities were separated into three primary categories: those with no units placed, those with 

only a few units placed, and those that manage to place a large number of units. Extreme 

exclusion of HUD-Code homes was fairly rare among the respondent communities, with only 

12.2 percent of respondents to a national survey indicating that their jurisdictions never or rarely 

allow HUD-Code homes to be used. Many of the jurisdictions that have not placed HUD-Code 

units in the past five years do allow such units. This suggests that both regulatory practices and 

market factors are important in determining whether developers choose to include HUD-Code 

units in new housing developments. 

Among those communities placing manufactured housing units in their communities, the 

majority allow HUD-Code units as a by-right use, either with or without additional requirements 

that ensure consistency with other single-family residential units. Further analysis of these design 

requirements suggests that most standards are clear, nondiscretionary, and easy to meet. 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 41 
The analysis also suggests that the best approach to increasing the supply of HUD-Code homes 

would be to promote the use of manufactured housing in HUD-Code parks and for infill in 

traditional subdivisions, along with allowing by-right placement in new single-family 

subdivisions. Jurisdictions approving new parks were twice as likely to have more than 50 units 

placed in the past five years than those not approving new parks. Finally, a higher number of 

units placed (in any location) is associated with communities achieving a balance between infill 

and other locations (particularly parks). 

However, jurisdictions with by-right regulations were less likely to approve new parks than those 

requiring special permits or restricting units to special districts. These findings suggest that to 

promote the supply of HUD-Code homes, regulations protecting by-right use in traditional 

single-family districts and infill locations should not be viewed as replacing regulations allowing 

the development of subdivisions devoted to manufactured housing. 

Among the perceived barriers to placing manufactured housing in communities, high land costs 

was most frequently selected as a significant or preventive barrier, followed by citizen 

opposition, no new parks, zoning codes, and not much land. Fees, permits, wind codes, snow 

load standards, fire codes, and environmental regulations were among the least likely items to be 

identified as regulatory barriers. 

A multivariate statistical analysis suggests that the placement of local HUD-Code units is 

influenced by a variety of market factors, including regional location, population density, median 

family income, the existing inventory of manufactured housing units, and proximity to 

manufactured housing plants. Regarding the influence of regulatory barriers, by-right zoning of 

manufactured housing units influences the likelihood of a small number of HUD-Code units 

being placed. At higher numbers of placements, other local economic factors become more 

important in determining the supply of manufactured housing units. 

In models that measure the impact of regulations and other local constraints in terms of the 

degree to which they are perceived to be barriers by local officials, almost all regulatory barriers, 

with the exception of subdivision regulations, zoning, wind standards, and architectural design 

standards, do not reduce HUD-Code shipments or sales at statistically significant levels. A 

number of regulatory and market barriers – including burdensome fees, permits, snow load 

standards, fire codes, zoning codes, subdivision regulations, architectural design standards, 

citizen opposition, environmental regulations, high land costs, not much land, no new 

manufactured housing communities approved, and insufficient demand for manufactured 

housing – reduce the probability that a HUD-Code unit is placed in a community. Among these 

regulatory influences, the overall permitting system, when perceived to be burdensome, has the 

largest negative impact on unit placement. Different regulatory barriers have different impacts on 

unit placement across the distribution of units placed, with almost all exhibiting threshold effects 

at the 0–1 unit level. This is consistent with the findings discussed earlier which suggest that 

regulatory barriers are associated more with whether jurisdictions have no or any HUD-Code 

units, while market barriers have a greater role in determining the number of units that are placed 

in a community, given that units are allowed. 

42 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
 

CASE STUDIES 

Introduction 

The statistical research and analysis of regulatory and market factors influencing the placement 

of HUD-Code homes in CDBG-entitlement communities highlights the complexity of the topic. 

Not only do the survey data and statistical models help identify the complexity of the measurable 

effects influencing the use of HUD-Code homes, they demonstrate that the majority of variation 

in the use of HUD-Code homes was not captured in the statistical analysis. Unmeasured 

variables could help explain the large amount of unexplained variation. In addition, some 

important effects could be random or so highly contextual that they cannot be adequately 

measured in quantitative research. 

To help expand understanding of the contextual and unmeasured factors influencing the use of 

HUD-Code homes, four qualitative case studies were conducted. The cases were identified 

through news stories, industry reports, discussions with advocates and leaders within the 

manufactured housing and affordable housing industries. They four cases were selected to 

illustrate a range from state to local efforts spanning public, for-profit and nonprofit 

development. 

The cases include Oakland (California), state of Washington, Pima County (Arizona), and 

Owensboro (Kentucky). Oakland is one of the premier success stories of the use of manufactured 

housing in urban infill. Washington recently passed state legislation enabling broader use of 

manufactured housing after a near three-decade long advocacy effort and the success of several 

well publicized subdivisions featuring manufactured housing. Pima County profiles efforts to 

promote manufactured housing in the high-growth area of Tucson and the complexities of 

placing manufactured units in the expanding suburbs. Owensboro illustrates the ongoing 

challenges of developing and marketing manufactured housing even within a state with a long 

reliance on manufactured housing in rural areas and a record of state legislative support. 

Throughout the case studies, the nonprofit affordable housing sector is shown to play a critical 

role in promoting the use of manufactured housing. 

Lessons Learned from the Case Studies 

The prominent lessons provided by these cases include: 

•	 Built-out urban areas can promote affordable redevelopment using manufactured housing 

on vacant infill lots, as illustrated by Oakland, particularly in cities with the potential to 

capture an important share of the moderate priced housing market. 

•	 Regulatory reforms should be seen as enabling rather than causing change—regulatory 

reform is a necessary but not sufficient condition to promote change. 

•	 Competitive advantage (price and quality) and the support of financial and other housing 

market institutions have to be secured. Nonetheless, the numerical impact of regulatory 

reforms and promotional efforts is likely to be modest. 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 43 
•	 Prominent successes and local initiatives, such as found in several manufactured housing 

subdivisions in Washington, can help promote statewide legislative reform. 

•	 The nonprofit and public development sectors can be leaders in facilitating change, but 

the broader impact of national market forces must be recognized and the expectations for 

impacts need to be realistic. 

•	 Although more units can be placed through the development of manufactured housing 

subdivisions, acceptance (public, governmental, and market) in high-growth suburban 

areas will be difficult, but not impossible, as illustrated in Pima. 

•	 Infill in older cities in high-growth metropolitan markets, although likely to reach only 

modest levels, might prove more fruitful in high-growth markets. 

•	 The potential in lower-cost, lower-growth communities, such as Owensboro, might 

remain with the rural fringe urban areas more than with urban subdivisions and infill 

unless greater competitive advantages and public support can be gained. 

•	 The greater potential for developing new manufactured housing subdivisions outside the 

city could create a higher volume of units but many of these would be considered rural 

placement rather than urban. 

•	 The nonprofit affordable housing sector could be an important ally in promoting 

manufactured housing, but the city/suburb, infill and new subdivision mix will depend on 

local market conditions that create greater competitive advantage for manufactured 

housing. 

•	 Nonprofit housing organizations can utilize manufactured housing as a means of 

expanding opportunity for affordable homeownership within urban areas. 

44 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
 

 

 

Oakland, California Case Study1 

Introduction 

Since 1980, the placement of manufactured homes on individual vacant lots has been a steady 

activity in the urban setting of Oakland, California over a 27 year period2

. The current case study 

covers the overall Oakland experience with manufactured housing following significant city and 

state regulatory changes in 1980. 

Unlike its more glamorous San Francisco neighbor across the Bay, Oakland is blessed with an 

abundance of relatively level land. The building-friendly landscape facilitated Oakland’s 

development and steady growth from the Gold Rush days of the 1850s until growth waned 

shortly after World War II. Because of the availability of vacant lots in areas served by 

developed streets and utilities and because of a forward-looking City Council that adopted 

favorable ordinances lifting restrictions on the development of urban lots with manufactured 

homes, the city has seen a very large investment of private capital that has contributed to 

revitalization of many declining neighborhoods. 

The majority of manufactured housing units in Oakland are single-family homes placed on 

scattered single lots (see Figures 2.1 and 2.2). 

1

 Case study prepared by Steve Hullibarger, The Home Team, Fair Oaks, California. 

2

 The dataset used in this case study is maintained and the property of Steve Hullibarger and contains information on 

259 HUD-Code homes covering the time period 1980 through present (2007) located on individual lots in the City 

of Oakland. In addition, the database includes eight modular homes in the city. For all of Alameda County, the 

count totals 332 HUD-Code homes and 10 modular homes. 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 45 
Figure 2.1: Single-section, Single-family Manufactured Home 

Figure 2.2: Multi-section Single-family Manufactured Home 

46 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
 

Beginning in the mid-1980s, a hybrid type of manufactured home began to appear in Oakland— 

manufactured home duplexes as small investment rental properties. Inasmuch as the HUD Code 

does not address multi-family homes, the creation of manufactured home duplexes was achieved 

through an interesting merging of two single-family homes on a single lot. The most popular 

format to emerge was the placement of two large single-section homes on a single foundation, 

with two one-hour fire resistive construction walls separating the two modules. The homes, most 

commonly 14 feet wide by 66 feet long with three bedrooms and two baths, were built in mirror 

image to each other. Additionally, roof trusses more commonly used on double section homes 

were used on each home. At the match line between the units, the floor plans were altered to 

eliminate any openings, such as windows. When placed within one inch of each other on the 

foundation, the two units assumed the physical characteristic of one large two-family home. 

Garages were added to many, but not all, of the homes. 

More recently, multi-family (and multi-story) HUD-Code homes have been used in 

developments of significantly greater sophistication (and price). 

City Background 

Oakland, California, surrounded by Alameda County, is located in the San Francisco Bay Area 

of Northern California as seen in Map 2.1. The city of Oakland is highlighted in red within the 

breakout map of Alameda County. 

Map 2.1: Location of Oakland, California 

As of July 1, 2006, the population of Oakland was estimated by the Census Bureau at 397,067, 

down slightly from 2000 (a decline of only 0.6%). However, the city’s finance department 

estimated that as of January 1, 2006, Oakland’s population was 411,755. Only 56 of Oakland’s 

78 square miles are land area and the city’s population density is approximately 7,100 people per 

square mile. Oakland is generally considered one of the most diverse cities in the U.S., with 

whites and African-Americans each accounting for about one-third of the population in 2006. In 

addition, the Hispanic/Latino population was almost double the national percentage (2000). 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 47 
 

 

While the 2006 median household income in Oakland, at $45,552, was approximately $3,000 

less than the national median, it was well under California’s median household income of 

$56,645. The average household size in 2006 (2.56) was lower than the national and state 

averages (2.61 and 2.93 respectively). 

Over half (56.3%) of the occupied housing units in 2006 were renter-occupied and 43.7 percent 

were owner-occupied. The ownership rate was considerably lower than the national rate of 66.2 

percent, reflecting both Oakland’s urban setting and high owner costs. Oakland had a very low 

owner vacancy rate in 2006 (1.7%) in comparison to a national rate of 2.4 percent. The rental 

vacancy rate in Oakland, on the other hand, was relatively high in 2006 (11.1% as compared to 

the national rate of 9.7%). With over 65 percent of Oakland’s housing stock built prior to 1960, 

the housing stock was significantly older than that of the nation (35% of the housing stock built 

prior to 1960 based on the 2006 American Community Survey). 

Oakland’s principal economic activities are light manufacturing, business services and shipping 

(the Port of Oakland is the fourth largest container port in the country). The California 

Employment Development Department reported that Oakland’s unemployment rate was 6.9 

percent in 2006, comparing poorly to the surrounding Alameda County’s rate of 4.4 percent. 

Even for those with jobs, the average wage in Oakland does not support the high cost of owner 

housing. According to the Bureau of Labor Statistics, the annual mean wage for the Oakland 

metropolitan area in May 2006 was $49,830. The median owner-occupied home value for the 

City of Oakland as estimated by the U.S. Census 2006 American Community Survey was 

$590,800. Median monthly gross rent in Oakland for 2006 was estimated at $947. Oakland’s 

relatively low homeownership rate (43.7% in 2006) is partly a factor of the high owner costs 

relative to wages. 

Manufactured Housing Characteristics 

Table 2.1 depicts manufactured housing characteristics for the city of Oakland (data reported are 

for 2000 due to the sampling variability of the ACS 2006 estimate of number of manufactured 

homes). Less than one percent of all housing units in Oakland in 2000 were manufactured 

homes. The city gained 178 manufactured housing units between 1990 and 2000 according the 

U.S. Census, and manufactured homes as a percentage of all housing units in Oakland almost 

doubled from 0.12 percent in 1990 to 0.23 percent in 2000. Manufactured housing units had a 

higher homeownership rate than all housing units within Oakland in 2000 (56.2% and 41.4% 

respectively). However, the median value of these owner-occupied housing units was lower for 

manufactured homes at $95,000 than for all housing units at $227,300 indicating that 

manufactured housing has created affordable ownership opportunities in Oakland. 

48 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
 

Table 2.1: Comparison of Manufactured Homes with All Housing Units in Oakland 

MANUFACTURED 

HOME UNITS 

ALL HOUSING 

UNITS 

Total Number of Units 2000 364 157,505 

Total Number of Units 1990 186 154,737 

Percent Change in Number of Units 1990–2000 95.7% 1.8% 

Percent Owner Occupied 2000 56.2% 41.4% 

Percent Renter Occupied 2000 43.4% 58.6% 

Median Value Owner-Occupied Housing Units 2000 $95,000 $227,300 

Median Value Owner-Occupied Housing Units 2006 Not Available $590,800 

Source: U.S. Census, 1990 and 2000 and American Community Survey, 2006 

Terrain and Lot Characteristics 

Oakland is divided into two principal areas known as the hills and the flatlands. In general the 

areas west and south of International Avenue (formerly East 14th Street) and Telegraph Avenue 

are referred to as the flatlands. There are considerable differences in property values between the 

lower value flatlands and the higher value hills which have some extremely expensive housing 

and are mostly built out. The northerly hills experienced a catastrophic fire in 1991, in which 

more than 3,300 houses were destroyed. While the area is mostly rebuilt today, few if any of the 

properties were rebuilt with manufactured homes, partly due to the steep terrain in the area. On 

the other hand, the flatlands are peppered with vacant lots and dilapidated houses. The flatland 

area is level, ideal for manufactured homes. 

There is no standard lot description for the hills other than from steep to very steep, and mostly 

unsuitable for manufactured homes. On the other hand, lots are quite suitable for manufactured 

homes in the aptly-named flatlands. In the older neighborhoods, many tracts were originally 

mapped with 25-foot widths and 100 to 130-foot depths. Over the years, a large number of these 

narrow lots were combined to result in more-adaptable 50-foot wide properties. Occasionally, 

larger lots are found, but they are rare. 

Almost all vacant lots in Oakland had a structure on them at one time in the past. Few true 

greenfield sites exist. When developers search for their prospective sites, many encounter lots 

that are filled with trash, overgrown with vegetation, encroached upon with structures from 

adjacent lots, and otherwise discouraging to consider for purchase. 

To find legitimate vacant lots, imagination must be used, along with detective skills. What may 

appear to be someone’s garden or parking lot frequently turns out to be an individual property, 

owned by a third party. Previously, infill entrepreneurs needed to spend a lot of time at the 

Alameda County Assessors Office, perusing assessor parcel maps to determine whether target 

properties were truly independent. Today, with the myriad of Internet tools, this process is 

greatly simplified. 

While many of the lots have remnants of old foundations and storage tanks, they also often have 

existing fencing, sidewalks, curbs, gutters, driveway aprons, and often-useable utility 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 49 
 

 

connections. However, lots may shrink in their appeal for placement of manufactured homes if 

they are on narrow streets or fronted by large trees, both of which can severely restrict access for 

placing a manufactured home. However, with the numerous clever devices the manufactured 

housing industry has invented to maneuver the homes, almost no obstacle is any longer fatal. 

Manufactured Homes in Oakland 

Neighborhood Areas of Greatest Manufactured Home Activity 

For over 27 years, the areas of greatest manufactured home infill activity have been in the 

flatland neighborhoods of North Oakland, West Oakland, San Antonio, Fruitvale, East Oakland 

and Elmhurst. In general, these are all older areas, having been originally developed in the 1860 

to 1880 period in the westerly areas and the 1940 to1960 period in the east. See Map 2.2. 

Map 2.2: Oakland Neighborhood Areas 

Table 2.2 shows the more concentrated areas of manufactured housing activity by Zip Code 

zones. A zip code reference map follows (see Map 2.3). Manufactured housing is located mainly 

in the southeastern portion of the city (zip codes 94603 and 94619). 

50 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
 

 

 

Table 2.2: Distribution of Oakland’s 259 Manufactured Homes by Zip Code 

ZIP CODE NUMBER OF 

HOMES ZIP CODE NUMBER OF 

HOMES 

94601 20 94608 25 

94602 18 94609 12 

94603 49 94611 1 

94605 17 94612 1 

94606 15 94619 19 

94607 30 94621 52 

Source: The Home Team 

Map 2.3: Oakland Zip Code Areas 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 51 
Architectural Context 

Manufactured homes are best accepted when they successfully fit within the architectural context 

of existing structures. Oakland is rich in architectural history and was known as the Athens of the 

West in the period following the California Gold Rush. Due to the abundance of level land in 

Oakland and the milder climate as compared to the rocky and hilly San Francisco, many affluent 

neighborhoods were developed in the mid to late 1800s, particularly in West Oakland. 

Extravagant homes, constructed in the Italianate, Queen Anne and Stick styles, still exist in these 

areas. Similarly, other parts of Oakland have extensive neighborhoods of strong architectural 

styles. In the north areas near Berkeley, Craftsman style homes predominate. Only in the East 

Oakland and Elmhurst areas are there large neighborhoods of simple tract or bungalow style 

homes. Obviously, for the modern manufactured home to fit into many of these neighborhoods, 

architectural modifications or enhancements are desirable. 

Description of Oakland’s Manufactured Homes 

Physical Configuration (Singles / Doubles / Triples / Number of stories) 

Oakland provides examples of several configurations of manufactured housing that demonstrate 

the products flexibility for infill housing in urban areas. The first manufactured homes to be 

placed in Oakland in the early 1980s were single-section models, measuring 14 feet by 60 to 64 

feet (see Figure 2.3). Almost all of these early homes were unadorned and few had garages. With 

lot dimensions of 25 feet by 100 feet, there was not much room to add accessory structures. Of 

the 259 homes tracked on the database, 80 are single-section single family homes. 

52 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
Figure 2.3: Single-section HUD-Code Home 

Multi-section homes began to appear in Oakland after the 1980s. Again, due to the narrow lot 

characteristics, almost all of these homes were two-section models oriented with the gable end to 

the street. Currently, 112 of the 259 HUD-Code homes in Oakland are of two-section, singlefamily design (see Figure 2.4). Due to their size, triple-section homes do not represent a good fit 

with Oakland’s small flatlands lots, although 6 homes have been place, mostly in the hills where 

lots are often larger. 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 53 
 

Figure 2.4: Two-section HUD-Code Home 

Oakland provides examples of numerous interesting adaptations of single-section homes, such as 

transforming them into duplexes by abutting two units together on one lot. Of the 249 properties 

in the database, 21 are duplexes that were created this way. Additionally, two properties were 

developed with three single-section homes as triplexes (see Figure 2.5), and five four-plexes 

were built. Of the five four-plexes, four were built with four single-section homes and one was 

developed with two multi-section homes. 

54 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
Figure 2.5: Tri-section HUD-Code Home Located in the Hills 

Twenty-four two-story manufactured homes have been sited in Oakland, all since 2002 when 

two-story manufactured homes began to be built and offered by HUD-Code manufacturers. Twostory manufactured homes are constructed under the special provisions of the HUD Alternative 

Construction Letter program. 

Foundations 

With few exceptions, the manufactured homes in Oakland are supported by foundations 

constructed of poured-in-place concrete, or mortared and grouted concrete blocks. Almost all of 

the homes enjoy full perimeter wall structural support with additional piers placed under the steel 

sub frame under the house (see Figures 2.6 and 2.7). Since Oakland is located in the highest 

known seismic risk area (the San Andreas fault is a few miles to the west and the Hayward fault 

lies along the city’s east limits), all foundations have enhanced steel reinforcing and heavy 

fastening schedules for the attachment of the home to the foundation. 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 55 
Figure 2.6: Foundation for a Two-story Manufactured Home 

Figure 2.7: Foundation for a Manufactured Home Duplex 

56 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
 

Exterior Designs/Architectural Modifications 

Developers use a number of techniques to harmonize the exteriors of manufactured homes with 

the streetscape. Among these are garages and porches that are meant to add utility to the home 

and to create a more permanent appearance. Some homes have exterior material overlays that 

match nearby existing homes. In some areas, reducing the elevation of the home by using an 

excavated foundation adds to the appeal of the home. In other neighborhoods, raising the home is 

necessary (see Figures 2.8 through 2.11). Some small lot developers do not budget for exterior 

designs that help the home fit into the neighborhood and consequently a minority of Oakland’s 

manufactured homes may appear out of place. 

Figure 2.8: Garage Abutting Front of Manufactured Home 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 57 
Figure 2.9: Early Attempt to Get Rid of the Singlewide Look by Extending Roof 

Figure 2.10: Carpenter Built Front Porch and Detailing on Manufactured Home 

58 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
Figure 2.11: A Tract Style Manuf actured Home (Montclair Area) 

Developers making changes or additions must observe an overlay of building codes. Any sitebuilt structure, such as a foundation, garage or porch, must conform to city building codes, go 

through city plan checking and city inspection. In addition, if the manufactured house is 

physically modified, with the addition of an attached garage for example, an alteration permit 

must be obtained from the state of California. 

Manufactured Housing Regulations 

Regulations at both the city and state levels have significantly impacted manufactured housing 

development in Oakland. In1980, the city enabled manufactured housing development by 

allowing placement of HUD-Code homes in residential zones. At the same time, the state passed 

legislation allowing HUD-Code homes to be developed according to the same standards as 

conventional, single-family housing. Removing regulatory barriers regarding placement and 

development standards resulted in evolving designs and innovation in manufactured housing. 

City Ordinances 

On December 9, 1980, the Oakland City Council unanimously enacted Ordinance No. 10004, 

“An Ordinance Authorizing Development of Manufactured Housing in Residential Zones.” 

Among the Council’s findings were these critical statements: 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 59 
“Whereas, the City of Oakland recognizes that manufactured houses on permanent 

foundations in the City would provide many Oakland residents, who are priced out of the 

conventional housing market, with decent, safe and affordable housing....” 

“Whereas, improved construction techniques and materials have made manufactured 

houses on permanent foundations virtually indistinguishable from conventionally 

constructed houses and have decreased the cost of said manufactured homes up to 50 

percent less than conventionally constructed houses....” 

The effect of Ordinance No. 10004 was to allow the placement, on permanent foundations, of 

HUD-Code homes, with certain qualifying standards, throughout the city (see Ordinance No. 

10004 in Appendix B–1.1). 

In July 1981, the council adopted Ordinance No. 10092 (see Appendix B–1.2), which removed 

any qualifications listed in the prior statute that were out of conformance with California 

legislation (described in following section) that became effective July 1, 1980. At that point, the 

regulatory barriers had been removed, and private enterprise, with private capital and risk-takers, 

began to seek out urban vacant lots for development with HUD-Code homes, possibly for the 

first time in the country. 

State Legislation 

The California legislature passed Senate Bill 1960 (Rains-Ventura) in 1980, which was then 

signed by Governor Jerry Brown. This bill created Section 65852.3 of the California 

Government Code regulating the installation of manufactured homes, and became operative July 

1, 1981, about 6 months after Oakland’s ordinance. The bill mandated that cities and counties 

allow the installation of HUD-code homes on an approved foundation system on lots zoned for 

conventional single-family residential dwellings. Except with respect to architectural 

requirements, manufactured housing would be subject only to the same development standards 

applied to a conventional single-family residential dwelling on the same lot. Any architectural 

requirements imposed on the manufactured home structure itself, exclusive of requirements for 

additional enclosures, are limited to roof overhang, roofing material, and siding material. any 

architectural requirements for roofing and siding material shall not exceed those which would be 

required of single family dwellings constructed on the same lot. Local government can prohibit 

installation of manufactured units that were manufactured more than 10 years prior to 

installation. Local governments may not apply any development standards having the effect of 

precluding manufactured homes from being installed as permanent residences. 

Special Considerations 

California might be the only state to create a special class of contractor licensing in recognition 

of the unique nature of installing manufactured homes. This allows the licensee to complete a 

wide range of tasks associated with installing the home that otherwise would have to be done by 

holders of other licenses. Because some of these tasks are minor (connecting plumbing lines, for 

example), the cost of bringing in a specialty contractor would add unnecessarily to costs and this 

regulation has helped keep on-site costs lower. 

60 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
Impact of Regulatory Changes on Volume of Development 

Subsequent to the adoption of favorable regulations, the volume of manufactured housing 

development began to increase. Shortly after the new regulations took effect, Bay Area 

entrepreneurs began to approach Sacramento-area manufacturers to learn of the types of 

manufactured homes available to them. Developers and manufacturers had to learn how to 

satisfy the regulations (for example, foundation requirements, building permits, code conflicts, 

on-site inspections, transfer of legal title, conversion to real property and the jurisdiction of 

various professional licenses), but eventually homes began to move into the neighborhoods as 

these obstacles were ironed out. 

Manufactured home retailers (or street dealers) have traditionally brokered the supply of 

manufactured homes. These dealers had no experience and often no interest in buying and 

developing urban lots and the bulk of the development activity was by developers, builders and 

Realtors. Many developers obtained their own retailer licenses in order to purchase the homes 

directly from the factories. Unlike traditional retailers, nearly all infill developers were 

unconcerned about exclusive distribution rights and manufacturers experienced little backlash 

from developers with retailer licenses when manufacturers provided homes to other developers 

who were often operating in nearby neighborhoods. 

Other traditional practices of the manufactured home industry can impede the creation of a 

smooth supply chain for developers. Manufacturers require up-front deposits of 20 to 25 percent 

of the eventual factory invoice to protect themselves from a developer’s failure to pay for the 

home. The balance of the invoice is due before the home is shipped from the factory. The 

developer cannot finance this purchase as part of a construction loan as the construction lender 

will not advance on a property improvement before it is affixed to the land securing the 

construction note. This financing gap reduces the appeal of factory-built housing to developers 

and remains an impediment to their use of HUD-Code homes. 

Housing Price/Home Equity Effects 

Developers’ Market Pricing Advantage 

Almost all developers enjoyed significant savings of both hard and soft costs by using 

manufactured homes versus doing on-site construction. The primary component of hard cost 

savings was the transfer of the material and labor costs to an industrial site located in a lower 

cost area, such as the Central Valley. Other advantages accrue to the builder by doing the 

assembly work in a factory setting. These savings are compounded by using the factory-built 

dwelling in an expensive, high labor cost market. 

Manufactured housing can also reduce time-sensitive soft costs such as insurance, property taxes 

and the cost of borrowed capital. In many parts of urbanized Oakland, the manufactured housing 

reduced costs associated with property security and the risk of loss. Most often, the houses were 

transported from the factory and installed on the concrete foundation in one day. By the end of 

the day, the building could be secured, using plywood to cover windows and doors, if necessary. 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 61 
 

Thus, in lieu of having a semi-complete structure exposed to overnight and weekend theft and 

vandalism, use of manufactured units allowed the house to be secured within 8 to 12 hours. 

With often significant savings, developers using manufactured housing found themselves in a 

good sales position. Developers could sell the property at the market price and enjoy attractive 

profit margins, or they could offer the property at a below market price and enjoy a rapid sale. 

Homeownership and Growing Family Wealth 

Based on the 259 HUD-Code home database referenced earlier and data from the Alameda 

County Assessor, it has been possible to track price appreciation in manufactured housing over 

the years. Beginning in the early 1980s, new single-section manufactured homes sited on 

foundations on city lots sold for prices in the $50,000 to $75,000 range, including the land. Later, 

larger homes, many with garages, were sited and sold for prices ranging up to $300,000. 

The real story is in the subsequent resale of these homes. In each instance, the homes are listed 

with a real estate broker, entered in the multiple listing services, and sold in exactly the same 

manner as any other parcel of real property. While there are too many transactions to describe in 

detail, some examples may serve to illustrate the point about manufactured home property 

values. In 1989, Outlook Development Company placed a single-section Silvercrest home on a 

25-foot wide by 121-foot deep, $12,000 lot on 25th Avenue in Oakland’s San Antonio 

neighborhood. The lot was too small for a garage. With only 933 square feet, the house has three 

bedrooms and two baths. In January of 1989, the new home sold for $88,500. Eleven years later, 

the home was sold for $130,000. Most recently, in January of 2006, the home again sold for 

$360,000. 

Oakland architect and developer Paul Wang (see following section for more on Paul Wang) 

placed a 1,233 square foot two-section home on a 2,800 square foot lot on 35th Avenue, finishing 

it with a one-car attached garage. The original property sale was $92,000 in September 1987. 

Subsequent resales of the property were: January 1996 ($145,000), February 2001 ($280,000), 

and December 2003 ($365,000). 

A small developer used a crane to install two specially designed single-section homes over a 

ground floor garage on an up-sloping lot to create a duplex in 1987. Each home had 933 square 

feet with three bedrooms and two baths. The units were built in mirror image to each other, with 

a fire wall separation. The 13th Avenue lot in the San Antonio District was a little over 7,000 

square feet, a luxury in densely-populated Oakland. The developer kept the duplex as an 

investment property until selling it in 1998 for $146,500. In a few short years, the property 

changed hands several times: December 2000 ($274,000), October 2002 ($420,000), October 

2003 (falling back to $375,000), and finally in March 2006 ($620,000). 

Obviously, much of the impetus for rising prices comes from being located in a hot real estate 

market. Since 2006, all of California has seen what began as normal market adjustment, a 

leveling off and some backing down on prices. Most recently, however, there have been some 

substantial declines in prices due to in large part to the affects of poor lending practices. 

62 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
 

Families living in these manufactured homes enjoy the same potential for wealth building as 

families living in other homes built through different processes. However, the fact that welllocated manufactured homes will increase in value (and decrease in value, periodically), in 

concert with their neighborhood, is undisputed by these data. 

Views of Manufactured Home Participants 

Developers / Entrepreneurs 

Paul Wang began using manufactured homes in his urban lot development plans in the mid 

1980s. A practicing architect, Wang has become one of the most prolific and successful 

manufactured home infill entrepreneurs in the Bay Area. 

Prior to completing his first manufactured home project in 1987, Wang designed and constructed 

site-built homes in Oakland and Berkeley. Commenting that he had always been interested in 

factory-built housing, Wang said, “I had an opportunity to squeeze a profit from a neighborhood 

housing project where the city sold me the land at market prices, but I was required to sell the 

completed homes to qualifying families based on limited income and affordability yardsticks.” 

He is sure that he could not have done that using traditional building processes. As of mid 2007, 

Wang had completed 39 homes in Oakland and had two more in progress. 

Wang’s contribution to the evolving practice of urban infill development with manufactured 

homes has been to demonstrate the value of sensible visual enhancements to the often plain 

looking base unit. However, he does not seek to completely revamp the look of the house, but to 

add to the structure’s natural virtues, especially those of texture and color. When planning each 

new project, he spends time looking at other houses in the neighborhood. “I don’t want to clone 

the houses in the area,” he says, “but rather bring some variety that adds interesting details to the 

streetscape.” 

Wang tries to economize where possible and is guided by a preference for utilizing wood in a 

straightforward way to get those interesting looks without exceeding his budget. “I’ve never been 

hurt by the addition of exterior treatments, and I have never had to discount a house merely 

because it was manufactured and not built on site,” he said. Wang’s two most recent completed 

homes were two-story models shown in Figure 2.12. 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 63 
 

Figure 2.12: Two-story Manufactured Home 

Builder / Investors and Rental Property Owners 

David Bonde and Tom Blean discovered attractive advantages to using manufactured homes to 

build their portfolio of rental properties. The partners had previously constructed their properties 

via the stick and brick method. Beginning in 1988, they acquired vacant lots in the West Oakland 

and San Antonio neighborhoods. Each was developed with the unique duplex configuration 

described above. Market rents in the mid-$800 range were achieved, growing to nearly $1,700 in 

the 2005 period, and declining slightly with the overall market since. Almost all renters received 

HUD Section-8 and Voucher rental assistance through the Oakland Housing Authority; although 

Bonde and Blean report that there have been numerous non-assisted tenants over the two 

decades. 

The partners report that, with some exceptions, the property components have held up well to 

tenant wear and tear over the years. “We would recommend against using particleboard for 

flooring,” Blean says, “opting instead for plywood whenever we have the choice.” The problem 

lies mainly in the potential for damage due to water. Fortunately, almost all manufacturers offer 

plywood or equivalent materials for floor decking. 

The other bane of Bonde and Blean’s maintenance program was the use of polybutylene (PB) 

plumbing lines in the houses, a material now discredited and no longer used in any form of 

housing construction. 

64 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
 

The ability to transform the personal property manufactured home into real property under 

California’s laws has created financial benefits for the partners. “We were able to arrange equity 

lines of credit on our manufactured rental properties,” Bonde comments, “and that has allowed 

us to use some of our equity to embark on additional manufactured home developments here in 

the Bay Area.” As of mid 2007, they are nearing completion on a four-section, two-story 

manufactured home that they intend to put on the market in nearby Crockett (see Figure 2.13). 

Figure 2.13: Four-section, Two-story HUD-Code Home 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 65 
 

Nonprofit Housing Corporations 

Oakland Community Housing, Inc. (OCHI), a 34-year-old 501(c)(3) nonprofit housing 

corporation has been attracting much attention in the Bay Area and the West with its advanced 

applications of one- and two-story manufactured homes. OCHI’s first property was a two-section 

HUD-Code home placed in 2003 on a 40 foot by 100 foot lot in the flatlands area of Central East 

Oakland (see Figure 2.14). The 1,300 square foot house came from the factory with a fullyintegrated front porch, which minimized OCHI’s need to add costs for architectural 

enhancements. OCHI constructed a one-car detached garage in the rear yard. This new home was 

purchased by a single mother of two, whose yearly earnings were only 45 percent of the area 

median income. 

Figure 2.14: Nonprofit Developed Single-family HUD-Code Home With Factory Built Porch 

Advancing on this design, OCHI next acquired a half-acre parcel in the Elmhurst District which 

they split into four lots and in 2005 installed manufactured homes with a similar design. 

Attached one-car garages were site-built alongside each home. Low- and moderate-income 

families purchased these homes for $390,000 each, with low interest rate mortgages and down 

payment assistance programs from the California Housing Finance Agency (CALHFA). 

In a dramatic leap into the far more complex area of multi-story manufactured homes, OCHI 

then completed Linden Terrace, a West Oakland collection of eight two-story manufactured 

homes placed with a crane atop a ground-level garage. Installed in four buildings of two homes 

each, the configuration is that of a “duet” or zero-lot-line single-family attached homes with 

1,500 to 1,700 square feet each. These were also sold to low- and moderate-income households 

66 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
using down payment assistance from CALHFA and the City of Oakland’s mortgage assistance 

program (see Figures 2.15 and 2.16). 

Figure 2.15: Crane Installation of HUD-Code Home 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 67
 
Figure 2.16: Two-family HUD-Code Home Developed by a Nonprofit Organization 

The most recent OCHI development is also in West Oakland, another eight-house project with 

similarities to the Linden Terrace plan, but with a new manufacturer. These 1,600 square foot 

homes were installed with a crane in June 2006. The houses are now on the market at about 

$500,000 each. 

OCHI, like private developers, was able to successfully utilize manufactured homes in its 

development programs due to the favorable regulatory environment that exists in Oakland. 

However, recent trends in the mortgage market (for example, Fannie Mae’s decision to increase 

its underwriting criteria for manufactured home loans) disfavored this segment of the industry 

68 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
 

 

and OCHI experienced problems with lenders. Amanda Kobler, OCHI’s Director of Real Estate 

Development, describes their obstacles, “OCHI is building high quality homes that fit into the 

urban neighborhoods where we work, yet we have met with a surprising amount of resistance 

from mortgage lenders. The mortgage stigma against manufactured housing runs deep. In some 

cases it has made it difficult for our low-income buyers to get enough mortgage financing, not 

because of their ability to pay, but because lenders are nervous about underwriting manufactured 

houses. Our houses are often the nicest, newest homes on the block in Oakland but the lenders 

aren't looking at that.” 

Manufacturers 

Silvercrest/Western Homes (a subsidiary of Champion Enterprises), with 98 houses, is the top 

manufacturer of the 220 homes in Oakland with manufacturer data. Next, with 46 homes, is 

Kaufman & Broad Home Systems, a former operating subsidiary of the homebuilding giant now 

known as KB Homes. The other manufacturers represented are Fleetwood, Fuqua, Guerdon, 

Madison (now out of business), and Golden West and Marlette (both now part of Clayton 

Homes). 

The manufacturing locations, especially in the 1980–2000 era, have primarily been in the 

Sacramento area, 75 miles away. In recent years, homes have been transported to Oakland and 

other cities in the Bay Area from southern California, a distance of 400 miles, and from central 

and northeast Oregon, over distances as far as 750 miles. 

The expansion into more expensive neighborhoods, with the corollary need for more elaborate 

specifications, has pushed developers to look further into the market in pursuit of exactly the 

right manufactured home for each building site. 

Conclusions and Benefits 

Oakland is an excellent example of the benefits that can come to a city and its people through the 

intelligent regulation of manufactured housing. The city and the state both put carefully crafted 

regulations in place that encourage the use of this alternative method of home building, while 

assuring that development standards are observed, and that the homes are a good fit to the 

neighborhoods in which they are placed. 

Oakland has reaped these benefits: 

•	 A large number of trashy, weed-infested vacant lots no longer exist. Instead of being 

burdens on city budgets through nuisance-abatement work, these properties now generate 

property taxes. 

•	 Many families now have their own home in a city which may have been prohibitively 

expensive for them and are benefiting from wealth accumulation through appreciation. 

•	 Many renters live in new homes in neighborhoods where there has been a dearth of sitebuilt homes constructed for decades. 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 69 
•	 Some neighborhoods have witnessed reversals in deterioration and decline, when a new 

home reignites some pride of ownership up and down the street. 

•	 Local jobs have been created through the need for labor in site prep, foundations, fencing, 

landscaping and other tasks. 

70 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
 

 

State of Washington Case Study3 

Introduction 

In 2004, the state of Washington mandated that all local governments regulate qualifying 

manufactured homes in the same way as all other homes in terms of land use and zoning. This 

landmark legislation was not easily obtained and was the result of an intensive effort on behalf of 

the Washington Manufactured Housing Association (WMHA) and other supporters of 

manufactured homes. This case study traces the events and prior legislation leading up to the 

passage of the 2004 law. The case demonstrates that the support of the public and of state and 

local legislators can be gained through a diligent and thorough education and lobbying campaign. 

Following implementation of the National Manufactured Housing Construction and Safety 

Standards (the HUD Code) in 1976, WMHA began a jurisdiction-by-jurisdiction effort to 

educate and inform the public and policy makers about HUD-Code homes. Over the years, many 

individual local regulations were changed making it easier for manufactured homes to be placed 

within communities. WHMA’s ultimate goal was fair and equitable treatment of manufactured 

homes statewide. WHMA was instrumental in passing state legislation that required all 

jurisdictions in the state to allow manufactured homes with qualifying criteria anywhere that sitebuilt homes are allowed. 

Washington Background 

The state of Washington is located in the northwest region of the United States. According to the 

July 1, 2007 Census Population Estimates, the population of Washington was 6,468,424, a 10 

percent increase since 2000. With approximately 66,544 square miles of land area, Washington’s 

population density was 88.6 people per square miles. Table 3.1 shows the population of 

Washington’s five largest cities in both 2000 and 2006. 

Table 3.1: Population of Washington’s Five Largest Cities 

FIVE LARGEST CITIES 2000 2006 CITIES (2007 STATE) 

Seattle 563,374 582,454 

Spokane 195,629 198,081 

Tacoma 193,556 196,532 

Vancouver 143,560 158,855 

Bellevue 109,569 118,186 

State of Washington 5,894,121 6,468,424 

Source: U.S. Census 2000 and July 1, 2006 Census Population Estimates (cities) and July 1, 2007 state of Washington 

The racial composition of Washington is predominantly white (80% in 2006). Washington has a 

relatively large percentage of Asian alone compared to the country as a whole (7% and 4% 

respectively). The state’s median household income was $52,583, approximately $4,000 more 

3

 Case study prepared by Steve Hullibarger, The Home Team, Fair Oaks, California. 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 71 
 

 

than the national median income of $48,451(2006 American Community Survey). The state’s 

average household size in 2006 was 2.53, slightly below the national average of 2.61. 

Of the total occupied housing units in Washington, 65.5 percent were owner-occupied in 2006, 

slightly below the national rate of 67.3 percent. In 2006, the owner market, with a vacancy rate 

of only 1.6%, was extremely tight and the rental vacancy rate (6.1%) was barely adequate for 

demand. With nearly 30 percent of Washington’s housing stock built since 1990 and only 26 

percent built prior to 1960, the state’s housing stock is relatively new. 

Manufactured Housing Characteristics 

Table 3.2 displays manufactured housing characteristics for the state of Washington. In 2006, 7.7 

percent of all housing units were manufactured housing units. While Washington’s total number 

of housing units increased by 10 percent from 2000 to 2006, the number of manufactured 

housing units decreased slightly by 0.5%. Manufactured housing units had a higher 

homeownership rate (77%) than the overall homeownership rate (65.5%) in 2006 and the median 

value of owner-occupied manufactured housing units was significantly lower than the median 

value of all housing units in both 2000 and 2006. As with Oakland, these data suggest that 

manufactured housing has created affordable ownership opportunities in the state of Washington. 

Table 3.2: Comparison of Manufactured Homes With All Housing Units in Washington 

MANUFACTURED 

HOME UNITS 

ALL HOUSING 

UNITS 

Total Number of Units 2006 206,809 2,699,658 

Total Number of Units 2000 207,861 2,451,075 

Percent Change in Number of Units 2000–06 -0.51% 10.1% 

Percent Owner Occupied 2006 77% 65.5% 

Percent Renter Occupied 2006 23% 35.5% 

Median Value Owner-Occupied Housing Units 2000 $66,000 $158,800 

Median Value Owner-Occupied Housing Units 2006 $90,300 $267,600 

 Source: U.S. Census, 2000 and American Community Survey, 2006 

Table 3.3 shows manufactured home shipments from 1977 to 2006 reflecting all manufactured 

homes shipped to Washington retailers, including those from out-of-state factories. Almost all of 

the homes shipped to, and sold by, Washington’s retailers originate in Oregon and Idaho. 

72 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
Table 3.3: Manufactured Home Shipments to Washington Retailers 1977 to 2006 

YEAR SHIPMENTS YEAR SHIPMENTS YEAR SHIPMENTS 

1977 11,211 1987 3,873 1997 6,419 

1978 11,978 1988 4,184 1998 6,874 

1979 10,814 1989 4,397 1999 5,339 

1980 7,505 1990 5,645 2000 3,853 

1981 6,163 1991 5,353 2001 2,971 

1982 4,840 1992 5,964 2002 2,933 

1983 6,153 1993 6,849 2003 2,868 

1984 6,014 1994 7,332 2004 2,705 

1985 5,597 1995 7,252 2005 2,723 

1986 4,550 1996 6,257 2006 2,653 

Source: Manufactured Housing Institute 

Washington has long been a net importer of manufactured homes. In 1995, in-state production of 

2,329 homes was only 32 percent of the total of 7,232 homes shipped to Washington’s retailers. 

In 1999, Washington’s plants produced 1,131 (21%) of total shipments. (Note: years 1995 and 

1999 both included actual production numbers from Washington since there were three or more 

operating factories in the state. However, some years do not include all production numbers since 

the number of operating factories has to be three or more to avoid disclosure of proprietary 

information.) 

Washington, like the other West Coast states, is a predominantly multi-section market. For 

example, of Washington’s 5,964 homes shipped in 1992, 5,240 or 88 percent were multi-section 

homes. Similarly, of the 2,868 shipments in 2003, 97 percent were multi-section homes. 

Regulatory Impact of Manufactured Homes 

On March 31, 2004, Washington Governor Gary Locke signed Senate Bill 6593 into law and 

thus brought manufactured homes into a position of equity and fairness among all forms of 

housing construction with respect to zoning and land-use regulations throughout the state. 

Termed “An Act Prohibiting Discrimination Against Consumers’ Choices in Housing,” the law 

mandates that all local governments regulate qualifying manufactured homes the same as all 

other homes. Although the legislation is too recent to be able to document its impact, the 

legislative history provides a valuable example for other states where regulations may restrict the 

fair and equitable treatment of manufactured homes. 

Regulatory Reform History 1977–2003 

1977—An early effort to pass state legislation requiring cities and counties to include 

manufactured homes in a minimum designated percentage of residential zoning failed to 

pass out of its Committee. 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 73 
1979—The state legislature passed Mobile Home Study Resolutions providing for the formation 

of research groups to study the impact of restrictions on manufactured housing in three 

specific areas. Committees convened all over the state to gather facts and evidence 

related to these three issues. 

Spokane County liberalized its land use regulations by declaring that all multi-section 

homes would be permitted by right on land zoned as agricultural-suburban. Additionally, 

both single- and multi-sectional homes would be permitted on any agriculturally-zoned 

property. 

WMHA retained the services of Ronald J. Clarke who would play a pivotal role in the 

regulatory reform effort over the next 20 years. Mr. Clarke brought with him a resume 

and a credibility that would benefit the reform effort handsomely based on his past 

experience in both the public and private sectors as a planner, urban renewal specialist, 

city administrator, consultant and educator. He was later elected President of the Planning 

Association of Washington. 

1981—House Bill 397 declared the need for land to be zoned for manufactured housing and 

encouraged local governments to address the issue but had little effect on local zoning 

barriers. Snohomish County (Everett), Stevenson, Anacortes, North Bend, Moses Lake 

and Colville modified their zoning codes to be more permissible toward manufactured 

homes. 

1984—The city of Aberdeen qualified manufactured homes to be placed on individual lots in all 

residential districts if they had multiple sections, at least a 3/12 roof pitch and rain 

gutters, and were not more than five years old. 

1985—State legislation requiring manufactured housing as a permissible use in single-family 

districts stalls; Spokane, the second largest city in Washington, began steps toward 

relaxing its zoning barriers. 

1986—The industry trade associations in Washington, Oregon, and Idaho formed Northwest 

PRIDE (Public Relations and Industry Development Effort), a tri-state program with the 

objective of improving the public’s perception of the industry and its homes. 

1988—Successful passage of an interim state law requiring that city and town 

comprehensive plans which did not allow for mobile homes on individual lots 

needed to be reviewed for the need and demand for such homes by December 31, 

1990. Cities and towns had to meet one of the four following criteria by the 

deadline date: 1) have zoning that permits mobile homes on individual lots as a 

permitted use, as a conditional use, or by administrative review; 2) have zoning 

which defines mobile homes as single-family residences and regulating them as 

site-built homes; 3) have existing language in the comprehensive plan which 

indicates that mobile homes should be sited on individual lots; or 4) initiate a 

comprehensive plan amendment review process whereby the planning 

74 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
commission through the public hearing process considers the issue of mobile 

homes on individual lots. Afterwards, WMHA worked with the cities to prepare 

for meeting the requirements of SHB 1690 through meetings and conferences. 

1989—Three of the state’s larger cities, Bellevue, Yakima and Bremerton, authorized the 

installation of manufactured homes on individual lots in residential neighborhoods as a 

permitted use by right. 

1994—WMHA distributed copies to cities of HUD preemption letters strongly suggesting that 

zoning actions may be in conflict with the HUD Code, related to the preemption clause, if 

the locality required specified construction features that superseded the national building 

code. 

1996—Seattle mayor wrote, “In summary, single-family manufactured housing which meets 

Seattle's building, electrical, and energy code requirements and the development 

standards of the Seattle Land Use Code, and are placed on a permanent foundation are 

permitted as single-family dwelling units on individual lots in the City of Seattle.” 

1997—Spokane, Washington’s second largest city, approved the placement of manufactured 

homes on individual city lots if they were less than five years old, at least two sections in 

size, and were judged to be architecturally compatible with surrounding homes. 

Indicating a lingering reservation about the regulations, a final stipulation (later 

rescinded) was that a manufactured home could not be placed on any city block that 

already contained two existing manufactured homes. 

2003—After a series of un-passed bills introduced in the state legislature in the late 1990s, 

WMHA sponsored House Bill 1741 in 2003 declaring that consumers’ choices in housing 

were being denied because certain types of homes were arbitrarily outlawed in the 

neighborhoods in which people wanted to live. An identical bill, SB 6593, was 

introduced in the 2003 senate which eventually passed as the 2004 law known as “An Act 

Prohibiting Discrimination Against Consumers’ Choices in Housing.” 

2004 Landmark Legislation 

Each of the bills introduced in 2003 needed to first pass its own house and then be passed by the 

other house. Initial results were startling: HB 1741 passed by a vote of 86–7, and SB 6593 

passed unanimously, 49–0. Since both bills were identical, only one—SB 6593—went forward 

and successfully passed the opposite house and was signed by Governor Locke on the last day of 

March in 2004. SB 6593, An Act Prohibiting Discrimination Against Consumer’s Choices in 

Housing, became effective July 1, 2005. The Act requires that local governments regulate 

manufactured housing in the same manner as any other housing and may not enact any statue or 

ordinance that has the effect of directly or indirectly discriminating against consumers' housing 

choices that is not equally applicable to all homes. Local governments MAY, however, require 

that a manufactured home: be new; be set upon a permanent foundation as specified by the 

manufacturer; have the space from the bottom of the home to the ground enclosed by concrete or 

an approved concrete product; comply with all local design standards applicable to all other 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 75 
homes in the neighborhood; be thermally equivalent to the state energy code; be comprised of at 

least two fully enclosed parallel sections each not less than twelve feet wide by thirty-six feet 

long; have a composition, wood shake or shingle, coated metal or similar roof of nominal 3:12 

pitch; and have exterior siding similar in appearance to siding materials commonly used on 

conventional site-built residences. 

Immediately after the bill’s signing, WMHA planned for its implementation by designing 

educational materials and budgeting for staff to visit cities as needed. The information 

summarized in an Affordable Housing Brochure (see Appendix B–2). 

WMHA contracted with a certified planner, Michael Davolio, to become the source of credible 

information for the cities. His own credentials were impressive: former President and Legislative 

Chairman of the Washington Chapter of the American Planning Association. Over the next two 

years, WMHA advised its members to take advantage of newly-opened markets, but cautioned 

them against giving ammunition to critics. In a newsletter, WMHA advised, “Pay attention to 

what your consumers are purchasing for placement in these cities and do everything you can to 

make sure it is legal, appropriate and responsible.” 

Manufacturer Acquisition Program 

Further burnishing the image of quality in manufactured housing was the successful energy 

conservation program that became known as MAP (Manufacturer Acquisition Program). Electric 

utilities in the northwest, in conjunction with the Bonneville Power Administration, determined 

that it would be less costly to subsidize higher energy standards in manufactured homes than to 

construct new power generation facilities. A demand-side management deal was struck with all 

18 manufacturers in the three states, by which the manufacturers would beef up the energy 

efficiency of every all-electric home they built, in exchange for a $2,500 subsidy per house, paid 

directly to the manufacturer. The utilities’ consensus was that these specifications would together 

save homeowners of MAP homes approximately $200 per year in electric costs. 

Exemplary Developments Demonstrate the Benefits of Manufactured Housing 

A number of highly publicized manufactured home developments began expanding the design 

envelope of the homes themselves. These developments demonstrated the benefits of 

manufactured housing and designs that promote community acceptance. Public authorities and 

nonprofit organizations were instrumental in these efforts. Several of these projects would gather 

media attention and spur increased demand for the homes. Notable among them were The Lakes 

(Gig Harbor), Laurel Oaks (Lacey), Azalea Gardens (Graham), Lake Wilderness Villa (Maple 

Valley), HarvestGate (Puyallup), Sierra Estates (Yakima), and Sunny Creek (Spokane). Figures 

3.1 through 3.6 illustrate the physical attractiveness of these developments. 

76 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
 

 

Figure 3.1: Manufactured Home in Laurel Oaks, Lacey, Washington 

Figure 3.2: Manufactured Home in Azalea Gardens, Graham, Washington 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 77
 
Figure 3.3: Manufactured Home in Lake Wilderness Villa, Maple Valley, Washington 

Figure 3.4: Manufactured Home in HarvestGate, Puyallup, Washington 

78 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
Figure 3.5: Manufactured Home in Sierra Estates, Yakima, Washington 

Figure 3.6: Manufactured Home in Sunny Creek, Spokane, Washington 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 79
 
 

Further, the King County (Seattle) Housing Authority (KCHA) had been utilizing manufactured 

homes in several subdivisions and land-lease communities over recent years. KCHA was both 

the developer and the marketer of homes in their developments Vantage Glen and Glenbrook. A 

key KCHA staff member became executive director of the Snohomish County (Everett) Housing 

Authority and, based on his KCHA experience, developed two notable properties in Everett: 

Thomas Place (see Figure 3.7) and Millwood Estates. 

Figure 3.7: Manufactured Home in Thomas Place, Everett, Washington 

Perhaps the most innovative and notable development of all was Noji Gardens, built in 2000 in 

southwest Seattle (see Figure 3.8). Developed by HomeSight, a prominent Seattle nonprofit 

housing corporation, Noji Gardens created 75 new homes, including duplex and two-story 

models. It was the first major development in the city of Seattle. Building on its success, 

HomeSight then developed another notable subdivision, Kokanee Creek, in Everett. The 

community of two-story manufactured homes was completed in 2005. 

80 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
Figure 3.8: Duplex, Two-story Manufactured Home in Noji Gardens, Seattle, Washington 

Infill developers doing individual lot developments scattered around Washington also 

demonstrated the attractiveness of manufactured housing in existing neighborhoods (see Figures 

3.9 and 3.10 of Olympia and Pasco). 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 81 
Figure 3.9: Manufactured Home on Infill Site in Olympia, Washington 

Figure 3.10: Manufactured Home on Infill Site in Pasco, Washington 

82 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
Conclusions 

This case study documents the nearly 30-year struggle to get legislation passed in the state of 

Washington to put HUD-Code manufactured homes on par with site-built homes in regard to 

land use and zoning. Led by the Washington Manufactured Housing Association, advocates of 

manufactured housing achieved their goal in 2004 when Senate Bill 6593 was passed into law. 

The Washington law stipulates that local governments regulate manufactured housing (localities 

may require the manufactured home to meet certain criteria and standards) in the same manner as 

any other housing and may not enact any statue or ordinance that has the effect of directly or 

indirectly discriminating against consumers' housing choices that is not equally applicable to all 

homes. 

Beginning in 1976, WMHA began a city-by-city and county-by-county campaign to educate 

policy makers and the general public about HUD-Code homes. WMHA faced long-term 

perceptions of manufactured housing as poor quality and not up to the standards of traditional 

site-built housing. Advocates of manufactured housing in other states can draw from the 

experiences of the Washington Manufactured Home Association in their successful quest for 

equal treatment in terms of zoning and land use regulations for HUD-Code manufactured homes, 

including these strategies: 

•	 Routine meetings with local public officials. 

•	 Hosting plant tours and visits to manufacturers. 

•	 Participating in conferences such as the Governor’s Housing Conference and the 

Washington Association of Cities Conference. 

•	 Retaining the services of a advocates who are well-respected throughout the state for 

their knowledge of land use and planning. 

•	 Hosting exhibitions and display homes in many venues across the state. 

•	 Developing and distributing brochures and other information packets on why 

manufactured housing should be treated as any other housing. 

•	 Partnering with other state associations in a multi-state coalition to increase awareness 

regarding manufactured housing. 

•	 Improving the environmental quality of manufactured housing by supporting programs 

such as the Management Acquisition Program to help finance energy efficiency features 

in manufactured homes. 

•	 Encouraging best practices in designing and developing with manufactured homes. 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 83 
 

Pima County, Arizona Case Study4 

Introduction 

Zoning and land use regulations regarding manufactured housing in Tucson, Arizona are much 

less stringent than those currently in place in Pima County, the adjacent jurisdiction. However, 

some of the most desirable neighborhoods are located in the county in close proximity to the 

Tucson city limits. Currently manufactured housing in these neighborhoods is restricted by 

county regulations. This study describes and discusses an effort on the part of for-profit and 

nonprofit organizations and trade groups, in conjunction with local government officials, to 

equalize zoning and land-use regulations for manufactured homes in the unincorporated areas of 

Pima County, Arizona to those which exist within Tucson. Opening opportunity for living in 

these desirable neighborhoods and increasing affordable housing options are, in large part, the 

impetus behind the organized effort for changing regulations affecting manufactured homes in 

Pima County. 

County Background 

Surrounding the city of Tucson, Pima County is located in the Sonoran Desert of southern 

Arizona (see Map 4.1). Pima County is relatively large, spreading over 9,186 square miles. 

However, most of the county is fairly remote and sparsely populated desert and range country. 

The bulk of Pima County’s population is concentrated in the eastern third of the county on the 

outskirts of Tucson. The county borders on Mexico, with the city of Nogales just over the 

Mexican side of the border. 

4

 Case study prepared by Steve Hullibarger, The Home Team, Fair Oaks, California. 

84 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
 

Map 4.1: Pima County, Arizona 

Source: U.S. Census Bureau 

Demographic Characteristics 

According to the U.S. Census Bureau, Pima County experienced rapid population growth 

between 2000 and 2006, increasing from 843,746 in 2000 to an estimated 946,362 in 2006, an 

increase of 12.2 percent. Arizona as a whole is growing even faster, 20.2 percent over the same 

period. One reason is that the Phoenix metropolitan area (Maricopa County, 100 miles to the 

northwest) has been at or near the top of the nation in terms of growth for many years and had a 

22.6 percent increase over this period. However, Pima County’s own growth is impressive. 

With approximately 9,000 square miles of land area, Pima County had a population density of 92 

people per square mile. Based on the 2006 American Community Survey, Pima County was just 

under 70 percent white. At 32.5 percent, the County’s Hispanic/Latino population was more than 

double the national percentage of 14.8 percent and the County’s percentage of some other race 

alone (17.5%) was almost triple the national percentage (6.4%). The city of Tucson is the 

population, employment, educational, cultural, and financial center of Pima County. Tucson’s 

population, according to the Census, was an estimated 518,084 in 2006, comprising 55 percent of 

the entire county. 

The 2006 median household income in Pima County was $42,984 which was below the Arizona 

median of $47,265 and the national median of $48,451. The average household size in Pima 

County was 2.51, below the Arizona average of 2.72 and the national average of 2.61, and the 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 85 
County’s percent elderly population (65 years and older) in 2006 was well above those of 

Arizona and the nation ((14.6%, 12.8% and 12.4%, respectively). 

The county’s ownership rate was 66 percent in 2006 with an owner vacancy rate of 2.4 percent 

and renter vacancy rate of 7.3 percent (all very similar to national rates). The housing stock is 

relatively new, with about one-third of units built since 1990 and only 15 percent built prior to 

1960. 

The economy was stable based on an unemployment rate of 4.0 percent in 2006 in Pima County 

compared to the state and nation (4.1% and 4.6% respectively). Manufacturing is a relatively 

small part of the local economy, which has higher concentrations of employment in 2007 in 

government (77,400), trade, transportation and utilities (63,200), professional, business and 

information services (58,300), leisure and hospitality (41,700), and construction (28,900). 

Manufactured Housing Characteristics 

Approximately 11 percent of all housing units in Pima County were manufactured homes in 

2006 (Table 4.1). The percentage of manufactured housing units decreased by approximately 2 

percent in Pima County from 2000 to 2006. However, manufactured housing units (81.1%) had a 

much higher homeownership rate than all housing units (66%) in Pima County in 2006 and the 

median value of owner-occupied manufactured housing units was significantly lower than that of 

all housing units in 2000 ($42,500 and $102,600 respectively). While the median value for all 

housing units in Pima County almost doubled from 2000 to 2006 ($102,600 to $204,800), the 

median value for manufactured housing units increased by 23 percent (from $42,500 to $52,300), 

improving their affordability relative to other owner-occupied housing while still appreciating in 

value. Some portion of this increase is likely due to increases in land costs which affect all 

housing types. 

Table 4.1: Comparison of Manufactured Homes With All Housing Units in Pima County 

MANUFACTURED 

HOME UNITS ALL HOUSING UNITS 

Total Number of Units 2006 46,142 418,213 

Total Number of Units 2000 47,112 366,737 

Percent Change in Number of Units 2000–06 -2.06% 14.04% 

Percent Owner Occupied 2006 81.09% 65.95% 

Percent Renter Occupied 2006 18.91% 34.05% 

Median Value Owner-Occupied Housing Units 2000 $42,500 $102,600 

Median Value Owner-Occupied Housing Units 2006 $52,300 $204,800 

Source: U.S. Census 2000 and American Community Survey, 2006 

Manufactured Homes 

Manufactured Home Production in Arizona and Surrounding States 

For many years, Arizona has been a center for manufactured housing, with production 

86 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
 

 

 

concentrated in the Phoenix metropolitan area. As of late 2007, there were nine operating 

factories in the Phoenix area. In addition to homes produced in Arizona factories, the state 

imports large numbers of homes from surrounding states, including New Mexico, Texas, 

Colorado, and Southern California. 

Manufactured Home Sales in Arizona 

Manufacturers report their home shipments to the various states as part of the HUD program and 

these shipments provide a highly accurate picture of manufactured home sales. Lag times 

between shipment and sale dates frequently are no more than a few months. Arizona has been a 

significant market for manufactured homes over the last three decades, as shown in Table 4.2. 

Table 4.2: Shipments of Manufactured Homes to Arizona Retailers 

YEAR SHIPMENTS YEAR SHIPMENTS YEAR SHIPMENTS YEAR SHIPMENTS 

1970 8,735 1980 5,616 1990 3,047 2000 6,664 

1971 17,380 1981 6,457 1991 2,721 2001 8,859 

1972 21,452 1982 5,108 1992 3,470 2002 5,419 

1973 21,055 1983 7,150 1993 4,654 2003 4,454 

1974 9,312 1984 6,694 1994 6,258 2004 4,570 

1975 4,371 1985 5,565 1995 6,999 2005 6,056 

1976 4,465 1986 5,728 1996 8,095 2006 5,518 

1977 6,257 1987 5,871 1997 8,545 

1978 8,103 1988 4,717 1998 8,611 

1979 9,276 1989 3,276 1999 8,827 

Source: Manufactured Housing Institute 

Manufactured Homes in Pima County 

Manufactured housing has long been an important part of the eastern Pima County/Tucson area. 

The Pima Association of Governments (PAG) estimates that there are 52,863 manufactured 

homes in the Tucson metro area, accounting for 12.3 percent of the overall 428,722 homes. 

Part of the appeal of manufactured homes is their affordability. As in other areas around the 

country, housing affordability is a serious concern in Pima County. PAG reports, 

“As the affordability of new single-family housing has lessened, used housing has acted 

as a substitute. Growth in real incomes has not kept pace with housing costs, an issue 

that is coming to the forefront regionally. When housing returns to be priced as shelter 

rather than an investment, stability will return to the market.” 

The Pima County housing market has been cooling since mid-2005, as it has in other areas of the 

nation. Board of Realtors data show that the average number of days on the market before a 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 87 
 

home sold was 65 days in mid-2007, compared to only 35 days in mid-2005. Still, prices in Pima 

County have not dropped. The median selling price in mid-2007 was consistent with the median 

price in mid-2005. 

Manufactured Housing Regulations 

There is a significant difference between zoning policies in the unincorporated portion of Pima 

County and in the city of Tucson. The city has relatively relaxed and liberal regulations related to 

manufactured home placements, while the county limits their placement to very large, and often 

rural, properties. 

Tucson Regulations 

Prior to 2001, the city of Tucson’s Land Use Code permitted units in all zoning districts 

where dwellings were permitted with the exception of the R–1 zone. In the R–1 zone, 

manufactured homes could only be placed in subdivisions recorded after January 1, 1982. 

Design criteria were added in 2000 for placing manufactured homes in a variety of 

residential zones. For the details of Tucson’s zoning ordinance, see Appendix B–3. 

Pima County Regulations 

Pima County’s regulations specify particular zones where the installation of individual 

manufactured homes is allowed. All are rural, and several require extremely large parcels. Table 

4.3 presents critical zoning specifications for the installation of individual manufactured homes. 

This limitation acts to keep manufactured homes out of higher density, developed areas. Persons 

wanting to live in a manufactured home thus face severely restricted access to the amenities of 

urban living, including schools, shopping, employment, parks, transportation and cultural events. 

Table 4.3: Zoning Specifications for Installation of Manufactured Homes 

CODE NAME MINIMUM LOT 

SIZE 

RELATED ISSUES 

IR Institutional Reserve 36 acres Individual manufactured homes permitted. 

RH Rural Homestead 180,000 sq.ft. Individual manufactured homes permitted. 

GR–1 Rural Residential 36,000 sq.ft. Individual manufactured homes permitted. 

SH Suburban Homestead 72,000 sq.ft. Individual manufactured homes permitted. 

CMH–1 County Manufactured 

and Mobile Home-1 8,000 sq.ft. Manufactured home parks permitted; not individual homes 

on individual lots. 

CMH–2 County Manufactured 

and Mobile Home-2 No minimum Manufactured home parks permitted; not individual homes 

on individual lots. 

MU Multiple Use 7,000 sq.ft. 

Other permitted uses are incompatible with residential: 

manufacturing, food processing, stables, kennels, 

crematoria, and so forth. 

Source: Pima County 

88 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
In addition to these regulations pertaining to the placement of individual manufactured homes, 

multi-sectional manufactured homes are permitted in all residential subdivisions recorded after 

June 15, 1981 if the designation "multisectional manufactured homes permitted" is approved by 

the Board of Supervisors at the time of rezoning and is noted on the plat at the time of recording. 

Under this provision, multisectional homes could be included as the subdivision was being built 

or subsequently as infill. 

Changing Pima County Regulations 

Early in 2007, the Pima County Board of Supervisors initiated a movement that could remove 

some of the restrictions on manufactured home placements in the county’s unincorporated areas. 

A Manufactured / Affordable Housing Strategy Committee (MAHSC) was organized to: 

•	 Review the zoning code and propose amendments to code sections that govern 

manufactured housing in Pima County. 

•	 Explore and propose strategies that promote, expand and encourage the 

availability of affordable housing options in Pima County. 

•	 Generate reasonable and viable zoning code text amendments to be forwarded to 

the Pima County Planning and Zoning Commission and the Board of Supervisors 

for consideration. 

The Manufactured/Affordable Housing Strategy Committee has 18 members and a hired 

professional mediator to act as Chairperson and facilitator. Committee members include one 

appointee from each of the five supervisorial districts, two manufactured housing industry 

representatives, representatives from several community associations, and a staff person from the 

Pima County Assessors Office. 

The initial meeting was held in Tucson on October 2, 2007. At the time of this writing, it is still 

too soon to know the outcome of this effort, but hopes are high that a reasonable compromise can 

be reached that will work to the benefit of persons wishing to live in a manufactured home and 

enjoy the many benefits of urban or suburban living. 

Successful relaxation of Pima County’s zoning regulations regarding manufactured homes, 

however, will not be easy. Reports have surfaced that neighborhood groups are fearful that, if 

Pima County’s zoning restrictions against manufactured homes are eased, their own home values 

could decline. This is mostly based on the concern that manufactured homes will not conform to 

neighborhood aesthetic norms. There are solid reasons for these concerns as it is easy to spot 

examples of homes that will be terribly out of place in typical neighborhoods (see Figure 4.1). 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 89 
Figure 4.1: Typical Manufactured Home in Rural Pima County 

However, if careful structuring of new regulations result in standards for architectural 

compatibility, new manufactured homes could enhance any neighborhood. In fact, there are 

already good examples of such homes throughout the Tucson area (see Figures 4.2 through 4.6). 

Often, however, the public has no awareness of such homes, as they blend into their streetscapes 

so well that they are no longer distinguishable as manufactured homes. By using examples such 

as manufactured homes pictured below, public concerns could be ameliorated. 

90 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
 

Figure 4.2: Manufactured Home Located in Subdivision in Rural Pima County With 

 Exterior Stucco, Tile Roof, and Garage 

Figure 4.3: Conventional Looking Manufactured Home in Subdivision in Rural Pima County 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 91 
 

 

 

Figure 4.4: Manufactured Home in Rural Pima County That Would Easily Fit Into

 A Suburban or Urban Area 

Figure 4.5: Manufactured Home in Rural Pima County Displaying On-site Architectural 

Modifications 

92 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
 

Figure 4.6: Manufactured Home Located Within Tucson City Limits in a Small Infill 

 Subdivision Exemplifying Santa Fe Architecture 

Conclusions 

Pima County, Arizona serves as an example of where an ongoing effort is taking place to look 

into the feasibility of changing land use and zoning regulations so that citizens may place 

manufactured homes in more suburban or urban areas of the county. For-profit, nonprofit 

organizations, and trade groups, in conjunction with local government officials, are attempting to 

equalize zoning and land-use regulations for manufactured homes in the unincorporated areas of 

Pima County with those of Tucson (Pima County’s central city) where zoning restrictions are 

less restrictive. Current county regulations allow manufactured homes only on large rural lots 

relatively far from the Tucson city limits. Promoting affordable housing in the desirable 

neighborhoods on the outskirts of Tucson are, in large part, the impetus behind the organized 

effort for changing regulations affecting manufactured homes in Pima County. 

Proponents of change believe that revising the county zoning and land use regulations to allow 

manufactured homes in a broader range of areas will help address housing affordability issues 

and discriminatory practices of the county. Current restrictions deprive those county residents 

who choose to live in manufactured homes from benefiting from the advantages of a more urban 

setting. Some citizens, however, are concerned that manufactured homes could negatively impact 

housing values in certain areas. Appearance, design, and architectural compatibility of 

manufactured homes will be a key issue impacting any change in regulations. 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 93 
In 2007, a Manufactured/Affordable Housing Strategy Committee was organized with goals to 

review the zoning code and propose amendments to code sections that govern manufactured 

housing in Pima County and to explore and propose strategies that promote, expand, and 

encourage the availability of affordable housing options. Members serving on this committee 

consist of a staff member from the Pima County Assessor’s Office, representatives of nonprofit 

associations, appointees from each of the five supervisorial districts in Pima County, and 

representatives from the manufactured housing industry. A paid professional mediator serves as 

the chairperson. 

After becoming fully informed of the current codes and issues surrounding manufactured homes 

and affordable housing concerns, the committee will make recommendations to the Zoning and 

Planning Commission and Board of Supervisors. Recommendations may include any code 

amendments that are the result of a consensus of the committee. In addition, any housing policy 

recommendations that are supported by the majority of the committee will be forwarded to the 

Pima County Housing Commission, the Board of Supervisors, and other relevant parties. 

94 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
 

Owensboro, Kentucky (Doe Ridge Subdivision) Case Study5 

Introduction 

The Owensboro, Kentucky case study illustrates where local regulations were revised in 1982 to 

allow manufactured housing in all residential zones of a city long before the state passed similar 

legislation. However, it took nearly 20 years before a significant development was able to take 

advantage of the local area regulatory reform. In 1999, Doe Ridge Subdivision was the first 

project with manufactured housing to apply the Owensboro zoning ordinance enacted 17 years 

before. The subdivision is located in Owensboro, Kentucky in the northwestern corner of the 

state. The developer, Robert Wimsatt, received approval for the first subdivision unit (18 lots) 

from the city of Owensboro in March 1999. With that approval, the city annexed the subdivision 

from Daviess County. In June of 2000, unit two (containing 17 lots) was approved and annexed. 

Following subsequent approvals, Doe Ridge is currently a subdivision of 70 single-family, onestory manufactured homes located within a 183-acre site that includes site-built lots as well. The 

subdivision is planned to include 150–200 manufactured homes. 

The developer’s business model previously was limited to purchasing land, site development and 

selling lots to individual homebuilders. The land at Doe Ridge is located in the proximity of gas 

wells and compressor stations, leading the developer to consider it appropriate for low- to 

middle-range housing, but he did not want a trailer park. In 1999, a progressive and aggressive 

Fleetwood dealer with the backing of Fleetwood’s corporate policy of development provided the 

developer with an opportunity to put in a manufactured housing development on individual lots. 

5 Case study prepared by David Hattis, Building Techology, Inc. 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 95 
City Background 

Owensboro is located in Northwestern Kentucky along the Ohio River bordering southern 

Indiana (see Map 5.1). Owensboro is relatively flat, with rolling hills in the western part of the 

county. With the Ohio River bordering the north and the Green River bordering on the west, 25 

percent of the area of Owensboro is flood plain. Recent residential development has been located 

in the flood plain. 

Owensboro is in an area affected by the New Madrid Seismic Zone and seismic design is 

required by the local building code. Foundations and their attachments to accommodate seismic 

loads (Category C or D1 in the International Residential Code) are subject to local regulation and 

enforcement. Seismic design along with other local building code issues such as sprinkler 

requirements are not addressed in the HUD Code. 

Map 5.1: Owensboro, Kentucky 

Source: U.S. Census Bureau 

Demographic Characteristics 

According to the 2000 Census (most recent Census data available), Owensboro’s population was 

54,067, an annual increase of less than 0.1 percent since 1990, on approximately 17 square miles 

of land area for a population density of 3,102 people per square mile. The population of Daviess 

96 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
County (including Owensboro) is growing somewhat more, with 93,613 people in 2006 and an 

annual growth rate of approximately 0.3 percent since 2000. The County’s growth rate is 

projected to continue through 2025. 

Owensboro and Daviess County were over 90 percent white in 2000. The median household 

income in Owensboro was just under $32,000, almost $2,000 less than the Kentucky median, 

$4,800 below the Daviess County median and over $10,000 below the national median. 

The median age in both Owensboro and Daviess County was 37 years, approximately 2 years 

older than the Kentucky and national median ages. This can be explained, at least partially, by 

the relatively large proportion of elderly in Owensboro and Daviess County in 2000 (16.5% and 

13.8% respectively), well above the Kentucky and national rates which were just over 12 percent 

in 2000. 

The local economy has been shifting from manufacturing to services. In 1970, manufacturing 

comprised 33 percent of employment, while the 2007 Owensboro Comprehensive Plan reports 

manufacturing represented 16 percent of employment in 2000. Manufacturing had been 

surpassed by services (32%), retail trade (24%) and government (18%) as sources of 

employment. 

Owensboro’s homeownership rate was 60 percent in 2000, well below Daviess County, 

Kentucky and the nation (70.8%, 70.3% and 66.2% respectively). Owensboro and Daviess 

County had vacancy rates for owner-occupancy units of 1.9 percent and 1.7 percent in 2000, 

similar to state and national rates and indicative of a tight market. In 2000, Owensboro and 

Daviess County had rental vacancy rates of 7.7 percent and 7.9 percent, both lower than the 

Kentucky rate of 8.7 percent but still indicating an adequate supply of rental housing. 

Owensboro’s housing stock was older (approximately 39% built prior to 1960) than the nation’s 

housing stock (approximately 35% built prior to 1960). Typical of less urban areas, Daviess 

County’s housing stock was somewhat newer with 34 percent of the housing stock built prior to 

1960. Housing units in the city of Owensboro consisted primarily of single-family units, which 

account for 70 percent of all units. 

Manufactured Housing Characteristics 

Manufactured homes made up less than 1.5 percent of all housing units in Owensboro in 2000 

which was well below the Kentucky rate of 14.1 percent and also below the national rate of 7.6 

percent (Table 5.1). In contrast to the other case studies, manufactured homes had a lower 

homeownership rate (approximately 45%) than the rate among all housing units (approximately 

60%) in Owensboro in 2000. The median value of owner-occupied manufactured home units was 

$20,000 compared to $76,100 for all owner-occupied housing units. Almost all of the 

manufactured housing in Owensboro is located in manufactured housing parks at the fringes of 

the city. There are a few units located on scattered sites within the city. 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 97 
 

 

Table 5.1: Comparison of Manufactured Housing With All Housing Units in Owensboro 

MANUFACTURED 

HOME UNITS ALL HOUSING UNITS 

Total Number of Units 2000 347 24,361 

Total Number of Units 1990 262 23,074 

Percent Change in Number of Units 1990–2000 32.4% 5.6% 

Percent Owner-Occupied 2000 44.5% 60.4% 

Median Value Owner-Occupied Housing Units 2000 $20,000 $76,100 

Source: U.S. Census, 1990 and U.S. Census, 2000 

In 2003, the Kentucky Manufactured Housing Institute (KMHI) reported, “Manufactured homes 

now represent 33 percent of all new home building permits, as well as 25 percent of all the 

housing stock in Kentucky.” The percentages were considerably lower in the city of Owensboro 

(4.7% and 1.5% respectively) based on 2005 estimates published in Owensboro’s 2007 

Comprehensive Plan. Of 548 building permits issued after March 2000 through December 2005 

in Owensboro, 26 or 4.7 percent were for manufactured homes. Based on the 2005 estimated 

housing stock total for Owensboro, 1.5 percent or 373 of 24,909 total units were manufactured 

homes. Seventy units are located in Doe Ridge subdivision, which is the subject of this case 

study. Manufactured homes are more prevalent in Daviess County, with 2,826 units and 7 

percent of the total housing stock. 

The dealer/builder of the manufactured housing at Doe Ridge reported that he has done one other 

manufactured housing development in the county’s rural area consisting of eight units on eight 

lots. Almost all of the manufactured homes in the county are in mobile home parks, and a small 

number are built on scattered sites, using the conditional use permit process and consisting of 

one-story single-wide units. The developer of Doe Ridge reported that typically manufactured 

housing dealers do not do development and builders do not use manufactured housing because it 

cuts into their profits. 

Few manufactured homes are built on the available vacant lots in the city. The Associate 

Director of Planning in Owensboro reported that there is “no large quantity of vacant lots” in 

Owensboro. While there is a community development program to develop the few existing lots 

as affordable housing, the city prefers site-built units as the costs are perceived to be similar to 

that of constructing manufactured housing. 

Recently, a very small number (in 1996, three units) of manufactured homes have been 

constructed in the city of Owensboro. The Owensboro Metropolitan Zoning Ordinance classifies 

manufactured homes into three Classes. In 2006, 27 permits were issued for Class 1 

manufactured homes (double-wide or larger units that meet installation and appearance 

standards), and 25 of these were in Daviess County outside the Owensboro city limits. Thirty 

permits were issued for Class 2 manufactured homes (single-wide units permitted under 

specified conditions), and 29 of these were in Daviess County outside the Owensboro city limits. 

98 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
 

Manufactured Homes in Doe Ridge 

Doe Ridge subdivision, positioned on the northwest fringe of the city of Owensboro, is currently 

a subdivision of 70 single-family, one-story manufactured homes. The subdivision is outside the 

flood plain, with gently rolling hills, according to the dealer/builder. The manufactured homes 

are located within the 183-acre subdivision that includes site-built lots and homes as well. An 

article on Doe Ridge in the Owensboro Messenger Inquirer, in June 2000 (see Appendix B–4.1) 

provides a detailed description of the project. 

Doe Ridge was the first project to apply the Owensboro zoning ordinance to a subdivision, 20 

years after zoning regulations were revised to allow manufactured housing in all residentially 

zoned areas. The subdivision is planned to include 150–200 manufactured homes, but 

development has slowed in recent years. 

According to the developer, Robert Wimsatt, Doe Ridge was possible due to the combination of 

reasonably priced land and the participation of the Fleetwood Corporation in the purchase of part 

of the land. Recently, Fleetwood reportedly decided to eliminate their development business, 

stalling the manufactured housing subdivision at 70 units. It is currently unclear whether another 

manufacturer will participate in the future of this development. 

Description of Doe Ridge Manufactured Homes 

Physical Configuration (Singles / Doubles / Triples / Number of Stories) 

The single-family manufactured homes at Doe Ridge are all single-story double-wide units (see 

Figures 5.1 through 5.4). The average area of the units is 1,680 sq. ft. (28’ x 60’), and about 20 

percent of the units are 2,430 sq. ft. (32’ x 76’). The average lot size at Doe Ridge is 75’ x 85’– 

100’. The homes are all HUD-Code homes, and none were subject to any Alternative 

Construction Letter from HUD. 

Exterior Designs 

Foundation and skirting: Block foundation; split-faced block skirting. 

Siding: Vinyl siding and shutters. 

Porches: Post-production porches and stairs on all the houses. 

Garages: About 10 percent of the houses have garages. Two or three of them are 

attached to garage-ready homes, and the rest are detached. The 

dealer/builder reported that lot size and configuration constrained the 

use of attached garages. 

Roofing: Roofs are all asphalt shingles. Roof slopes are 3/12, 4/12, and 5/12. A 

dealer reported they got away from 7/12 roof slopes for reasons of 

transportation. 

Other additions: 10’ x 20’ elevated rear decks; sidewalk lights. 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 99 
 

Figure 5.1: Manufactured Home With Post-production Porch, Vinyl Decorative 

 Column, and Roof Vents (attributed to steeper pitch) 

Figure 5.2: Manufactured Home With Post-production Porch 

100 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
 Figure 5.3: Manufactured Home With Post-production Porch and Attached Garage 

Figure 5.4: Manufactured Home With Attached Garage 

Doe Ridge is a subdivision that includes an area of manufactured housing lots while the rest of 

the development is site-built. The site-built houses are not interspersed with the manufactured, 

but the two types do back up on each other at several points. The manufactured housing 

subdivision was the first to be built and design compatibility with site-built homes was not 

considered. The dealer/builder reported that an architectural committee has been established for 

the subdivision to review additions such as fences. The developer stated, “Roof pitches are the 

biggest giveaway.” Figure 5.5 shows a manufactured home in relationship to several site-built 

homes behind it. 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 101 
 

Figure 5.5: Manufactured Home With Three Site-built Homes in the Background 

Existing Homes Similar to Manufactured Housing 

Architectural Context 

There are a few two-story homes in Owensboro, but these are mostly older houses. One-story 

residential construction in the city of Owensboro is predominant and exclusive in the Doe Ridge 

subdivision. The site-built homes of the subdivision set themselves apart by having steeper roof 

pitches than manufactured homes. 

Site-built Homes in the Doe Ridge Development 

The site-built homes in the Doe Ridge Development are similar in size and appearance to the 

manufactured homes except for the steeper roofs. Figures 5.6 through 5.8 illustrate site-built 

homes in the subdivision. 

Figure 5.6: One-story Site-built Home Under Construction with Attached Garage 

102 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
Figure 5.7: One-story Site-built Home With Double Attached Garage 

Figure 5.8: One-story Site-built Home With Brick and Single Attached Garage 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 103 
Impact of Manufactured Home Regulations 

Owensboro’s zoning ordinance was amended in 1982 to allow manufactured housing on 

residentially zoned sites. In 2004, the 1982 provision on manufactured housing was revised so 

that manufactured home definitions would be in accordance with the recently passed state 

legislation (KRS 100.348 and KRS 227.550) discussed below, and with KMHI definitions. 

The Owensboro Metropolitan Zoning Ordinance permits the use of double-wide or larger 

manufactured housing units that meet installation and appearance standards in all Single-Family 

Residential Zones. Single-wide manufactured homes or larger units not meeting installation and 

appearance standards are conditionally permitted (with Board of Adjustment approval) in those 

zones. Manufactured housing built prior to the HUD Code are permitted only in Agriculture 

Zones. (See Appendix B–4.2 for an excerpt from Owensboro Metropolitan Zoning Ordinance, 

Article 8, Zones and Uses Table showing where each class of manufactured home is principally 

or conditionally permitted. Also see Appendix B–4.3 for definitions and descriptions of the 

installation and appearance standards for each class of manufactured home from Article 14, 

Definitions of the Owensboro Metropolitan Zoning Ordinance which were reviewed by the 

Kentucky Manufactured Housing Institute prior to their adoption.) 

In April 2002, the Kentucky General Assembly passed legislation (SB 197, which was signed 

into law effective July 1, 2003) and was codified into KRS 100.348 addressing land use 

regulation of manufactured homes within cities and counties across Kentucky (see Appendix B– 

4.4). The intent of the legislation was to ensure that manufactured homes were included within 

jurisdictions as an acceptable form of economically priced housing. Owensboro’s zoning 

ordinance preceded this legislation by 20 years and the Doe Ridge development was not affected 

by the state legislation. 

Doe Ridge was undoubtedly enabled by the zoning ordinance of 1982, but this ordinance had not 

prompted other subdivisions to include manufactured housing. Although the use of manufactured 

housing in Doe Ridge was facilitated by the zoning ordinance, it was the combination of 

acquiring land at a reasonable price and the participation of Fleetwood corporate headquarters in 

the purchase of part of the land that made the project possible. Absent these circumstances, 

volume development of manufactured housing subdivisions has simply not happened in 

Owensboro, and seems unlikely in the foreseeable future. 

Market and Non-regulatory Impacts 

The dealer/builder of the manufactured housing at Doe Ridge reported that the manufactured 

units sold in the range of $80,000–$115,000. Site-built houses at Doe Ridge were in the range of 

$125,000–$165,000. The dealer/builder’s other development in the county, on lots ranging from 

1/2 to 3/4 acre, sold in the range of $90,000–$125,000. The Associate Director for Planning 

stated that it is hard to compare pricing advantage, but acknowledged that standard double-wide 

units are significantly less costly than equivalent site-built units. 

The purchases of the first set of manufactured homes at Doe Ridge were financed by Green Tree, 

which finances manufactured homes, but the rest of the units were financed by conventional 

104 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
loans at rates equivalent to those applicable to site-built homes (6–6.5% based on the 

dealer/builder’s recollection). 

Reports on long-term values of manufactured homes at Doe Ridge are mixed. The dealer/builder 

at Doe Ridge stated, “Our customers are our best salesmen. These aren’t trailers.” He reported 

that to his knowledge about eight houses have been resold, and they were listed by realtors. The 

developer stated that he had heard that some owners had a tough time selling their units. 

The developer’s feeling is that the units maintain their long-term value, but stated that insurance 

for manufactured housing can be expensive. “It doesn’t reflect the reduced risk of HUD-Code 

houses.” The developer believes that on average the manufactured houses will appreciate, 

although at a lower rate than site-built homes. An Owensboro Board of Realtors staff member 

stated there is no indication of decline in value of manufactured homes, and that value is a 

function of the maintenance of the home. The Director of the Owensboro Community 

Development Department, however, stated that resales at Doe Ridge have lagged, and owners 

have had a hard time selling. 

There was no indication from any of the interviews of public or nonprofit promotion of 

manufactured housing. The Director of the Community Development Department reported that 

the city has not used manufactured housing because of architectural features and the requirement 

for steeper roof pitches. He believes that manufactured housing is not appropriate for infill 

housing. In infill situations, the price becomes similar to site-built, and the city prefers that local 

contractors build the infill housing. The dealer/builder of the manufactured homes at Doe Ridge 

reported that in 1998 he applied for a Community Development grant of $20,000–$30,000 for an 

infill unit, but the Department of Community Development conditioned the grant on use of a roof 

slope of 7/12 which could not be done. 

The Executive Director of the Housing Authority of Owensboro reported that the Authority is 

currently involved in managing existing inventory of public housing and Section 8 housing 

vouchers and has not produced housing in quite a while. He has recently become aware of 

factory-produced housing as a solution to housing affordability and stated that he would consider 

using manufactured housing should the Authority produce housing in the future. 

Discussions were conducted with the Executive Director of Habitat for Humanity in Owensboro 

and with GRADD (Green River Area Development district) which is active in seven counties 

surrounding Owensboro (Daviess, Hancock, Henderson, McLean, Ohio, Webster and Union 

Counties). Neither has used manufactured housing as part of their affordable housing programs. 

The Executive Director of Habitat for Humanity also stated that Owensboro is in tornado alley 

and manufactured housing is not appropriate, adding “There is a stigma to mobile homes.” 

Conclusions 

•	 Regulatory reform is necessary, but not sufficient, for the development of fee-simple 

manufactured homes in either subdivisions or scattered sites. 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 105 
•	 There is a need to better communicate the benefits of manufactured housing to nonprofit 

housing developers. 

•	 Although manufactured housing is prevalent in rural Kentucky, the Owensboro case 

indicates significant obstacles beyond regulatory impediments facing any significant 

increase as an affordable housing alternative in urban development. 

106 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
CONCLUSION 

HUD-Code housing offers much promise as a technological solution to the affordable housing 

crisis facing many Americans. This study examined the factors influencing the placement of 

HUD-Code units to determine if local regulatory practices play a role in limiting the use of 

HUD-Code homes within urban communities. Two separate analyses were performed: (1) an 

empirical analysis of local regulations, emphasizing their implementation and influence on 

manufactured housing supply, and (2) qualitative case studies of four communities reported to 

have success in regulatory reforms and the urban placement of HUD-Code homes. The results of 

these analyses are summarized below, followed by a discussion of policy recommendations. 

Overall Summary of Results 

Over the 2000 to 2005 period, there were significant regional differences in manufactured 

housing shipment activity. The South continued to attract the largest share of shipments, 

although this share declined somewhat since 2000. The relative decline in shipments to Southern 

states was accompanied by a relative decline in retention of the existing stock of units. The 

Midwest also saw declining shares of shipments over the 2000 to 2005 period, while the 

Northeast and West saw consistently low levels of shipment activity. 

Almost all states address the regulation of manufactured housing, and more than half of states 

require localities to allow HUD-Code units somewhere within local jurisdictions. The majority 

of states do not address additional local regulations governing design, installation, lot 

improvements, or placement on site, however. 

States that most strongly promoted HUD-Code usage captured the highest share of shipments 

over the 2000 to 2005 period. Furthermore, the gap between strong states and other states has 

grown over time. At the state level, this suggests that requirements to enact accommodating local 

standards appear to be having an influence on shipment activity at least at the state level. 

Local regulatory barriers play a larger role in limiting the placement of manufactured housing 

than in limiting the sale or shipment of manufactured housing units. By-right zoning does not 

significantly impact shipments or sales, and few perceived regulatory barriers impede HUDCode shipments or sales at statistically significant levels. This is somewhat expected, given that 

shipments to communities are influenced primarily by transportation costs and logistical factors, 

while sales are influenced by market conditions, given the existing supply of units. Manufactured 

housing placements, on the other hand, are influenced by a variety of regulatory barriers, 

including the lack of by-right zoning, burdensome fees, permits, snow load standards, fire codes, 

zoning codes, subdivision regulations, architectural design standards, and environmental 

regulations. Among these regulatory influences, the overall permitting system has the largest 

negative impact on unit placement. Different regulatory barriers have different impacts on unit 

placement across the distribution of units placed, with the largest number exhibiting threshold 

effects at the 0–1 unit level. This suggests that regulatory barriers are associated more with 

whether jurisdictions have no or any HUD-Code units, while market conditions have a greater 

role in determining the number of units that are placed in a community, given that units are 

allowed. Market factors shown to have a statistically significant impact on placements include 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 107 
regional location, population density, median family income, the existing inventory of 

manufactured housing units, and proximity to manufactured housing plants. 

This study’s analysis of HUD-Code placements in urban communities also suggests that the best 

approach to increasing the supply of HUD-Code homes would be to promote the use of 

manufactured housing in HUD-Code parks and infill in traditional subdivisions, along with 

allowing by-right placement in new single-family subdivisions. Jurisdictions approving new 

parks were twice as likely to have more than 50 units placed in the past five years than those not 

approving new parks. Communities with the highest placements of HUD-Code units were those 

with a mix of placements among HUD-Code parks, as infill in traditional subdivisions or in new 

subdivisions. 

However, jurisdictions with by-right regulations were less likely to approve new parks than those 

requiring special permits or restricting units to special districts. These findings suggest that to 

promote the supply of HUD-Code homes, regulations protecting by-right use in traditional 

single-family districts and infill locations should not be viewed as replacing regulations allowing 

the development of subdivisions devoted to manufactured housing. 

Obviously, allowing HUD-Code homes as a by right use in single-family zones is not a panacea 

and does not guarantee that these homes become part of the housing production stream. Even if 

permitted to do so, developer-builders might not mix different housing production systems 

within a subdivision. In single-family subdivisions where local regulations allow HUD-Code 

homes as a by-right use along with other types of housing, land developers might place private 

restrictions on lots sold to builders that exclude HUD-Code homes. The impact of government 

regulations are mediated by market dynamics that those regulations cannot control. 

To augment the survey and statistical analysis, four case studies were conducted on communities 

reported to have success in regulatory reforms and the urban placement of HUD-Code homes: 

Oakland (California), state of Washington, Pima County (Arizona), and Owensboro (Kentucky). 

Oakland is one of the premier success stories of the use of manufactured housing in urban infill. 

Washington recently passed state legislation enabling broader use of manufactured housing after 

a near three-decade-long advocacy effort and the success of several well-publicized subdivisions 

featuring manufactured housing. The Pima County case illustrates the complexities of placing 

manufactured units in the expanding suburbs of a high-growth urban area. Owensboro illustrates 

the ongoing challenges of developing and marketing manufactured housing even within a state 

with a long reliance on manufactured housing in rural areas and a record of state legislative 

support. 

Nonprofit organizations played a critical role in placing HUD-Code homes within the urban 

locations documented in the case studies, particularly in the state of Washington. Nationwide, 

nonprofits are a relatively untapped resource for promoting placement of manufactured homes in 

urban areas. CFED (Corporation for Enterprise Development), whose I’M HOME program 

provides funding nationally to nonprofit organizations for implementing manufactured housing 

initiatives, reports that efforts are focused primarily in rural areas. Less than 10% of grant 

recipients concentrate efforts within urban areas and less than 25% concentrate efforts in 

urban/suburban areas. 

108 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
 

The most important lesson emerging from the case studies is that successful manufactured 

housing based affordable housing strategies require strong community support, institutional 

mechanisms for delivering manufactured housing units, along with sustained political leadership. 

Communities must also be familiar with the technical constraints to transporting and securing 

units onsite. 

Recommendations 

These findings suggest that if HUD-Code homes are to be considered viable affordable housing 

options in urban communities, steps must be taken to remove the barriers that currently exist to 

placing such units. The following are offered as recommendations for achieving this goal: 

•	 Since local regulations influence manufactured housing placement through a variety of 

channels, local regulators should seek to ensure that the overall permitting system is 

supportive of manufactured housing placement. Regulations protecting by-right use in 

traditional single-family districts and infill locations should not be viewed as replacing 

regulations allowing the development of subdivisions and parks devoted exclusively to 

manufactured housing. However, parks are only one element of the affordable housing 

toolkit, and HUD’s previous research has shown that capital appreciation potential is 

significantly tied to land ownership. States wishing to have the most significant impact on 

reducing local regulatory barriers should focus on minimizing the cumulative effect of all 

local regulations, rather than on requiring specific local provisions such as design 

requirements and by-right allowances. 

•	 Regulatory reforms will help to alleviate some constraints to placing manufactured 

housing units, but market conditions will ultimately determine if manufactured housing is 

viable locally. Residents must be willing to pay for manufactured housing units, and 

financing must be available to those seeking to purchase a manufactured home. 

Furthermore, the manufactured housing industry’s supply chain (manufacturer-dealerinstaller-buyer), and the difficulty of financing units under traditional construction loans 

until they are secured onsite, can impede the placement of units. 

•	 Built-out urban areas can promote affordable redevelopment using manufactured housing 

on vacant infill lots, particularly in cities with the potential to capture an important share 

of the moderate priced housing market. Using manufactured housing also reduces the 

time required to enclose and secure the unit from theft or vandalism, potentially adding to 

the cost-savings particularly when used as infill. 

•	 Although regulations requiring by-right use of HUD-Code homes in single-family 

districts are necessary to promote the supply of such homes on infill lots and in 

traditional subdivisions, these regulations do not eliminate the need for regulations 

allowing the creation of special HUD-Code subdivisions. The creation of new 

subdivisions targeted to HUD-Code homes can expand opportunities for affordable 

housing and should be considered as a way of promoting manufactured homes along with 

regulations allowing their use in traditional residential zones. 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities 109 
•	 Manufactured housing may not be a viable affordable housing alternative for all 

communities. Although more units can be placed through the development of 

manufactured housing subdivisions, acceptance (public, governmental, and market) in 

high growth suburban areas will be difficult, but not impossible. Infill in older cities 

within high-growth metropolitan markets might prove more fruitful. 

•	 Urban areas where placement of manufactured housing has been successful are models 

for other communities. For example, Oakland, California capitalized on state regulatory 

reforms to introduce manufactured housing on infill lots. Without a forward thinking or 

motivating leader (in the case of Oakland, a progressive city council), regulatory reform 

will not in itself promote manufactured housing. 

•	 The nonprofit affordable housing sector could be an important ally in promoting 

manufactured housing. Efforts should be taken to familiarize nonprofit housing producers 

with the unique aspects of the manufactured housing supply chain, in addition to the role 

of regulations and local market conditions in influencing the viability of manufactured 

housing as an affordable housing alternative. 

•	 Local nonprofit housing organizations should investigate opportunities provided by 

national nonprofit organizations to support manufactured housing initiatives. One such 

organization, CFED (Corporation for Enterprise Development), promotes manufactured 

housing through an initiative called I’M HOME, or Innovations in Manufactured Homes, 

offering grants and contracts to nonprofit organizations interested in promoting or 

developing manufactured housing. 

•	 Research on this topic is severely limited by the paucity of jurisdiction-level data on 

manufactured housing supply. Shipments are only provided in state-level aggregate form, 

and placements at the local level are not provided by any publicly-available sources. 

Furthermore, information on important aspects of the supply chain, particularly supplierto-dealer relationships, is nonexistent. Collection of these data would help to generate 

additional research on the manufactured housing industry and provide local planners with 

a useful source of information for analyzing the impacts of local regulatory measures. 

110 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
 

 

 

 

 

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APPENDIXES 

Appendix A: Impact of Regulations on Manufactured Housing Survey 

LOCAL REGULATORY PRACTICES AND MANUFACTURED HOMES 

Please answer the following questions about your jurisdiction’s practices regarding manufactured homes which we refer to 

as HUD-Code homes. A manufactured home (formerly known as a mobile home) is built to the Manufactured Home 

Construction and Safety Standards (HUD Code). Manufactured homes are built in the controlled environment of a 

manufacturing plant and are transported in one or more sections on a permanent chassis. These questions have been 

approved by the United States Office of Management and Budget. Answering is completely voluntary and information 

provided will be protected. If you believe there is another person better suited to answer questions on regulations related to 

manufactured housing, please ask that person to complete this questionnaire. After answering all the questions, please 

promptly return the questionnaire in the envelope provided. Thank you for your valuable input and time. 

Total N=940 out of 1,725. Questions have N followed by the % that answered for each choice 

Q1. In the past 5 years has your jurisdiction approved the placement or location of any new HUDCode homes (please check the answer that best fits)? 

 No 235, 26%  Not Sure, 56, 6.2%  Not Sure, 54, 6.0%  Yes 558, 61.8%

 Probably Not Probably Yes 

If you answered Q1 as No or Not Sure, Probably Not: 

Q1a. Does your jurisdiction ever allow HUD-Code homes to be used? 

 Yes  Rarely  No 

159, 58.0% 41, 15.0% 74, 27.0% 

If you answered Q1a as Rarely or No, please skip to Q8 at end. 

If you answered Q1a as Yes: 

Q1b. Please check which one of the following best describes your jurisdiction’s 

regulations on HUD-Code homes? 

73, 46.8% HUD-Code homes are allowed as a by right use in single-family 

zones, but there have been no requests to locate HUD-Code homes in the 

past 5 years. 

 16, 10.3% HUD-Code homes are allowed in single-family zones on a 

temporary basis or with special or conditional use permits, but there have 

been no requests to locate HUD-Code homes in the past 5 years. 

 67, 42.9% HUD-Code homes are restricted to designated “mobile home 

parks”, communities, or subdivisions, but we haven’t received any proposals 

for new parks in the past 5 years. 

Please skip to Q6. 

If you answered Q1 as Yes or Not Sure, Probably Yes, please continue: 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities A-1 
 

 

 

 

 

 

 

 

 

 

Q2. Approximately how many HUD-Code homes have been placed or located in your 

jurisdiction in the past 5 years? 

 1-10  11-20  21-30  31-40  41-50  51-99  100+ 

191, 33.4% 105, 18.4% 67, 11.7% 29, 5.1% 35, 6.1% 36, 6.3% 109, 19.1% 

Q3. Does your jurisdiction: 

1. Restrict HUD-Code homes to special zoning categories such as “mobile home parks”, 

communities, or subdivisions?  Yes  No 

238, 40.9% 343, 58.9% 1, .2% other 

2. Require a special or conditional use permit for HUD-Code homes to be placed or 

located in single-family zones?  Yes  No 

128, 22.5% 419, 73.8% 21, 3.7% other 

3. Allow HUD-Code homes as a by right use in one or more single-family zones if design 

standards are met?  Yes  No 

357, 62.7% 209, 36.7% 3, .5% other 

4. Allow HUD-Code homes as a by right use in one or more single-family zones subject 

to the same rules as other housing?  Yes 

346, 61.3% 

 No 

214, 37.9% 4, .7% other 

If you answered Yes to #3. above: 

Does the planning staff or building department have any discretion in the 

administration of these design standards? 

259, 71.3% No, the standards are fixed and clear. 

91, 21.5% Yes, describe ______________________________________________ 

13, 3.6% Not Applicable 

How difficult is it for HUD-Code homes to meet these design standards? 

256, 73.6% They are easily met. 

64, 18.4% They can be met, but the standards significantly affect unit costs. 

5, 1.4% They are hard to meet. 

23, 6.6% Not Applicable 

Q4. Has your jurisdiction approved any new “parks”, communities, or subdivisions for HUDCode homes in the past 5 years? 

104, 17.3%  Yes 495 82.5%  No 1, .2% other 

If Yes, how many “parks”, communities, or subdivisions for HUD-Code homes were 

approved?
 

_______________ (please write in the number) 

492, 82.6%=0 (includes those who said no above); 65, 10.9%=1; 21, 3.5%=2; 9, 1.5%=3; 9, 1.6%=4 or more 

A-2 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
 

 

 

 

 

 

 

 

____________________________________________________________________ 

 

 

 

Q5. Approximately what proportion of HUD-Code homes placed or located in your jurisdiction in 

past 5 years have been in: 

HUD-Code parks, communities, or subdivisions? 

 0-24%  25-49%  50-74%  75-89% 90%+  Don’t Know 

223, 39.7% 30, 5.3% 39, 6.9% 30, 5.3% 169, 30.1% 71, 12.6% 

Infill in older single-family neighborhoods? 

 0-24%  25-49%  50-74%  75-89% 90%+  Don’t Know 

 325, 59.1% 50, 9.1% 26, 4.7% 31, 5.6% 60, 10.9% 58, 10.5% 

New single-family subdivisions (not restricted HUD-Code homes)? 

 0-24%  25-49%  50-74%  75-89% 90%+  Don’t Know 

 401, 80.4% 20, 4.0% 7, 1.4% 6, 1.2% 4, .8% 61, 12.1% 

Q6. Does your jurisdiction require a special or conditional use permit or other permit if HUD-Code 

homes are placed or located in single-family zones (other than designated mobile home parks, 

communities, and subdivisions)? 

 Yes  No 

198, 26.3% 514, 68.2% 42, 5.5% other 

Q7. Does your jurisdiction promote the use of HUD-Code homes through any special incentives or 

programs? 

 Yes  No (Please skip to Q8) 

11, 1.4% 759, 98.6% 

If you answered Yes to Q7: 

Are these incentives or programs targeted to redevelopment or infill? 

 Yes  No  Not Applicable 

9, 90% 1, 10%

 If Yes, please describe the incentives used:__________________________________ 

____________________________________________________________________ 

` 

Do you use Community Development Block Grants (CDBG), HOME or other federal 

funding in these programs? 

 Yes  No  Not Applicable 

 7, 70% 3, 30% 

Of the HUD-Code homes placed or located in your jurisdiction in the past 5 years, what 

percentage of homes were placed in areas targeted by these programs? 

 Less than half  50%-74%  75-89%  90%+  Don’t Know  Not Applicable 

 7, 70% 1, 10% 0, 0% 2, 20% 0, 0% 

 Regulatory Barriers to Manufactured Housing Placement in Urban Communities A-3 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

__________________________________________________________________________ 

Q8. For your jurisdiction, please rate the following potential barriers to HUD-Code homes 

(please check one box per barrier): Based on full N = 940 

Not Not a Minor Significant Prevent 

Applicable Barrier Barrier Barrier HUD-Code 

Homes 

Fees   1 67.3%  2 17.6%  3 2.5%  4 .5% 

Permits   1 66.4%  2 19.0%  3 5.1%  4 1.5% 

Deed restrictions/covenants   1 33.5%  2 19.6%  3 20.4%  4 6.4% 

Wind standards   1 53.7%  2 23.1%  3 7.4%  4 1.1% 

Snow load standards   1 50.5%  2 16.3%  3 2.7%  4 .8% 

Fire codes   1 62.6%  2 20.0%  3 5.6%  4 .7% 

Zoning codes   1 34.2%  2 28.7%  3 4.2%  4 9.2% 

Subdivision regulations   1 46.6%  2 24.1%  3 14.4%  4 6.0% 

Architectural design standards   1 39.0%  2 24.7%  3 10.2%  4 3.1% 

Citizen opposition   1 22.2%  2 31.6%  3 31.3%  4 4.8% 

Environmental regulations   1 64.4%  2 13.3%  3 2.7%  4 .5% 

Historic district regulations   1 31.8%  2 16.1%  3 16.2%  4 9.9% 

High land costs   1 26.5%  2 22.0%  3 38.0%  4 4.4% 

Not much land (built-out)   1 35.9%  2 20.0%  3 27.3%  4 3.8% 

No new HUD-Code parks, 

communities, or subdivisions 

approved   1 27.03%  2 14.6%  3 28.4%  4 7.2% 

Insufficient demand for 

HUD-Code homes   1 37.8%  2 20.7%  3 18.2%  4 3.6% 

THANK YOU! Please make sure you have answered all the questions and return the 

questionnaire in the business reply envelope provided (no postage required) or, if envelope 

misplaced, to: 

Casey Dawkins, Ph.D. 

Center for Housing Research, Mail Code 0451 

Virginia Tech 

Blacksburg, Virginia 24061 

Optional: To receive the results of this survey, provide your email or mailing address: 

A-4 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
 

Appendix B: Supporting Documents for Case Studies 

Appendix B–1: Oakland, California 

Appendix B–1.1: Oakland, California, City Ordinance 10004
 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities B-1 
B-2 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
 

Appendix B–1.2: Oakland, California, City Ordinance 10092 

 Regulatory Barriers to Manufactured Housing Placement in Urban Communities B-3 
Appendix B–2: Washington Manufactured Housing Association Brochure 

B-4 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
 Regulatory Barriers to Manufactured Housing Placement in Urban Communities B-5 
Appendix B–3: Pima County, Arizona: Ordinance 9443, City of Tucson 

An information bulletin dated January 8, 2001, issued by the city of Tucson Planning 

Department, encapsulates the current status of manufactured homes within the city: 

On November 27, 2000, Mayor and Council adopted Ordinance #9443, which became 

effective on December 27, 2000. The ordinance sets forth certain criteria for installation 

of a manufactured housing unit on a site. The restrictions and design criteria do not apply 

to development in the mobile home zones, MH–1 or MH–2. 

Prior to the adoption of this ordinance, the Land Use Code: 

•	 Defined a manufactured housing unit as "A multisectional mobile home dwelling 

manufactured after June 15, 1976, to standards established by the U. S. 

Department of Housing and Urban Development which has external dimensions 

of at least twenty-four (24) feet by forty (40) feet and is installed on a permanent 

foundation. A manufactured housing unit is considered equivalent to a singlefamily dwelling. A wall shall be installed continuously, except for ventilation and 

access, along the entire perimeter of the unit between the unit and the ground to 

give it the appearance of a site-built house. The wall shall be of masonry 

construction or similar material. The tongue, axles, transporting lights, and towing 

apparatus shall be removed before occupancy." (LUC Section 6.2.13). 

•	 Permitted units in all zoning districts where dwellings were permitted, with the 

exception of the R–1 zone, where they could be placed only in subdivisions 

recorded after January 1, 1982. 

Ordinance #9443: 

•	 Does not change the definition of a manufactured housing unit. 

•	 Adds design criteria for placement of the unit in SR, RX–1, RX–2, R–1, R–2, and 

R–3 zones. 

•	 Further restricts placement of manufactured homes in the R–1 zone, in that they 

must be located in a subdivision in the R–1 zone recorded after January 1, 1982, 

and also may not be located in any resubdivision of a subdivision recorded prior 

to January 1, 1982. 

•	 Permits the use of manufactured housing units in Residential Cluster Project 

development (per Section 3.5.7.1.F of the Land Use Code). 

•	 Permits the use of manufactured housing units within a subdivision clearly 

identified as a manufactured housing subdivision which has been approved and 

for which permits for manufactured homes for twenty-five (25) percent or more of 

the lots within the subdivision have been issued prior to November 27, 2000. 

•	 Establishes design criteria which require that the unit be placed on an excavated 

and backfilled foundation (ground-set). 

•	 If the home is located within a floodplain, the bottom of the lowest floor joist is to 

be a minimum of one (1) foot above the one-hundred year base flood elevation. 

•	 No more than eight (8) inches of perimeter skirting wall is to be visible from the 

street frontage of the property. 

B-6 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
 

•	 The skirting wall must match the exterior color of the home. 

•	 The exterior siding materials are to be either hardboard, vinyl, or stucco. 

•	 Concrete or masonry steps are to be provided for the entry on the street side of 

the home. 

•	 All entry doors on the street side of the home are to be inward-swinging. 

The roofing style and materials are to be either flat roof (Pueblo style), steel rib roof, or a shingle or tile 

roof, with all roofs other than the flat roof having a minimum pitch of 3:12, and all pitched roofs other than 

a roof behind a parapet to have a minimum six (6) inch eave on all sides of the home. 

 Regulatory Barriers to Manufactured Housing Placement in Urban Communities B-7 
Appendix B–4: Owensboro, Kentucky 

Appendix B–4.1: Owensboro Messenger Inquirer Article on Doe Ridge 

Copyright of the Owensboro Messenger Inquirer. This material is strictly for personal use 

and can not be resold or used in any manner without the explicit written consent of 

Owensboro Messenger Inquirer. 

Title: Manufactured housing subdivision in demand. 

Date: 06/04/2000. 

Byline: Keith Lawrence 

Dick Berry wanted to have Deer Haven Drive—his main street—paved and several model homes 

ready to show customers before he announced plans for his new Doe Ridge Subdivision off 

Medley Road east of Ben Hawes State Park. 

But demand for homes in Daviess County's first manufactured housing subdivision has been so 

strong that Berry is having trouble keeping up Deer Haven Drive is still covered with white rock. 

And customers have to visit Home Folks Housing Center on U.S. 60 East to see the model 

homes. 

But people are already moving into the subdivision, and grass is growing on what were bare lots a 

month ago. 

"We've already sold 12 lots," Berry said last week. "And three families have already moved in. If we 

can keep up with demand, we should have 35 to 40 families living here by fall.” Eventually, the 

subdivision will have between 150 and 200 manufactured homes, and its streets will link with 

other subdivisions to a second exit on U.S. 60 West near the post office. 

"Manufactured housing subdivision" is not a fancy way to say "trailer park," Berry said. 

"This is just like any other subdivision," he said. "We build the streets, put in the sidewalks, street 

lights, curbs, gutters and driveways and sell the lots. The houses are set on concrete foundations. 

They're just made in a factory." 

Gary Adams, associate director of planning for the Owensboro Metropolitan Planning Commission, 

said Daviess County has two types of mobile home parks. In one type, the owners of the mobile 

homes also own the land. 

"But there, the lots are smaller than the typical subdivision," Adams said. "Doe Ridge is technically a 

regular subdivision," he said. "The lots are size of other subdivisions, and it's zoned residential." 

Class A manufactured houses like those in Doe Ridge could be placed in any subdivision in 

Owensboro or on any street in town, Adams said. They meet all residential criteria of the planning 

commission. 

The houses being erected in Doe Ridge are manufactured by Fleetwood Homes, a national company 

that bought Berry's Home Folks Housing two years ago. 

He now works as a consultant to Fleetwood and is overseeing development of the subdivision. 

Fleetwood says it built more than 65,000 homes in its factories last year. Sales totaled $2 billion. 

The homes in Doe Ridge range from 1,100 square feet to around 2,000 square feet. Prices range 

from $69,900 to $100,000 including land. Payments on a 30-year mortgage will run from $490 to 

$795 a month, Berry said. 

"They're not mobile homes," he said. "We bring them in two sections and assemble them on site. 

They have a foundation just like a site-built home. They're not to be moved again." 

Berry is adding large concrete front porches to the homes with enough space for porch swings. 

Thursday, Greg McFarland was watching workers assemble his new home beneath large shade trees 

near the northern edge of Doe Ridge. 

"I've lived on Industrial Drive for the past eight years," he said. "I'm used to this side of town. This is 

close to work. And it looks like a great place to raise a family. I've got three little girls." 

B-8 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
 

McFarland bought the house a month ago, he said, and should be able to move in within two weeks. 

"It would have been sooner, but the rain delayed," he said. 

McFarland said he was impressed with both the house and the site. "It's nice," he said. "I like the 

atmosphere here." 

Although it's in the woods, Doe Ridge is inside the city limits and has all city services, Berry said. The 

utilities are underground. 

One of the complaints about manufactured housing in the past has been that depreciated in value 

through the years rather than increasing like site-built homes. 

But that's changing, according to Ron Durbin, Daviess County's property valuation administrator. 

"For double-wides or larger, my guess is that they will increase in value, but not as fast as 

conventional homes," he said. 

Keith Lawrence, (270) 691–7301, klawrence@messenger-inquirer.com 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities B-9 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Appendix B–4.2: Owensboro, Kentucky Metropolitan Zoning Ordinance, Article 8 

Following is an excerpt from Owensboro Metropolitan Zoning Ordinance, Article 8, Zones and 

Uses Table showing where each class of manufactured home is principally or conditionally 

permitted (highlighted). Note that only Class 1 manufactured homes are principally permitted 

uses in all Single-Family Residential Zones (R–1A, R–1B, and R–1C), the Townhouse Zone (R– 

1T) and the Inner-City Residential Zone (R–4DT), that Class 2 manufactured homes are 

conditionally permitted (with Board of Adjustment approval) in those zones, and that Class 3 is 

permitted only in Agriculture Zones (A–R and A–U). 

8.2 ZONES AND USES TABLE 

P = PRINCIPALLY PERMITTED USES: Uses listed and other uses (not 

otherwise listed in table) substantially similar to those listed are 

deemed permitted. 

NOTE: Only those uses specifically permitted or substantially 

similar to permitted uses are permitted in each zone; all uses 

which lack substantial similarity to permitted uses in each 

zone are deemed prohibited (as per Article 3 of this Zoning 

Ordinance). 

Numbers following the "P", "C" or "A" in the table refer to 

special conditions, additional information, or detailed use 

listings, which follow in numerical order in Section 8.4. 

C = CONDITIONALLY PERMITTED USES: Uses which are permitted 

only with Board of Adjustment approval. 

A = ACCESSORY USES: Uses and structures permitted which are 

customarily accessory, clearly incidental and subordinate to 

permitted uses. 

ZONES 

A–R 

A–U 

R–1A 

R–1B 

R–1C 

R– 

1T 

R– 

2MF 

R– 

3MF 

R– 

4DT P–1 B–1 B–2 

B–3 

B–4 B–5 I–1 I–2 

USES 

C/1 C/1 C/1 C/1 1A Bed and breakfast home 

C/6a C/6a 1B Boarding or lodging house 

A/2A A/2A A/2A,52 A/2A A/2B A/2B A/2B 2 Dwelling: Accessory

 P P P P/3,52 3 Dwelling: Multi-family

 P P P P 4 Dwelling: Single-family 

detached 

P/4 5 Dwelling: Townhouse 

P P P 6 Dwelling: Two-family

 P P P P P 6A Residential Care Facilities 

C/6a C/6a C/53,6a C/6a C/6a 7 Fraternity or sorority house, 

dormitory

 C/6b C/6a C/6a 7A Seasonal farm worker 

housing 

A/5 A/5 A/5 A/5 A/5 A/5,52 8 Guest quarters

 A A/6 A/6 A/6 A/6 A/6 A/6 9 Keeping of roomers or 

boarders by a resident family

 P/7 P/7 P/7 P/7 10A Manufactured Home, 

Class 1 (see Section 14.7521) 

P/7 C/7 C/7 C/7 10B Manufactured Home, 

Class 2 (see Section 14.7522) 

P/7 10C Manufactured Home, 

Class 3 (see Section 14.7523) 

P P 11 Motel or hotel 

P/8 P/8 P/8 P/8 12 Planned residential 

development project 

/7. Conditionally permitted Class 2 Manufactured Homes must meet all Class 1 Acceptable Installation Standards of Section 14.75211 

and must meet, at a minimum, the Class 1 Similarity Appearance Standard of Section 14.75212(1). Manufactured Homes of Classes 1, 

2, and 3 are also permitted in Planned Manufactured Housing Park MHP Zones (see Article 11). 

Source: Owensboro Metropolitan Zoning Ordinance, 2003 

B-10 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
 

 

Appendix B–4.3: Owensboro Metropolitan Zoning Ordinance Article 14 

Following are the definitions and descriptions of the installation and appearance standards for 

each class of manufactured home from Article 14, Definitions of the Owensboro Metropolitan 

Zoning Ordinance. The Kentucky Manufactured Housing Institute reviewed these regulations 

prior to their adoption. 

14.75 MANUFACTURED BUILDING has the following features or characteristics; it is: 

(1) Mass-produced in a factory; 

(2) Designed and constructed for transportation to a site for installation and use when
 

connected to required utilities; 

(3) Either an independent, individual building or a module for combination with other 

elements to form a building on the site.
 

14.751. The term "manufactured building" is not intended to apply to use of prefabricated 

panels, trusses, plumbing subsystems, or other prefabricated sub elements 

incorporated in the course of construction of buildings on the site, but only to major 

elements requiring minor and incidental on-site combination or installation. 

14.752 Manufactured Home. A manufactured building or portion of a building built on a 

chassis designed for long-term single-family residential use with or without a 

permanent foundation when connected to the required utilities, and which includes the 

plumbing, heating, air conditioning, and electrical systems contained therein. All 

manufactured homes shall contain an intact “HUD seal” issued by the United States 

Department of Housing and Urban Development, or a “B1 seal” issued by the 

Kentucky Department of Housing, Buildings and Construction, Office of the State Fire 

Marshall, before an application will be processed for placement. KRS 227.550 defines 

Class B inspection seals for manufactured homes as follows: 

(1) “B1 seal” means the unit has been inspected and found to be in compliance with 

applicable standards for human habitation. 

(2) “B2 seal” means the unit has been inspected and found not to be in compliance with 

applicable codes and is unfit for human habitation. Units receiving a “B2 seal” are
 

prohibited in all zones. 

For the purposes of these zoning regulations, manufactured homes are divided into three 

(3) classes. 

14.7521 Class 1 Manufactured Home. A manufactured home constructed after June 15, 

1976, in accordance with the National Manufactured Home Construction and Safety 

Standards Act of 1974, 42 U.S.C. Section 5401, et seq., as amended, and designed to 

be used as a single family residential dwelling. This definition includes “qualified 

manufactured homes” as defined by KRS 100.348(d). The manufactured home shall 

be approved by the Zoning Administrator as meeting all of the "Acceptable Installation 

Standards" and all of the "Acceptable Similarity Appearance Standards" herein below. 

14.75211 Acceptable Installation Standards. Class 1 Manufactured Homes must meet 

all of the following standards to achieve acceptable installation in Owensboro-Daviess 

County: 

(1) They shall be permanently installed on a permanent foundation in accordance with 

KRS 227.550 and KAR 25:090 or American national Standards Institute (ANSI) 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities B-11 
 

 

 

A.225.1 (the manufacturer’s installation specifications as approved by the U.S. 

Department of Housing and Urban Development). Permanent foundation means a 

system of supports that is capable of transferring, without failure, into soil or bedrock, 

the maximum design load imposed by or upon the structure, constructed of concrete, 

and placed at a depth below grade adequate of prevent frost damage. 

(2) All wheel, trailer-tongue and hitch assemblies shall be removed upon installation. 

(3) They shall be permanently connected to an approved water and sewer system when 

available, and shall comply with all public health requirements governing plumbing 

installation. 

14.75212 Acceptable Similarity Appearance Standards. Class 1 Manufactured Homes 

must meet all of the following standards to achieve acceptable similarity in 

appearance between the manufactured home and site-built housing in OwensboroDaviess County: 

(1) A poured concrete or masonry block skirting wall shall be constructed beneath and 

along the entire perimeter of the manufactured home, compatible in appearance with 

community site-built housing foundations, even if the wall is not structurally required 

by the manufacturer's installation specifications. 

(2) Minimum width of main body of the manufactured home as assembled on the site shall 

not be less than twenty (20) feet at its smallest width measurement unless it is two (2) 

stories in height and oriented on the lot or parcel so that its main entrance door faces 

the street. 

(3) The pitch of the main roof shall be not less than two and one-half (2 1/2) feet of rise for 

each twelve (12) feet of horizontal run. In general, any roofing material may be used 

that is generally acceptable for housing built on the site, if applied in such a manner as 

to be similar in appearance. 

(4) Any materials that are generally acceptable for housing built on the site may be used 

for exterior finish if applied in such a manner as to be similar in appearance, provided, 

however, that reflections from such exterior shall not be greater than from siding 

coated with clean, white, gloss, exterior enamel. 

(5) The manufactured home shall have a minimum total living area of nine hundred (900) 

square feet. 

14.7522 Class 2 Manufactured Home. A manufactured home constructed after June 15, 

1976, in accordance with the National Manufactured Home Construction and Safety 

Standards Act of 1974, and which does not meet all of the "Acceptable Installation 

Standards" and "Acceptable Similarity Appearance Standards" hereinabove. Class 2 

Manufactured Homes may include manufactured homes that have received a “B1 

seal” provided the date of manufacture is June 15, 1976 or later. All Class 2 

Manufactured Homes must meet installation standards described in 14.75211 (1) and 

(3). 

14.7523 Class 3 Manufactured Home. A manufactured home constructed prior to June 

15, 1976 and commonly referred to as a “mobile home”, and which does not meet all 

“Acceptable Installation Standards” or “Acceptable Similarity Appearance Standards”, 

but is found upon inspection to be safe and fit for residential occupancy. Class 3 

manufactured homes shall include manufactured homes that have received a “B1 

seal”, but does not include those units inspected and receiving a “B2 seal”. All Class 3 

Manufactured Homes must meet installation standards described in 14.75211 (1) and 

(3). 

B-12 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
 

 

 

 

14.76 MANUFACTURED HOUSING PARK. A planned development in an MHP Zone of 

ten (10) acres or more in area, designed for the siting of ten (10) or more 

manufactured homes. 

14.761 Manufactured Housing Park Complex. A manufactured housing park held under 

single ownership or control. 

14.762 Manufactured Housing Park Subdivision. A manufactured housing park in which 

individuals may own their own lots and share in the use and maintenance of common 

areas and facilities. 

Source: Owensboro Metropolitan Zoning Ordinance, 2003 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities B-13 
 

Appendix B–4.4: Kentucky Legislation: KRS 100.348 

100.348 Compatibility standards for manufactured homes—Definitions—
 

Adoption of standards by local governments. 

(1) The Kentucky General Assembly hereby recognizes and affirms that the protection 

of property values is a legitimate issue to local governments and the enactment of 

regulations designed to protect property values is a proper exercise of local 

government legislative power. 

(2) As used in this section, unless the context requires otherwise: 

(a) "Compatibility standards" means standards that have been enacted by a local 

government under the authority of this section for the purpose of protecting 

and preserving the monetary value of real property located within the local 

government's jurisdiction; 

(b) "Local government" means a city, county, urban-county government, charter 

county government, or consolidated local government that is engaged in 

planning and zoning under KRS Chapter 100; 

(c) "Manufactured home" means a single-family residential dwelling constructed 

after June 15, 1976, in accordance with the National Manufactured Home 

Construction and Safety Standards Act of 1974, 42 U.S.C. Section 5401, et 

seq., as amended, and designed to be used as a single-family residential 

dwelling with or without permanent foundation when connected to the 

required utilities, and which includes the plumbing, heating, air conditioning, 

and electrical systems contained therein; 

(d) "Qualified manufactured home" means a manufactured home that meets all of 

the following criteria: 

1. Is manufactured on or after July 15, 2002; 

2. Is affixed to a permanent foundation and is connected to the appropriate 

facilities and is installed in compliance with KRS 227.570; 

3. Has a width of at least twenty (20) feet at its smallest width measurement 

or is two (2) stories in height and oriented on the lot or parcel so that its 

main entrance door faces the street; 

4. Has a minimum total living area of nine hundred (900) square feet; and 

5. Is not located in a manufactured home land-lease community; and 

(e) "Permanent foundation" means a system of supports that is: 

1. Capable of transferring, without failure, into soil or bedrock, the 

maximum design load imposed by or upon the structure; 

2. Constructed of concrete; and 

3. Placed at a depth below grade adequate to prevent frost damage. 

(3) Any local government may adopt and enforce, as a part of its zoning regulations, 

compatibility standards governing the placement of qualified manufactured homes 

in residential zones within the local government's jurisdiction. Compatibility 

standards shall be adopted, amended, and enforced in the same manner as other 

zoning regulations and shall be in addition to any zoning regulations that are 

generally applicable to single-family residences. The compatibility standards shall 

Page 1 of 2 

B-14 Regulatory Barriers to Manufactured Housing Placement in Urban Communities 
 

be designed to ensure that when a qualified manufactured home is placed in a 

residential zone it is compatible, in terms of assessed value, with existing housing 

located with a one-eighth (1/8) mile or less radius from the proposed location of the 

qualified manufactured home. The compatibility standards adopted by a local 

government shall relate to architectural features that have a significant impact on 

the overall assessed value of the structure, including, for example, but not limited 

to features such as: 

(a) Roof pitch; 

(b) Square footage of livable space; 

(c) Type and quality of exterior finishing materials; 

(d) Foundation skirting; and 

(e) Existence and type of attached structures. 

(4) Nothing in this section shall be construed to affect, modify, or abolish restrictions 

contained in recorded deeds, covenants, or developers' subdivision restrictions. 

(5) Nothing in this section shall be construed as limiting in any way the authority of 

local governments to adopt regulations designed to protect historic properties or 

historic districts. 

Effective: July 1, 2003 

History: Created 2002 Ky. Acts ch. 337, sec. 1, effective July 1, 2003. 

Page 2 of 2 

Source: www.lrc.ky.gov/KRS/100–00/348.PDF 

Regulatory Barriers to Manufactured Housing Placement in Urban Communities B-15 

 

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U.S. Department of Housing and Urban Development 

HUD USER 

P.O. Box 23268 

Washington, DC 20026-3268 

Official Business 

Penalty for Private Use $300 

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