Comment Detail

Comment

I am submitting comments on Freddie Mac’s strategic priorities for the manufactured housing to support very low income homeowners and renters who live in manufactured housing communities (MHC). MHC provide a critical housing type for very low income households. However, preserving manufactured housing and facilitating asset creation are impeded by an ownership structure that makes homeowners at risk of park closure, deteriorating conditions and limited options to sell and upgrade their homes. I am a professor in the Community and Regional Planning Department at the University of New Mexico. I have conducted a research project in which I spoke with representatives of nonprofit organizations and community land trusts about barriers and opportunities to acquiring manufactured housing communities as an affordable housing preservation strategy.

The Duty to Serve plan recognizes that manufactured housing is an important form of naturally occurring affordable housing and very affordable homeownership. While tenant protections are critical for MHCs, facilitating transition from investor ownership to ownership by a community land trust, a nonprofit organization, a public entity or residents provides a more stable, long term solution to maintaining high quality affordable housing. As the Duty to Serve proposed plan recognizes, community land trusts are not well understood by lenders, and increasing awareness about shared equity models as an aspect of a affordable housing preservation strategy is promising. A few community land trusts own MHC and more have tried to acquire them to assist in preserving manufactured housing communities.

As reflected in Activity 3, and the visibility of ROC USA, there is a tendency to express preference for resident-owned communities over ownership by community land trusts and other nonprofit organizations. While more research is needed to understand the dynamics of resident ownership, it is likely that those communities that successfully become resident owned have relatively more resources (human capital and monetary) than those for which a nonprofit organization or community land trust is a better model. It is likely that manufactured housing communities serving residents with the fewest resources will be more successful with a nonprofit or community land trust owner. These organizations need access to credit to acquire and upgrade MHC. Any pilot should also focus on other forms of land tenure and not only ROCs.

The second factor that needs to be directly addressed is access to credit for ‘renovation’ loans to upgrade infrastructure when residents, community land trusts and other nonprofit organizations acquire manufactured housing communities. In some cases, the land must also be reconfigured to make sites that can accommodate homes built to contemporary HUD standards. In addition, manufactured housing communities are located in areas at risks of flooding and reconfigured sites can reduce environmental hazards. Aging infrastructure or environmental hazards can impede the purchase of MHC by residents, nonprofits or community land trusts.

Thank you for your consideration.