Report on Water Access and Safety in Manufactured Housing Communities in Relation to Sustainable Development Goals

Despite progress in water safety following the Flint water crisis, a significant gap remains in ensuring access to safe and clean water for residents of manufactured housing communities in Michigan and across the United States. This report analyzes the systemic challenges preventing the realization of key Sustainable Development Goals (SDGs), primarily SDG 6 (Clean Water and Sanitation), but also impacting SDG 1 (No Poverty), SDG 3 (Good Health and Well-being), SDG 10 (Reduced Inequalities), SDG 11 (Sustainable Cities and Communities), and SDG 16 (Peace, Justice and Strong Institutions).

Challenges to SDG 6: Clean Water and Sanitation

The failure to provide universal and equitable access to safe and affordable drinking water (SDG Target 6.1) is acutely evident in manufactured housing communities. These communities face widespread issues with water quality, infrastructure, and regulatory compliance.

Widespread Non-Compliance with Federal Drinking Water Standards

Data indicates a systemic failure to meet basic safety regulations. An Associated Press investigation revealed that within the last five years:

• More than 50% of mobile home parks in the U.S. violated federal drinking water rules.
• 41% of these parks were repeat offenders, failing to submit required tests.

Furthermore, data from the Environmental Protection Agency (EPA) suggests that as many as 70% of private water systems within these communities have violated safe drinking water regulations.

Infrastructure Deficiencies and Flawed Ownership Models

The root of the problem often lies in the ownership structure and aging infrastructure.

1. Land-Rent Model: Residents typically own their homes but rent the land, making them dependent on park owners for the maintenance of essential utilities and infrastructure.
2. Disincentivized Investment: Landlords have a financial incentive to minimize costly investments in infrastructure maintenance and upgrades.
3. Aging Systems: Many parks, developed in the 1970s and 1980s, operate with outdated and deteriorating water systems. Even when water is sourced from a compliant municipal system, it can become contaminated while passing through the park’s poorly maintained “customer site piping,” which often lacks regulatory oversight.

Socio-Economic Impacts: Intersection with SDG 1, SDG 10, and SDG 11

The water crisis in manufactured housing communities has profound socio-economic consequences, undermining progress on multiple SDGs related to poverty, inequality, and sustainable communities.

Threats to Affordable Housing (SDG 1 & SDG 11)

Manufactured housing is a critical source of unsubsidized affordable housing (SDG Target 11.1). However, this affordability is under threat.

• A trend of corporate and private institutional investors acquiring these communities is leading to significant increases in lot rent.
• As noted by Esther Sullivan, an associate professor at the University of Colorado, these rent hikes are pricing many residents out of their homes, jeopardizing their financial stability and increasing poverty risks (SDG 1).

Disproportionate Burdens and Inequality (SDG 3 & SDG 10)

The issue highlights a stark inequality in access to basic services (SDG 10). Residents face significant health and financial burdens that undermine their well-being (SDG 3).

• Health Impacts: Residents experience constant stress and anxiety over the safety of their water, in addition to the physical health risks from potential contaminants.
• Financial Strain: The unreliability of tap water forces many to purchase bottled water or filters, creating an additional financial burden on households that are often low-income.
• Service Unreliability: Beyond quality, water reliability is a major concern, with some residents experiencing service shut-offs that can last for days.

Institutional and Regulatory Failures: A Barrier to SDG 16

Achieving peace, justice, and strong institutions (SDG 16) requires effective and accountable governance, which is currently lacking in the oversight of many manufactured housing communities.

Regulatory Gaps and Enforcement Deficiencies

Significant challenges prevent effective regulation and enforcement.

• Unlicensed Parks: It is estimated that over 100 unlicensed parks operate in Michigan alone, effectively outside of any regulatory framework.
• Accountability Issues: Residents report that approximately 50% of licensed parks have unclear or out-of-state ownership, making it difficult to report issues and hold owners accountable.
• Enforcement Lapses: According to John Lindley of the Michigan Manufactured Housing Association, the authority to enforce regulations exists, but the failure to do so allows communities to operate in violation of state law by simply letting their licenses lapse.

Legislative and Legal Responses

Efforts are underway to strengthen institutional frameworks (SDG Target 16.6). The prosecution of North Morris Estates for operating without a license and providing unsafe water demonstrates a move toward enforcement. Concurrently, Senator John Cherry is supporting legislation to grant the Michigan Department of Environment, Great Lakes, and Energy (EGLE) the same regulatory authority over “customer site piping” as it has over public water systems, aiming to close a critical regulatory gap.

Recommendations and Path Forward

To address these systemic failures and align with SDG targets, stakeholders suggest a multi-pronged approach focused on transparency, accountability, and legislative reform.

• Strengthen Enforcement: State and local governments must enforce existing laws and licensing standards to ensure all communities, regardless of ownership, provide safe and clean living conditions.
• Enhance Regulatory Oversight: New legislation is needed to give agencies like EGLE clear authority over all parts of the water delivery system within parks, including customer site piping.
• Improve Transparency: Creating a public database of manufactured housing communities that clarifies ownership structures would empower both residents and regulatory agencies, fostering greater accountability.

SDGs Addressed in the Article

Explanation of Relevant SDGs

• SDG 6: Clean Water and Sanitation

  This is the most prominent SDG in the article. The entire text revolves around the struggle of mobile home residents to access “safe, clean water.” It explicitly mentions issues like “unsafe drinking water,” “lead pipes and harmful chemicals,” violations of “federal drinking water rules,” and the need for residents to buy bottled water. This directly connects to the goal of ensuring availability and sustainable management of water for all.

• SDG 11: Sustainable Cities and Communities

  The article focuses on a specific type of housing: “manufactured housing communities” or “mobile home parks.” It discusses issues of affordability (“priced out of their mobile homes”), safety (due to poor infrastructure), and access to basic services (water). This aligns with the goal of making human settlements inclusive, safe, resilient, and sustainable.

• SDG 3: Good Health and Well-being

  The lack of safe drinking water poses a direct health risk. The article mentions “lead pipes and harmful chemicals,” which are known to cause significant health problems. The “worrying about drinking water they cannot trust” also points to mental stress, impacting overall well-being. This connects to the goal of ensuring healthy lives and promoting well-being.

• SDG 10: Reduced Inequalities

  The article highlights a clear inequality. While Michigan is becoming a “leader in safe water” for the general population, a specific, often vulnerable group—mobile home residents—is left behind. The problem is framed as an issue affecting a particular community that lacks the power and resources to address it, as their “complaints go nowhere.” This relates to the goal of reducing inequality within and among countries.

• SDG 16: Peace, Justice and Strong Institutions

  A significant portion of the article discusses regulatory failures. It mentions “unlicensed parks,” the difficulty for officials to “pursue unlicensed parks,” laws not being enforced, and the need for new “legislation” to give agencies like EGLE more oversight. The call for a “database of manufactured housing communities” to foster transparency and the legal action taken by a prosecutor against a non-compliant owner are all related to building effective, accountable, and inclusive institutions.

Specific SDG Targets Identified

Explanation of Relevant Targets

1. Target 6.1: By 2030, achieve universal and equitable access to safe and affordable drinking water for all.

   The article’s central theme is the failure to provide safe and affordable drinking water to residents of mobile home parks. Phrases like “struggle to receive safe, clean water,” “not providing safe drinking water to residents,” and residents having to buy “bottled water or filters, which can create financial strain” directly address the core components of this target: access, safety, equity, and affordability.

2. Target 11.1: By 2030, ensure access for all to adequate, safe and affordable housing and basic services and upgrade slums.

   Mobile home parks are presented as a key source of “affordable housing.” However, the article notes this is under threat due to rising lot rents. Furthermore, the lack of reliable water is a failure in providing “basic services.” The mention of “outdated, poorly maintained infrastructure” within these parks points to the need for upgrades to ensure safe living conditions.

3. Target 3.9: By 2030, substantially reduce the number of deaths and illnesses from hazardous chemicals and air, water and soil pollution and contamination.

   The article explicitly mentions the risk of contamination from “lead pipes and harmful chemicals.” While it doesn’t quantify deaths or illnesses, the presence of these contaminants in drinking water is the primary driver of the health problems this target aims to prevent.

4. Target 16.6: Develop effective, accountable and transparent institutions at all levels.

   The article details institutional failures, such as the existence of “unlicensed parks,” “unclear or out-of-state ownership,” and the fact that laws are not being enforced. The proposed solution to create “a database of manufactured housing communities” is a direct attempt to foster the transparency and accountability called for in this target. The discussion around giving EGLE more authority and making laws “more enforceable” also aligns with strengthening institutions.

Indicators for Measuring Progress

Explanation of Relevant Indicators

• Indicator for Target 6.1: Proportion of population using safely managed drinking water services.

  The article provides direct data points that can serve as indicators. It states that “more than half of mobile home parks in the U.S. broke federal drinking water rules,” “41% doing so repeatedly,” and “up to 70% of private water systems in country’s mobile home parks violated safe drinking water rules.” The fact that residents resort to buying “bottled water or filters” is a qualitative indicator that they are not using a safely managed service.

• Indicator for Target 11.1: Proportion of urban population living in slums, informal settlements or inadequate housing.

  While not a formal slum, the conditions described—inadequate basic services (water), “outdated, poorly maintained infrastructure,” and insecure tenure due to rising rents—are characteristics of inadequate housing. The number of residents being “priced out of their mobile homes” could serve as a specific metric for this indicator.

• Indicator for Target 16.6: Proportion of population satisfied with their last experience of public services.

  The article implies a very low level of satisfaction. It notes that residents’ “complaints go nowhere” and that some “feel they have nowhere to report these issues.” The number of unlicensed parks (“over 100 unlicensed parks in the state of Michigan”) and the percentage of parks with unclear ownership (“around 50% had unclear or out-of-state ownership”) are concrete indicators of institutional failure and lack of accountability, which directly impact public satisfaction and trust.

SDGs, Targets, and Indicators Analysis

Source: michiganpublic.org