Policy-Related Disasters from Disaster-Related Policies

Mobile and manufactured housing communities (MHCs) are a key affordable housing source in the United States. Nevertheless, MHC homeowners are subject to a suite of policies that uniquely impact their housing type, both pushing them into floodplains and simultaneously barring them from adaptation tools. FEMA’s substantial improvement/substantial damage or “50 percent rule” is one such policy.

This paper identifies the number of MHC homes impacted by the 50 percent rule in 12 Colorado counties, finding that 25.65 percent of MHCs and 8.64 percent of MHC homes intersect a FEMA-regulated floodplain, while comprising only 1.92 percent of homes overall. For 35.77 percent of MHC homeowners in the sample whose homes were built prior to 1976 HUD regulations, there are no allowable state or federal funding sources that can offset the cost of these required flood mitigation activities. Further, there is no federally-backed personally property financing for MHC homes’ floodplain mitigation.