Advocates urge statutory changes, SRF tweaks to help manufactured‑home communities fund aging water and sewer systems

Two housing advocates told the House General and Commerce committee on April 10 that Vermont's manufactured‑home communities (MHCs) face urgent infrastructure needs for drinking water, wastewater and stormwater systems, and that state rules and the State Revolving Fund (SRF) process are structured for municipalities rather than small, low‑income parks.

Liz Curry, a consultant with Common Land Solutions, and Jeremiah Ward of the Cooperative Development Institute said the sector serves low‑ and moderate‑income households but lacks scale to absorb major capital costs. "The average median household income of MHCs that my program, WISP, has surveyed is 37,000," Curry said. Ward added, "Vermont has 238 MHCs that provide housing to nearly 7,700 households with low and moderate incomes."

Why it matters: presenters said MHCs are a critical affordable‑housing resource in Vermont but carry aging, often failing infrastructure installed in the 1950s–1970s. Curry and Ward said small community size (the average park surveyed has about 30 households) and low lot rents (median lot rent cited at $413 per month) mean parks cannot easily raise rates to repay large loans. Ward said a 2019 Vermont Housing & Conservation Board (VHCB) assessment estimated that roughly 25% of parks have capital needs in the $200,000 to $3 million range per park.

Presenters described specific barriers in the SRF and related state statute (Title 24, chapter 120). They said the SRF program and state implementing statute assume municipal borrowers and make privately owned public water systems—including MHCs and co‑ops—subject to a separate underwriting and priority process that is harder for small parks to navigate. Curry told committee members the program "is not aligned at all well with the affordable housing industry needs" and that SRF application and underwriting procedures are complex and slow for urgent park emergencies.

The advocates' ask: Curry and Ward proposed statutory language changes to embed an environmental‑justice‑style "disadvantaged" or "hardship" definition for privately owned public water systems in Title 24, chapter 120 (subchapters 1–4). They asked that loan‑priority criteria explicitly recognize financial hardship for MHCs and that a provision in subchapter 4 that bars privately owned wastewater projects from being prioritized ahead of a municipal clean water project be removed or revised to allow case‑by‑case prioritization for failing park systems. They said many fixes can also be pursued administratively via the SRF's annual intended‑use plan, but they want statutory changes so recognition of MHC hardship is not purely discretionary.

Operational context and examples: Ward described efforts to use SRF funds during the pandemic for two projects—one led by Addison Housing Works and one for a Milton co‑op—that exposed SRF program limitations for MHCs. He said the Vermont SRF mixes federal EPA funds with state funds and that the federal statutes (Safe Drinking Water Act, Clean Water Act) and common SRF practice default to municipal applications. Curry said staff at the water investment division have been receptive and that Deputy Commissioner Neil Kamen has engaged on the issue; she said a memo and draft language have been shared with staff but may require statute changes to make protections non‑discretionary.

Committee response and next steps: committee members said the topic is substantive and likely belongs with the House Environment Committee or a dedicated statutory bill rather than a last‑minute addition to the committee's omnibus housing bill. The presenters said they will continue discussions with DEC water investment staff and work on refined language; the committee chair said she would consult the Environment Committee chair about next procedural steps.

Ending: Advocates called for legislative and administrative fixes to make SRF resources and state priorities more accessible to small manufactured‑home communities so parks can address failing water, wastewater and stormwater systems without imposing untenable costs on low‑income residents.