Staff recommend manufactured‑home‑park overlay to reduce displacement; council seeks stronger tenant protections

County staff and a housing consultant presented recommendations on manufactured‑home parks at a July 1 work session, proposing a manufactured‑home‑park overlay for existing parks within urban growth areas to reduce redevelopment pressure and protect residents from displacement.

The case: Elizabeth Decker of Jet Planning told the council there are 34 manufactured‑home parks in Clark County containing a little over 2,000 homes (median park roughly 50 homes), most within urban growth areas. She said the parks provide a uniquely affordable route to homeownership—single‑story units appealing to older adults and households on fixed incomes—but are vulnerable because households typically own homes while renting lots. "The homes aren't very mobile," Decker said, and lot‑rent increases, ownership changes, and aging infrastructure can force displacement.

State context: Decker and staff reviewed recent state statutes that cap certain rent increases for lot rents, extend closure notification periods, and create tenant‑opportunity‑to‑purchase mechanics intended to give residents time to organize to buy parks. Staff noted these state provisions are helpful but may not be sufficient in practice due to financial and timing barriers for residents.

Staff recommendation: Decker recommended creating an overlay zone limited to existing parks inside urban growth areas, with these core features:

- a single‑use overlay that preserves park use and reduces redevelopment pressure; - a use‑exception requirement so a landowner seeking to redevelop must demonstrate a lack of reasonable economic use of the park before a zone change is approved; and - tailored development standards and flexibility to keep parks viable (setbacks, densities, nonconforming use flexibility where appropriate).

Staff did not recommend a TDR program for manufactured‑home parks at this time, saying county conditions and increased residential capacities make TDR transfers less likely to be used.

Council concerns and requested refinements: Councilors broadly supported protecting existing residents but pressed staff for more precise, implementable criteria. Questions included whether the overlay would apply automatically to new parks (staff: no—overlays would be applied via an application and legislative process), whether permitting other affordable housing types within the overlay would create redevelopment pressure or disincentives for new parks, and how the county could strengthen tenant protections beyond state law (longer notification, clearer compensation, and practical supports for tenant‑opportunity purchases).

Several councilors recommended limiting the overlay to older parks (for example, parks over a specified age) to avoid deterring new affordable projects; others urged staff to define the financial‑feasibility test that a park owner must meet to obtain a rezoning. Staff agreed to research legal options, potential county actions to augment state protections, and to return with draft code language and clearer use‑exception criteria. Decker said staff plan to follow with community engagement, including resident open houses, and to aim to include any zoning measures with the comprehensive plan adoption schedule while the county's moratorium runs through February 2027.

Next steps: staff will return with more detailed drafting options and legal research on tenant protections, use‑exception tests, and whether limited allowances for affordable multifamily on particular sites should be permitted with strong affordability covenants.