Manufactured Home Park Bill of Rights

Baseline standards for habitability, affordability, and fair treatment in every Erie County park

In March 2026 I held a listening session in Evans for residents of our manufactured home parks, co-hosted with the Manufactured Housing Alliance of New York (MHANY). What residents told me that night became this proposal, developed in partnership with MHANY: a countywide Bill of Rights that sets minimum, enforceable standards for every park in Erie County. It is a framework, meant to be refined with residents, resident associations, and MHANY before it is adopted. Here it is in full.

Executive Summary

Manufactured home parks are an important source of naturally occurring affordable housing in Erie County. The county has 53 active manufactured home parks in the state Health Department’s inspection records, but only 38 parks in the county registered with the state in 2025. Those 38 alone reported 4,495 occupied lots. Across New York State there are 192,890 manufactured housing units, and in rural areas they make up 10.3% of all housing. In these communities, residents typically own their homes but rent the land beneath them, creating a unique vulnerability to rising costs, deferred maintenance, and retaliation when concerns are raised.

The number of manufactured home communities in New York fell 12% between 1989 and 2019, and Western New York lost 15%, among the steepest declines in the state. As communities disappear and costs rise, the residents who remain face growing instability with fewer protections.

State inspections in 2019 found that more than one-third of parks had at least one recorded violation, with home conditions and infrastructure conditions the most common issues identified. In the Health Department’s current records, 21 of Erie County’s 53 active parks had at least one violation at their last inspection. Yet the biggest barrier to accountability is not the absence of law. It is the absence of enforcement.

MHANY, which co-developed this framework, documents what residents confirmed at our March 2026 listening session: tenants regularly face rising rents and water, sewer, and tree issues, alongside fear of eviction or retaliation for speaking up. That fear is the enforcement gap this Bill of Rights is designed to close.

This proposal establishes minimum, enforceable standards across Erie County without preempting stronger local laws.

Purpose and Scope

Purpose: To protect resident health, safety, affordability, and basic rights while providing clarity and consistency for responsible park owners and municipalities.

Scope:

  • Establishes countywide baseline standards, not ceilings
  • Applies to manufactured home parks where residents rent lots
  • Preserves municipal authority to adopt stronger protections
  • Positions the county as a backstop and coordinator, not a replacement for towns

The proposed Bill of Rights is grounded in Erie County’s existing authority related to public health and environmental health; safety and emergency access; consumer protection and disclosure; and housing stability and code enforcement coordination. The county already has a foothold: the Erie County Department of Health is the inspecting agency for all 53 active parks in the county under Part 17 of the State Sanitary Code.

Manufactured home parks present a distinct housing dynamic because of high relocation costs and captive tenancy. Residents who own their homes but rent the land beneath them carry the costs of owning and the insecurity of renting at the same time, and moving a home is expensive enough that leaving is rarely a real option.

Relationship to state law: MHANY is actively working to strengthen New York Real Property Law Section 233 and close loopholes that park owners currently exploit. The Rural Housing Coalition has identified New York’s opportunity-to-purchase law as nearly ineffective in its current form, because it only applies when a park is being converted to another use, precisely when prices are highest and residents are least able to act. This Bill of Rights is designed to complement those state-level reforms, not substitute for them. Where state law establishes resident rights, this framework focuses on consistent local enforcement and implementation. Nothing here limits, weakens, or preempts state-level protections.

Section I: Resident Rights

1. Right to Habitability and Safety

Grounded in: state Health Department inspection data showing infrastructure and home conditions as top violation categories; resident accounts of collapsed culverts, dangerous trees, and inaccessible driveways.

Residents have the right to safe and reliable water, sewer or septic, and utility service; maintained internal roads, drainage, lighting, and snow removal; fire safety compliance and emergency vehicle access; proactive tree and grounds maintenance; winter safety, including driveway access and culvert maintenance; and sanitary conditions, including trash removal and pest control.

2. Right to Transparency

Grounded in: MHANY documentation of unexplained rent increases, billing irregularities, and fees not disclosed in leases; resident accounts of 6% increases when the standard cap in Real Property Law Section 233-b is 3%.

Residents have the right to clear, plain-language disclosure of all fees and charges; annual notice of any changes to fees or rules; written justification for any rent increase; itemized billing for utilities; and access to leases, park rules, and complaint procedures.

3. Right to Affordability and Stability

Grounded in: MHANY’s identification of predatory real estate investment practices driving up costs; resident accounts of lot rent doubling over time with no explanation, and of increases above the 3% cap without the documented costs the law requires.

Residents have the right to advance notice of rent increases; written justification tied to documented costs; protection from sudden or excessive cost shocks; and freedom from junk fees, including tag fees, collection fees, carport damage charges, and improvement fees, that were not disclosed in the original lease.

4. Right to Proactive Maintenance

Grounded in: resident accounts of reactive-only maintenance; dead trees left standing; water lines damaged by unlicensed workers; landscaping left unrepaired, enabling animal intrusion; street lights unaddressed for over a year.

Park owners must maintain all infrastructure, grounds, and common areas proactively, not reactively. Responding to damage after it occurs does not satisfy this obligation. Owners are responsible for hiring licensed contractors for repair work and ensuring all work meets applicable codes.

5. Right to Organize

Grounded in: MHANY’s core mission of turning individual voices into collective power; resident fear of retaliation documented by MHANY.

Residents have the right to form associations and meet without interference; communicate with one another and with outside advocates, including MHANY; and engage in collective problem-solving without fear of retaliation.

6. Protection from Retaliation

Grounded in: MHANY documentation that fear of eviction is the single greatest barrier to residents speaking up; consistent resident accounts at the March 2026 listening session.

Residents may not be penalized for reporting health or safety concerns; requesting repairs; participating in resident associations; cooperating with inspections or enforcement; or contacting county, state, or advocacy organizations about conditions in their park.

Section II: Owner Responsibilities

Grounded in: state Health Department inspection findings that infrastructure and home conditions are leading violation categories; resident accounts of owners shifting responsibility for damage onto residents.

Park owners are responsible for maintaining infrastructure and common areas in safe, functional condition; responding to maintenance issues within defined timeframes; providing accurate and complete fee disclosures; ensuring utility billing is transparent, itemized, and reasonable; allowing inspections and cooperating with enforcement; hiring licensed contractors for all repair and maintenance work; and following their own lease and park rules consistently and without selective enforcement.

Owners are bound by the same rules they enforce on residents.

Section III: Fee and Rent Guardrails

Grounded in: resident accounts of unexplained increases, of 6% increases above the 3% cap in Real Property Law Section 233-b, and of fees with no basis in any lease; MHANY documentation of predatory fee practices.

This framework does not impose blanket rent control. Instead it establishes reasonable stability measures, including minimum notice periods for rent increases; required written justification tied to documented costs; automatic review triggers when increases coincide with unresolved habitability violations; prohibition of fees not disclosed in the original lease; standardized limits on non-rent fees; and transparency and dispute resolution mechanisms.

Section IV: Sale, Closure, and Redevelopment Protections

Grounded in: the Rural Housing Coalition finding that New York’s opportunity-to-purchase law is nearly ineffective; the 12% statewide decline in manufactured home communities between 1989 and 2019; Western New York’s 15% decline.

When manufactured home parks are sold, closed, or redeveloped, residents must receive extended notice; good-faith engagement with resident associations is required; relocation assistance or mitigation planning must be addressed; residents must be given a meaningful opportunity to organize a purchase; and county oversight ensures transitions do not create housing emergencies.

Section V: Enforcement and Accountability

County role:

  • Centralized complaint intake and tracking
  • Baseline inspection standards
  • Coordination with town code enforcement and health departments
  • Escalation for repeat or serious violations

Enforcement tools:

  • Corrective action plans
  • Civil penalties for persistent noncompliance
  • Mediation as an option, not a substitute for enforcement
  • Public reporting on compliance trends

Section VI: Registration, Complaint, and Escalating Enforcement

Grounded in: Colorado’s 2019 Mobile Home Park Act Oversight law, which created a state program to register parks, take complaints, investigate, and impose penalties; the Rural Housing Coalition finding that since the state Department of Taxation and Finance took over park registration in 2020, the number of registered parks has fallen from 1,800 to 1,200.

Park Registration

All manufactured home parks operating in Erie County must register annually with the county. Registration requires current ownership and management contact information; the total number of lots and current occupancy; a copy of the standard lease and all park rules; a complete fee schedule; certification of compliance with habitability standards; and disclosure of any outstanding violations or complaints.

Registration is public record. A searchable database of registered parks, compliance history, and outstanding violations will be maintained on the Erie County website. Failure to register is itself a violation subject to penalty.

Required Posting and Distribution of Rights

Every registered park must post a plain-language Notice of Resident Rights in a common area; provide a copy to every resident at lease signing and annual renewal; and include the county complaint intake number and process with every rent increase or fee change notice. The county produces the Notice. Owners are responsible for posting and delivery.

Complaint Intake

Residents may file complaints with the county by phone, online, or in person. The county assigns a case number, notifies the resident within five business days, and forwards the complaint to the park owner with a required response deadline.

Escalating Enforcement Timeline

  • Days 1 to 15: owner notified, response required
  • Days 15 to 30: corrective action plan due
  • Day 30: if unresolved, initial civil fine issued
  • Days 30 to 60: fine doubles every 15 days while unresolved
  • Day 60 and after: referral to the county attorney; potential registration suspension

During an open complaint, the owner may not increase rent or fees connected to the disputed issue, enforce new rules against the complaining resident, or take any action that could constitute retaliation.

Penalty Structure

  • Notice failures and fee disclosure violations: $250 to $500 per occurrence
  • Habitability violations: $500 to $2,500 per occurrence
  • Retaliation against a resident: $1,000 to $5,000 per occurrence
  • Repeat violations within 24 months: doubled penalties
  • Penalties fund the county complaint and enforcement program

Repeat Violator Designation

Parks with three or more substantiated violations within 24 months are designated Repeat Violators. The designation is published in the public compliance database, triggers mandatory county inspection, and may result in registration suspension pending a compliance hearing.

Implementation Timeline

Phase 1: Habitability standards, transparency, anti-retaliation protections, park registration, complaint intake

Phase 2: Fee standards, rent increase guardrails, billing protections, escalating enforcement

Phase 3: Sale and closure protections, long-term housing stability measures, alignment with state reforms to Real Property Law Section 233

Resident associations and MHANY will be engaged throughout implementation and review.

What This Bill of Rights Does Not Do

  • Does not override stronger municipal laws
  • Does not impose blanket rent control
  • Does not penalize responsible owners without due process
  • Does not interfere with routine park operations
  • Does not replace or duplicate state enforcement. It complements it.

Conclusion

Erie County has 53 active manufactured home parks, and only 38 registered with the state in 2025. In 2019, more than one-third of New York’s parks had a recorded violation. The number of communities is declining, costs are rising, and residents have nowhere to turn when the system fails them.

The Countywide Manufactured Home Park Bill of Rights closes that gap. It is a practical, enforceable framework built on what residents said at the table, grounded in statewide research, and developed in partnership with MHANY, the organization that has been fighting for these protections across New York.

This document is presented as a resident-informed framework, intended to be refined in partnership with manufactured home park residents, MHANY, and resident associations before formal adoption.

County government should fill gaps, not create them.

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