Programs Support Energy-Efficient Modular and Manufactured Housing

Programs Support Energy-Efficient Modular and Manufactured Housing

Highlights

• Efficiency Vermont provides technical and financial assistance to replace aging manufactured homes with Zero Energy Modular homes, which offer energy-efficient features to maintain long-term affordability and comfort.
• The state of Oregon funds loans to nonprofit organizations and individual homeowners striving to preserve manufactured home parks and replace older manufactured homes with new, energy-efficient ones.
• Both Vermont and Oregon have passed resident purchase laws that require advance notice from park owners before the sale of a manufactured home park, giving residents the opportunity to form cooperatives to facilitate the financing process.

Modular and manufactured homes offer low-income families an affordable alternative to traditional site-built housing. For many households looking to purchase a manufactured home, however, financing can be a significant obstacle. High energy costs reduce affordability for many existing residents of older units, whereas others have lost their homes because of the rising cost of leasing the land or a decision to close a manufactured home park. Some states are addressing these challenges through programs that offer prospective and current manufactured housing residents financial assistance and energy-efficiency upgrades. Efficiency Vermont and its partners help low-income homebuyers purchase and move into Zero Energy Modular (ZEM) homes, which offer highly durable features to maintain efficiency and comfort. Oregon Housing and Community Services and the state legislature have developed several initiatives, such as funding for weatherization programs and the replacement of old manufactured housing units as well as legislation for preserving manufactured home parks.

Zero Energy Modular Housing in Vermont

Manufactured homes make up about 7.2 percent of residential housing units in Vermont, with more than one-third of these located in manufactured home parks. As of November 2019, the state had 238 manufactured home parks, many of which were built more than 40 years ago; some have closed due to water or septic problems, flooding, sale of the property, or new development on the land.1 According to a 2011 survey, more than 70 percent of Vermont households living in manufactured home parks were low-income, very low-income, or extremely low-income households as defined by HUD. Furthermore, 26 percent of households had at least one child under the age of 18, and 37 percent of households had at least one person over age 65. Households with health conditions or disabilities made up 41 percent of those surveyed. Manufactured homeowners in Vermont spend 66 percent more of their income on energy costs than do owners of traditional site-built homes in the state, largely because of the age and inefficiency of the homes.2

Modular homes are built inside a factory and transported using flatbed trailers and cranes for installation on a permanent foundation. Photo Courtesy of USDA Rural Development

In 2011, Tropical Storm Irene caused widespread damage to the state’s housing stock. Although manufactured homes represent only 7 percent of Vermont’s housing stock, they made up 15 percent of the homes damaged in the storm.3 Public sentiment already favored making more affordable housing options available to low- to moderate-income Vermonters. The devastation from Tropical Storm Irene, however, “revealed more dramatically how little resiliency there was” in manufactured housing, according to Phoebe Howe, program manager at Efficiency Vermont, and was the catalyst for creating the ZEM pilot program as a more durable solution.4

In the wake of Tropical Storm Irene, Efficiency Vermont — a statewide energy-efficiency utility created by the Vermont General Assembly and the Vermont Public Utility Commission — and the Vermont Housing and Conservation Board (VHCB) initiated the Modular Housing Innovation Project (MHIP).5 According to Howe, MHIP was a working group to devise high-quality housing options for low- and moderate-income Vermonters.6 The 10-home ZEM pilot resulted from the working group discussions.7 In 2013, VHCB received a $90,000 grant from the High Meadows Fund to build and site the first ZEM home, which was unveiled and marketed at a fall 2013 press conference at Vermod Homes — the first company to build ZEM homes.8 On the first day of the conference, more than 100 visitors toured the model home.9 Housing advocates and representatives from nonprofit organizations who toured the model learned about the benefits of ZEM homes.10 Efficiency Vermont partnered with local affordable housing organizations to find interested buyers for the 10 pilot homes.11

Constructing ZEM homes inside the Vermod factory reduces weather-related delays and provides stable working conditions for employees. Photo Courtesy of Efficiency Vermont

ZEM homes meet Efficiency Vermont’s High Performance Homes standard, which sets requirements for durability, insulation, airtightness, and water and energy efficiency.12 Every home is customized to the needs and wishes of buyers, and all models have the same level of energy efficiency as an all-electric home built to identical specifications regardless of budget.13 The roofs have insulation values of R60, which translates into better thermal performance. For an uninsulated attic, the U.S. Department of Energy and the U.S. Environmental Protection Agency recommend R-values of between 49 and 60 for homes in the colder climates of Zones 5 to 8, and Vermont is in Zone 6.14 ZEM homes also feature rooftop solar panels to help reduce energy costs and triple-paned windows to prevent drafts and increase comfort. The double 2-by-4-foot walls use more than twice the blown fiberglass insulation found in a typical manufactured home, keeping the homes warm in the winter and cool in the summer.15 In addition, optional backup batteries help ZEM residents manage power outages during heavy snowfall, ice storms, high winds, and other severe weather events.16 ENERGY STAR®-certified lighting and appliances and water conserving features maintain energy and resource efficiency. The homes also have cold climate heat pumps and a fresh air ventilation system that provide heating, cooling, and optimal indoor air quality, reducing pollutants that cause allergies and asthma.17 An average two- to three-bedroom ZEM home ranges from 800 to 1,200 square feet.18 The homes can also accommodate porches and decks and can comply with Americans with Disabilities Act requirements by adding wheelchair-accessible ramps.19

To date, all ZEM homes delivered in Vermont have been constructed at the Vermod Homes factory in Wilder, Vermont. Vermod Homes is the only partner builder of ZEM homes in Vermont, although other builders and initiatives are starting in other parts of the country. Howe noted that other modular builders in Vermont and elsewhere in the northeast region are also capable of building to ZEM standards. Efficiency Vermont is collaborating with two of these builders to meet ZEM specifications while maintaining affordability standards in the hope that they will become ZEM partner builders.20 Efficiency Vermont provides residents needing to replace older manufactured homes with technical assistance and financial support through referrals for homebuyer education, incentives, and financing; advocacy for homeowners negotiating with lenders, manufactured home park owners, and builders; and training and ongoing support for homeowners during the move-in process and the first few months in the new home.21 According to Howe, the typical cost per square foot for a ZEM home of 800 to 1,200 square feet is approximately $170 inclusive of the home, finishes, and appliances. The total cost of an average project, including the site work, solar panels, sales tax, foundation, truck delivery, and foundation placement, ranges from $150,000 to $250,000 for a basic home aimed at low- to moderate-income buyers. This figure also includes all energy production for the ZEM home annually, Howe noted.22 According to the 2013 to 2017 American Community Survey 5-Year Estimates, the state’s median home value is $220,600, and Efficiency Vermont estimates that households pay an average of $3,200 annually in energy costs.23 Efficiency Vermont works with other affordable housing partners to help homebuyers access subsidies, incentives, and low-interest financing to bring down the overall cost and create manageable monthly mortgage payments.24

One of the financing sources available to buyers interested in purchasing a ZEM home in a manufactured home park or replacing an old manufactured home on owned land with a new one is the Manufactured Housing Down Payment Loan Program. Champlain Housing Trust, a community land trust, manages the loan program. The maximum loan amount is $35,000 with zero interest and no payments until the home is sold. To be eligible for the program, participants must meet several criteria. A borrower’s monthly income must be less than 120 percent of the area median income. Borrowers must contribute a minimum of $2,500 toward closing costs on their first mortgage. Because the program is a second mortgage, residents must qualify for a first mortgage to cover the balance of the purchase and site costs. Residents must prove that they have successfully completed a homebuyer education course. The new home must be located on a permanent foundation in a park that is not in a Federal Emergency Management Agency Special Flood Hazard Area, and it must be the borrower’s primary residence.25 In addition, the U.S. Department of Agriculture (USDA) Rural Development’s Direct Loan program delivers financing through 30-year first mortgages with interest rates of 1 to 3 percent.26

Achieving Positive Results

As of October 2019, Vermont had nearly 100 ZEM homes. More than 50 percent of these homes are in manufactured home parks, cooperatives, or multifamily communities, with the remaining homes on private land. More than 60 percent of ZEM homes are owner occupied, with the balance being affordable rental homes. Collectively, ZEM residents have saved an estimated $1 million in heating and electric costs.27 Although the homes are designed to produce as much electricity as they need each year and draw on net-metering credits during Vermont’s cold, snowy winters, Efficiency Vermont estimated that owners of ZEM homes would spend approximately $180 per year in utility charges to be connected to the power grid.28 Howe observed that several outreach tactics to attract interest have been effective, including word-of-mouth recommendations. Efficiency Vermont maintains a model home that is transported to community events to increase visibility. People can tour the model, familiarize themselves with the features of ZEM homes and learn strategies to weatherize their own homes, said Howe.29

In 2017, researchers at the University of Vermont’s Center for Rural Studies interviewed 16 residents of ZEM homes. Most residents indicated that the air quality in their ZEM home was better than their previous home, and more than half said that their monthly costs were lower. Most residents expressed positive or very positive experiences with their homes’ energy-efficient features. The resident interviews indicated that residents purchased their home intending to stay for many years. Residents pointed to the high upfront cost for the purchase of a ZEM home as a weakness of the program, and many indicated that they would not have been able to afford a ZEM home without the subsidies.30 Residents identified the opportunities that ZEM homes can have in Vermont, a state with an aging housing stock and a lack of affordable housing. ZEM homes may be attractive to first-time homebuyers, seniors, people with disabilities, and other homebuyers on fixed incomes. Howe noted that ZEM housing can also appeal to residents with various interests and needs, such as those seeking environmentally friendly housing, overall comfort during the cold winter months, or a healthy living environment for children with allergies and asthma.31

Tenant protection laws in Vermont and Oregon help maintain stability if a manufactured home park owner sells or closes a community. Photo Courtesy of Jacob Hannah for the New York Times

In Vermont, ZEM and non-ZEM residents of manufactured home parks have several options if a park owner decides to sell. Although most manufactured home parks are privately owned, 13 have converted to resident-owned cooperatives since 2011. A total of 17 parks are cooperatively owned, and 47 are owned by nonprofit housing development organizations.32 The Vermont General Assembly resident purchase law requires park owners to provide residents with 45 days’ notice before selling a manufactured home park. A majority of residents must express interest in purchasing the park within the 45-day advance notice period. During these 45 days, a park owner cannot accept a “final unconditional offer to purchase the park.”33 Arthur Hamlin, housing program coordinator for mobile home parks at the state’s Agency of Commerce and Community Development, indicated that park owners can continue to negotiate and draft private purchase and sale agreements as long as they do not sign anything. If residents exercise their right to purchase the park, the park owner must “negotiate in good faith” with the group or nonprofit that represents the residents. In 2012, the Vermont General Assembly updated the 1987 resident purchase law after considering feedback from cooperative and nonprofit buyers, who determined that the steps needed to develop a sale agreement exceeded 90 days. As a result, one of the major components of the 2012 law was an update extending the negotiating period to 120 days, which certainly can delay the private sale of a park.34 Although the community owner remains free to choose between the residents’ offer and the competing offer, good faith negotiation requires landlords to allow residents to develop their offer. The landlord is required to give it reasonable consideration and notify residents if an outside bidder submits a higher offer. Community owners who fail to comply are liable to homeowners in the amount of $10,000 or 50 percent of the gain realized from the sale of the community, whichever is greater.35

Opportunities

Although ZEM housing has been around since 2013, many opportunities have yet to be fully realized in the field. Howe noted that the lack of qualified contractors in the industry has constrained the production of ZEM houses.36 According to Kristen Connors, general manager at Vermod Homes, employees at all levels earn a competitive living wage, but many tradespeople are retiring, and few qualified and reliable applicants exist to replace them.37 One remedy, explained Howe, is to partner with trade schools and other workforce development groups to establish a pipeline for qualified tradespeople. ZEM housing can also be a great economic development tool for the state because it creates local business opportunities for green supply chains, manufacturers, and distributors. Howe emphasized that the work environment for ZEM builders is very stable, pointing out that the “job site is in the same location every day, [and] they have reliable hours and good working conditions.” Furthermore, constructing a ZEM house inside a factory eliminates weather-related delays.38

Families that replace older manufactured homes with ZEM homes, such as this one located in a nonprofit-owned park in Vergennes, Vermont, can customize them to include porches, decks, and wheelchair accessible ramps. Photo Courtesy of Efficiency Vermont

To make the adoption of ZEM housing more widespread, Howe suggested that developers should be involved in the construction of cluster ZEM communities, where homebuyers can purchase an existing ZEM home. Although building a ZEM home in the factory takes approximately six to seven weeks, the entire process to learn about ZEM, prequalify for loans, identify subsidies, select designs, and finalize paperwork can be complex for people who may also be juggling health issues, low incomes, and uncertainty about their current living arrangements. By constructing cluster ZEM communities with already-built ZEM homes, said Howe, developers can make ZEM homes more attainable because it is much easier to purchase “an existing home instead of having to figure it out from scratch.” Finally, Howe emphasized that ZEM housing lends itself to many creative uses, such as farmworker housing or transitional housing, that can benefit communities. The ultimate opportunity that ZEM offers, Howe suggested, is to revitalize manufactured home parks in Vermont and foster manufactured home replacement. Manufactured home parks offer many opportunities for “public investment in infrastructure and high-quality housing to be models of a true sustainable community.”39

Preserving Manufactured Housing in Oregon

The state of Oregon recognizes that manufactured homes are an important source of affordable housing. Representing more than 14 percent of the housing stock in the state, manufactured housing is a “critical naturally occurring affordable homeownership opportunity for Oregonians in communities large and small,” said Nicole Stoenner, legislative and communications coordinator at Oregon Housing and Community Services (OHCS), the state’s housing finance agency. Oregon has approximately 1,060 manufactured home parks, one-third of which are senior parks housing residents aged 55 and older.40 More than 55 percent of manufactured homes in Oregon were built before 1980.41 According to Energy Trust of Oregon, these older manufactured homes have several energy challenges: reduced insulation in the ceiling, walls, and floors; air leaks; and inefficient windows and heating systems. These issues lead to higher energy costs and health challenges, such as asthma, stemming from poor indoor air quality.42 Because so many homes have exceeded their life expectancy, the state has made the preservation and replacement of these units a high priority.43 OHCS has developed initiatives to replace these units. Several needs exist for this housing stock and its residents, such as obtaining energy assistance, preventing park closures and subsequent displacement of residents, and securing financing. OHCS and local Community Action Agencies (CAAs) offer Oregonians resources to address these needs.

Current Initiatives

OHCS administers Oregon’s Low-Income Weatherization Assistance Program. Primary funding for the program is from the U.S. Department of Energy’s Low-Income Home Energy Assistance Program, along with other funds from the U.S. Department of Health and Human Services, utility companies, and the Bonneville Power Administration. These resources are delivered through a network of CAAs that serve every county in Oregon. CAAs provide weatherization and energy conservation services at no cost to households earning incomes at or below 200 percent of the federal poverty level.44 Approximately half of all weatherization efforts are performed on manufactured homes — particularly older homes — with critical energy efficiency, health, and environmental concerns. The state also administers funds through the Energy Conservation Helping Oregonians (ECHO) program, which provides resources to Pacific Power and Portland General Electric residential customers for weatherization and updates to reduce energy burden while improving the health and financial stability of residents. To determine the feasibility of weatherizing a home rather than replacing it, CAAs first determine whether they have the financial resources to replace the home. If they do, CAAs then examine the overall livability of the home, “looking to see if there are health and safety concerns [and] energy-efficiency concerns,” explained Stoenner.45 According to Ken Pryor, program coordinator at OHCS, these programs overlap, and weatherization can encompass window and roof replacement, improved insulation, and a new furnace, for example.46 In 2017, these programs helped weatherize 670 units.47

Energy Trust of Oregon, in partnership with OHCS, Community and Shelter Assistance Corporation (CASA) of Oregon, NeighborWorks Umpqua, St. Vincent de Paul of Lane County, and regional CAAs, launched a pilot program to retire aging manufactured homes and replace them with new, energy-efficient manufactured homes that exceed code requirements. The pilot will identify qualified homes or parks, seek additional funding opportunities and partners, and monitor the impact of retiring and replacing older (pre-1995) manufactured homes with new, energy-efficient models. Energy Trust of Oregon is offering participants up to $15,000. In addition, OHCS is allowing participating pilot CAAs to use up to $20,000 of ECHO program funds to support the replacement and decommissioning work. Evaluation activities will help the state understand the energy and nonenergy benefits achieved from the replacement homes, needed financial resources of the market, and the qualitative benefits and challenges of replacing the homes.48

The Oregon Legislative Assembly passed House Bill 2896, effective September 2019, which allocates $9.5 million to OHCS to provide loans to nonprofit corporations to establish preservation programs for manufactured home parks. The law also allocates $2.5 million to the Manufactured Home Preservation Fund, which provides loans of up to $35,000 per individual homeowner to replace older, inefficient manufactured homes with energy-efficient ones that meet OHCS standards. The Manufactured Home Preservation Fund also helps families decommission and dispose of a manufactured dwelling and will help finance advisory board initiatives such as annual evaluations. To qualify for loans, households must have an income that does not exceed 100 percent of the statewide or local area median income, whichever is greater; purchase a home that meets energy-efficiency standards as prescribed by OHCS; and agree to site the unit in a park that is registered with OHCS’ Manufactured Communities Resource Center (MCRC) and either has currently entered into a regulatory agreement or is negotiating one with OHCS. OHCS will administer a grant program funded from $3 million deposited in the Manufactured Dwelling Park Account aimed at people who need to decommission and dispose of a manufactured dwelling. OHCS recently established an advisory committee, required under House Bill 2896, that includes representatives from relevant state and local agencies; HUD; USDA Rural Development; park owners; park residents; lenders; and nonprofit organizations such as Craft3, St. Vincent de Paul of Lane County, and the Network for Oregon Affordable Housing that offer loan programs, financial counseling, and homebuyer education. The advisory committee will develop strategies to preserve manufactured home parks as affordable housing; propose solutions to mitigate barriers that hinder the development of parks; identify strategies to fund, preserve, and improve park infrastructure; establish equitable financing sources for purchasing manufactured dwellings; develop services to help homeowners weatherize existing manufactured dwellings; promote homebuyer education; and annually evaluate the progress of the committee and state agencies.49

Fostering Positive Outcomes

Land values in Oregon have been increasing, encouraging landowners to sell and risking the closure of manufactured home parks to make way for new development. Between 1997 and 2008, 65 manufactured home parks closed in Oregon. In 2007, however, the state passed Residential Landlord and Tenant legislation to protect homeowners in the event of a closure, and since 2014, only 3 of the state’s roughly 1,060 parks have closed.50 The legislation requires park owners to give tenants no less than one year’s notice before the park’s closure. Owners are required to compensate tenants $6,000, $8,000, or $10,000 for a single-wide, double-wide, or triple-wide home, respectively. Landlords are also required to notify tenants of eligibility criteria and application information for a tax credit as well as information on how to appeal property tax assessments on their manufactured homes.51 Pryor noted that the one-year notification requirement for park closures gives residents time to meet with CAAs to attend job fairs and employment training, determine new schools for their children to attend, and identify transportation needs.52

The Oregon Legislative Assembly created MCRC in 1989 to provide services and information to residents and landlords of manufactured housing parks, develop positive working relationships, implement a referral program to encourage voluntary dispute resolution, and maintain a directory of manufactured home parks. MCRC monitors the park closure notification process and offers counseling and service referrals to residents. MCRC collaborates with OHCS’ park preservation program to encourage resident ownership of parks that might otherwise close.53 OHCS has funded 22 preservation efforts through the cooperative and nonprofit model. MCRC is funded through an annual assessment of $10 for each manufactured home on rented or leased land and an annual park registration fee of $50 or $100, for landlords of parks with 20 or fewer lots and parks with more than 20 lots, respectively.54 MCRC is also part of the tenant relocation team that helps residents navigate park closures, access service referrals, and understand their rights and responsibilities and the availability of services.55 CAAs also assist residents by helping them access rapid rehousing, rent assistance, and voucher waiting lists.56

In 2014, the Oregon Legislative Assembly approved changes to the Residential Landlord and Tenant Act requiring the owner of a manufactured home park to give written notice of interest in selling the park before marketing it for sale or upon receipt of an offer. Owners must give this notice to all tenants or a tenants committee as well as the Office of Manufactured Dwelling Park Community Relations of OHCS. Within 10 days after receiving this notice, tenants choosing to purchase the park must notify the owner in writing to express their interest, indicate that they have formed a single tenants committee, and provide a representative’s contact information.57 During this 10-day period, a representative of the tenants committee can issue a written request for financial information that a park’s seller customarily provides to a prospective purchaser, which the owner must supply within 7 days. If the owner fails to comply, tenants can restrict the landowner from selling the park or transferring it to another entity.58 Once the tenants committee submits an offer, the owner can accept or reject the offer or submit a counteroffer. Although park owners were initially opposed to some of these requirements, concessions from both park owners and tenants eventually led to the passage of the legislation.59

For tenants interested in purchasing their manufactured home parks, CASA will also appraise the property and interview residents to determine how much they can afford to pay.60 CASA helps manufactured homeowners attain the financing and technical assistance needed to purchase their communities, and it operates the Manufactured Housing Cooperative Development Center, which is one of nine certified technical assistance providers under the national ROC USA network. To date, CASA’s loan fund has provided resident cooperatives with more than $3.8 million in park purchase financing and more than $250,000 in predevelopment financing.61

Challenges and Lessons

Stoenner emphasized the need for more resources to assist manufactured housing residents. She indicated, for example, that the waiting list to get homes weatherized is long. Personal property loans commonly used to purchase manufactured homes often come with higher interest rates and shorter repayment periods than traditional mortgages, making state and nonprofit loan programs a vital source of financing. Financing remains a critical need, particularly in rural areas, where manufactured homes make up a substantial portion of the housing stock. In addition, as Pryor mentioned, residents attempting to purchase their manufactured home park may be outbid by private-market buyers who present an all-cash offer. Despite these challenges, however, OHCS is committed to serving this population, which is more likely to be over age 75, receive Supplemental Nutrition Assistance Program benefits, and earn an annual median income of approximately $35,000. The state recognizes that manufactured housing is a vital source of affordable housing, and improvements in manufactured housing and financing mechanisms can make homeownership and housing stability a reality for vulnerable groups, said Stoenner.62

Conclusion

Implementing strategies to finance, preserve, and construct energy-efficient modular and manufactured homes is essential to ensuring that this type of housing gains traction in the marketplace. Programs such as Efficiency Vermont’s ZEM housing initiative can help factory-built homes remain a viable, affordable housing option for low-income families. According to Howe, recognizing the “power of partnerships” is critical for other communities wishing to implement similar initiatives. ZEM housing would not have been possible without partner organizations to manage financing, homebuyer education, construction, and public outreach.63 Although Oregon’s MCRC has been around for more than 25 years, the passage of House Bill 2896 has made manufactured housing a newer priority for OHCS. The new advisory group will be essential for leading discussion and evaluating progress toward manufactured housing goals.64 Assessing current needs, harnessing existing resources, and cross-sector collaboration are important steps when determining how to scale up factory-built housing and ensure long-term benefits.

Related Information:

Next Step’s SmartMH Program

1. State of Vermont Agency of Commerce and Community Development. "Mobile Home Facts and Park Registry" (accd.vermont.gov/housing/mobile-home-parks/registry). Accessed 7 August 2019.
2. VEIC. "Zero Energy ModularSM Homes Offer Comfort, Affordability to All" (www.veic.org/our-results/success-stories/zero-energy-modular-homes-offer-comfort-affordability-to-all). Accessed 10 April 2019; University of Vermont. 2012. "Vermont Mobile Home Parks: Resident Demographics."
3. VEIC.
4. Interview with Phoebe Howe, 27 September 2019.
5. Efficiency Vermont. "Our History" (www.efficiencyvermont.com/about/history). Accessed 26 August 2019; Interview with Phoebe Howe.
6. Interview with Phoebe Howe.
7. Ibid; Email correspondence with Phoebe Howe, 18 October 2019.
8. Charlotte Albright. 2013. "Weather-Resistant Modular House Unveiled in White River Junction"; High Meadows Fund. "2013 Grants Listed Alphabetically by Organization" (www.highmeadowsfund.org/2013-grantmaking). Accessed 23 October 2019.
9. Peter Schneider. 2013. "The mobile home of tomorrow: Vermont leads the way."
10. Albright.
11. Email correspondence with Phoebe Howe, 18 October 2019.
12. Phoebe Howe. 2018. "Efficiency Vermont Zero Energy Modular Initiative"; Schneider.
13. Interview with Phoebe Howe.
14. Ibid; "Recommended Home Insulation R– Values," Energy Star website (www.energystar.gov/index.cfm?c=home_sealing.hm_improvement_insulation_table). Accessed 18 October 2019.
15. Efficiency Vermont. 2016. "Comfort, quality and long-term affordability that sets the stage for your future"; Vermont Housing and Conservation Board. "Zero Energy Modular Construction Details & Financing Options" (vhcb.org/zero-energy-modular-construction-details-financing-options). Accessed 21 August 2019; VEIC.
16. Email correspondence with Phoebe Howe, 23 October 2019.
17. Schneider; Efficiency Vermont 2016.
18. Interview with Phoebe Howe.
19. Schneider.
20. Interview with Phoebe Howe.
21. "Efficiency Vermont ZEM Program," VERMOD Homes website (vermodhomes.com/efficiency-vermont-zem-program/). Accessed 10 April 2019.
22. Interview with Phoebe Howe.
23. U.S. Census Bureau. "Selected Housing Characteristics: 2013-2017 American Community Survey 5-Year Estimates" (data.census.gov). Accessed 4 September 2019; Justine Sears and Kelly Lucci. 2019. "Vermont Energy Burden Report," Efficiency Vermont, 6.
24. Interview with Phoebe Howe.
25. Champlain Housing Trust. "Manufactured Housing Down Payment Loan Program" (www.getahome.org/loans/manufactured-housing-down-payment-loan-program). Accessed 13 November 2019; Interview with Phoebe Howe; Champlain Housing Trust. n.d. "Quick Reference Guide and Consumer Privacy Policy"; Champlain Housing Trust. "About Us" (www.getahome.org/about-us). Accessed 13 November 2019
26. Interview with Phoebe Howe.
27. "ZEM impact: 2013-August 2019," Document provided by Phoebe Howe; Interview with Phoebe Howe.
28. Megan Roush. 2015. "USDA housing chief: New, long-term affordable mortgages available for mobile home park residents," 30 June press release.
29. Interview with Phoebe Howe.
30. Jane Kolondinsky, Dan Baker, Erin Roche, Orest Pazuniak, Jini Kades. 2017. "Assessment of the market for energy-efficient factory-built homes sold in Vermont," Center for Rural Studies at the University of Vermont, 6–7; 16–8; 25.
31. Interview with Phoebe Howe.
32. State of Vermont Agency of Commerce and Community Development. "Mobile Home Facts and Park Registry" (accd.vermont.gov/housing/mobile-home-parks/registry). Accessed 7 August 2019.
33. Vermont General Assembly. 2012. Title 10: Conservation and Development Chapter 153: Mobile Home Parks. § 6242. Mobile home owners' right to notification prior to park sale; Vermont General Assembly. 2011–2012 Session. "Acts Affecting Vermont Statutes."
34. Ibid; Email correspondence with Phoebe Howe, 7 February 2020.
35. Vermont General Assembly 2012; Vermont General Assembly 2011–2012 Session.
36. Interview with Phoebe Howe.
37. Email correspondence with Phoebe Howe, 7 February 2020.
38. Interview with Phoebe Howe.
39. Ibid.
40. Joint interview with Nicole R. Stoenner and Ken Pryor, 2 October 2019.
41. Oregon Housing and Community Services. 2016a. "Manufactured Home Park Solutions Collaborative Local Agency Toolkit," 8.
42. Energy Trust of Oregon. 2017. "Energy Trust of Oregon Manufactured Home Replacement Pilot"; Shelley Beaulieu, Alexandra Buylova, Mitchell Hannoosh, and Peter Schaffer. 2018. "Ten-Year Plan: Reducing the Energy Burden in Oregon Affordable Housing," 4.
43. Claire Seguin. 2019. "Oregon Sets an Example for Preserving, Repairing and Replacing Manufactured Housing."
44. Oregon Housing and Community Services. 2018. "Low-Income Home Energy Assistance Program"; Joint interview with Nicole R. Stoenner and Ken Pryor.
45. Joint interview with Nicole R. Stoenner and Ken Pryor.
46. Ibid.
47. Seguin.
48. Beaulieu et al., 34–5; Joint interview with Nicole R. Stoenner and Ken Pryor.
49. Oregon Legislative Assembly. 2019. House Bill 2896. An Act Relating to manufactured dwellings; creating new provisions; amending ORS 90.840, 90.849, 456.579 and 456.581; and prescribing an effective date; Joint interview with Nicole R. Stoenner and Ken Pryor.
50. Joint interview with Nicole R. Stoenner and Ken Pryor; Oregon Housing and Community Services. "Manufactured Home Park Closures in Oregon" (www.oregon.gov/ohcs/Pages/manufactured-dwelling-park-closures-oregon.aspx). Accessed 7 October 2019; Oregon Housing and Community Services. "Oregon Manufactured Dwelling Parks Closure Information" (o.hcs.state.or.us/MDPCRParks/ClosedParks.jsp). Accessed 7 October 2019.
51. Oregon Housing and Community Services. "Manufactured Home Park Closures in Oregon"; Oregon State Legislature. 2017. Title 10 Property Rights and Transactions. Chapter 90 — Residential Landlord and Tenant. 90.645 Closure of manufactured dwelling park; notices; payments to tenants; rules; 90.650 Notice of taxprovisions to tenants of closing manufactured dwelling park; rules.
52. Joint interview with Nicole R. Stoenner and Ken Pryor.
53. Oregon Housing and Community Services. 2016b. "Manufactured Communities Resource Center (MCRC) Overview."
54. Joint interview with Nicole R. Stoenner and Ken Pryor.
55. Oregon Housing and Community Services 2016a, 23.
56. Joint Interview with Nicole R. Stoenner and Ken Pryor.
57. Oregon State Legislature. 2017. Title 10 Property Rights and Transactions. Chapter 90 — Residential Landlord and Tenant. 90.842 Notice of sale of manufactured dwelling park; contents; formation of tenants committee for purchasing park.
58. Ibid.
59. Oregon Park Owners Alliance. 2014. "HB 4038-3: Clarifying and substantive amendments are necessary"; Brian Johnson, Johnson Mobile Estates. 2014. "Witness Testimony," Senate Committee on General Government, Consumer & Small Business Protection; Amber Monte, Owner of Country Estates in Grants Pass & Columbus Greens in Albany. 2014. "Witness Testimony," Senate Committee on General Government, Consumer & Small Business Protection; John VanLandingham, Lane County Legal Aid & Advocacy Center. 2014. "Comparison of Current Law with HB 4038A."
60. Joint interview with Nicole R. Stoenner and Ken Pryor.
61. CASA of Oregon. "Promoting affordable home ownership through the creation of resident-owned, manufactured housing communities" (www.casaoforegon.org/for-individual/manufactured-housing-cooperative-development/). Accessed 25 September 2019.
62. Joint Interview with Nicole R. Stoenner and Ken Pryor.
63. Interview with Phoebe Howe.
64. Joint Interview with Nicole R. Stoenner and Ken Pryor.

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