Abstract
Abstract
Existing evidence regarding drinking water access and environmental service access more broadly suggests that service provision is substandard in mobile home parks (MHPs). Insufficient water access conditions are particularly troubling given that a substantial proportion of the population resides in MHPs. There have been few targeted studies on environmental service conditions, much less water access conditions within parks. To address this paucity in the literature, we combine a range of data sources to provide the richest analysis to date of water access across a substantive sample of MHPs. We find that the state's MHPs are no less likely to be served by publicly regulated community water systems than other types of housing settlements, but that MHP systems are much more likely to be small, a characteristic well documented to diminish access. In fact, MHP systems represent 13% of all state systems, despite parks housing around 3% of the state's population. We then evaluate drinking water service to MHP systems by the stated dimensions of California's Human Right to Water. Water access disparities identified in a content analysis of 1300 news stories allow us to qualitatively illustrate the severity of substandard access—quality, reliability, and affordability—in parks. These findings are supported by an analysis of state-level data from a range of administrative sources. MHP systems are more likely to incur more health-related violations than other systems. They are also four times more likely to experience a significant service shutoff and 40% more likely to rely on groundwater. The evidence on affordability is less conclusive.
Introduction
I
Parks are primarily composed of households that are not only more ethnically diverse but also poorer and have lower levels of formal education than the general population. 4 The effect of implicit or overt racial or ethnic discrimination on water provision has been documented in rural and semirural communities across the United States, similar to and sometimes including MHPs. 5 We also know that small water systems, which are more likely to serve as MHPs, tend to perform worse than larger systems in terms of quality and reliability. 6 The targeted literature assessing drinking water service to residents of mobile homes is very limited, but suggestive. We have previously demonstrated that there is a higher propensity of quality violations made by water systems that exclusively serve MHPs in Los Angeles County 7 and that mobile home residents across the United States experience a higher proportion of water access shutoffs, even after controlling for socioeconomic factors and spatial marginality 8 . MHPs are also singled out in several policy reports identifying the worst-performing public water systems in California and Texas. 9 Otherwise, however, there has been little study of the topic.
While evidence from the gray literature and studies of water access among similar populations suggests that water service in parks is likely to be substandard compared to the general population, much less the standards outlined in the state's legislated Human Right to Water, it is far from conclusive. Accordingly, in this study we use a range of qualitative and quantitative data sources to provide the richest profile of water access in MHPs to date. Contrary to expectations, we find that MHPs in California are as likely to be served by publicly regulated community water systems as other types of housing settlements, suggesting that deficiencies in service must be viewed as a public sector problem. We next show that MHPs are much more likely to be served by small systems than medium or larger sized systems. In fact, MHP systems represent 13% of all state systems, despite parks housing around 3% of the state's population.
We then evaluate drinking water service to MHP systems by the stated dimensions of California's Human Right to Water: quality, reliability, and affordability. Water access disparities identified in a content analysis of 1300 news stories in California newspapers from 2000 to 2015 allow us to qualitatively illustrate the breadth and depth of substandard access in parks. These findings are supported by an analysis of administrative data on system quality and reliability. MHP systems are more likely to incur at least one health-related violation and have a higher average number of violations than other systems. They are also four times more likely to experience a significant service shutoff and 40% more likely to rely on groundwater. The evidence on affordability is less conclusive. Many of these problems are exacerbated, if not directly caused, by poor oversight and management of drinking water systems by private MHP operators. We conclude by outlining the feasibility of planning and policy responses that can be targeted to improve service by MHP systems. The problem of insufficient water access and necessary policy development to redress inequalities are likely to be even larger outside of California, where the proportion of mobile home residents is larger and the Human Right to Water is not legislated much less supported by policy.
Data and Methods
As shown in Table 1, we use a range of qualitative and quantitative data from different sources to characterize water service provision to MHPs in California. We first analyze stories from the Access World News online database, which pools news stories from 237 Californian newspapers, over the period January 1, 2000 to January 1, 2015. This database search (Appendix 1) used key water access and mobile home terms which allowed us to identify 1331 potentially relevant news stories across 23 of the state's 58 counties. Using these stories, we perform a content analysis on those which discuss relevant dimensions of water access. We code news articles along the three dimensions. We use the coded data that describe in granular detail the water access obstacles faced by mobile home communities and potential policy responses. We do not claim that these stories are representative of the water service conditions faced in MHPs. In fact, we assume that the information we can derive from news stories represented just a fraction of the service deficiencies faced by these communities.
MHP, mobile home park.
Accordingly, we also draw on a range of administrative data sources to support findings derived from the content analysis. We rely on 2010–2014 American Community Survey data to derive our estimate of the percentage of population living in a MHP in California. 10 We draw on the State Water Resource Control Board's Safe Drinking Water Information System 3.21 (SDWIS) for data on the prevalence of publicly regulated MHP systems, systems' chief water source, and system quality violations. 11 To determine own park systems, we searched among system names for “trailer,” “park,” “mobile,” and “estates” and then manually checked to see that each was a MHP.
We rely on the 2011 American Housing Survey (AHS) for data on water system reliability, as there is no better extant source at the household level for the state or U.S. population. 12 The AHS data allow us to distinguish between MHP housing units and other housing types and whether housing units rely on water systems serving 15 or more households, which mirror the regulated–unregulated water system classification. We construct the outcome of interest, unreliable water access, from a categorical variable in the AHS. This variable records the number of times water service was completely cutoff in a given housing unit (for a 24-hour + period) during the resident's tenancy. Finally, while we identify very little quantitative evidence on household-level water cost, for MHP residents or otherwise, we draw on legislation from the California Assembly which suggests an outsized affordability problem among some MHP systems.
Findings
We first present results on the average size, prevalence, and governance of MHP systems from administrative data. We then analyze drinking water quality, reliability, and affordability of service provided by MHP systems as opposed to other public water systems in California using both findings from our content analysis, as well as data points available in administrative sources. We conclude by discussing tradeoffs and complementarities in the three dimensions of service.
Prevalence of mobile home park systems
The U.S. Environmental Protection Agency and its state level primacy agencies, including the California State Water Resources Control Board (State Board), call drinking water systems, which serve 15 or more connections for at least 60 days of the year, community water systems. The state regulates quality and other service dimensions provided by community water systems. Systems serving fewer than 15 households are labeled “state small systems” or private wells by the California government and are more lightly regulated, if at all. 13 Small noncommunity systems perform worse in terms of quality and reliability than public systems, but feasible planning and policy solutions for these systems are few. 14 The exact proportion of the state population served by community versus noncommunity water systems in California (or any state) is not known, as the U.S. census stopped collecting data on the type of water system serving households in 1990, but available estimates suggest that around 95% of the state receives water from public systems. 15 Data from the AHS, however, suggest surprisingly that MHPs in California are as likely as the general population to be served by community water systems. This demonstrates that any deficiencies in water service in parks are indeed problems for which the public sector maintains oversight and authority to rectify.
We also examine whether MHPs tend to rely on small community water systems, because previous studies have shown that, among the universe of public water systems, smaller systems tend to perform worse in terms of quality and reliability. 16 According to our calculation using the State SDWIS database, about 13% of California's active, year round public water systems exclusively serve MHPs (383 out of 2976 systems as of August 2016). If anything, this is a conservative estimate, as the only other (proprietary) estimate puts the figure around 15%. 17 By any accounting, however, the proportion of public water systems that exclusively serve MHPs far outweighs the proportion of the state's population living in MHPs (3%). As anyone served by an MHP system by definition lives in a MHP, this also means that MHP systems are on average much smaller than other public water systems.
Quality
Both the qualitative and quantitative evidence on observed water quality in MHP systems confirms our expectations of subpar quality. 18 Residents of West Lane Mobile Home Park in San Joaquin County were left without safe drinking water for at least 3 weeks after bacterial contamination of their system's well. Toward the end of the 3-week ordeal, residents voiced concerns over their struggle to pay for bottle water. 19 MHP system drinking water quality contamination is often caused by the improper maintenance of local sewage systems and improper land-use oversight. In 2010 the city of Menifee went so far as to order the closure of Baileywick Mobile Home Park in Riverside County on the grounds that it was a public nuisance. The county had repeatedly cited the park owner for leaky or clogged septic pipes which caused sewage backup and spillage as a result of overcrowding and faulty piping. 20
There are three broad types of violations. We use data from the SDWIS on maximum contaminant level (health-related) and other violations in all state community water systems from 2010 to 2014 to quantify the extent of water quality problems in MHP system. During this period, over 40% of MHP systems incurred any type of violation and one-third incurred an MCL violation, as opposed to one-third of all other systems incurring any violations and one-fourth incurring an MCL violation. 21 Moreover, among those with an MCL violation, MHP systems tended to incur more: 5.85 versus 5.22 for all other systems.
Reliability
Residents reliant on MHP systems are additionally vulnerable to drinking water service unreliability. Service interruptions can occur due to technical system failure, as is more probable with any other small public or private system. An additional source of unreliability, however, is introduced by the role private park managers or owners often play in being responsible for operating public water systems. MHP system operators frequently penalize delinquent rent payers by shutting off water access. 22 For instance, residents of Mountain Gate Mobile Home Park in Shasta County reported drinking water (and electricity) service being periodically cut off from homes as a way to intimidate and harass them. 23 In other cases, operators neglect to pay the system's bills, perform routine maintenance, or are simply unqualified to run a water system.
We use data from the 2011 AHS to illustrate this point. About 13% of residents of MH parks (n = 542) in California reported experiencing a significant shutoff during their tenure, as opposed to <4% in the general population. As with quality violations, the average number of shutoffs was also higher for park residents than residents in other type of housing units. In addition to the generally lower reliability of small systems and the special role of park operators, MHP systems are much more likely to rely primarily, if not exclusively on groundwater wells for drinking water service, a known risk factor for reliability. 24 Our analysis of State Board data shows that 96% of all MHP systems reported local groundwater as their primary source of water, while only two-thirds of all other systems did so. Exclusive reliance on groundwater wells was the primary factor identified in our content analysis to explain cutoffs in service.
Affordability
A single statewide data point on the cost or affordability of drinking water service provided by MHP systems is much more difficult to obtain than for the service dimensions of quality and reliability. This is true for multiple reasons. First, drinking water cost data are difficult to obtain for any population even at the system level, much less the household scale. Data from administrative sources such as the American Community Survey and AHS lump drinking water and wastewater service costs together. Moreover, many households in multifamily units and MHPs do not directly pay for water at all; the cost of service is included in their rent.
Findings from our content analysis and recent legislation by the California state Assembly, however, suggest that the cost of drinking water is indeed an outsized burden for at least some served by MHP systems. For instance, residents of Lake Oaks Mobile Home Park in El Dorado County expressed concern about dramatic increases in water rates and appealed to their city council to mandate lower rates for residents. 25 More often, affordability issues are tied to quality and sometimes reliability. In 2014, residents of Quail Trails Village park in Butte County began purchasing bottled water, which is uniformly much more expensive than other water sources, due to quality concerns. 26
In response to a number of similar incidents in parks, in 2012 the California State Assembly passed Assembly Bill 1830. The text of the bill gives MHP tenants the right to file a complaint with the California Public Utilities Commission (CPUC) if they believe that “their mobile home park is charging too much for the water service or if you think the water service is bad.” 27 While this means to begin addressing unaffordable water is legislated, the CPUC itself indicates that MHP residents are not necessarily aware of their rights and have thus not taken advantage of this redress opportunity. 28
Trade-offs and complementarities between dimensions
Qualitative findings on each of the dimensions of drinking water access clearly show that there are concurrent impacts across dimensions and adverse connections to other environmental service sectors, such as wastewater, sewage, and power. 29 Most clearly, when drinking water quality is affected and detected, reliability is invariably reduced. Moreover, the obstacle to improving quality is often an affordability concern. When improvements to drinking water service are too daunting, residents may even be faced with eviction and displacement from affordable housing.
This can be illustrated vividly in the case of Trailer City Mobile Home Park in Solano County. Residents of Trailer City have been struggling for years with recurring contamination issues and subsequent shutdowns that have often forced them to pay out of pocket for bottled water, which is uniformly much more expensive than other water sources. To address the ongoing problem, the park has applied to connect with the County's water supply, but this would in turn incur per-unit fees which residents cannot afford. 30
Conclusion
Residents served by substandard MHP systems are not passive bystanders. Many of the qualitative accounts analyzed in our study highlight the anger, fear, and concern of residents about the inadequate response by park owners and city officials to address substandard access. Several of the accounts also detailed ad hoc efforts by residents to organize and directly overcome access deficiencies, including complaints to the city council and legal action.
There are several potential strategies to improve MHP systems. Most promisingly, at the state level, the State Board has embarked on a serious effort and has new legislative authority, to encourage consolidation of small underperforming water systems, including MHP systems, with larger high-performing public systems. 31 While this effort is likely to move slowly, it is still more likely to make an impact than municipal annexation efforts which would connect parks to larger drinking water systems. 32 Moreover, consolidation is likely to yield more improvements than through the Board's Drinking Water State Revolving Fund (DWSRF). While California devotes the majority of its DWSRF to quality improvements for small public systems, MHP systems with access deficiencies must compete with hundreds of other small systems and are only likely to be able to do so with the support of experienced nonprofit organizations, such as Pueblo Unido CDC in the Coachella Valley. 33 Another opportunity for support comes from the CPUC, which manages to regulate energy usage in MHPs and cross-subsidizes larger private systems and nominally takes responsibility for MHP drinking water systems. 34 The Department of Housing and Community Development also maintains an Office of the Mobilehome Ombudsman, which states that it can help residents with water quality and reliability issues. 35 While this seems like the best means to put third-party pressure on park managers and system operators, it is unclear to what extent this office is known among MHP tenants, as it did not appear in our other research as a tool used by MHP residents or supportive advocates. Other solutions proposed to improve water access involve local nonprofit or community based organization support for self-reliant water systems managed by MHP residents as nonprofits or by supportive third-party nonprofits. 36
In most cases, multiple means of support and pressure, from residents to state agencies, will likely be needed for sustainable access to be ensured for MHP systems. This study focuses on California as the federal government plays little role in ongoing drinking water system governance and support. The ubiquity of MHP systems and the problem of insufficient water access provided by MHP systems are likely to be even more prevalent in states outside of California, where the proportion of mobile home residents is larger and the Human Right to Water is not legislated much less supported by concerted policy and program development. Accordingly, any proactive policy development in California to redress inequalities should serve as a model that can be adapted across the United States.
Footnotes
Appendix 1. Search Using Access World News (Formerly America's Newspaper) Database
Click on “California Newspapers” in shortcuts
Dates: January 1, 2000–January 1, 2015
Use the following terms in all text field:
“water quality” AND “mobile home” (329 results)
“contamination” AND “mobile home” (271 results)
“water” AND “landlord” AND “mobile home” (164 results)
“water” AND “shortage” AND “mobile home” (112 results)
“water service” AND “mobile home” (135 results)
“water system” AND “mobile home” (177 results)
“water bill” AND “mobile home” (58 results)
“water rate” AND “mobile home” (73 results)
“water well” AND “mobile home” (20 results)
(Other terms such as manager, access, cutoff, shutoff, quantity, deficit, problem, outrage, activism, groundwater, and health did not appear relevant in our searches).
1
California State Assembly Bill No. 685. “The Human Right to Water,” September 25, 2012. <
2
U.S. Census Bureau. American Community Survey 2010–2014 5-Year Estimates.
3
U.S. Census Bureau. American Housing Survey 2011.
4
Richard Genz. “Why Advocates Need to Rethink Manufactured Housing.” Housing Policy Debate 12 (2001): 393–414; Katherine MacTavish, Michelle Eley, and Sonya Salamon. “Housing Vulnerability Among Rural Trailer-Park Households.” Georgetown Journal on Poverty Law & Policy 8 (2006): 95–118.
5
Vinit Mukhija and Paavo Monkkonen. “What's in a Name? A Critique of ‘Colonias’ in the United States.” International Journal of Urban and Regional Research 31 (2007): 475–488.
6
Shadi Eskaf. “Small Water Systems with Financial Difficulties are More Likely to Violate EPA Regulations.” University of North Carolina Environmental Finance Blog. January 28, 2015. <
7
Silvia Jimenez and Gregory Pierce. “Inequality at the Tap: Explaining Shortcomings in Safe Water Access in Los Angeles' Mobile Home Communities.” (2013).
8
Gregory Pierce and Silvia Jimenez. “Unreliable water access in US mobile homes: evidence from the American Housing Survey.” Housing Policy Debate 25 (2015): 739–753.
9
Environmental Integrity Project. “Arsenic in California Drinking Water: Three Years After EPA Notice of Noncompliance to State, Arsenic Levels Still Unsafe in Drinking Water for 55,000 Californians,” September 2016. <
10
U.S. Census Bureau. American Community Survey 2010–2014 5-Year Estimates.
11
State Water Resources Control Board. “Drinking Water Watch.” State Drinking Water Information System 3.21. <
12
U.S. Census Bureau. American Housing Survey 2011.
13
California Health & Safety Code, Section 116270 and 116275. <
14
Lynda Knobeloch, Patrick Gorski, Megan Christensen, and Henry Anderson. “Private Drinking Water Quality in Rural Wisconsin.” Journal of Environmental Health 75 (2013): 16–20; Kelsey Pieper, Leigh-Anne Krometis, Daniel Gallagher, Brian Benham, and Marc Edwards. “Profiling Private Water Systems to Identify Patterns of Waterborne Lead Exposure.” Environmental Science & Technology 49 (2015): 12697–12704.
15
Tyler D. Johnson and Kenneth Belitz. “Identifying the Location and Population Served by Domestic Wells in California.” Journal of Hydrology: Regional Studies 3 (2015): 31–86.
16
Eskaf, 2015.
17
Wes Strickland. “The Organization of Water Utilities in California.” Private Water Law Blog, September 25, 2013.
18
Data from the American Housing Survey also suggests household perception of water quality is also slightly lower in MHPs than other types of housing, 21% to 18%, although the difference is not startling.
19
Lodi News-Sentinel. Regional Roundup—Mobile Home Park Water May Be Cleared Today. Lodi News-Sentinel. Comp. Inc., NewsBank. Lodi, California, November 6, 2007.
20
Julissa McKinnon. “Two Decry Trailer Park Closure,” The Press-Enterprise. Comp. Inc., NewsBank. Riverside, California, July 26, 2010.
21
Mobile home park systems never receive treatment technique violations because most treatment technique requirements are only imposed on large systems. MHP systems are also more likely than other systems to receive a monitoring violation, 22% versus 15%.
22
Gary Rivlin. “The Cold, Hard Lessons of Mobile Home U,” The New York Times, 11 July 2016.
23
Sean Longoria. “Deputies Clear Out Residents of Blighted Mobile Home Park (Updated).” Reeding Record Searchlight. Comp. Inc., NewsBank. Mountain Gate, California, February 8, 2013.
24
J.R. DeShazo, Henry McCann, and Gregory Pierce. “Los Angeles County Community Water Systems: Atlas and Policy Guide Volume I Supply Vulnerabilities, at-Risk Populations, Opportunities for Conservation.” 2015.
25
Molly Rhodes. “Even Though the Latest El Dorado Irrigation District Sewer Rate Hikes Won't Be Seen on Bills Until April, Residents in the Lake Oaks Mobile Home Park Are Already Feeling the Crunch.” Comp. Inc., NewsBank. El Dorado, California, September 12, 2000.
26
Trevor Warner. “Mobile Home Park Residents Concerned About Water Quality.” Chico Enterprise-Record. Comp. Inc., NewsBank. Chico, California, October 29, 2014.
27
California State Assembly Bill No. 1830. “Water Service: Mobile Home Parks,” September 25, 2012. <
28
Public Advisor. Division of Water and Audits, California Public Utilities Commission. (E-Mail Message to Author, August 25, 2015).
29
Julissa McKinnon. “Two Decry Trailer Park Closure.” The Press-Enterprise. Comp. Inc., NewsBank. Riverside, California, July 26, 2010. Lee Peterson. “Options Less Than Soothing.” Daily Breeze. Comp. Inc., NewsBank. Gardena, California, October 2003. Emily Slater. “Stuck on Septic: New Hookup Fee Blocks Local from Hooking Up To Sewer System Soon.” Adobe Press. Comp. Inc., NewsBank. Nipomo, California, August 23, 2002.
30
Chris Denina. “Trailer Park Looks for Funding to Tap City Water Supply.” Vallejo Times-Herald. February 10, 2003.
31
California State Senate Bill No. 88. “Water,” June 24, 2015. <
32
Vinit Mukhija and David Mason. “Reluctant Cities, Colonias and Municipal Underbounding in the US: Can Cities Be Convinced to Annex Poor Enclaves?” Urban Studies 50 (2013): 2959–2975.
33
Jesse Marx and The Desert Sun. Coachella Valley Water Candidates Debate Mobile Home Park Water Solutions. 2016. <
34
California Public Utilities Code. Section 2705.6 on Water Companies. <
35
Office of the Mobilehome Ombudsman. California Department of Housing and Community Development. 2005. <
36
Daniel Zwerdling. “When Residents Take Ownership, A Mobile Home Community Thrives.” National Public Radio. 2016. <
