Water System Challenges in Manufactured Housing
Manufactured housing communities frequently rely on small water systems that face compliance challenges beyond the resources of typical large municipal utilities. These systems serve communities that are disproportionately lower-income, may have aging infrastructure, and often lack the technical, managerial, and financial capacity needed to implement PFAS treatment upgrades. The combination of elevated PFAS compliance costs and limited rate base creates a funding gap that threatens water system viability in some manufactured housing communities.
Regulatory Compliance Burden on Small Systems
The EPA’s 2024 PFAS MCLs apply to all public water systems serving 25 or more people, including small systems serving manufactured housing communities. Per-customer compliance costs are significantly higher for small systems than large ones due to fixed infrastructure costs spread over fewer rate payers. A small system serving 200 connections may face per-customer annual compliance costs 10 to 20 times higher than a large utility serving 50,000 connections — a disparity that the federal regulatory framework does not automatically address.
Consolidation and Regional Solutions
State primacy agencies — which oversee SDWA compliance — increasingly promote consolidation of small water systems with adjacent larger utilities as a strategy for addressing PFAS compliance affordability. Physical consolidation — extending utility distribution to connect previously independent small systems — eliminates duplicative infrastructure and brings larger-utility economies of scale to formerly isolated communities. Where physical consolidation is impractical, administrative consolidation or management assistance programs can improve technical and financial capacity without full system merger.
Federal Funding Prioritization
Both the Bipartisan Infrastructure Law and EPA’s State Revolving Fund programs have established priority weighting for disadvantaged communities in PFAS treatment funding allocation. Manufactured housing communities that qualify as disadvantaged under established income and rate burden criteria can access grant funding (in addition to low-interest loans) for PFAS treatment infrastructure. State-level advocacy for adequate disadvantaged community set-asides within PFAS treatment funding programs is an important equity consideration in implementation of the 2024 MCL rule.