Pages

Wednesday, June 30, 2021

Providing water for mobile home park communities

We want every Coloradan to have safe drinking water, but when it comes to mobile home parks, the department does not have regulatory authority over most of these communities. While we cannot always address complaints and concerns we get from mobile home park communities, we work closely with other state agencies, counties, and cities to try to resolve them. 

The Department of Local Affairs (DOLA) oversees the Mobile Home Park Act. We partner with DOLA to share information to protect public health and ensure residents have a livable environment. DOLA and their Dispute Resolution and Enforcement Program is a useful resource for public drinking water system operators to know about. 

What does DOLA regulate at mobile home parks?

In 2019, the state legislature passed the Mobile Home Park Act, setting up a state registration program for mobile home parks and a complaint program. The Mobile Home Park Oversight Program within the Department of Local Affairs (DOLA) oversees the Mobile Home Park Act, registers mobile home parks, and runs the Dispute Resolution and Enforcement Program. 

Program activities include:

  • Receiving and investigating complaints.
  • Facilitating dispute resolutions between mobile home owners and their mobile home park managers. 
  • Determining whether violations of the law have occurred and issuing a Notice of Violation when necessary.
  • Registering all mobile home parks annually. 
  • Conducting outreach and education on mobile home park laws, such as informing landlords of their responsibility to provide and pay for alternative sources of potable water and maintaining portable toilets no later than 24 hours after a service disruption begins, unless conditions beyond the landlord’s control prevent compliance.

Under the Mobile Home Park Act, “mobile homes” do not include camper coaches, camper trailers, fifth wheel trailers, motor homes, recreational park trailers, recreational vehicles, travel trailers, or truck campers. DOLA does not oversee these vehicles nor parks that rent space to these vehicles unless they also rent space to five or more “mobile homes” as defined in 8 CCR 1302-15-1.1.

What does CDPHE regulate at mobile home parks?

CDPHE is the regulatory authority under the Colorado Primary Drinking Water Regulations, Regulation 11(5-CCR 1002-11). Regulation 11 focuses on safe drinking water in accordance with the federal Safe Drinking Water Act. Our enforcement authority is limited to specific violations of Regulation 11, which does not address concerns with taste, odor, color or other issues that may not directly impact safety.

We regulate any entity that provides drinking water and meets the following criteria:

  • Provides water to at least 25 people per day for at least 60 days per year or at least 15 service connections (trailers, buildings, etc) AND: 
    • Has their own source of drinking water (well or surface water source); or
    • Purchases water from another utility and they bill the residents specifically for water (e.g. their water bill fluctuates every billing cycle); or 
    • Receives water from another utility and provides additional treatment to meet safety standards on site for the water.
  • We do not regulate mobile home parks (or other entities) if:
    • They receive water from another utility and do not bill the residents for water or water usage (e.g. included in rent, lease, or flat-rate utility billing).
    • They do not serve water to at least 25 people per day for at least 60 days per year or at least 15 service connections.

What does this mean for water at mobile home park communities?

Most mobile home parks do not meet the criteria to be a regulated water provider. This means that the department does not have an inventory of these parks or regularly interact with them about drinking water. This typically leads to residents reaching out to DOLA or their local government when they have concerns about their water.

DOLA’s Dispute Resolution and Enforcement Program allows mobile home park residents, managers, and owners to file complaints about many different issues they may come across at the mobile home park. This includes issues with water safety, connection, and maintenance. DOLA then investigates the complaint and may issue a violation if necessary. Oftentimes DOLA’s investigation into water-related complaints turns up no concrete violation as the complaint stems from water smell, odor, or color which is not regulated by the department. 

In promoting a culture of health, we want to ensure that everyone has access to safe and enjoyable drinking water. We are building an open dialogue with DOLA so complaints and concerns they receive are addressed as quickly as possible to protect human health. We also share issues at mobile home parks we are alerted to so that DOLA can make sure the owner follows all required statutes for resident safety and livability.

For any disruptions of service, we will work with the public water system who provides water to the mobile home park or the certified water operator if the mobile home park is a regulated public water system.