Attachment B - Staff Report - Z-TA-3-23-Y.pdf

Staff Report 
Zoning Ordinance Text Amendment 
Z-TA-3-23-Y
 (Expansion of Nonconforming Mobile Home Developments) 
April 21, 2023 
Application No. Z-TA-3-23-Y: Amend Chapter 9, Section 902 (Expansion of 
Nonconforming Use) of the Phoenix Zoning Ordinance to allow existing mobile home 
developments to increase the number of units by 50% with administrative review and 
approval by the Zoning Administrator. 
Staff recommendation:  Staff recommends approval of Z-TA-3-23-Y as shown in 
Exhibit A. 
BACKGROUND 
Residents of mobile home communities throughout the City of Phoenix have faced 
displacement due to the redevelopment of mobile home park sites. In response to 
community concerns and in coordination with the Mayor and City Council, an 
internal work group was formed on September 28, 2022, to determine how the city 
could assist families facing imminent displacement and to identify measures to reduce 
future risk.  
The Work Group was comprised of City staff from throughout the organization and 
included the Phoenix Industrial Development Authority (IDA). The team was charged 
with evaluating all legal and financial assistance the City could offer to the tenants of the 
displaced communities. The team also reviewed and evaluated options to develop long-
term strategies to prevent this issue from happening in the future. The resulting 
research report from the internal work group was issued November 25, 2022, and an 
updated report was issued on February 23, 2023 (Exhibit B). 
The report detailed programs, initiatives, and strategies to address the displacement of 
mobile home residents in the city of Phoenix. However, due to limitations from Arizona 
Revised Statutes, the city is limited from taking certain actions. The report included legal 
analysis and also covered approaches taken by other jurisdictions to address similar 
challenges in their communities. Each proposed program and strategy were detailed in 
this report along with a set of recommended actions. Recommended programs and 
strategies were organized by the following: 
1. Immediate Solutions - Financial Assistance and Support Services;
2. Medium Term Solutions - Planning and Zoning Initiatives;
3. Long Term Solutions - Ownership and Acquisition Strategies.
ATTACHMENT B

Z-TA-3-23-Y 
June 1, 2023 Planning Commission 
Page 2 of 3 
 
On March 22, 2023, Mayor and Council directed staff to move forward with 12 viable 
recommended actions outlined in Exhibit B. Action Item #8 recommended modifications 
to nonconforming Zoning Ordinance provisions. 
 
Staff obtained input from various stakeholders and held four meetings to review and 
request additional input on the proposed text amendment. Stakeholders included 
individuals from the following organizations: 
 
• Manufactured Housing Communities of Arizona (MHCA) 
 
• Manufactured Housing Industry of Arizona (MHIA) 
 
• Arizona Department of Housing Board of Manufactured Housing Member 
 
• Affordable Housing/Private Developers 
 
• Arizona State University, Real Estate Development 
 
PURPOSE 
The intent of the proposed text amendment is to allow for the expansion of legal non-
conforming mobile home developments by increasing the number of mobile home units 
and other types of units like Park Models (aka Tiny Homes) in existing mobile home 
developments. Many existing mobile home developments within the City of Phoenix are 
considered nonconforming. Many were annexed from Maricopa County or were 
developed under different zoning requirements which rendered them nonconforming. An 
expansion of a nonconforming use is limited to a structure housing a nonconforming 
single-family residential use or an accessory structure for a nonconforming single-family 
residential use. Existing mobile home developments are frozen in time at the time they 
became nonconforming. Any expansions or changes would require bringing the site into 
compliance with existing requirements for offsite manufactured home developments, 
adding significant costs for improvements. The proposed text amendment would allow 
existing mobile home developments to expand by adding additional units through an 
administrative review to ensure that the added units meet the intent of adequate 
setback between units, perimeter setbacks, and other development standards that are 
consistent with that mobile home development. 
 
DESCRIPTION OF THE PROPOSED TEXT 
The proposed text provides an administrative process for existing legal nonconforming 
mobile home developments to increase the number of mobile homes units that existed 
legally before July 1, 2023, up to 50%. The administrative review would include 
adequate setbacks between units, perimeter setbacks, and other development 
standards that are consistent with that mobile home development. 
 
CONCLUSION 
The proposed text amendment will allow existing mobile home developments to 
increase the number of units by 50% with administrative review and approval by the 
Zoning Administrator.

Z-TA-3-23-Y 
June 1, 2023 Planning Commission 
Page 3 of 3 
 
Staff recommends approval of Z-TA-3-23-Y as proposed in Exhibit A.  
 
Writer 
T. Gomes 
4/21/23 
 
Exhibits 
A. Proposed Language 
B. Research Report City Manager’s Office dated 2/23/23

EXHIBIT A 
Text Amendment Z-TA-3-23-Y:  
Expansion of Nonconforming Mobile Home Developments 
 
Proposed Language: 
 
Amend Chapter 9, Section 902 (Expansion of Nonconforming Use) as follows: 
A nonconforming use shall not be expanded or extended beyond the floor area or lot area 
that it occupied on the effective date of these regulations, the effective date of any 
amendment to these regulations, or the effective date of annexation into the City 
rendering such use nonconforming, except that: 
A. A structure housing a nonconforming single-family residential use may be 
expanded up to fifty percent beyond the floor area or lot area that it occupied on 
the date it was rendered nonconforming, subject to obtaining a use permit in 
accordance with the procedures and standards of section 307; and 
B. An accessory structure for a nonconforming single-family residential use may be 
expanded up to fifty percent beyond the floor area or lot area that it occupied on 
the date it was rendered nonconforming, subject to obtaining a use permit in 
accordance with the procedures and standards of section 307. 
C. AN EXPANSION OF A MOBILE HOME DEVELOPMENT SHALL BE PERMITTED 
TO INCREASE THE NUMBER OF MOBILE HOME UNITS BY UP TO FIFTY 
PERCENT OF THE UNITS THAT LEGALLY EXISTED BEFORE JULY 1, 2023 
WITH ADMINISTRATIVE REVIEW AND APPROVAL BY THE ZONING 
ADMINISTRATOR.  THE ZONING ADMINISTRATOR SHALL REVIEW AND HAVE
DISCRETION TO ENSURE THAT THE ADDED UNITS MEET THE INTENT OF 
ADEQUATE SETBACK BETWEEN UNITS, PERIMETER SETBACKS, AND 
OTHER DEVELOPMENT STANDARDS THAT ARE CONSISTENT WITH THAT 
MOBILE HOME DEVELOPMENT. 
No provision in this chapter shall be construed to permit expanding or extending a 
nonconforming use beyond the confines of the lot or parcel of land upon which it was 
located on the date the use became nonconforming or to permit any expansion of a 
nonresidential or multiple-family residential nonconforming use. 
***

Page 1 of 12 
RESEARCH REPORT 
CITY MANAGER’S OFFICE 
DATE ISSUED 
2/23/23 
TO: 
Mayor and Council 
FROM: 
Jeff Barton, City Manager 
SUBJECT 
Mobile Home Resident and Mobile Home Park Displacement Options 
Introduction 
Residents of mobile home communities throughout the City of Phoenix have faced displacement 
due to the redevelopment of mobile home park sites. Residents of three communities, including 
Periwinkle, Weldon Court, and Las Casitas, are under imminent threat of displacement. Many 
residents of these communities have contacted the City of Phoenix to seek assistance. In 
response to these concerns and in coordination with the Mayor and City Council, an internal 
work group was formed on Sept. 28, 2022, to determine how the City of Phoenix can assist 
families facing imminent displacement and to identify measures to reduce this risk in the future.   
Background 
The Work Group is comprised of City staff from throughout the organization and includes the 
Phoenix Industrial Development Authority (IDA). The team was charged with evaluating all legal 
and financial assistance the City could offer to the tenants of the three properties mentioned 
earlier in this report. The team also reviewed and evaluated options to develop long-term 
strategies to prevent this issue from happening in the future.  
This report details programs, initiatives, and strategies to address the displacement of mobile 
home residents in the City of Phoenix. However, due to limitations from Arizona State Statutes, 
the City is constrained from taking certain actions. This report includes legal analysis and also 
covers approaches taken by other jurisdictions to address similar challenges in their 
communities. Each proposed program and strategy is detailed in this report along with a set of 
recommended actions. Recommended programs and strategies are organized by the following: 
1. Immediate Solutions - Financial Assistance and Support Services;
2. Medium Term Solutions - Planning and Zoning Initiatives;
3. Long Term Solutions - Ownership and Acquisition Strategies.
EXHIBIT B
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Staff also recommends supporting Arizona State legislative changes that would increase the 
State-administered displacement funds for each resident that is impacted by redevelopment of 
mobile home parks, as well as any legislative changes that would allow for a Right of First 
Refusal Purchase by the existing residents when mobile home park developments are offered 
for sale.  
The section entitled Viable Options details the actions staff recommends the City implement to 
assist families facing displacement. The section entitled Non-Viable Options provides 
information on programs and strategies that were evaluated but determined to be non-viable 
options. Attachment A provides an overview of staff recommendations as well as the evaluated 
programs which were determined to be non-viable options, based on legal analysis and the 
research conducted by the Work Group. 
Legal Analysis and Discussion 
The Work Group on mobile home parks asked the Law Department to analyze the legal risks of: 
1. Imposing a development moratorium on redeveloping mobile home parks;
2. Eliminating non-mobile home park zoning entitlements from existing mobile homes;
3. Requiring mobile home park landlords to pay relocation assistance exceeding the amount
required by Arizona Revised Statute;
4. Using City funds to pay residents additional relocation assistance exceeding the amount
required by Arizona Revised Statute.
First, the City cannot impose a development moratorium on any private property, including 
mobile home parks, without clear justification. The Arizona State Legislature has declared 
development moratoriums a matter of statewide concern, because moratoriums could negatively 
affect property rights and property owners. The City would have to determine that a moratorium 
is justified (e.g., a lack of adequate infrastructure, among other things), and limit the location and 
duration of any moratorium.  
Second, the City can eliminate non-mobile home park zoning entitlements from an existing 
mobile home park without exposing the City to potentially significant claims for diminution of 
property value under Prop. 207. However, any land use law that diminishes a landowner’s 
existing rights to use, divide, sell or possess their land would require the City to compensate the 
landowner for the diminished value.  
Third, the State established a regulatory system for all mobile landlord-tenant relationships, 
including a relocation fund to pay relocation assistance to tenants displaced from a mobile home 
park. Thus, the City is potentially preempted from requiring landlords to pay more than what is 
available from the site relocation fund. 
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Finally, the Arizona Constitution prohibits the City from giving or loaning its public resources 
(e.g., general fund dollars) to aid, donate, or subsidize individuals or companies. The City may 
be subject to a challenge for violation of the gift clause if the City expends general funds to 
provide additional relocation assistance to mobile home park tenants.  
Viable Options 
This section details recommended actions for the City of Phoenix to implement to assist 
individuals and families facing displacement from mobile home communities. 
Immediate Solutions: Financial Assistance and Support Services 
1. Rental/Utility Deposit and Rental Payment Assistance
Staff recommends two financial assistance programs which can be implemented
immediately to support impacted residents. Using already approved American Rescue
Plan Act (ARPA) Tranche One and remaining Emergency Rental Assistance (ERA)
funds, the proposed programs include rent and utility (water/sewer, gas and electric)
deposits, and rental/utility payments for up to 15 months (inclusive of three months
forward rent and utility credits) or 12 months lump sum rental payment.
The following eligibility requirements will be used for deposit and payment assistance:
•
Must be a Phoenix resident.
•
Must have an income at or below 120 percent of Area Median Income (AMI) or
$106,560 for a family of four.
•
Must qualify for unemployment benefits, experience a reduction in income, or
experience other financial hardships caused by the COVID-19 pandemic.
•
Must demonstrate risk of homelessness or housing instability.
•
Must have incurred rent (including deposits, move-in costs, legal and late fees) and
utility bills after March 13, 2020. (If rent has not been charged, they are not eligible
for assistance beyond help securing a new dwelling unit.)
2. Case Management and Housing Navigation Services
Staff recommends a new program to provide case management and housing navigation
services in partnership with a local, community-based non-profit that specializes in
providing these types of services. If approved, the Human Services Department will
request Council Approval to enter into an Intergovernmental Agreement (IGA) for up to
$300,000 using American Rescue Plan Act (ARPA) Tranche One funding with the City of
Phoenix Industrial Development Authority (IDA) to contract with Helping Families in Need
(HFIN). Currently, Trellis is providing these services through a contract with Grand
Canyon University (GCU) for Periwinkle residents.
With Council approval, HFIN would provide services to residents of the Las Casitas and
Weldon Court communities. The services would include case management that supports
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housing needs, access to physical healthcare, behavioral healthcare, nutrition 
assistance, cash assistance, workforce development, emergency rental assistance and 
vouchers, etc.  
3. Emergency Housing Vouchers (EHV)
Staff recommends providing Emergency Housing Vouchers (EHV) to assist individuals and
families facing displacement from mobile home parks. The EHV program is available
through the American Rescue Plan Act (ARPA) via the U.S. Department of Housing and
Urban Development (HUD). The vouchers are available to assist individuals and families
who are homeless, at risk of homelessness, recently homeless or have a high risk of
housing instability. The program is managed through a direct referral process from the
Continuum of Care (CoC) regional Coordinated Entry (CE) System and could potentially be
utilized by displaced residents, pending availability and meeting eligibility requirements.
Eligibility for use of the voucher program is determined through the CoC CE System. At 
least one family member must be a U.S. Citizen or eligible non-citizen to utilize the 
program. Once eligibility has been determined, referrals are made to the Housing 
Department through designated coordinated entry points. This resource is limited and will 
be utilized until exhausted.
4. Communication Strategy and Action Protocol
Staff recommends developing a communication strategy and action protocol to inform
residents of critical information related to their potential displacement as well as available
assistance programs and other resources.
In 2019, the City of Apache Junction and Arizona State University completed a study on 
Mobile Home Parks. The study focused on preserving affordable housing, improving the 
conditions of mobile home parks, increasing the quality of life for residents, and promoting 
the redevelopment of parks when appropriate. One of the key recommendations was the 
creation of a communication strategy and action protocol for the notification and provision of 
resource assistance for mobile home residents when the park in which they reside 
becomes available for sale.
This recommendation is to develop communication strategies that connect mobile home 
residents with resources and inform residents at risk of displacement of opportunities for 
other affordable housing options. The information would include an overview of the rights of 
mobile home residents, approved programs within this report and other available resources, 
such as the State of Arizona’s Mobile Home Relocation Fund. This fund provides monetary 
assistance to mobile home owners when mobile home parks are closed or redeveloped. 
The fund provides moving expense assistance, through direct payment to an installer, of up 
to $7,500 for a single-wide or $12,500 for a multi-section home.
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5. Homeownership Down Payment Assistance
A. Open Doors Down Payment Assistance Program
Staff recommends providing residents information and assistance to participate in the 
Open Doors Down Payment Assistance program, which is designed to assist eligible first-
time homebuyers with the purchase of an affordable home in the City of Phoenix.  
The program, funded by the federal HOME Investment Partnerships Program, provides 
down payment and/or closing cost assistance to households earning at or below 80 
percent of the Area Median Income (AMI). The beneficiary must be a U.S. citizen or 
eligible non-citizen. To utilize program funding for a manufactured home purchase, the 
home must be affixed as real property, on a permanent foundation and connected to 
permanent utility hook-ups. 
Total assistance is based on eligibility and individual need. Homebuyers will be required 
to attend pre-purchasing counseling provided by a U.S. Department of Housing and 
Urban Development (HUD) certified housing counseling agency and certified housing 
counselor. Homeownership down payment assistance funds are offered as a deferred 
payment loan that:   
• Has an interest rate of 0 percent with no monthly principal payments;
• Provides up to 10 percent of the purchase price of a home;
• Is fully forgiven after the period of affordability;
• Can be layered with other homeownership down payment assistance programs.
B. Additional Support through Community Development Block Grant (CDBG)
Staff also recommends pursuing the possibility of supplementing the Housing 
Department’s Open Doors Down Payment Assistance Program with available CDBG 
funding. The additional assistance could be provided to eligible families interested in 
homeownership. Beneficiary must be a U.S. citizen or eligible non-citizen.  
CDBG funds can assist low- to moderate-income households with the following 
homeownership activities for the purchase of single-family homes:  
• 50 percent of the lender required down payment;
• Payment of closing costs, which must be deemed reasonable;
• Subsidized interest rates and mortgage principal amounts.
Note: The following medium- and long-term recommended solutions would be included 
in the City’s overall strategy to assist residents of mobile home communities. However, 
these recommendations would not address the current concerns related to the imminent 
displacement of residents at the three identified communities.  
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Medium Term Solutions: Planning and Zoning Initiatives 
6. Modify Existing Special Permit Mobile Home Park Development Requirements
Staff recommends the consideration of modifying existing Special Permit Mobile Home
Park Development requirements to make it easier to continue to operate, expand, or
create new mobile home parks. This could be done by modifying the existing special
permit allowances.
Staff recommends modifying the existing special permit allowances for mobile home
parks through a text amendment to the zoning ordinance. This text amendment would
address current zoning ordinance requirements to look for ways to increase market
viability so that developers could develop new mobile home parks. This amendment
would look at zoning requirements for items such as but not limited to minimum acreage
size, spacing between units, and common open space. It could also allow other housing
types within the new mobile home park. This could allow for new parks to be built that
would offer more affordable housing than traditional homes. The expansion could include
additional relocation requirements if developed under the new text amendment
provisions.
7. Create A Mobile Home Park Zoning Overlay Incentive District
Staff recommends the consideration of drafting a Mobile Home Park Zoning Overlay
Incentive District with incentives for property owners of existing mobile home parks to opt
into the overlay and operate as a mobile home park.
With the Overlay District, property owners could “opt in” and obtain greater property
entitlements in one of two ways. The first option would be the property owner would
maintain the existing mobile home park for (e.g., 10 years) in exchange for additional
density, height, or setbacks, etc. after the specified timeframe was met. The second
option would allow the property owner to redevelop the site in exchange for additional
density, height, or setbacks, etc., before the specified timeframe was met, if onsite
affordable housing was provided or funds were allocated for relocation fees. In order for
this option to be viable, logistical challenges would need to be remedied through robust
stakeholder meetings and feedback, to discuss any potential incentive for additional
setbacks, height requirement, density, etc. As a result, there could be significant
challenges associated with this option.
Arizona Revised Statute (A.R.S.) 12-1134 precludes the City from requiring the overlay
be applied to existing mobile home parks but incentivizes the maintenance of existing
mobile home parks.
8. Modify Legal Non-Conforming Zoning Ordinance Provisions
Staff recommends modifying Legal Non-Conforming Zoning Ordinance provisions to
allow for expansion of existing mobile home parks. Staff recommends a text amendment
that specifically allows for the expansion of legal non-conforming zoning rights to cite
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additional mobile home units and other types of units like tiny homes in existing mobile 
home parks. This effort will also allow for a review of the on-site development code and 
infrastructure requirements to ensure that minimum requirements are as safe and 
efficient as possible. Staff recommends expanding the allowable housing types such as 
tiny homes (Park Models) to replace existing mobile homes. Tiny homes provide an 
affordable alternative to mobile or manufactured homes. Currently, Phoenix Zoning 
Ordinance allows existing mobile home parks to replace older mobile homes (built prior to 
June 15, 1976) with a manufactured home (built after June 15, 1976, per U.S. 
Department of Housing and Urban Development (HUD) standards) by right. 
Additionally, most existing mobile home parks are considered nonconforming. Many were 
annexed from Maricopa County or were developed under different zoning requirements 
which rendered them nonconforming. An expansion of a nonconforming use is limited to 
a structure housing a nonconforming single-family residential use or an accessory 
structure for a nonconforming single-family residential use. Existing mobile home parks 
are frozen in time at the time they became nonconforming. Any expansions or changes 
would require bringing the site into compliance with existing requirements for mobile 
home parks, adding significant costs for improvements. An amendment to the Phoenix 
Zoning Ordinance to allow existing mobile home parks to expand by adding additional 
units and make proportional improvements could also be considered.  
9. Explore Opportunities to Partner with Qualified Opportunity Fund (QOF)
Staff recommends exploring opportunities to partner with a Qualified Opportunity Fund
(QOF) to invest in purchasing mobile home park land when a property owner desires to
sell for redevelopment.  Purchase by the fund would allow for additional time to help
impacted mobile home residents move to another location or pursue other options.  Any
purchased land would take advantage of the Mobile Home Park Zoning Overlay Incentive
District allowances to enhance their interest in purchasing the parcel.
Long Term Solutions: Ownership and Acquisition Strategies  
10. Partner with Nonprofit(s) to Purchase Mobile Home Parks
Staff recommends working to identify nonprofit partners to purchase existing mobile
home parks to stabilize the existing park operations and/or allow for redevelopment of the
property that limits displacement of existing residents.
If redevelopment is pursued, the City can partner by offering funding assistance for new
affordable housing development that prioritizes new housing options for mobile home
park residents. Available funding for purchase and/or redevelopment must be identified
and may have residency requirements. Due to the timing associated with redevelopment,
residents may need to be temporarily relocated and potentially pursue alternative housing
options.
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The Phoenix Industrial Development Authority (IDA) has agreed to work with the City to 
develop financing options that may assist non-profits or other community partners in their 
purchasing efforts. 
11. Establish Resident Owned Communities (ROC USA)
Staff recommends engaging with ROC USA, which is a national nonprofit that assists
existing mobile homeowners in forming a cooperative entity to finance the purchase of a
mobile home park.
ROC USA works with regional technical assistance affiliates to study the feasibility of
purchasing mobile home parks, helping residents form a cooperative association, and
identifying funding sources for the purchase. ROC USA may be able to provide loans to
assist with the resident purchase of a mobile home park. To pursue resident purchase of
a mobile home park, park ownership concurrence and traditional and/or nonprofit funding
sources must be identified. Increasing land values and potential for park redevelopment
could make it difficult to find park owners who are willing to participate in this program.
12. Develop a Comprehensive Strategy and Action Plan
Staff recommends the development of a Comprehensive Strategy and Action Plan
related to mobile home communities and manufactured housing. This Comprehensive
Strategy and Action Plan would be developed through the formation of a steering
committee comprised of City staff, community members, and housing experts.
The City of Boulder, Colorado developed a Manufactured Housing Strategy with an
Action Plan focused on efforts that encourage the preservation of existing manufactured
home communities, facilitating the development of new manufactured home
communities, increasing opportunities for Resident Owned Communities (ROCs),
reducing or eliminating health and safety issues, and rehousing displaced households.
By engaging in a comprehensive study and analysis the City will be better prepared to
take a proactive approach in assisting residents of mobile home and manufactured
housing communities.
Non-Viable Options 
This section provides information on the programs and strategies that were evaluated by staff 
but determined to be non-viable options to assist individuals and families facing displacement 
from mobile home communities. 
Financial Assistance and Support Services 
1. City of Phoenix Affordable Housing Units and Housing Choice Vouchers
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Staff evaluated the possibility of providing displaced mobile home residents access to 
public housing or affordable units by housing displaced communities at City properties. 
Staff also evaluated providing Housing Choice Vouchers to eligible individuals and 
families. Both strategies were determined to be non-viable solutions. 
Currently all public housing and affordable housing properties have high occupancy rates 
and a wait list of interested residents. Similarly, the Housing Choice Voucher wait list is 
currently closed. The current U.S. Department of Housing and Urban Development 
(HUD) approved Administrative Plan for wait list local preferences does not include 
private displacement action, therefore mobile home park residents being displaced by 
private action could not be directly placed into vacant units or provided a Housing Choice 
Voucher.  
Ownership and Acquisition Strategies 
2. City Purchase of At-Risk Mobile Home Parks
Staff evaluated the possibility of the City of Phoenix purchasing mobile home parks that
are at risk of investor purchase, which would potentially result in the displacement of
residents. This option would prevent resident displacement and increase stability while
preserving affordable housing.
However, staff determined this was a non-viable solution due to the following challenges:
•
Current park owners would need to agree to sell to the City of Phoenix.
•
There is a high number of mobile home parks Citywide.
•
There would be additional costs including required infrastructure improvements,
replacement of unsafe units, contract with third-party management companies, etc.
•
It would be inconsistent with previous community planning efforts.
•
Long-term financial costs associated with being a mobile home park owner are not in
line with City priorities.
3. City Acquisition of Land for Mobile Home Use
Staff evaluated the possibility of the City of Phoenix purchasing land for mobile home
use. This option would increase affordable housing options. However, staff determined
this was a non-viable solution due to the following challenges:
•
It would be an inefficient use of land and subsidy when higher density housing could
be developed to address the current housing shortage more effectively.
•
There is limited availability of suitable sites (10-acre minimum, correct zoning, etc.).
•
There would be additional costs including required infrastructure improvements,
replacement of unsafe units, contract with third-party management company, etc.
•
It would be inconsistent with previous community planning efforts.
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4. City-Owned Property for Use as Manufactured/Mobile Home Park or Tiny Homes
Staff reviewed the list of City-owned properties for use as a manufactured home park and
the requirements for use including development, relocation of units, and
management. The minimum site size for development of an average 100-space park is
seven and one-half acres.
Staff concluded the use of City-owned property for use as a manufactured home park is
non-viable since the City does not have excess land suitable for this purpose.
Furthermore, the high cost and risk associated with this type of development, as well as
ongoing management and maintenance, are impediments to using City-owned
property. The current inventory of City-owned land is comprised of sites that are either
too small to accommodate a manufactured home park or larger sites set aside for
affordable housing, future fire stations, water facilities, other public uses, or located within
a residential neighborhood and originally planned for a neighborhood park.
Utilizing City-owned property would require homes currently facing displacement to be
physically moved from their current locations. This type of move is estimated to cost
approximately $10,000 to relocate a mobile home. In most situations, moving
professionals have been unwilling to relocate these structures due to the age and
associated risk of moving these units. Additionally, development cost of a 100-space
manufactured home park is estimated to be approximately $1.8 million. Considering the
gift clause, the use of City-owned land as a manufactured home park would require
leases at market rent. Management fees are generally seven to ten percent of collected
rents, plus ongoing operation and maintenance costs, reserves for replacement, liability,
and risk. As a result, residents would still face affordability challenges. For these reasons,
staff determined the utilization of City-owned property is a non-viable option.
Planning and Zoning Initiatives 
5. Exclusive Zoning District for Mobile Home Parks
Staff does not recommend the consideration of drafting a Mobile Home Park Zoning
District and rezoning existing mobile home parks because it would be a new land use that
diminishes the value of the properties zoning entitlements, and the City would be required
to pay for the diminished value under Arizona Revised Statute (A.R.S.) 12-1134.
This exclusive zoning district would limit the allowed land use to mobile home parks and
accessory uses for the park (e.g., clubhouse, pool, etc.). Most existing mobile home
parks are entitled with multifamily or commercial zoning which makes the land extremely
vulnerable to redevelopment, loss of low-income housing options, and contributes further
to resident displacement. This approach was found not to be a regulatory taking in the
State of Washington under LAUREL PARK COMMUNITY v. CITY OF TUMWATER;
however, the City is liable to diminution of property value under Arizona Revised Statute
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(A.R.S.) 12-1134 if new zoning district is applied retroactively, meaning landowners 
would need to be compensated. American Rescue Plan Act (ARPA) funds are likely not a 
source of compensation for affected landowners.  
Recommendations 
Based on legal analysis and the research conducted by the Work Group: 
Staff recommends the following immediate programs: 
•
Utilizing American Rescue Plan Act (ARPA) and Emergency Rental Assistance (ERA)
funding for Rental/Utility Deposit, Rental Payment Assistance, Case Management and
Housing Navigation Services. It is important to note that the amount of funds available is
limited, as is the timeframe the funds are available.
•
Providing Emergency Housing Vouchers (EHV) to individuals facing displacement.
•
Developing a Communication Strategy and Action Protocol.
•
Focusing outreach efforts of the Open Doors Down Payment Assistance Program to
benefit mobile home park residents, and possibly supplementing the program with
Community Development Block Grant (CDBG) funding.
Staff recommends the following medium-term programs: 
•
Addressing existing Special Permit Mobile Home Park Development requirements,
making it easier for landowners to continue to operate, expand, or create new mobile
home parks.
•
Creating a Mobile Home Park Zoning Overlay Incentive District to provide incentives for
property owners to delay redevelopment of existing mobile home parks.
•
Addressing Legal Non-Conforming Zoning Ordinance provisions to allow expansion of
existing mobile home parks and tiny homes.
•
Explore opportunities to partner with a Qualified Opportunity Fund (QOF) to invest in
purchasing mobile home park land when a property owner desires to sell for
redevelopment.
Staff recommends the following long-term programs: 
•
Partnering with nonprofit(s) to purchase mobile home parks.
•
Working with residents at risk of displacement to engage with and create Resident
Owned Communities (ROC USA).
•
Developing a comprehensive strategy and action plan to take a proactive approach in
assisting residents of mobile home and manufactured housing communities.
Staff also recommends supporting Arizona State legislative changes that would the State-
administered displacement funds for each resident that is impacted by the redevelopment of 
mobile home parks, as well as any legislative changes that would allow for a Right of First 
Refusal Purchase by the existing residents when mobile home park developments are offered 
for sale.  
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Attachment A 
Based on legal analysis, staff recommends the following proposed programs and strategies to 
assist mobile home residents in the City of Phoenix: 
RECOMMENDED PROGRAMS 
TIMELINE 
Rental/Utility Deposit and Rental Payment Assistance 
Immediate 
Case Management and Housing Navigation Services 
Immediate 
Emergency Housing Vouchers (EHV) 
Immediate 
Communication Strategy and Action Protocol 
Immediate 
Homeownership Down Payment Assistance 
Immediate 
Modify Existing Special Permit Mobile Home Park Development 
Requirements 
Medium Term 
Create A Mobile Home Park Zoning Overlay Incentive District 
Medium Term 
Modify Legal Non-Conforming Zoning Ordinance Provisions 
Medium Term 
Explore Opportunities to Partner with Qualified Opportunity Fund 
(QOF) 
Medium Term 
Partner with Nonprofit(s) to Purchase Mobile Home Parks 
Long Term 
Establish Resident Owned Communities (ROC USA) 
Long Term 
Develop a Comprehensive Strategy and Action Plan 
Long Term 
Staff evaluated the following programs and strategies but determined they are non-viable 
options to assist families facing displacement from mobile home communities: 
EVALUATED PROGRAMS – NON-VIABLE OPTIONS 
TIMELINE 
City Affordable Housing Units and Housing Choice Vouchers 
N/A 
City Purchase of At-Risk Mobile Home Parks 
N/A 
City Acquisition of Land for Mobile Home Parks 
N/A 
City Property for Manufactured/Mobile Home Park or Tiny Homes 
N/A 
Exclusive Zoning District for Mobile Home Parks 
N/A 
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