v>EPA
United States
Environmental Protection
Agency
Office of Water
(WH-550)
EPA 570/9-89-009
July 1989
Drinking Water Systems
Three Approaches
To Improve
Mobile Home Park
Compliance
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510-
A Study of Improving
Compliance of Mobile Home Parks
Final Report
June 30, 1989
Prepared By
The National Rural Water Association
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ACKNOWLEDGMENTS
In conducting this study for the U.S. Environmental
Protection Agency, Office of Drinking Water, the National
Rural Water Association has been assisted by many indi-
viduals. We would like to thank especially Ms. Lois Canada
and Ms. Jane Ephremides who provided guidance during each
phase of the study.
The other individuals who diligently participated in this
study were:
o Mr. Tom Duck, Executive Director, Texas Rural Water
Association
o Mr. Larry Brown, Program Manager, Texas Rural Water
Association
o Mr. David Snead, Circuit Rider, Texas Rural Water
Association
o Mr. Bill Sparks, Field Representative, Texas Rural
Water Association
o Mr. Rick Tanner, Circuit Rider, Texas Rural Water
Association
o Ms. Janie Duderstadt, Administrative Secretary, Texas
Rural Water Association
o Mr. Dan Gilligan, President, National Manufactured
Housing Federation
o Ms. Charlotte Zimmerman, Vice President, Texas
Manufactured Housing Association
o Mr. Charles Maddox, Chief, Water Supply Division,
Texas Department of Health and his Staff
o Mr. Warren Norris, Environmental Engineer, U.S. EPA,
Region VI
o Mr. Mark Burrows, Environmental Protection Specialist,
U.S. EPA, Headquarters
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TABLE OF CONTENTS
EXECUTIVE SUMMARY
CHAPTER 1: INTRODUCTION
1.1
1.2
1.3
CHAPTER 2:
CHAPTER 3:
3.1
3.2
3.3
3.4
CHAPTER 4:
4.1
4.2
4.3
4.4
CHAPTER 5:
5.1
5.2
5.3
5.4
CHAPTER 6:
CHAPTER 7;
APPENDIX
Background
Purpose
Objectives
STUDY APPROACH
CLUSTER A - HOUSTON AREA
Profile
Principal Noncompliance Problems
Approach
Results
CLUSTER B - SAN ANTONIO AREA
Profile
Principal Noncompliance Problems
Approach
Results
CLUSTER C - DALLAS AREA
Profile
Principal Noncompliance Problems
Approach
Results
CONCLUSIONS
PROPOSAL FOR A NATIONAL PLAN TO
IMPROVE COMPLIANCE OF MOBILE
HOME PARKS
Page
iii
1
6
8
12
18
22
27
30
ii
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A STUDY OF IMPROVING COMPLIANCE
OF MOBILE HOME PARKS
Executive Summary
Background
Small systems account for most of the compliance
problems that exist in water systems today. The segment of
small systems that are identified as mobile home parks
(MHPs) represents 17 percent of the universe of small
systems and account for about 20 percent of all small
systems having microbiological violations nationwide.
Problems which contribute to the inability of the
mobile home park owners/operators to comply with the
requirements of the National Primary Drinking water
Regulations (NPOWRs) are: lack of education; confusion as
to which regulations to follow, State or EPA; lack of
appropriate personnel; reluctance of owners to put money
into their water systems; economic conditions; and cost
requirements of the 1986 Safe Drinking Water Act
Amendments. In addition, mobile home parks, for the most
part, have not been a target for education, training, and
technical assistance offered by Federal and State drinking
water programs.
Because of the magnitude of the noncompliance problem
in mobile home parks, a pilot project was designed to
assess the effectiveness of three different approaches to
improve compliance. The approaches used were information
dissemination, training and technical assistance, and
notification of possible liabilities due to system
noncompliance coupled with technical assistance.
Three clusters of mobile home parks were selected in
the State of Texas to receive a particular approach.
Cluster A - the Houston area received the information
dissemination approach. Cluster B - the San Antonio area
received the training and technical assistance approach.
And Cluster c - the Dallas area received the notification
of liabilities coupled with technical assistance approach.
All mobile home park water systems were ground water
systems. System size ranged from the smallest serving 17
people to the largest serving 2550 people.
ill
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For each cluster a set of measures was used to evaluate
responses to the approach used. For the purpose of this
study, the period of October 1, 1987 thru June 30, 1988 was
the base for determining whether systems were in
compliance. Compliance was tracked during the project
period, July 1, 1988 thru December 31, 1988 and was
compared to compliance during the base period.
Findings
Cluster A:
o Information dissemination as conducted was
ineffective. There were contributing factors which
were detrimental to this approach. First, the
information in the Texas Department of Health (TDH)
inventory was not entirely accurate due to the
difficulty in keeping abreast with frequent changes
in MHP ownership, owner addresses and phone
numbers. Secondly, it was found that many owners
are not located at the MHP. As a result, the
on-site contact was often not aware of the
material. Thirdly, the Houston District, TDH
routinely sends out sample bottles to water systems
for collection of compliance samples. This may have
confused those MHPs in the area as to the proper
procedure for dealing with the compliance
monitoring. However, no MHPs chose to use the
sample bag in lieu of the sample bottle.
o While compliance for the microbiological
requirements did improve during the period of July 1
to December 31, 1988, it cannot be directly
attributed to this special effort. However, it is
interesting to note that 14 MHPs returned to
compliance while eight went out of compliance.
Further examination of TDH compliance records could
reveal if this pattern is typical or not.
Cluster B:
o The training seminars were successful as judged by
the evaluation forms completed by the MHP
participants at the Kerrville and San Antonio
seminars. Information dissemination, however, was
marginally effective. The technical assistance
visits were successful from the perspective that
twenty-eight MHP contacts had a positive or neutral
reaction to the visit. Two MHP contacts were not
IV
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receptive to the circuit rider. "Hands-on"
technical assistance was rendered successfully in
four cases.
o Compliance did improve slightly but cannot be
directly attributed to this effort. Only three
systems that were visited were out of compliance at
the time of the visit. Additional compliance data
is needed to verify continued improvement in the
future.
Cluster C:
o The effectiveness of the enforcement effort is
difficult to judge. Comments from the TRWA circuit
riders indicate that MHP owner/operator visits may
have been more productive had a TDH representative
been present during the visit. Technical assistance
visits were marginally successful in that
information was disseminated and received by the 10
MHP owners/operators, however, only one MHP owner
accepted "hands-on" technical assistance. The
result that only one MHP was not receptive to the TA
is encouraging. The direct approach as employed for
this cluster opens the door for potential work in
the future.
o Compliance did improve, however, it cannot be
directly attributed to this effort. Additional
compliance data is needed to verify continued
improvement and the TDH needs to complete the
follow-up MHP inspections.
General:
o A coordinated or team approach used to address the
MHP noncompliance problem was beneficial. All
parties gained from the sharing of ideas and working
together to help solve the MHP noncompliance
problem. The effort provided a firm base from which
additional activities can be undertaken in the
future.
o Manufactured housing associations or groups
representing the MHPs should be utilized in
promoting and encouraging better compliance amongst
MHPs nationwide. EPA should encourage the National
Manufactured Housing Federation to place special
emphasis on this issue over the next few years.
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o Generally, MHP contacts were open to listening and
participating in some discussion concerning drinking
water information.
o Attempting to improve MHP compliance through the
dissemination of information via the mail was an
ineffective means of transferring information. This
was particularly true since the information often
failed to reach the intended owners/operators.
o MHP owners/operators do not see themselves as
purveyors of drinking water. Supplying water to
residents is just one of many responsibilities in
operating their business. This attitude is
reinforced and reflected in fact that most MHPs do
not separate the cost of supplying water from other
operating costs when billing MHP residents.
o Training seminars can be effective in transferring
information to MHP owners/managers and operators but
extensive ground work must be laid to assure
attendance at seminars.
NRWA Proposal to EPA
o A proposal for a national plan to address MHP
noncompliance was developed using the findings of
this project and the experience of NRWA in dealing
with small water systems.
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1.0 Introduction
1.1 Background
The highest priority of Federal and State drinking water
programs is to assure the compliance of public water supplies
(PWSs) with the National Primary Drinking Water Regulations
(NPDWRs). The Environmental Protection Agency's (EPA) FY 1987
Compliance Report indicates that microbiological noncompliance
is primarily a small systems problem. Systems defined as small
or very small (i.e., those serving between 25 and 3,300 persons
on a regular basis) account for both the greatest number of
systems and the greatest number of systems out of compliance
with the microbiological, turbidity and TTHM requirements.
Specifically, 95 percent of all significant noncompliers and
91.8 percent of all other noncompliers were small and very small
water systems.
Nationally, there are approximately 8,760 mobile home parks
(MHPs) which account for 17 percent of the small community
public water supplies serving populations between 25 and 3,300
individuals. Because States are not required to identify water
systems as MHPs in the Office of Drinking Water's Federal
Reporting Data System (FRDS) inventory, the actual number of
MHPs is probably greater. The Texas Department of Health, for
example, maintains an inventory of approximately 790 MHPs which
are not identified in FRDS. Sixty percent of the MHPs serve
less than 100 individuals and 94 percent of the MHPs serve
populations under 500 individuals. In addition, 97 percent of
all MHPs rely on ground water.
Based on the FRDS inventory, Region IV has the highest
concentration of MHPs while Regions I, II and X have the lowest
concentrations (Exhibit 1.1). The use of manufactured housing
is particularly widespread throughout rural areas of the country
and around small to medium-sized cities with populations under
half a million. Mobile homes have been an important source of
new housing over the past two decades because they are generally
more affordable, particularly in rural areas where incomes are
often low.
According to a market study conducted by Foremost Insurance,
traditional tenant MHPs are declining in popularity as more
manufactured homeowners locate their homes on their own property
or property belonging to either a friend or relative. Foremost
^Meeks, Carol B. "Mobile Homes - A Viable Alternative in Rural
America," Rural Development Perspectives. Feb. 1988. pp. 29-32.
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Exhibit 1.1
NUMBER OF MHPs IN
U.S. EPA REGIONS*
Insurance speculates that a primary reason for this change lies
in the continued rise in lot rents which averaged $138.00 a
month in 1987.2
MHPs account for 17 percent of all small public community
water supplies and represent 20 percent of all systems in
violation. The MHP problem is national in scope, however, the
greatest problem areas are concentrated in the south, Midwest
and western States. Region III has the highest concentration of
MHPs in violation as a percentage of the total number of small
systems in violation. In comparison, Region II has the fewest
MHP violations (Exhibit 1.2). Data further indicates that
microbiological monitoring and reporting (M/R) violations
account for approximately 70 percent of the MHP violations and
maximum contaminant level (MCL) violations represent the
remaining 30 percent.
Factors contributing to the problems associated with the MHP
water supplies include: absentee ownership; lack of trained
Manufactured Homes - The Market Facts. Foremost Insurance
Group, p. 10, 1988.
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EXHIBIT 1.2
REGIONAL MOBILE HOME PARK (MHP) STATISTICS
REGION
REGION
REGION
REGION
REGION
REGION
REGION
REGION
REGION
REGION
I 'SMALL
MHP
*
II SMALL
MHP
*
III SMALL
MHP
*
IV SMALL
MHP
*
V SMALL
MHP
%
VI SMALL
MHP
%
VII SMALL
MHP
%
VIII SMALL
MHP
%
IX SMALL
MHP
%
X SMALL
MHP
%
MHP
MICROBIOLOGICAL
TOTAL VIOLATION TYPE
SYSTEMS IN
VIOLATION MCL M/R
SYS 412
50 21 33
12%
SYS 5,451
70 7 65
1%
SYS 6,009
540 243 424
9%
SYS 5,642
1,130 392 1,006
20%
SYS 2,502
460 134 396
18%
SYS 2,695
176 127 88
7%
SYS 1,578
172 93 111
11%
SYS 3,069
590 172 451
19%
SYS 2,320
261 115 222
11%
SYS 6,575
168 19 161
3%
STATES
NOT REPORTING
MHP DATA I/
RHODE ISLAND
NEW YORK
VIRGIN ISLANDS
PUERTO RICO
GEORGIA
TEXAS
UTAH
CALIFORNIA
HAWAII
GUAM/SAMOA
WASHINGTON
TOTAL SMALL SYS 36,253
TOTAL MHP 3,617 1,323 2,957
% 10%
1987 FRDS DATA (2/22/88)
I/ States are not required to code water systems as MHPs
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personnel; poor management practices including a lack of
on-going maintenance; regional economic conditions; cost
requirements to implement the 1986 Safe Drinking Water Act
(SDWA) Amendments; and a general reluctance by MHP owners and
operators to work with primacy agencies.
MHPs, for the most part, are profit-making enterprises
dependent upon ground water and are very simple in design,
usually having only a pressurized storage tank and possibly a
chlorinator. Because of their small size, rural composition and
apparently low profit margins, MHPs are very susceptible to
slight economic changes. Unlike the small community public
water supply systems whose management is by an elected public
official, MHP owners and operators are often motivated by
maintaining the greatest profit margin possible. As a result,
many MHP owners and operators have been reluctant to make
improvements to their water systems in order to comply with the
current SDWA Amendments.
In addition, MHPs have not been a target for education,
training, and technical assistance offered by Federal and State
drinking water programs. Efforts and materials that are
available from the national and State levels have not addressed
the issues, problems and needs that relate directly to the MHP
community.
1.2 Purpose
The purpose of this project is to document the effectiveness
of three approaches to improving compliance of MHP water
systems. The three approaches are: (1) information
dissemination, (2) training and technical assistance (TA), and
(3) notification of possible liabilities due to noncompliance
coupled with on-site technical assistance.
By determining the effectiveness of these approaches,
primacy agencies and EPA can develop and implement more
effective compliance improvement programs directed at MHPs. In
addition, any brochures or pamphlets developed as part of this
project could be useful, with some slight changes, on a
nationwide or regional basis.
1.3 Obj ectives
Specific objectives developed for this pilot project are:
1. To demonstrate that a coordinated effort is essential
and effective in solving compliance problems with
targeted group of MHPs.
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2. To field test three approaches for improving MCL and M/R
compliance of MHP water systems.
3. To assess the field test and prepare a final report to
include: materials used for information dissemination
and seminars, a summary of the TA provided, and an
assessment of the overall effectiveness of the program
considering each element individually and together.
4. To identify other methods, materials, or initiatives
that could be utilized to effectively increase
compliance among MHPs either on a national or regional
basis.
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2.0 The Texas MHP Study
The National Rural Water Association (NRWA) and EPA
representatives considered Texas to be the best State for the
MHP study. Several factors were considered including: 1) the
number of MHPs, 2) strong commitments to support the study by
both the Texas Rural Water Association (TRWA) and the Texas
Manufactured Housing Association (TMHA), and 3) State and
regional support.3
Once Texas was selected, the NRWA established and managed a
Steering Committee comprised of representatives from EPA
Headquarters and Regional Offices, Texas Department of Health
(TDH), TMHA and the TRWA. The Steering Committee's
responsibility was to oversee the project and review final
plans, training and educational materials, and assist in the
development of the outline for the final report. For the
purpose of this project the Steering Committee decided that
technical assistance include: (1) furnishing of technical
advice, educational materials or referrals to sources of
information via telephone or mail, and (2) furnishing advice,
educational materials, or training on-site.
Three approaches to improving compliance with the
microbiological requirements were designed by the Steering
Committee early in the project period. Three separate clusters
of MHPs were identified by EPA and TDH and were targeted to
receive one of the approaches to improve compliance (see
Appendix A for Location and Inventory).
Cluster A (Houston Area) received the information
dissemination approach. This approach consisted of providing a
pamphlet and booklet to all MHP owner/operators containing
information on SDWA requirements and offering additional
information and assistance upon request. The pamphlet and
booklet (Appendix B) were provided by EPA and distributed by the
TMHA. A coded sampling form was included for use by the system
operator.
Cluster B (San Antonio Area) received the training and
technical assistance approach. This approach conisted of
conducting two one-day training seminars organized and designed
to meet the needs of the MHP owners/operators. The sessions
focused on the requirements that are the major causes of
noncompliance. In conjunction with the training seminars, TRWA
offered on-site technical assistance to systems in attendance.
3Because Texas is not required to identify public water systems
as MHPs in the Office of Drinking Water's FRDS inventory, it was
necessary use State MHP data for this study.
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Cluster C (Dallas Area) received the notification of legal
liabilities due to noncompliance coupled with the offer of
technical assistance. This approach targeted ten MHP systems,
each having a history of microbiological violations. They were
identified by the TDK, and mutually agreed upon by the TRWA and
EPA Region VI as viable systems to receive technical
assistance. These ten systems were notified by the TMHA of the
SDWA requirements and possible liabilities for noncompliance
with the requirements. The notification was coupled with
on-site technical assistance by the TRWA.
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3.0 Cluster A - Houston Area
3.1 Profile
Cluster A has a total of 290 MHPs covering an eight county
area in the Houston Region (see Appendix A for map). Exhibit
3.1 shows the total number of MHPs by county. Harris county,
which includes the city of Houston, contains the most MHPs (163)
and represents 56 percent of the total number of MHPs in this
cluster. All the systems are ground water systems and
collectively serve a population of 35,997. The smallest MHP
water system serves 17 people and the largest serves 1200 people
and is located in Montgomery County. The average MHP water
system serves 124 individuals.
Exhibit 3.1
Houston Region Mobile Home Parks
County
Brazoria
Chambers
Ft. Bend
Galveston
Harris
Liberty
Montgomery
Waller
Total MHPs
49
8
11
4
163
15
34
6
Total 290
Total
Pop. Served
4,111
1,061
588
196
20,671
1,706
7,340
324
35,997
3.2 Principal Noncompliance Problems
During the base compliance period 25 MHPs or 8.6 percent of
the total 290 MHPs were out of compliance one or more times.
Exhibit 3.2 shows the number of MHPs in violation of the
mirobiological requirements which are categorized as MCL and M/R
violations. The major area of violation was microbiological M/R
requirements (15) followed by microbiological MCL (10).
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Exhibit 3.2
Houston Region Mobile Home Parks
Compliance Summary
October 1, 1987 - June 30, 1988
County
Brazoria
Chambers
Ft. Bend
Galveston
Harris
Liberty
Montgomery
Waller
Total
Number of
Systems Having
Microbiological
Violations
MCL M/R
4 0
0 1
1 2
1 0
4 9
0 1
0 2
0 0
To Is
3.3 Approach - Cluster A
Dissemination of educational information was the only tool
used to promote compliance of MHPs in Cluster A. A pamphlet and
a booklet were developed for and distributed to MHP owners and
operators (see Appendix B). The pamphlet "Keeping Drinking
Water Safe to Drink - It's Up To You" provided general
information about drinking water quality, SDWA requirements,
Texas drinking water regulations and specific information about
testing and sampling for microbiological contaminants. The
booklet "Straight Talk About Water Sampling" was developed in a
question and answer format and provides information on when
microbiological sampling is necessary, where and how to take
samples using the provided plastic sample bags, where to send
the sample, and what to do if there was a positive result
(microbiological contamination present).
The pamphlet and booklet together with a pre-coded sample
form (Appendix C) and plastic sample bag were sent to each MHP
in Cluster A. A cover letter (Appendix D) was written and sent
by TMHA. The tone of the letter was designed to "soft sell" the
responsibility of MHP owners and operators. The letter
explained that their understanding of the information in both
the pamphlet and booklet would make their job easier. The
letter also offered assistance through the TMHA. Within
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a two to three week period after sending the information, TMHA
contacted 20 percent of the MHPs in Cluster A to determine if
the package had been received and what general reaction each had
to the information.
The Steering Committee agreed that the following parameters
would measure the success of this approach:
1. The number of MHPs requesting additional information and
the type of information requested.
2. The number of MHPs sending in a water sample using the
pre-coded sample form and sample bag.
3. Compliance improvement of entire cluster based on the
compliance record prior to the project (Oct. 1, 1987
thru June 30, 1988).
4. Compliance improvement of MHPs who requested additional
information.
3.4 Results
Phone calls were placed by the TMHA to 197 MHPs in this
Cluster. A total of 58 MHP owners/operators/managers were
contacted by phone. General observations made by the TMHA as a
result of talking to the 58 MHP contacts were, as follows:
o Many respondents had not read the material thoroughly.
o Very few respondents grasped the fact that the letter
was for general information and was an attempt to assist
them.
o Many questioned why they were "singled out" by EPA and
the TDK to receive the letter. Some respondents were
hostile to the caller.
As to the remaining measures of effectiveness for this
approach, the following observations were made:
o TMHA, TRWA and TOH did not receive any calls for
technical assistance.
o No MHPs returned the pre-coded sample forms or sample
bags to be analyzed.
o Many MHPs could not be reached because of inaccurate
inventory data; names of systems' owners/operators and
their telephone numbers change frequently over time.
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o Fourteen systems out of compliance during the base
period returned to compliance during the period July l
to December 31, 1988 (project period). Eight MHPs which
were in compliance during the base period went out of
compliance during the project period.
o During the six month period (July 1 thru December 31,
1988) compliance improved. Three more systems were in
compliance with each of the microbiological MCL and M/R
requirements (see Exhibit 3.3). Although compliance did
improve, it is difficult to attribute the change to this
special effort. Further examination of TDK compliance
records may reveal if this pattern is typical or not.
Exhibit 3.3
Houston Region Mobile Home Park
Compliance Summary
Period July 1 - December 31, 1988
County
Brazoria
Chambers
Ft. Bend
Galveston
Harris
Liberty
Montgomery
Waller
Total
Number of
Systems Having
Microbiological
Violations
(Change)
MCL M/R
1 (-3) 1 (+1)
0 0 (-1)
1 2
0 (-1) 0
5 (+1) 7 (-2)
0 0 (-1)
0 2
0 0
7 (-3) 12 (-3)
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4.0 Cluster B - San Antonio Area
4.1 Profile
Cluster B has a total of 76 MHPs covering a 10 county area
in the San Antonio Region (see Appendix B). Exhibit 4.1 shows
the total number of MHPs by county. Two counties, Bexar and
Kerr, have the largest number of MHPs and together account for
39 percent of the MHPs in the Cluster. All MHP systems are
groundwater systems and collectively serve a population of
11,981. The smallest MHP water systems serves 25 people and the
largest serves 1,200 people and is located in Travis county.
The average MHP serves 158 residents.
Exhibit 4.l
San Antonio Region Mobile Home Parks
County
Bexar
Blanco
Caldwell
Comal
Hays
Kendall
Kerr
Medina
Travis
Williamson
Total
Total MHP
22
1
1
5
4
8
18
4
9
4
76
Total
POD. Served
3,493
60
120
834
465
736
2,320
449
3,020
484
11,981
4.2 Principal Noncompliance Problems
During the base compliance period 9 MHPs or 11.0 percent of
the total 76 MHPs had one or more microbiological violations.
Exhibit 4.2 shows the number of MHPs in violation of the
microbiological MCL and M/R requirements. The major area of
violation was the microbiological MCL (5) followed by
microbiological M/R (4).
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Exhibit 4.2
San Antonio Region Mobile Home Parks
Compliance Summary
October 1, 1987 - June 30, 1988
County
Bexar
Blanco
Caldwell
Comal
Hays
Kendall
Kerr (1)
Medina
Travis
Williamson
Total
(1) One system had MCL and
was counted as both.
Number of
Systems Having
Microbiological
Violations
MCL M/R
1 0
0 0
0 0
1 1
1 0
0 0
2 3
0 0
0 0
0 0
~~5 ~4
M/R violations and
4.3 Approach
Information dissemination, training, and technical
assistance were used to encourage compliance in Cluster B. The
information dissemination package (Appendix E) differed from
Cluster A by offering a free seminar to the MHP owners and
operators. Date and location of each seminar was given and and
an agenda was provided (Appendix F) as an enclosure. Also
included in the information package was a seminar registration
form and the pamphlet entitled "Keeping Drinking Water Safe To
Drink - It's Up To You."
A important feature of the seminars was that the TDH would
give operator certification credit to the participants. The
seminars were organized by TRWA with the TDH being the chief
contributor to the program. Information on each topic covered
during the seminar (Appendix G) and the booklet entitled
"Straight Talk About Water" together with the pre-coded sample
form and plastic sample bag were given to each participant. The
attendees were asked to fill out a registration form and a
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training evaluation form (Appendix H). At the conclusion of the
training session on-site technical assistance was offered to the
participants.
A slight modification was made in this approach due to the
small number of MHP owners/operators/managers attending the
seminars. Originally, it was assumed that 30 to 35 on-site
technical assistance visits would be made to MHPs in this
cluster. Assistance would be given to seminar participants and
any MHPs calling TMHA for on-site TA. However, as a result to
the lower than anticipated attendance, TRWA also provided random
on-site technical assistance to other MHPs in the cluster not
represented at the seminar.
The Steering Committee agreed to the following as measures
of success using this approach:
1. The number of MHPs attending the seminars.
2. The number of MHPs requesting on-site technical
assistance.
3. Compliance improvement based on compliance records prior
to project versus compliance after receipt of
information.
4. Evaluation of seminar participants:
- number of certified operators/years experience
- number of operators
- number of owners
- number of others
- number of years with MHPs.
5. Evaluation of seminar content (participant evaluation
forms).
6. Assessment of pamphlet and booklet:
- content
- format
- improvements needed (does it meet your needs for
information).
4.4 Results
The TMHA tried to contact 20 MHPs by telephone in this
Cluster, however, only 15 were actually reached. All MHPs
contacted had received the information. None of the 15 were out
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of compliance during the base period. One system which was
contacted violated the microbiological M/R requirement during
the period July 1 thru September 30, 1988, but returned to
compliance during the subsequent period, October 1 thru December
30, 1988.
Response to the training sessions was limited. A total of
22 persons attended the training session in San Antonio
(Appendix I). Seven individuals were MHP officials,
representing five different MHPs. The remaining participants
were associated with the sponsoring groups. The seven MHP
representatives were all owners/managers. None of them
represented systems that were out of compliance during the base
compliance period. However, one system went out of compliance
with the microbiological MCL during the October - December, 1988
period. Two had received training previously from the TDH
and/or TRWA. Four of the MHP representatives completed the
training evaluation forms. All felt that the training helped
them professionally and rated the overall session in its
usefulness between 7 and 10 on a rating scale of 1 to 10 with
one being poor and 10 being good. As a side note, the other
participants (EPA, TDH, TMHA and TRWA) rated the session in the
range of 6-10 (see Appendix J for all evaluations).
The Kerrville training session had 21 attendees with eight
individuals representing eight different MHPs (Appendix K). All
MHP representatives were system owners/managers. Of these MHPs,
one system was out of compliance during the base period and
remained out of compliance during the project period. Two MHP
participants had received TDH or TRWA training previously. Six
of the eight MHP participants completed the evaluation forms.
They rated the session in its usefulness between 8-10. The
remaining participants representing sponsoring groups did not
fill out evaluation forms, but many felt that the session went
smoother than the San Antonio session (see Appendix L for
evaluation).
None of the participants in either session voluntarily
requested on-site TA. Results that can be ascertained from the
circuit rider's contact of 30 MHPs in this cluster (see Appendix
M) are as follows:
o No phone calls were received by TMHA or TDH asking for
additional information (off-site technical assistance).
o Reaction of the people contacted by the circuit rider
during the TA visit was largely neutral in that they were
willing to listen, and participate in some discussion
about the project. Ten contacts were clearly
15
-------
positive in
idea. Two
rider.
that they thought the project was a good
contacts were not receptive to the circuit
o Five MHP contacts remembered receiving the information
and materials mailed to them about the project. Of these
five contacts, two indicated that they understood the
materials and three were confused and did not understand
it.
o During the six month period June 1 thru December 31,
1988, two more systems came into compliance with the MCL
while one more system was out of compliance with the M/R
requirements (see Exhibit 4.3).
Exhibit 4.3
San Antonio Region Mobile Home Park
Compliance Summary
Period July 1 - December 31, 1988
County
Number of
Systems Having
Microbiological
Violations
(Change)
MCL
Bexar
Blanco
Caldwell
Comal
Hays
Kendall
Kerr
Medina
Travis
Williamson
Total
0
0
0
0
0
1
1
l
0
0
3
(-D
(-D
(-1)
(+D
(-D
( + 1)
(-2)
M/R
0
0
0
0
0
0
3
0
2
0
5
(-D
(4-2)
( + D
Four MHPs contacted had technical problems which were
addressed by the circuit rider. One MHP had a leaking
chlorinator and was not familiar with proper sampling
procedures. One MHP had mapping problems and two had
16
-------
metering problems. Technical assistance was rendered in
all of these cases. The remaining 26 MHPs indicated that
they had no problems, and did not request any assistance.
o Six MHPs out of compliance during the base period
returned to compliance during the project period. Three
MHPs in compliance during the base period went out of
compliance during the project period.
17
-------
5.0 Cluster C - Dallas Area
5.1 Profile
Cluster C has a total of 142 MHPs covering an eight county
area. Johnson County has the largest number of MHPs (41),
representing 18 percent of the total MHPs in this cluster.
Exhibit 5.1 shows the total number of MHPs by county. All
systems are ground water systems with the smallest system
serving 18 people and the largest serving 2,550 people located
in Johnson County. The average MHP serves 175 individuals.
Exhibit 5.1
Dallas Region Mobile Home Parks
County
Collin
Dallas
Denton
Hood
Johnson
Parker
Tarrant
Wise
Total MHPs
1
10
26
15
41
11
31
7
Total 142
Total
POD . Served
800
1,303
7,505
2,385
6,280
2,529
3,342
620
24,764
5.2 Principle Noncompliance Problems
During the base compliance period 17 MHPs or 12 percent of
the total of 142 MHPs were out of compliance one or more times
with the microbiological requirements. Exhibit 5.2 shows the
number of MHPs in violation of the microbiological
requirements. There were nine systems with microbiological MCL
violations and eight systems with M/R violations.
18
-------
Exhibit 5.2
Dallas Region Mobile Home Parks
Compliance Summary
October 1, 1987 - June 30, 1988
County
Collin
Dallas
Denton
Hood
Johnson
Parker
Tarrant
Wise
Number of
Systems Having
Microbiological
Violations
MCL M/R
0 0
0 1
2 2
1 0
1 3
0 1
5 1
0 0
Total ~~9 ~8
5.3 Approach
Information dissemination followed by an offer for on-site
technical assistance were used to encourage compliance in this
cluster. Ten MHPs were selected from this cluster based on
their history of noncompliance and whether a routine sanitary
survey, by the TDH, was scheduled in the near future. The TDK
and the TRWA mutually agreed on the selection of the ten
systems. Initially a letter from TMHA was sent to the ten MHPs
in this cluster (Appendix N). The tone of the letter was a
"hard sell" to point out the responsibilities of providing safe
drinking water and the possible consequences of not meeting
current requirements. The pamphlet entitled "Keeping Drinking
Water Safe to Drink - It's Up To You" was an enclosure to the
letter. The letter indicated to the reader that the TRWA would
contact them to schedule an on-site technical assistance visit.
Each system was contacted to schedule an on-site visit. It
was agreed by the Steering Committee that a maximum of two
on-site visits would be made in an attempt to encourage the
owner/operator to receive help. Where TA was rendered the TRWA
prepared a routine report (Appendix O) of the visi't and action
taken. Following the TA visits by the TRWA, the TDH scheduled' a
routine sanitary survey on each system.
19
-------
The Steering Committee agreed that the following criteria
would be used to evaluate this approach:
1. Number of MHP receiving on-site technical assistance
2. Compliance improvement of the Cluster
3. Evaluation of on-site technical assistance given
- did compliance improve as a result?
- did TDK ranking improve as a result of TA?
- did the system make the recommended change(s)?
- type of TA given?
- type of material(s) provided?
- did TDK follow-up on TA provided by TRWA?
5.4 Results
The TMHA made phone calls to 54 MHPs in this cluster to
determine if the letter was received. Twenty systems were
actually contacted, others were busy, disconnected or the wrong
number was reached. Six of the MHPs did not receive the letter
while 14 did receive the letter. Those that received the letter
generally had the same reaction as those in the other clusters.
The primary reaction was concern for why they were singled out
for this project and many did not fully understand the project.
Technical assistance visits were conducted by the TRWA.
Prior to each initial visit, phone calls were made to the MHPs.
In four cases, appointments for on-site visits were made and the
remaining initial visits were all "cold calls". A total of 18
TA visits were made; three MHPs received one visit each, six
MHPs received two visits each and one MHP received three
visits. Hands-on TA was rendered to one MHP. The TA provided
was for proper sampling procedures, flushing water lines and
measuring chlorine residual. All MHPs visited received the
letter, pamphlet and booklet.
One MHP visited in this cluster was hostile to the circuit
rider. In this case the issue was State and Federal regulations
and there appeared to be little concern for complying with
them. As a side note, the person contacted indicated that the
MHP was for sale and that he was very anxious to get out "from
under the entire thing." On the second visit to this MHP, the
circuit rider indicated that the contact would not answer the
door. The remaining TA visits are characterized by the response
of the contact person. The two categories are indifferent and
interested. Five contacts expressed interest in the project
and/or improving their system. Four contacts expressed
indifference to the project and to receiving any technical
assistance.
20
-------
During the six month period July 1 thru December 31, 1988,
there were five fewer systems in violation of the micro-
biological MCL and four fewer systems in violation of the
microbiological M/R requirements (see Exhibit 5.4). Fourteen
systems out of compliance during the base period returned to
compliance during the project period. Five systems in
compliance during the base period went out of compliance during
the project period.
Exhibit 5.3
Dallas Region Mobile Home Parks
Compliance Summary
Period July 1 - December 31, 1988
Number of
Systems Having
Microbiological
Violations
(Change)
County
Coll in
Dallas
Denton
Hood
Johnson
Parker
Tarrant
Wise
MCL
0
0
0
0
1
1
1
1
Total 4
(-2)
(-1)
(+D
(-4)
(+D
(-5)
M/R
0
0
0
0
1
0
3
0
4
(-1)
(-2)
(-2)
(-1)
(+2)
(-4)
The TDH scheduled follow-up sanitary surveys on each of the
ten systems selected for the second and third quarters in FY
1989. As of this writing, however, none have been completed.
As a result, the evaluation of this TA effort is not possible.
21
-------
6.0 Texas MHP Study Conclusions
6.1 Conclusions
The project objective was to assess the effectiveness of
three different approaches to improving MHP compliance. MHP
compliance improved in all three clusters with the greatest
change occurring in Cluster C the Dallas Region, which
received the notification of liabilities coupled with technical
assistance approach. However, given the limitations of the
study, the improved compliance cannot be correlated directly
with the approach used. This is also true for the other
approaches. Further study of the TDK compliance records, which
is beyond the scope of this study, may provide more insight on
this matter. Specific conclusions and recommendations for each
approach follows.
Cluster A:
o Information dissemination as conducted was ineffective.
The objective of the information dissemination approach
was to encourage requests for information concerning
drinking water and to improve compliance. No requests
were received by TMHA or TRWA for TA from this cluster.
Even when phone calls were made to MHPs, no contacts
requested additional information.
There were contributing factors which were detrimental to
this approach. First, the information in the TDK
inventory was not entirely accurate due to the difficulty
in keeping abreast with frequent changes in owner
addresses and phone numbers. Second, it was found that
many owners are not located at the MHP. Consequently,
the information received by the off-site owner was not
made available to the on-site operator. Third, it was
discovered that the Houston District, TDH routinely sends
out sample bottles to water systems for collection of
compliance samples. This may have confused those MHPs in
the area as to the proper procedure for dealing with the
compliance monitoring. However, no MHPs chose to use the
sample bag in lieu of the sample bottle.
In the future, consider activities or events which stress
personal contact as a means of providing information to
MHP owners/operators such as such as at annual meetings
of State manufactured housing associations, local civic
meetings, and community fellowship activities.
22
-------
o State inventories of MHPs should include the name,
address and current phone number of the local contact
person in addition to the owners name, address and phone
number. This information can be updated during routine
site inspections, sanitary surveys, or compliance
monitoring by State personnel. Require systems to notify
the State when there is a change of address, ownership,
etc.
o The reaction of the MHPs to the letter from TMHA was
surprising because it was assumed that using TMHA as the
focal point that the MHPs would not be threatened by
potential enforcement by TDK or EPA, and therefore,
respond more favorably to the information. In
retrospect, however, the letter did include the names of
the participating organizations so that the reader could
easily associate and probably did associate or link the
letter to TDK and/or EPA.
o The fact that those that read the information seemed
confused is more attributed to their concern about being
singled out than to confusion over the substance of the
material. TMHA has been in the business of communicating
effectively with its membership for many years. Their
experience was used in preparing the letters and the
pamphlet and booklet.
o While compliance for the microbiological requirements did
improve during the period of July 1 to December 31, 1988,
it cannot be directly attributed to the special effort.
However, it is interesting to note that 14 MHPs returned
to compliance while seven went out of compliance.
Further examination of TDK compliance records could
reveal if this pattern is typical or not.
Cluster B:
o Information dissemination was marginally effective. The
MHPs contacted by phone that remembered receiving the
information had the same general reaction as those in
Cluster A. However, thirteen MHPs participated in the
seminars in San Antonio and Kerrville. This response may
be attributed to the letter to Cluster B which included
the offer of free seminars and receipt of classroom
credits towards State certification as a water operator.
o If training seminars are conducted for MHPs, ground work
must be laid to assure good attendance. On-site contacts
should be made well in advance of the seminars.
23
-------
Informational materials should be delivered at the time
of the contact and followed up with a phone call and an
announcement.
o TDK's inventory information was not sufficient to assure
the seminar announcement would be received by
managers/operators on-site who are responsible for the
day-to-day operations. Many of the letters went to
absentee owners.
o The training seminars were successful as judged by the
evaluation forms completed by the MHP participants. The
Kerrville seminar was more successful than the San
Antonio seminar based on the number of MHP participants
and their general reaction to it as discovered in
discussions with them during break periods and after the
conclusion of the seminar. Two things contributed
greatly to this. It.was the second seminar conducted and
the trainers were conveying the message more effectively
and the location was conducive to attracting more MHP
participants. On this last point, several of the
participants in the San Antonio seminar had difficulty
finding the site whereas no such problems were
encountered by the participants of the Kerrville
seminar. The San Antonio site was located adjacent to a
major freeway but was in an area of traffic congestion
and confusing traffic patterns. The Kerrville site was
in a rural area at a well known hotel.
o The technical assistance visits were successful from the
perspective that the majority of MHP contacts were either
neutral or receptive to the circuit rider. Technical
assistance in the form of information dissemination was
delivered to all contacts. "Hands-on" technical
assistance was rendered successfully in four cases.
o Compliance did improve slightly but cannot be directly
attributed to this effort. Only three systems that were
visited were out of compliance at the time of the visit.
Second quarter FY 1989 compliance data, not available at
the time of this writing, may provide further insight.
Cluster C:
o The effectiveness of the enforcement effort is difficult
to judge. Comments from the TRWA circuit riders indicate
that MHP owner/operator visits may have been more
productive had a TDK representative been present during
the visit. Technical assistance visits were marginally
successful in that information was disseminated and
24
-------
received by the 10 MHP owners and operators, however,
only one MHP owner accepted "hands-on" technical
assistance. The result that only one MHP was not
receptive is encouraging. At least the direct approach
as employed for this cluster opens the door for potential
work in the future.
o Compliance did improve, however, it cannot be directly
attributed to this effort. Additional compliance data is
needed to verify continued improvement and the TDH needs
to complete the follow-up MHP inspections.
General:
o The team approach used to address the MHP noncompliance
problem was beneficial. All parties gained from the
sharing of ideas and working together to help solve the
MHP noncompliance problem. The effort provided a firm
base from which additional activities can be undertaken
in the future.
o Manufactured housing associations or groups representing
the MHPs should be utilized in promoting and encouraging
better compliance amongst MHPs nationwide. EPA should
encourage the National Manufactured Housing Federation to
place special emphasis on this issue over the next few
years.
o Generally, MHP contacts were open to listening and
participating in some discussion concerning drinking
water information.
o Dissemination of information via the mail was an
ineffective means of transferring information to the MHPs
and attempting to improve compliance. This was
particularly true since the information did not reach the
intended owners/operators.
o MHP owners/operators do not see themselves as purveyors
of drinking water. Supplying water to residents is just
one of many responsibilities in operating their
business. This attitude is reinforced and reflected in
fact that most MHPs do not separate the cost of supplying
water from other operating costs when billing MHP
residents.
o Training seminars can be effective in transferring
information to MHP owners/managers and operators but
extensive ground work must be laid to assure attendance
at seminars.
25
-------
o TA visits were marginally successful. Information was
disseminated in all cases and hands on TA was
successfully given (received) in one case. However, at
this writing, it cannot be determined if that system
returned to compliance during the second quarter FY
1989. The result that only one MHP was not receptive is
encouraging. The direct approach a3 practiced for this
cluster opens the door for potential work in the future
and it appears that given additional time more positive
results would have been seen.
o A proposal for a national plan to address MHP
noncompliance was developed using the findings of this
project and the experience of NRWA in dealing with small
water systems.
26
-------
7.0 NRWA Proposal for A National Plan to Improve
Compliance of Mobile Home Paries
The timing for a special effort could not be better. New
microbiological regulations became Federal law in June 1989 and
States will begin adopting them during the following eighteen
months. Much information must be transferred to water systems
concerning these new requirements. This presents a unique
opportunity for EPA to incorporate changes in current policies
and procedures used in dealing with noncompliant MHPs.
Based on EPA's compliance data, NRWA recommends that EPA
initially focus it efforts in two Regions Region IV and
VIII. Approximately 44 percent of the MHP systems in violation
of the microbiological requirements are located in these
Regions. The Agency should consider efforts in selected States
in other Regions if resources permit. The Agency is already
partially funding some innovative MHP work in Pennsylvania.
Three tools enforcement, financial, and training and
technical assistance are the focus of this proposed plan.
Enforcement
Enforcement has been minimal on MHPs. Yet many States
generally have more enforcement tools to use against
noncompliant MHPs. Many States have permitting and/or licensing
requirements for MHPs. However, responsibility for permitting
and/or licensing is usually not under the primacy agency. Where
this is the case, primacy agencies should develop working
agreements with the licensing agencies. The end result being
that permits/licenses be suspended (provisionally or
permanently) based on level of noncompliance with drinking water
requirements. State agencies involved in the permitting and/or
licensing process should elevate the importance of delivering
safe drinking water.
An escalation of tougher permit and licensing requirements
could result in some difficult political realities, especially
if the State considers withdrawing the permit or license on a
permanent basis. However, with a clear statement of policy
up-front and the State playing the role of a "benevolent
regulator" the policy would be workable. On this point, the
State could devise a phased approach over two to three years
based on MHP size (population), violation history,
recalcitrance, etc.
The State may require noncompliant MHP owners and managers
to attend training courses and/or seek technical assistance in
order to maintain the MHP permit/license. Mandatory attendance
27
-------
at training sessions would serve two purposes: an incentive to
comply because of the cost of time and money (although minimal)
to attend, and an opportunity to learn how to meet the safe
drinking water requirements.
Financial
With few exceptions, MHPs are operated as a business
enterprise. The incentive for owning such a business is the
potential for income and profit. Using this basic premise,
primacy agencies should focus efforts on appealing to financial
incentives for owners to improve MHP water systems.
A basic financial information package should be developed by
EPA in cooperation with National Manufactured Housing
Federation. It should be modeled after the Small Business
Administration packages and should include the following
information:
o Financial Management of MHP with special emphasis on
utilities (Consider the concept of MHPs billing
separately for utility service and space rental to
encourage the idea of making both utilities and space
rental as profit centers);
o Tips on improving income in a competitive environment
(i.e., encouraging MHPs to install water meters); and
o Sources of additional information.
Training and Technical Assistance
Training should be focused on financial management and
utility operations and could be offered by State regulatory
agencies and other appropriate organizations such as the NRWA,
the Rural Community Association Program, AWWA, and the National
Environmental Health Association. The financial information
package as above could be used as the focus of the training.
Technical assistance could be offered to the participating MHPs,
however, sufficient ground work must be made prior to holding
these sessions. On-sight MHP visitations would be one way to
ensure good attendance at the training sessions.
28
-------
Plan
Primacy Agencies, in States with large numbers of MHPs,
should form a funded advisory committee to deal specifically
with MHPs. It should consist of representatives from the MHP
industry and association(s), State regulatory personnel
representing the MHP licensing agency, State training personnel,
public utility commissions, Rural Community Assistance Projects
and other associations as appropriate. The responsibility of
the committee is to advise the State on its activities and
effort to improve MHP compliance and assist in development of
specific plans and recommend policies concerning MHPs including:
1. Identifying organizations and groups that have an
interest or are able to assist MHPs;
2. Agreeing on the MHP problem(s) to address and designing a
plan of action to address them; and
3. Publicizing activities and results.
A training and technical assistance plan should be
established for a two to three year period that covers the State
geographically and offers financial and utility management. At
least one course should be conducted quarterly. On-site
technical assistance could be offered in conjunction with-the
training courses.
The primacy agency would focus its enforcement activities on
the permitting/licensing process and/or issuing administrative
orders. At the same time primacy agencies should require
recalcitrant MHP system owners to attend training sessions and
to seek technical assistance.
29
-------
APPENDIX
Appendix A
Appendix B
Appendix C
Appendix D
Appendix E
Appendix F
Appendix G
Appendix H
Appendix I
Appendix J
Appendix K
Appendix L
Appendix M
Appendix N
Appendix O
Cluster Location
Cluster Inventory
Pamphlet "Keeping Drinking Water
Safe to Drink"
Preceded Sample Form
Cover Letter to Cluster A
Cover Letter to Cluster B
Seminar Agenda
Seminar Materials
Seminar Registration Form
Seminar Evaluation Form
(Example)
San Antonio Seminar Registration
San Antonio Seminar Evaluations
(Example)
Kerrville Seminar Registration
Kerrville Seminar Evaluations
(Example)
Technical Assistance Reports for
Cluster B (Example)
Cover Letter to Cluster C
Technical Assistance Reports for
Cluster C (Example)
30
-------
Appendix A
-------
PUBLIC HEALTH REGIONS
CLUSTER C
REGIONAL OFFICES
CLUSTER A
CLUSTER B
TDK AG-5
-------
TDH INVENTORY - 1986 DATA
Cluster A
County No.
20
36
79
84
101
146
170
237
County
Brazoria
Chambers
Ft. Bend
Galveston
Harris
Liberty
Montgomery
Waller
* PWS
49
8
11
4
163
15
34
6
Cluster B
15
16
28
46
105
130
133
163
227
246
Bexar
Blanco
Caldwell
Comal
Hays
Kendall
Kerr
Medina
Travis
Wi 11 i amson
22
1
1
5
4
8
18
4
9
4
"76
Cluster C
43
57
61
111
126
184
220
249
Collin
Dal las
Denton
Hood
Johnson
Parker
Tarrant
Wise
1
10
26
15
41
11
31
7
w
-------
Texas Mobile Home Parks - 1986 Data
(CLUSTER A)
PWS ID POP. SERVED
0200017
0200055
0200064
0200099
0200102
0200105
0200118
0200119
0200122
0200129
0200133
0200134
0200137
0200144
0200151
0200153
0200158
0200181
0200183
0200190
0200191
0200219
0200223
0200226
0200227
0200229
0200242
0200244
0200248
0200251
0200252
0200255
0200258
0200273
0200274
0200275
0200282
0200307
0200329
0200337
0200353
0200379
0200382
0200390
0200403
0200413
0200415
0000108
0000080
0000075
0000025
0000195
0000026
0000032
0000030
0000039
0000033
0000045
0000105
0000060
0000075
0000042
0000045
0000084
0000045
0000135
0000054
0000080
0000111
0000045
0000066
0000066
0000093
0000108
0000150
0000033
0000069
0000045
0000048
0000045
0000120
0000144
0000108
0000141
0000057
0000030
0000042
0000087
0000051
0000027
0000345
0000090
0000069
0000033
PUS NAME
Black's Ferry Water Company
Mansfield Mobile Home Park
Berger Trailer Park
Colony Criik Mobile Home Park
Manvel Road Terrace Subdivision
Kagy's Mobile Home Park
Graves Trailer Park
Broadway Mobile Home Park
B & B E-Z Way Mobile Home Park
West Brazos Mobile Home Park
West's Mobile Home Park
Countryside Mobile Home Park
Wade's Mobile Home Park
Frontier Water Company
Flora No. 7
Flora No. 6
Thomas Water Service
Chapline's Mobile Home Development
Oak Ridge Mobile Home Park
Centennial Place
Mansfield Mobile
Quail Meadows No,
Pleasant Meadows
Morel and
Morel and
Windsong
Palmetto
COUNTY
Brazoria
Home Park
. 1
Subdivision
Subdivision Block
Subdivision Block
Subdivision
Subdivision
Angle Acres Water System
Pleasantdale Subd. Water System
Anchor Road Mobile Home Park
Chenango Trailer Park
Sandy Ridge Subdivision
Sharondale Subdivision
Country Meadows
Country Acre Estates
Coronado Country
Pearl and Heights Mobile Home
Willow Wedge Mobile Home Park
Bayou Breeze Mobile Home Park
Country Creek Estates Water
Country Village Mobile Home
Country Oaks Mobile Home Park
Gibbens Mobile Home Park
Raintree Acres Mobile Home
Iowa Colony Utilities Inc.
South Meadows
Ashley Oaks Mobile Home Com.
-------
Texas Mobile Home Parks - 1986 Data
Page 2
(CLUSTER A)
PWS ID POP. SERVED
0200419
0200435
0360004
0360006
0360008
0360024
0360029
0360069
0360072
0360076
0790002
0790039
0790042
0790048
0790052
0790054
0790088
0790139
0790185
0790190
0790205
0840016
0840045
0840046
0840067
1010085
1010140
1010149
1010162
1010164
1010219
1010282
1010283
1010285
1010288
1010307
1010322
1010339
1010349
1010354
1010364
1010452
0000075
0000400
0000084
0000132
0000044
0000198
0000069
0000378
0000096
0000060
0000150
0000051
0000060
0000039
0000036
0000039
0000039
0000045
0000060
0000033
0000036
0000066
0000025
0000030
0000075
0000076
0000492
0000180
0000228
0000072
0000153
0000342
0000130
0000069
0000486
0000450
0000567
0000105
0000360
0000036
0000025
0000150
PWS NAME
Pine Colony Mobile Home Park
Autumn Shadows MH Subdivision
Cotton Bayou Manor Mobile Home
Abbe Subdivision
Shady Oaks Mobile Home Park
Cedar Bayou Mobile Home Park
Sunny Villa Mobile Home Park
G & S Utility Co.
Solesbee Construction Inc.
Chambers County FWSD No. 1
Laterna Villa Subdivision
3411 - 5th Street Trailer Park
Sklar's Mobile Home Park
Marek's Mobile Home Park
Steinkamp Trailer Park
Fresno Mobile Home Park
Brdecka Water System
Hoyt Mobile Court
Brown's Mobile Home Park
H F Christman Water System
Ford Road Trailer Park
Pine Oak Trailer Court
Tranquility Mobile Home Park
Windsong Mobile Home Park
Greenvilla Mobile Home Park
Apache Land Mobile Home Sub.
North Pines Mobile Home Park
Greenspoint Trailer Park
Atascocita Village Mobile H
Aldine Mobile Home Park
Tall Cedars Mobile Home Sub.
Colonial Mobile Home Park
Cottonwood Park Water System
Highland Mobile Home Subdivision
Mobile Home Estates
Redwood Estates Mobile Home
White Oak Manor Mobile Home
Advance Country Mobile Home
Green Acres Mobile Home Park
Cypress Brook Estates
Aldine Mobile Home City
Gospel Assembly Water System
COUNTY
Brazoria
Chambers
Ft. Bend
Galveston
Harris
-------
Texas Mobile Home Parks - 1986 Data
Page 3
(CLUSTER A)
PWS ID POP. SERVED
1010459
1010514
1010520
1010524
1010531
1010533
1010546
1010560
1010566
1010570
1010574
1010579
1010583
1010584
1010587
1010603
1010628
1010629
1010642
1010651
1010657
1010661
1010663
1010664
1010665
1010666
1010667
1010669
1010672
1010674
1010680
1010681
1010686
1010690
1010691
1010693
1010695
1010700
1010706
1010734
1010735
1010736
1010737
1010743
1010744
0000450
0000114
0000420
0000039
0000025
0000093
0000075
0000060
0000090
0000025
0000064
0000066
0000060
0000066
0000174
0000045
0000049
0000120
0000033
0000032
0000027
0000030
0000069
0000060
0000075
0000030
0000049
0000060
0000060
0000110
0000477
0000480
0000075
0000050
0000066
0000027
0000039
0000243
0000087
0000022
0000030
0000025
0000042
0000123
0000033
PWS NAME
El Dorado Mobile Home Corporation
Lorri Heights Mobile Home
Royal Coach Mobile Home Park
Pin Oak Mobile Home Park No
Harvey & Gary Mobile Home Park
Sundown Mobile Home Park
Mt. Houston Trailer Park
Golden Carriage Mobile Home
Windfern Mobile Home Park
Quinlan Mobile Home Park
Apache Mobile Home Park
Royal Lake Mobile Home Park
Mohoot Village Mobile Home
Holliday Mobile Home Park
Longhorn Mobile Home Park
Kluge's Trailer Park
Cokers Mobile Home Park
Cypress Crossing
Acres North Mobile Home Park
Peake's Park
Pyburn Enterprises Incorp
Jordan Mobile Home Park
Lone Willow West Mobile Home
Lone Willow Mobile Home Park
Aldine MHW & KOA
Don Fitch Water System
Space Estates Mobile Home Park
Lauder Mobile Home Park
Belleau Wood Trailer Park
Moorpark Village Water System
Kings Row Mobile Home Park
Fruitland Water Corporation
Deer Trail Mobile Home Park
Blimp Mobile Home Park
Bluebonnet Mobile Home Comm
Buschong 1121 Mobile Home Park
G & C Trailer Park
Huffman Heights Subdivision
Fair Acres Mobile Home Park
Jones Road Mobile Home Park
Judge's Mobile Home Park
Spindle Mobile Home Park
River Oaks Mobile Home Comm
Mel rose Mobile Home Park No
Mentalbano Mobile Home Park
COUNTY
Harris
-------
Texas Mobile Home Parks - 1986 Data
Page 4
(CLUSTER A)
PWS ID POP. SERVED
1010746
1010747
1010760
1010763
1010783
1010788
1010792
1010795
1010801
1010805
1010808
1010809
1010810
1010811
1010814
1010821
1010825
1010826
1010827
1010832
1010887
1010904
1010914
1010933
1010934
1010935
1010947
1011032
1011049
1011067
1011075
1011084
1011112
1011219
1011236
1011253
1011268
1011302
1011321
1011382
1011433
1011441
1011442
1011459
1011460
1011492
0000087
0000039
0000057
0000048
0000105
0000081
0000228
0000072
0000035
0000150
0000225
0000040
0000207
0000105
0000026
0000048
0000103
0000140
0000075
0000090
0000100
0000036
0000090
0000030
0000030
0000017
0000069
0001167
0000138
0000054
0000081
0000025
0000048
0000215
0000150
0000075
0000065
0000267
0000117
0000078
0000276
0000040
0000054
0000081
0000140
0000087
PUS NAME
Fatima Family Village Mobile Home
Northwest Mobile Home Park
Tallow Mobile Home Park
Satsuma Park Villa Mobile Home
Genoa Trailer Park
Sjolander Mobile Home Park
Meadows Mobile Home Park
Fairway Mobile Home Village
Kimich Mobile Home Park
Woodloch Mobile Home Park
Pointe South Mobile Home Park
Bammel Oaks Estates No. 1
Bammel Oaks Estates No. 2
Chapman's Mobile Home Park
Lake Woods Mobile Home Park
Mahlmann Mobile Home Park
Aldine Gardens Mobile Home
Pin Oak Mobile Home Park No
Intercontinental Mobile Home
Deluxe Mobile Home Park
Brandywine Oaks
Greenwood Lake Subdivision
Roach Water System
Bob's Trailer Park No. 2
Farmette Meadows Mobile Home
Colletts Water System No. 2
Crickett Hill Estates
Northwest Pines Mobile Home
Oakland Village Mobile Home
Sunland Park
Fairmont Estates
Boudreaux Gardens
L & D Mobile Home Park
Brandywine Pines
Alice Acres Mobile Home Subdivision
Azalea Estates Mobile Home
Mar Dalf Mobile Home Park
Heathergate Water System
Royal Palms Mobile Home Park
Western Mobile Home Park
Van Manor Mobile Home Park
Coachlight Mobile Home Park
Bonanza Mobile Home Park
Sellers Estates Mobile Home
Atlasta Glen
Pa-Co Incorporated
COUNTY
Harris
-------
Texas Mobile Home Parks - 1986 Data
Page 5
(CLUSTER A)
PWS ID POP. SERVED
1011493
1011515
1011519
1011536
1011553
1011556
1011627
1011632
1011637
1011638
1011648
1011687
1011708
1011713
1011714
1011734
1011747
1011766
1011796
1011803
1011805
1011806
1011810
1011812
1011828
1011832
1011859
1011860
1011861
1011923
1011939
1011947
1011955
1011956
1011971
1011972
1011977
1011995
1011996
1011999
1012003
1012019
1012048
1012061
1012090
1012130
1012166
0000660
0000045
0000025
0000075
0000048
0000141
0000048
0000126
0000042
0000030
0000060
0000303
0000105
0000240
0000420
0000084
0000033
0000090
0000048
0000096
0000110
0000081
0000110
0000160
0000063
0000360
0000039
0000123
0000084
0000042
0000135
0000350
0000210
0000048
0000060
0000025
0000093
0000051
0000078
0000591
0000054
0000078
0000072
0000027
0000165
0000135
0000090
PWS NAME
Maple Leaf Mobile Home Subdivision
Houston Suburban Hts. MHP No
Twin Palms Mobile Home Park
Kitzwood
West Haven Mobile Home Park
Cedar Oaks Mobile Home Camp
Decker Investments MHP
Mel rose Mobile Home Park No
6403 Mobile Home Park
Tall Pine Mobile Home Park
Buffalo Bayou Mobile Home Park
Atascocita Acres
Whisper Meadows Mobile Home
Hooks' Mobile Home Park
Point West Mobile Home Comrn
Homestead Oaks Mobile Home
Guhn Road Mobile Home Park
Kickapoo Farms Subdivision
Woodgate Mobile Home Village
Oakwood Vi11 age Mobi1e Home
Telge Terrace Mobile Home S
Colony Mobile Home Subdivision
Timberdale Mobile Home Subdivision
Willow Oaks
Bentwood Estates Mobile Home
Five Oaks Mobile Home Subdivision
Deer Trails
Berry Hill Estates
Rolling Oaks
Rose Hill Ranchettes Mobile Home Subdivision
Telge Manor Mobile Home Park
West field Garden Mobile Home
Katy Country Estates
Northwoods Mobile Home Park
Rose Mobile Home Park
Romona Mobile Home Park
Ed-Lou Mobile Home Park
Bayou Forest Village Mobile
Grant Road Estates Mobile Home
North Belt Forest Subdivision
Herman Oaks Mobile Home Village
Weiman Mobile Home Park
Cypress Gardens Mobile Home
Youngblood Mobile Home Park
Spring Oaks Mobile Home Park
Padok Timbers Subdivision
Vernan Miller Mobile Home Park
COUNTY
Harris
-------
Texas Mobile Home Parks - 1986 Data
Page 6
(CLUSTER A)
PWS ID POP. SERVED
1012231
1012240
1012276
1012292
1012333
1012403
1012450
1012466
1460031
1460040
1460043
1460044
1460047
1460091
1460092
1460094
1460095
1460096
1460098
1460099
1460100
1460101
1460110
1700078
1700113
1700121
1700149
1700216
1700245
1700287
1700299
1700301
1700307
1700321
1700322
1700323
1700324
1700331
1700344
1700356
1700365
1700386
1700389
1700393
1700394
0000093
0000048
0000180
0000060
0000048
0000033
0000066
0000090
0000025
0000105
0000039
0000033
0000100
0000588
0000090
0000048
0000036
0000060
0000240
0000117
0000090
0000045
0000090
0000183
0000057
0000270
0000450
0000180
0000052
0000300
0000130
0000246
0000090
0000141
0001062
0000135
0000234
0000159
0000090
0000042
0000036
0000165
0001200
0000483
0000090
PWS NAME
Mohdot Village Mobile HP No
Barkaloo Homeowners Association
2920 West Subdivision
South Four Mobile Home Park
Acorn Mobile Home Park
River Oaks Mobile Home Community
Orchard Crossing Subdivision
Windfern Mobile Home Park
R's Mobile Home Park
Rainbow Lake Mobile Home Park
Cleveland Mobile Home Park
Pine Oaks Mobile Home Park
Derrington Mobile Home Park
Woodway Subdivision Water S
Northpark Subdivision No. 1
Uoodcreek Subdivision - Sec
Wildwood Subd Water Association
Oak Meadows II Subdivision
Lakeview Water System
Woodcreek Subdivision - Sec
Oak Meadows III Subdivision
Meadow Glen
North Park Subdivision No. 2
Pine Vista Mobile Home Village
Sweetgum Forest
Heritage Oaks
Hunters Retreat
Oakwood Acres
Pleasant Forest Subdivision
Turtle Creek
Greenwood County
Cypresswood Estates
Deer Ridge
Wilshire Subdivision
Deer Glenn Water System
Country Estates Water System
Huntington Estates
Crystal Springs Subdivision
Lazy Lane Mobile Home Park
Bear Branch Estates
Jays Mobile Home Park
Park Place Subdivision
Walnut Cove Subdivision
Shadow Bay Subdivision
Hilltop Village Mobile Home
COUNTY
Harris
Liberty
Montgomery
-------
Texas Mobile Home Parks - 1986 Data
Page 7
(CLUSTER A)
PWS ID POP. SERVED
1700431
1700432
1700433
1700434
1700435
1700447
1700454
1700478
1700481
1700482
1700483
1700490
2370044
2370045
2370047
2370048
2370049
2370051
(CLUSTER
0150088
0150120
0150125
0150131
0150135
0150156
0150186
0150187
0150199
0150204
0150207
0150208
0150230
0150233
0150248
0150252
0150253
0150256
0150265
0150290
0150430
0150478
0000240
0000051
0000084
0000072
0000339
0000135
0000090
0000090
0000081
0000111
0000132
0000120
0000040
0000040
0000093
0000025
0000036
0000090
B)
0000026
0000700
0000270
0000130
0000550
0000066
0000100
0000125
0000075
0000030
0000125
0000055
0000080
0000283
0000070
0000050
0000070
0000078
0000300
0000105
0000175
0000030
PWS NAME
Summer Hills Subdivision
Oak Creek II
Tower Glen Subdivision
Chaparral Place Water System
Country West Subdivision
Armadillo Woods
Oakwood Water System
Eastwood Hills Subdivision
Woodhaven Estates
Pinedale Mobile Home Park
Serenity Woods Subdivision
Westmont Mobile Home Community
Leaning Oak Mobile Home Park
Hidden Country Mobile Home
Beacon Estates Utility Company
Elite Mobile Home Park
Willowbrook Subdivision
Oak Hollow Subdivision
COUNTY
Montgomery
Waller
Robinson's Trailer Park
Leon Springs Villa Mobile Home
Mobile City Estates
Trailer City Water Company
Oaks North Mobile Home Estates
Oak Hill Acres Mobile Home
Lazy Acres Mobile Home Park
Brookdale Mobile Home Park
Grandview Mobile Home Park
Cardoza Trailer Park
Cozy Cove Trailer Park
North Breeze Mobile Home Park
90 West R V Park
Park West Estates Mobile Home
AAA Lookout Trailer Park
HPR Trailer Park
Shady Acres Trailer Park
Little Joe's Ice House & Trailer
Elm Valley Water Company
Vail's Mobile Home Park
Country Oaks Mobile Home Park
South Oaks Estates
Bexar
-------
Texas Mobile Home Parks - 1986 Data
(CLUSTER
PUS ID
0160007
0280017
0460079
0460151
0460161
0460166
0460175
1050023
1050057
1050063
1050072
1300005
1300006
1300007
1300008
1300010
1300013
1300014
1300027
1330002
1330017
1330018
1330019
1330020
1330024
1330029
1330044
1330101
1330110
1330120
1330121
1330122
1330123
1330131
1330132
1330133
1330134
1630011
1630014
1630025
1630030
B)
POP. SERVED
0000060
0000120
0000483
0000125
0000100
0000069
0000057
0000090
0000080
0000270
0000025
0000200
0000045
0000041
0000200
0000040
0000025 .
0000140
0000045
0000219
0000200
0000243
0000087
0000066
0000093
0000045
0000120
0000420
0000080
0000054
0000063
0000096
0000150
0000150
0000072
0000087
0000075
0000090
0000180
0000035
0000144
PWS NAME
Oaks Trailer Park
Pecan Trailer Park
Canyon Lake Hills Units No
Rockford Place Mobile Home
Tamiga Acres Mobile Home Park
Oak Valley Water Supply
Hart-N-Hart Mobile Home Park
Sunny Acres Mobile Home Park
Mockingbird Mobile Home Park
Aztec Village
Schulle Mobile Home Park
Cascade Mobile Home Park
Bel-Aire Mobile Home Park
Elms Mobile Home Park
Foothills Mobile Home Ranch
Cardinal Trailer Park
Foothills Mobile Home Ranch
Shady Rest Mobile Home Park
Merchants Mobile Home Park
Scenic Valley Mobile Home Park
Wilderness Park
Oak Grove Mobile Home Park
Cedar Springs Mobile Home V
Midway Mobile Home Park
Woodhaven Mobile Home Park
Hill Country Mobile Home Park
Hideaway Mobile Home Park
Hill Country Utility -Sleepy
Forest Oaks Mobile Home Park
Windcrest Mobile Home Park
Del Valle Mobile Home Park
Cherokee Mobile Home Park
Kerr Villa Mobile Home Park
Westwood Oaks Mobile Home Park
Rancho Oaks Mobile Home Park
Blue Ridge Mobile Home Park
Oak Ridge Estates Water System
Valley Mobile Home Properties
Highway 90 Ranch Water Company
Zinsmeyer Trailer Park
Cattlemans Crossing
Page 8
COUNTY
Blanco
Cal dwell
Comal
Hays
Kendal1
Kerr
Medina
-------
Texas Mobile Home Parks - 1986 Data
Page 9
(CLUSTER B)
PWS ID POP. SERVED
2270166
2270173
2270175
2270186
2270187
2270219
2270232
2270258
2270271
2460031
2460054
2460104
2460108
0000250
0000650
0000125
0000090
0000080
0000400
0001200
0000150
0000075
0000250
0000120
0000029
0000085
(CLUSTER C)
0430069 0000800
0570081
0570082
0570090
0570094
0570097
0570100
0570103
0570105
0570110
0570159
0610009
0610011
0610016
0610017
0610046
0610052
0610053
0610055
0610056
0610057
0610058
0610059
0610060
0610061
0610072
0610086
0000120
0000225
0000100
0000120
0000080
0000125
0000050
0000143
0000250
0000090
0000400
0001408
0000150
0000325
0000120
0000825
0000925
0000100
0000450
0000360
0000150
0000300
0000350
0000250
0000038
0000060
PUS NAME
Live Oaks US - Leander Hill
Hill Country Northwest WS
Eagle Ridge on Lake Travis
Sadik Mobile Home Park
Travis South Mobile Home Park
Branch Creek Estates
Northeast Utilities Inc. - N
Sweetwater Mobile Home Estates
Forest Oaks Mobile Home Co
Hardrock Mobile Home Park
Green Acres Water Supply
Liberty Hill Mobile Home Park
Rays Retirement Village
Spring Creek Village
Meadowlark Mobile Home Park
D Bar B Mobile Home Ranch
Stillmeadow Water System
Cottonwood Creek Mobile Home
Parkerville East Mobile Home
Bush Mobile Home Park
Traveler's End Mobile Home
Shady Creek Mobile Estates
Forty Acres Mobile Home Park
B & D Utilities
Denton NW Estates - Wren Water
Twin Lakes Mobile Home Park
Denton Estates Mobile Home
Rocky Point Mobile Home Park
Corral City Mobile Home Park
Vacation Village
Denton West Mobile Home Park
Trail Dust City
Marshall Creek, Town of
Royal Oaks Estates
Capricorn Mobile Home Park
Stonecrest Water Department
Silver Dome Mobile Home Park
Sherwood Mobile Home Park
Triangle Mobile Home Park
Cedar Creek Mobile Home Park
COUNTY
Travis
Williamson
Collin
Dallas
Denton
-------
Texas Mobile Home Parks - 1986 Data
Page 10
(CLUSTER C)
PWS ID POP. SERVED
0610090
0610120
0610149
0610162
0610169
0610171
0610172
0610179
0610181
0610191
1110028
1110031
1110034
1110044
1110045
1110059
1110074
1110076
1110077
1110078
1110079
1110080
1110083
1110086
1110088
1260028
1260031
1260037
1260060
1260061
1260062
1260064
1260065
1260066
1260069
1260070
1260071
1260072
1260073
1260074
1260075
1260076
1260077
1260078
1260079
1260080
0000075
0000075
0000066
0000350
0000360
0000075
0000050
0000030
0000045
0000168
0000375
0000070
0000075
0000264
0000120
0000525
0000105
0000186
0000035
0000066
0000185
0000065
0000054
0000050
0000210
0000141
0000087
0000045
0000078
0000065
0000096
0000141
0000156
0000200
0000063
0000135
0000120
0000141
0000090
0002550
0000087
0000162
0000068
0000153
0000264
0000120
PWS NAME
Acorn Ranch Mobile Home Park
Villager Mobile Home Park
Westpark Water Corporation
Ranch Mobile Home Park
Pine Creek Mobile Home Park
Water Association of North Lake
Cherokee Meadows
Double Rock Estates
Brittany Hill Water Association
Creekside Water System
Brazos River Acres
Lakeview Mobile Home Park
Lakeside Mobile Home Park
Montego Bay Estates
River Country Acres
Lake Country Acres
North Fork Creek I
River Run Subdivision
Sunset Acres Mobile Home
Lakeside Hills
Blue Water Shore
Nolan Creek Estates
Country Meadows
Rolling Acres Mobile Home Park
North Fork Creek No. 2
Green Valley Estates
Oakridge Square Mobile Home
Tex Rides Subdivision
Skyline Drive Landowners Association
A & A Mobile Home Park
Shorty's Mobile Home Village
Rolling Oaks Subdivision
Spring Valley Water Co-op
Mansfield South
Hilltop Water-Sunshine Acre
Woodland Oaks Estates
Shady Hills Estates Water
Shady Meadows Estates
Cahill Country Water System
Metroplex Homesteads Water
Whispering Meadows
Falcon Crest Water System
West Park Village
Rancho Villa Subdivision
Lark Meadow Subdivision
Bell Manor Subdivision
COUNTY
Denton
Hood
Johnson
-------
Texas Mobile Home Parks - 1986 Data
Page 11
(CLUSTER C)
PUS ID POP. SERVED
1260081
1260082
1260083
1260084
1260085
1260086
1260088
1260089
1260090
1260092
1260094
1260095
1260097
1260098
1260100
1260101
1260103
1260105
1260106
1260107
1840002
1840024
1840040
1840041
1840045
1840077
1840078
1840089
1840095
1840099
1840104
2200105
2200107
2200109
2200115
2200119
2200123
2200126
2200127
2200129
2200130
2200132
2200134
2200136
0000033
0000138
0000060
0000087
0000026
0000024
0000033
0000066
0000054
0000018
0000030
0000036
0000084
0000081
0000080
0000180
0000075
0000057
0000126
0000030
0001050
0000225
0000033
0000200
0000130
0000210
0000141
0000130
0000270
0000060
0000080
0000120
0000105
0000087
0000114
0000174
0000156
0000054
0000200
0000200
0000055
0000195
0000140
0000120
PUS NAME
Whispering Meadows Triangle
Rock Creek Estates
Wagon Wheel Estates
Buffalo Creek
Fox Hollow
Sanders View
North Whispering Meadows
Lander Bell Subdivision
John Dame
Garden Acres Subdivision Water System
Southern Acres Water System
Ace Mobile Home Park
Mountainaire Mobile Home Park
Westlake Village Mobile Home
Willow Bend Subdivision Water System
Wai den Estates Water Company
Shaded Lane Estates
Golden 60's Subdivision
Williams Mobile Home Park
Union Hill Water System
Horseshoe Bend Water Works
Crazy Horse Ranches
Western Mobile Manor
Aledo Mobile Home Park
Towne Oaks Mobile Home Park
Mountain River Water System
Hudson Heights
Spring Valley Estates
Oak Hill Mobile Home Park
Trinity River Estates
Harpoles Mobile Home Park
Friendly Oaks Water Supply
Hilltop Mobile Home Park
Oak Hills Mobile Home Park
Spring Creek Water Cooperative
Corbin Mobile Home Park
Charriot Mobile Home Park
Yates Mobile Home Park
Green Acres Mobile Home Park
Texas Mobile Home Park No
Horizon Mobile Home Park
Twin Points Resort
River Oaks Mobile Home Park
Lake Worth Mobile Home Park
COUNTY
Johnson
Parker
Tarrant
-------
Texas Mobile Home Parks - 1986 Data
Page 12
(CLUSTER C)
PWS ID POP. SERVED
2200139
2200140
2200141
2200146
2200147
2200148
2200150
2200151
2200157
2200168
2200172
2200190
2200211
2200269
2200278
2200284
2200288
2200290
2490013
2490018
2490027
2490028
2490029
2490034
2490035
0000180
0000075
0000072
0000094
0000054
0000125
0000100
0000030
0000135
0000080
0000036
0000100
0000075
0000030
0000150
0000075
0000066
0000145
0000100
0000090
0000090
0000140
0000090
0000060
0000050
PWS NAME
Country Oaks Mobile Home Park
Quiet Acres Mobile Home Park
Barnes Lakeside Resort
Acorn Mobile Home Park
Jordan's Mobile Home Park
Circle "R" Ranchettes
Oaks Mobile Home Park
Tenderfoot Trail Mobile Home
Lakeview Village Mobile Home
Shady Hill Mobile Home Park
Hi 11 crest Estates Mobile Home
Twin Lakes Water Company
Western Oaks Village
Bontke-Hodges Water System
Webb Water Supply No. 2
Avondale Heights Mobile Home
Meadow Glen Estates
Triple H. Estates
Killough Addition
Jones Acres
Miller Mobile Manor
Glider Base Estates
Town & Country Mobile Home
Griffin Country Addition
Golf Mobile Home Park
COUNTY
Tarrant
Wise
-------
Appendix B
-------
KEEPING
DRINKING WATER
SAFE TO DRINK
Straight Talk
About
Water Sampling
Prepared For The Texas Mobile Home Park Industry
By
The Texas Manufactured Housing Association
IT'S UP TO YOU!
-------
Appendix C
-------
WATER BACTERIOLOGY
Form No G-19 (rev 1044)
Teua Department ol Health
Bureau of Utxjritorles
Date and Time Rec'd
Sample No.
Date
Reported
Do nol mark above Ihrt line Please print with ballpoint pen or typewriter
NAME OF WATER SYSTEM
SEND RESULTS TO:
COUNTY
NAME
STREET ADDRESS (PO Bo.)
I II II I II I
JjTx
CITY
ZIP CODE
POINT OF COLLECTION COLLECTED BY
Water System Identification Number
mm
MONTH PAY
TYPE OF SYSTEM
G Public G Dairy
G Individual G Bottled
G School
SAMPLE IS
(Public Sysiems Only)
G Distribution G Raw
G Construction G Check
G Special
Ownership or other information1
YEAR
TIME
ED
AMIPM
WATER SOURCE
D River D Lake
G Well Well Depth.
Chlorine Residual
LABORATORY REPORT (Do not write below)
Water of satisfactory bacteriological quality should be free from Conform organisms
Coliform Organisms C Found D Not Found
MF Coliform Count (presumptive).
./100ml
M F Coliform Count (verified)
./100ml
UNSUITABLE FOR ANALYSIS-PLEASE RESUBMIT
D Sample too old Sample not received
within 30 hours of collection
D Date discrepancy or form incomplete
(See encircled item)
D Quantity insufficient for analysis
(100ml minimum)
D Leaked In transit
D Not an approved container
D Only one sample per time and point of collection
required
D Heavy (silt/bacterial growth) (with coliforms) present
possibly obscuring and compromising test results
G Quantity too great to permit agitation
G Other
MHPP
-------
Appendix D
-------
TEXAS MANOFACTOSED HOUSING ASSOCIATION
P.O. BOX 14428 AUSTIN, TEXAS 78761
July 20, 1988
TO: Texas Mobile Home Parks On Public Water Systems
FROM: Texas Manufactured Housing Association
(In cooperation with:
U. S. Environmental Protection Agency
Texas Health Department
Texas Rural Water Association
National Rural Water Association)
The Texas Health Department and the U. S. Environmental
Protection Agency are the state and federal agencies responsible
for seeing that the public has clean water to drink and use.
Because your mobile home park has a public water system, you are
also responsible for seeing that your residents are protected.
Enclosed vitb tbis letter are two very important brochures.
Please take the time to read them; they contain not only
necessary information, but helpful tips on how to test your
system's water quality. The brochures were written to help you
collect water samples properly. They cover a variety of
important topics such as when to collect, how to collect, and
where to send the collected samples.
You, as a mobile home park owner/operator, have a great deal
to do during the month, and these brochures were designed to help
make your job a little easier. That, in itself, is reason enough
to take the time to read the enclosed materials.
If you have any questions after reading the enclosed
materials, or need assistance of any kind, please call Charlotte
Zimmerman; Texas Manufactured Housing Association; Austin, Texas,
512/459-1221.
enclosures
2215 EAST ANDERSON LANE AUSTIN, TEXAS 512/459-1221
-------
Appendix E
-------
TEXAS
HOUS NG ASSOC ATION
P.O. BOX 14428 AUSTIN, TEXAS 78761
August 22, 1988
TO: All Texas Mobile Home Parks With Public Water Systems
FROM: Texas Manufactured Housing Association
The Texas Department of Health and the U.S. Environmental Protection
Agency are the state and federal agencies responsible for seeing that the
public has clean water to drink and use. Because your mobile home park has
a public water system, you are also responsible for seeing that your
residents are protected.
In trying to make your job a little easier, the Texas Manufactured
Housing Association and the Texas Rural Water Association are offering a
free 8-hour seminar which will be held in San Antonio and repeated in
Kerrville. As outlined in the enclosed agenda, each seminar will cover
such topics as (1) Texas Department of Health rules and regulations, (2)
how to obtain operator certification, (3) water sampling, (4) principles of
disinfection, (5) management and financial planning, and (6) how to get on-
site technical assistance. Also enclosed is an informative brochure
explaining how and when to collect water samples and where to send the
samples for analysis.
Each hour of seminar attendance will qualify participants for one hour
of classroom credit toward state certification as a waterworks operator.
Attendees will also be eligible for on-site technical assistance.
The seminars will be held as follows:
September 13, 1988
8:00 a.m.-4:30 p.m.
La Mansion del Norte Hotel
37 NE Loop 410 at McCullough
San Antonio, Texas
(512) 341-3535
1-800-531-7208 (reservations)
September 15, 1988
8:00 a.m.-4:30 p.m.
Y.O. Ranch Hilton
Interstate 10 at Highway 16
Kerrville, Texas
1-800-531-2800
2215 EAST ANDERSON LANE AUSTIN, TEXAS 512/459-1221
-------
REGISTRATION PROCEDURES
Preregistrati on for each seminar is required. Please fill out the-
registration form below and return it to: Texas Manufactured Housing
Association, P.O. Box 14428, Austin, Texas, 78761.
FORMS MUST BE RECEIVED BY SEPT. 6, 1988.
Be sure to indicate which seminar you wish to attend. Also, please note
that you must make your own arrangements for lunch and for lodging, if
necessary.
If you have any questions, please call Charlotte Zimmerman,
Texas Manufactured Housing Association, Austin, Texas, at (512)
459-1221.
Detach & mail to TMHA office.
MOBILE HOME PARK WATER SYSTEM COMPLIANCE IMPROVEMENT PROJECT
TRAINING SEMINAR
REGISTRATION FORM
Please register me for the [] SAN ANTONIO SEMINAR - Sept. 13, 1988
[] KERRVILLE SEMINAR ~ Sept. 15, 1988
NOTE: Please submit a separate form for each registrant.
FORMS MUST BE RECEIVED BY SEPT. 6.
NAME:
ADDRESS:
CITY & STATE:
ZIP CODE: PHONE:.
REPRESENTING:
Mail registration form to: TMHA
P.O. Box 14428
Austin, TX 78761
-------
Appendix F
-------
Mobile Home Park Water System
Compliance Improvement Project
Training Seminar
(JFree Attendance
Attendees eligible for on-site technical assistance
Hours of TDH operator certification credit offered
for each hour of instruction
September 13, 1988 September 15, 1988
La Mansion del Norte Y.O. Ranch Hilton
San Antonio, Texas Kcrrvillc, Texas
This seminar is being sponsored by a grain from ilic U S Environmental Protection Agency lo assist small
systems lowaid compli.incc with the Safe Drinking Water Act Amendments and Texas Department of
Health iulc& and regulations
The National Rural Water Association is administering this grant with assistance from the Texas Rural
Water Association anil the Texas Manufactured Housing Association
-------
Appendix G
-------
MOBILE HOME PARK WATER SYSTEM
COMPLIANCE IMPROVEMENT PROJECT
TRAINING SEMINAR
SEPTEMBER 13, AND 15, 1988
TEXAS DEPARTMENT OF HEALTH
DIVISION OF WATER HYGIENE
-------
WHY SAMPLE YOUR WATER?
1. SAMPLING IS REQUIRED BY LAW.
NATIONAL PRIMARY DRINKING WATER REGULATIONS
TEXAS DRINKING WATER STANDARDS
2. DETERMINES QUALITY OF WATER
BACTERIOLOGICAL
CHEMICAL
3. PROVIDES PROTECTION FOR SYSTEM OWNER
-------
WHAT SAMPLES ARE REQUIRED BY LAW?
CHEMICAL SAMPLES
COLLECTED BY TDH STAFF
OR IN COOPERATION WITH TDH STAFF
BACTERIOLOGICAL SAMPLES
COLLECTED SYSTEM OPERATOR
OR BY DESIGNATED INDIVIDUAL
-------
WHAT IS A BACTERIOLOGICAL TEST?
A TEST FOR COL I FORM ORGANISMS
MAJOR BACTERIOLOGICAL INHABITANT OF THE
INTESTINAL TRACT OF MAN OR ANY OTHER WARM
BLOODED ANIMAL
-------
WHY TEST FOR COL I FORMS?
PRESENCE OF COL I FORMS INDICATES THE POTENTIAL FOR
FECAL CONTAMINATION
TYPICAL WATERBORNE DISEASE OUTBREAKS ARE CAUSED B\
ORGANISMS FROM FECAL ORIGIN
-------
COLLECTING COL I FORM SAMPLES
LOCATE AN OUTSIDE FAUCET WHICH POINTS DOWNWARD
FLUSH FAUCET FOR 3 MINUTES
CHECK FOR LEAKING FROM THE STEM
CHECK FOR CHLORINE RESIDUAL
ADJUST TO A SLOW STEADY FLOW
TEAR OFF THE TOP OF THE BAG
PULL THE SIDE TABS TO OPEN THE BAG
FILL TO THE 4 OUNCE LINE
WATER SPLASHING INTO THE BAG IS CONTAMINATED
HOLD THE WIRE TABS /ND WHIRL THE BAG 3 TIMES
CHECK FOR AN AIRSPACE AT THE TOP OF THE BAG
FOLD THE WIRE TABS OVER TO SEAL THE BAG
-------
AFTER THE SAMPLE HAS BEEN COLLECTED
COMPLETE THE ANALYSIS FORM
COMPLETE ALL BLANKS TO INSURE SAMPLE CREDIT
SUBMIT THE SAMPLE TO THE LAB WITHIN 30 HOURS
MUST BE STATE APPROVED LABORATORY
FEE FOR ANALYSIS RANGES $2 TO $7
EXAMINE RESULTS WHEN RECEIVED FROM THE LAB
-------
WHAT ARE THE RESULTS?
NOT FOUND (NEGATIVE)
NO FURTHER SAMPLING IS REQUIRED
FOUND (POS ITIVE)
COLLECT CHECK SAMPLES ON CONSECUTIVE DAYS
UNSUITABLE FOR ANALYSIS
RECOLLECT SAMPLES
-------
CHECK SAMPLES
COLLECT ON CONSECUTIVE DAYS UNTIL 2 SAMPLES ARE
NEGATIVE
MUST BE MARKED AS "CKECK" FOR PROPER CREDIT
IF FIRST TWO CHECK SAMPLES ARE NEGATIVE, POSITIVE
SAMPLE IS NEGATED
-------
CHEMICAL SAMPLES
INORGANIC SAMPLES (MINERALS AND METALS)
GROUNDWATER - THREE YEAR INTERVALS
SURFACE WATER - ANNUALLY
ORGANIC SAMPLES
REGULATED PESTICIDES
GROUNDWATER - NOT REQUIRED
SURFACE WATER - FOUR YEAR INTERVALS
VOC'S (TO BE PHASED IN OVER 4 YEARS)
GROUNDWATER - AT LEAST EVERY 5 YEARS
SURFACE WATER - QUARTERLY FOR 1 YEAR
EVERY 5 YEARS
THM'S
POPULATION < 10,000 - NOT REQUIRED
POPULATION > 10,000 - QUARTERLY
OTHER ORGAN ICS - CURRENTLY IN REVIEW BY EPA
RADIOCHEMICAL SAMPLES
AT 4 YEAR INTERVALS
-------
Appendix H
-------
REGISTRATION
STATE:
DATE:
LOCATION:
NAME
ADDRESS/
PHONE NO.
MHP
WATER SYSTEM
POSITION
YRS. OF
SERV. IN
POSITION
CERT.
OPER.
YES NO
HAVE YOU
ATTENDED
, STATE/
AGNCY TRNINC
YES NO
-------
RURAL WATER TRAINING
ASSESSMENT QUESTIONNAIRE
Date Location
1. Please circle which best describes your position:
A. Operator/Manager
B. Board Member
C. Administrative
D. State or Federal Representative
E. Industry
F. Public
2. Generally speaking, this training: (Please circle one or more)
T A. Helped me professionally on how to do a task.
B. Helped me professionally by refreshing my memory.
C. Helped me professionally by providing needed information.
D. Was not interesting and/or wasted my time.
3. If improvement could be made I would recommend: (Please circle one or more)
A. Having different instructors.
B. More in-depth instruction.
C. Having more slides and films.
D. Having less lecture time and more learner participation.
E. Having a better learning environment.
4. Was there anything that particularly pleased or bothered you about the instructors or the facility:
'&£*
-------
in 9 8 7
GOOD ABOVE
AVERAGE
RATING SCALE
654
AVERAGE
3 2
BELOW
AVERAGE
1
POOR
Please answer the following questions using a number from the scale above.
5. In your opinion, was the topic matter clearly stated in the agenda you
received? Please rate by placing a number from the scale above.
6. Please rate how well the topics in the agenda were covered in the actual
training session.
7. Please rate your opportunity to participate in discussions, issues, and/or
information that was relevant to your job.
8. Please rate this session as to its overall use to you.
9. Please rate the following learning aids if used:
A. Slide and/or overhead projections.
B. Handout material by instructors.
C. Rural Water Training guides.
10. Please rate your instructors in terms of their subject matter knowledge.
Use a number from the above scale.
Instructor:
Instructor:
Instructor
Instructor:
Rating:
Rating:
Rating:
Rating:
This is my contribution to assuring that quality and effective training will continue to be provided by
the Rural Water Association in meeting the needs of rural and small water systems in this state and across
the nation.
(Signature)
Other Comments:
Arv.
-------
Appendix I
-------
STATE:
DATE:
nr.ciSTu/vTiON
/ / -?. '
l
LOCATION:
TYPE SESSION:
(Inslruclion Timc)
(F«,or,
(Crcdi.s)
Have You
Attended Other:
WATER SYSTEM
AGENCY
POSITION
Yes
Rural Water
Training
No
IHA/\L^ J-'x/J'^
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Slate Agency
Training
Yei
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No
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-------
STATE:
TYPE SESSION:
NAME
REGISTRATION
DATE:
(Inslruclion Time)
ADDRESS
-,0
ff Ot> Aj,
^sr'N
LOCATION:
eff
(F2clor)
(Credits)
WATER SYSTEM
FIRM
AGENCY
'ftx I f«v. '
"T. Vv/,C,
-TCJ- C-
POSITION
Have You
Attended Other:
Yes
Rural Water
Training
No
Stale Agency
Training
Yes No
-------
Appendix J
-------
RURAL WATER TRAINING
ASSESSMENT QUESTIONNAIRE
9* J3 - 8T> ation S,flt
Date * - _ Location
1. Please circle which best describes your position:
A. Operator/Manager
B. Board Member
(cP Administrative
D. State or Federal Representative
E. Industry
F. Public
2. Generally speaking, this training: (Please circle one or more)
A. Helped me professionally on how to do a task.
£jpHelped me professionally by refreshing my memory.
C. Helped me professionally by providing needed information.
D. Was not interesting and/or wasted my time.
3. If improvement could be made I would recommend (Please circle one or more)
A. Having different instructors.
B. More in-depth instruction.
C. Having more slides and films.
(lp Having less lecture time and more learner participation.
E Having a better learning environment
4. Was there anything that particularly pleased or bothered you about the instructors or the facility:
fOo
TSQ 001 ISA
(OVER)
-------
10
GOOD
RATING SCALE
987654
ABOVE AVERAGE
AVERAGE
3 2
BELOW
AVERAGE
I
POOR
Please answer the following questions using a number from the scale above.
5. In your opinion, was the topic matter clearly stated in the agenda you
received? Please rate by placing a number from the scale above.
6. Please rate how well the topics in the agenda were covered in the actual . c\.
training session.
7. Please rate your opportunity to participate in discussions, issues, and/or £>
information that was relevant to your job. 1
8. Please rate this session as to its overall use to you.
9. Please rate the following learning aids if used:
A. Slide and/or overhead projections.
B. Handout material by instructors.
C. Rural Water Training guides.
10. Please rate your instructors in terms of their subject matter knowledge.
Use a number from the above scale.
Instructor _ Rating:
Instructor ___ Rating:
Instructor Rating:
Instructor. __ Rating:
This is my contribution to assuring that quality and effective training will continue to be provided by
the Rural Water Association in meeting the needs of rural and small water systems in this state and across
the nation.
(Signature)
Other Comments:
TSQ 001 15B
-------
Appendix K
-------
Have You
Attended Other:
Stale Agency
Training
No
Yes
Rural Water
Training
Yes No
WATER SYSTEM
FIRM
AGENCY
'1SR001
13A
-------
REGISTRATION
STATE:
DATE:
TYPE SESSION:
LOCATION:
NAME
(Instruction Time)
ADDRESS
(Factor)
(Credits)
WATER SYSTEM
FIRM
AGENCY
POSITION
Have You
Attended Other:
Rural Water
Training
Yes
No
Stale Agency
Training
Yes
X
No
'IS ROD I
13A
-------
Appendix L
-------
RURAL WATER TRAINING
ASSESSMENT QUESTIONNAIRE
Date 7*- ** °" Location
1. Please circle which best describes your position:
(A) Operator/Manager
B. Board Member
C. Administrative
D. State or Federal Representative
E. Industry
F. Public
2. Generally speaking, this training: (Please circle one or more)
(A) Helped me professionally on how to do a task.
B. Helped me professionally by refreshing my memory.
(C) Helped me professionally by providing needed information.
D. Was not interesting and/or wasted my time.
3. If improvement could be made I would recommend: (Please circle one or more)
A. Having different instructors.
B. More in-depth instruction.
C. Having more slides and films.
D. Having less lecture time and more learner participation.
E Having a better learning environment
4. Was there anything that particularly pleased or bothered you about the instructors or the facility:
a
TSQ 001 ISA
(OVER)
-------
RATING SCALE
10 9 fl\ 7 6 S 4 3 2 L
GOOD "ABOVE AVERAGE BELOW POOR
AVERAGE AVERAGE
Please answer the following questions using a number from the scale above.
5. In your opinion, was the topic matter clearly stated in the agenda you
received? Please rate by placing a number from the scale above.
6. Please rate how well the topics in the agenda were covered in the actual
training session.
7. Please rate your opportunity to participate in discussions, issues, and/or ,~
information that was relevant to your job. ^
8. Please rate this session as to its overall use to you.
9. Please rate the following learning aids if used:
A. Slide and/or overhead projections.
B. Handout material by instructors.
C. Rural Water Training guides.
10. Please rate your instructors in terms of their subject matter knowledge.
Use a number from the above scale.
Instructor Rating:
Instructor
Instructor _ R*ring:
Instructor _ Raring:
This is my contribution to assuring that quality and effective training will continue to be provided by
the Rural Water Association in meeting the needs of rural and small water systems in this state and across
the nation.
(Signature)
Other Comments:
TSQ 001 15B
-------
Appendix M
-------
MHP COMPLIANCE IMPROVEMENT PROJECT
TECHNICAL ASSISTANCE REPORT
DATE:
ARRIVAL TIME:
SYSTEM THAT TA WAS PERFORMED ON:
PERSON CONTACTED:
*//*
SPECIFIC PROBLEM ENCOUNTERED:
/-Csas^
DEPARTURE TIME
/r>y
/
srs
EDUCATIONAL MATERIALS PROVIDED:
-------
Appendix N
-------
' SEXAS MAMUFACTOESEID HOUSING ASSOCIATION
P.O. BOX 14428 AUSTIN, TEXAS 78761
July 22, 1988
TO: Texas Mobile Home Parks With Public Water Systems
FROM: Texas Manufactured Housing Association
(In cooperation with:
Texas Health Department
Texas Rural Water Association
National Rural Water Association
U. S. Environmental Protection Agency)
Enclosed with this letter is a very important brochure.
PLEASE TAKE TEE TIME TO READ IT!! Four reasons why follow:
1. State and federal law requires all drinking water
for public use to be free from harmful bacteria. Furthermore,
such drinking water has to comply with purity standards
established by the Texas Department of Health and the U. S.
Environmental Protection Agency. The law further states that the
owner or manager of every water supply system shall submit to the
Texas Department of Health at least one (1) sample of water taken
from the supply for the purposes of bacteriological analysis
during each month that the service operates and that the
person taking these samples and operating the system must be
certified by the Texas Health Department.
HAVE YOU BEEN TAXING SAMPLES AND ARE YOU OR YOUR AUTHORIZED
REPRESENTATIVE A CERTIFIED WATERWORKS OPERATOR?
2. The penalties for not abiding by the above noted
law include fines of between $10 and $1,000 per violation per day
and/or confinement in jail for up to 30 days.
CAN YOU AFFORD THESE PENALTIES?
3. In all likelihood your insurance will not cover
you if a lawsuit is filed because of contaminated water that has
not been checked by your or your authorized representative.
CAN YOU AFFORD TO BE DROPPED BY YOUR INSURANCE COMPANY
OR NOT BACKED BY YOUR INSURANCE COMPANY IN CASE OF VIOLATION?
over, please
2215 EAST ANDERSON LANE AUSTIN, TEXAS 512/459-1221
-------
Ltr. to Parks on Private Water Systems
July 22, 1988
Page 2
4. Equally serious, as far as your business is
concerned, is that word of any complaints or actual lawsuits
concerning contaminated water might "get around" and your till
rate and profits would seriously decrease.
NOTHING TRAVELS FASTER THAN BAD NEWS
SPREAD BY YOUR RESIDENTS!!
It is to your benefit to read carefully the enclosed
brochure and then be sure you comply with the law.
YOUR POCXETBOOX AS WELL AS YOUR REPUTATION IS AT STAKE!
Representatives of Texas Rural Water Association, in
cooperation with the Texas Health Department, will be contacting
you, as owner or your authorized representative to schedule
on-site technical assistance. Please cooperate with them. They
will be there to help.
Additional information can be obtained by calling
Charlotte Zimmerman; Texas Manufactured Housing Association;
Austin, Texas, 512/459-1221.
enclosure
-------
Appendix 0
-------
MHP COMPLIANCE IMPROVEMENT PROJECT
TECHNICAL ASSISTANCE REPORT
3ATE: 9.
ARRIVAL TIME:
SYSTEM THAT TA WAS PERFORMED ON: fl'
PERSON CONTACTED: flirt** J^ fcAj
SPECIFIC PROBLEM ENCOUNTERED: ThL
987 - Klavl C£~pLi»»>Cr
DEPARTURE TIME:
Mr1.fi.-
/"/ 0
*- fm Z i*
HOW PROBLEM WAS ADDRESSED:
/T /V/W. Js>tf*iSo*J
++,. la*
OUTCOME
*J ^~» <=-s &~-&. *h
< ^ °°ne Of>
1 r
EDUCATIONAL MATERIALS PROVIDED:
.-1-J.J
------- |