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EV Charging in Manufactured Housing Communities: An Operator's Guide

EV Charging in Manufactured Housing Communities: An Operator's Guide

A resident knocks on the office door and says they have bought an electric car and would like to put a charger next to their home. What do you say?

There is almost no guidance for you. Search the question and you get RV campground blogs, a LinkedIn post, and utility programmes written for apartment buildings. The Department of Energy's own page on charging for multifamily housing does not contain the words "manufactured housing" or "mobile home park" anywhere in it.

That absence turns out to be the story. Manufactured housing communities sit in a structural gap on this issue that nobody has closed:

  • No state right-to-charge law covers you. The statutes reach condominiums, homeowner associations and apartment tenants. California has two of them, and a land-lease community falls outside both.
  • No utility funding programme covers you either, because they define a "multi-unit dwelling" as a building with five or more units — a test a community of detached homes on separate lots cannot meet.
  • Your park's electrical service was sized on a formula that assumed nobody would ever do this.

None of which makes it impossible. It makes it a decision you get to make on your own terms, with a real capacity constraint and a real regulatory question underneath it.

General information for operators, not legal or engineering advice. Load calculations are site-specific and must be done by a licensed electrician or engineer. Electricity resale rules vary sharply by state.

Key takeaways

  • Park distribution is sized at 16,000 VA per lot with a demand factor as low as 22% for large communities — an assumption EV charging erodes.
  • NEC permits load management instead of a service upgrade. This is the single most useful fact in the article.
  • No state right-to-charge law names manufactured housing communities. California's cover common interest developments and lessors of a dwelling; a land-lease resident is neither.
  • Utility make-ready programmes define you out by requiring a residential building with five or more units.
  • Reselling electricity carries real regulatory risk — an Ohio Supreme Court decision in April 2026 held a submetering company to be a public utility.
  • Five states have clarified that EV charging is not a utility sale — but whether that overrides a master-meter at-cost rule is unresolved.
  • The federal 30C credit expired for property placed in service after 30 June 2026.

Your service was sized assuming nobody would do this

Start with the arithmetic, because it constrains everything else.

Park distribution is calculated at 16,000 volt-amperes per lot, or the calculated load of the largest home the lot will take, whichever is greater — then reduced by a demand factor that falls from 100% for a single lot to 22% for communities of 61 lots or more. A worked example: 25 homes × 16,000 VA × 24% = 96,000 VA, or 400 amps at 240 volts for the entire community.

That demand factor is a statistical bet that not every home draws its maximum at once. It is a good bet for ranges, dryers and air conditioning, which cycle. It is a bad bet for EV charging, which runs at a constant draw for hours and clusters in the evening — exactly when the rest of the load peaks.

At the lot, California requires that service for a new lot be rated "not less than 100-amperes (24,000 volt-amperes)" — and notably does not require existing lots to be upgraded to that standard. Older communities routinely run less.

Now the load. Under the 2023 NEC, EV supply equipment is calculated at 7,200 VA or the nameplate rating, whichever is larger, and EV charging is treated as a continuous load — meaning the circuit is sized at 125% of it.

Put those together. A 100-amp pedestal serving a home with an electric range, dryer, water heater and central air has limited headroom, and a Level 2 charger wants a substantial share of what remains. Whether a specific pedestal can take one is a site-by-site load calculation, not a general answer — and nobody publishes a typical spare-capacity figure for a manufactured home lot, because there isn't one.

Load management is the code-sanctioned alternative

This is the fact that changes the economics, and most operators have not heard it.

You do not necessarily have to rebuild the service. The NEC expressly permits an automatic load management system as an alternative: where such a system is used, the maximum equipment load on a service and feeder is the maximum load permitted by that system — NEC 2023, §625.42(A).

In plain terms: a system that throttles or staggers charging so the total never exceeds available capacity lets you size to the managed load rather than the theoretical maximum. Ten chargers that will never all run at full output simultaneously can sit on a service that could not support ten unmanaged chargers.

For a community with constrained distribution and no appetite for a transformer upgrade, that is the difference between "no" and "yes, on these terms." It is also the argument to put to an electrician who opens with a service upgrade quote.

Level 1 deserves more credit than it gets. A standard 120-volt outlet adds modest range overnight, which for a resident driving a normal commute is often sufficient. It requires a dedicated circuit rather than a service rebuild. If your community's constraint is real, Level 1 is a legitimate answer rather than a fobbing-off.

No right-to-charge law covers you

Several states give residents a legal right to install charging. None of them reaches a manufactured housing community, and California is the clearest illustration because it has two such statutes and a land-lease resident falls outside both.

Civil Code §4745 applies to common interest developments — condominiums and homeowner associations. A land-lease community is not one.

Civil Code §1947.6 applies to "a lessor of a dwelling", and requires such a lessor to approve a written request from a lessee to install a charging station. But a manufactured housing resident leases a lot, not a dwelling — they own the dwelling. And the statute contains no reference to mobilehomes or manufactured housing anywhere.

Nor does the Mobilehome Residency Law fill the gap. The words "electric vehicle" do not appear in it.

The broader picture: Florida, Hawaii, New York, Oregon, Washington, Utah, Virginia, Maryland, New Jersey and North Dakota provide property-owner protection only — condominium, HOA and co-op. California, Colorado, Connecticut and Illinois extend to renters. Texas has no renter right-to-charge law at all.

Colorado is the one plausible exception, and it is worth watching. C.R.S. §38-12-601 states that the section "applies to residential rental properties and commercial rental properties," with no carve-out for manufactured housing communities, and permits a tenant to install Level 1 or Level 2 equipment on the leased premises or an assigned parking space. Since a manufactured home lot is residential rental property, coverage is arguable. We found no court decision or attorney general opinion applying it to a community, so treat it as unresolved rather than settled.

What this means practically. Outside Colorado, a resident has no statutory right to demand you permit a charger, and you have no statutory framework telling you how to say yes safely. Both halves matter. The absence of a law is not only freedom — it is also the absence of the safe harbour that apartment landlords get. Where your state sits on adjacent questions is mapped in the 50-state index.

The resale question, and the Ohio decision

If your community is master-metered and you bill residents for the electricity a charger consumes, are you selling electricity? And does that make you a utility?

The risk is not hypothetical. On 22 April 2026 the Ohio Supreme Court held that a submetering company reselling electricity to tenants was a public utility subject to state commission regulation, rejecting the argument that it acted merely as the landlord's agent. The court's characterisation was that reselling electricity was "by no means ancillary" to the business.

Five states have clarified that EV charging specifically is not a utility sale:

State Provision
California Pub. Util. Code §216(i) — supplying electricity "only for use to charge light duty plug-in electric vehicles does not make the corporation or person a public utility"
Florida §366.94 — "the provision of electric vehicle charging to the public by a nonutility is not the retail sale of electricity"
Washington RCW 80.28.320 — commission shall not regulate battery charging facilities
Iowa Admin. Code r. 199-20.20 — entities providing electricity for EV charging are not public utilities
Texas SB 1202 (2021) — an operator of EV charging equipment is not for that reason a retail electric utility

But there is an unresolved interaction, and it lands squarely on you. California's Public Utilities Code §739.5 — which names mobilehome parks explicitly — requires that a master-meter customer "charge each user of the service at the same rate that would be applicable if the user were receiving gas or electricity directly" from the utility. At cost, in other words.

Does the EV charging carve-out override the master-meter at-cost rule for a land-lease community? No source we could find addresses it. That is a genuine open question, and it means an operator planning to charge a premium for EV electricity in a master-metered California community is doing so without authority either way.

The safe posture, absent advice: bill EV consumption at cost, treat any charging fee as covering equipment and installation rather than the electricity itself, and disclose the whole structure in advance — which is what your lot rent and pass-through structure has to do anyway.

Where the funding stops

This is the finding worth knowing before you spend time on grant applications.

NEVI is not for you. The federal formula programme requires chargers to be located along designated Alternative Fuel Corridors, with limited exceptions only where a state's corridors are fully built out. A community is not eligible unless it sits on a corridor and offers public access.

The 30C tax credit has expired. It covered 30% of cost up to $100,000 per item in low-income or non-urban census tracts — but only for property placed in service through 30 June 2026. Anyone still citing it to you is working from stale material.

Utility make-ready programmes define you out by construction. New York's Joint Utilities programme funds up to 100% of eligible make-ready costs at qualifying multi-unit dwellings — and defines a multi-unit dwelling as "a multi-unit residential building with five or more dwelling units." A Massachusetts investor-owned utility programme uses the same shape: five or more residential units with shared parking on shared utility meters.

A community of 120 detached homes on 120 separate lots is not a building with five or more dwelling units. You fail a definition written for apartment blocks.

One angle that may work. Colorado's EV Home Charge programme awards grants of up to $350,000 per applicant to electric cooperatives and municipal utilities, funding rebates for panel and wiring upgrades. It does not name manufactured housing — but many communities sit in cooperative territory, and the applicant is the utility rather than you. Applications are not currently open; the next window is in October 2026.

The practical move: call your utility's key accounts or business EV team directly and ask whether a land-lease community qualifies under their programme's definitions. The answer may be no, but the definitions are set by tariff and programme design rather than statute, and they are the sort of thing that changes when somebody points out the gap.

What it actually costs

From the Department of Energy and NREL's cost study, which is a national-lab source rather than vendor marketing:

Item Cost
Level 1 hardware $300–$1,500
Level 1 installation $0–$3,000 (nil where a dedicated outlet exists)
Level 2 hardware $400–$6,500
Level 2 installation $600–$12,700, averaging around $3,000
Trenching through soil $10–$20 per foot
Trenching through asphalt or concrete $100–$150 per foot

Two numbers to sit with. About 72% of commercial Level 2 installations required work on the electrical panel — so treat panel work as the base case rather than the exception. And trenching through paving at $100 to $150 per foot means a hundred-foot run across a community road costs more than the charger.

That trenching differential is the reason a per-homesite charger at every lot is rarely the right first move, and a small number of shared units near existing service usually is.

For comparison, ICCT put the average cost per charger at $635 in a private home against $3,081 at a multifamily property. A manufactured home lot sits somewhere between — detached, but on shared distribution — and no published source models it directly.

The demand you will actually see

Be realistic about timing, because this is not yet a large number of residents.

Home charging access is the binding constraint on EV adoption generally. ICCT found personal garage access at 70% for single-family detached homes, 58% attached, and 5 to 6% across multifamily. The Department of Energy's survey work found every apartment category below 25% access or potential access to electricity at parking.

A manufactured housing community sits in an unusual position: detached homes, often with a driveway or carport, but on a shared distribution system with limited headroom. Physically closer to the single-family case, electrically closer to the multifamily one.

And nobody has measured it. We could not find a single federal, national-lab or academic source reporting EV ownership or home charging access broken out for manufactured housing. The housing type is simply absent from the data, which is the same absence that produced the funding gap above.

Practically: expect the first request soon if you are not already fielding them, expect a handful rather than a wave, and expect the residents who ask to be your better-credit, longer-tenure households — which is a reason to have an answer ready rather than a reason to say no.

Who owns what — the unsettled question

A resident owns the home. You own the land and the electrical infrastructure serving it. So a charger is a modification to which of those?

No authority resolves this in a land-lease context. We looked.

What is clear is the structural line: the lot service and its equipment are governed by state park regulations rather than by the home's HUD-code construction, so work at the pedestal is park infrastructure, not home modification. A charger mounted on the home and fed from the home's own panel is a different proposition from a pedestal-fed unit on the lot.

That distinction should drive your policy. A resident modifying their own home's electrical system, within its existing service, is doing something to their property. A resident wanting a new circuit from your pedestal is doing something to yours — and that is squarely yours to permit, condition or refuse.

California requires a permit before any alteration to a manufactured home, with submissions that can include electrical load calculations. The utility connection side is covered in the installation guide.

A practical sequence

  1. Get the community's actual available capacity calculated by a licensed electrician — the service size, the current peak, and the headroom. Not an estimate.
  2. Decide your model: shared chargers near existing service, or per-lot installations. Trenching cost usually settles this.
  3. Ask your utility about programme eligibility and about make-ready support, in that order.
  4. Establish your state's resale position before you decide how to bill. At cost is the safe default.
  5. Write a policy, whether or not your state requires one: who may install, at whose cost, to what standard, who owns the equipment at the end of the tenancy, and what happens on a lot transfer.
  6. Require load management where capacity is tight — it is code-sanctioned and cheaper than a service upgrade.
  7. Record it per homesite, because the capacity you have allocated at one lot is capacity you no longer have at another.

Step 7 is the one that gets missed. Approving chargers one at a time without tracking cumulative allocated load is how a community discovers its constraint by tripping something. The broader infrastructure position belongs in the operations and acquisition diligence picture.

How RIOO fits

RIOO is a property management platform built natively on Oracle NetSuite, with the homesite as the record — which matters here because electrical capacity is a per-lot resource you spend down.

Pedestal service size, approved charger installations and allocated load sit on the homesite, so cumulative committed capacity across the community is a number you can read before approving the next request. Installation approvals, conditions and equipment ownership are dated events on the record, which is what stops a charger installed in 2026 becoming an argument about who owns it in 2032.

Where you bill EV consumption, it is a separate revenue line on the same homesite as the site rent, which is what keeps an at-cost charge demonstrably at cost.

See how RIOO handles manufactured housing communities.

Conclusion

Manufactured housing communities have been left out of the EV charging framework twice over — out of the right-to-charge statutes, and out of the funding definitions. The federal data does not count you, and the utility programmes define a multi-unit dwelling in a way you structurally cannot satisfy.

The upside of being unregulated here is that the decision is genuinely yours. The downside is that there is no safe harbour, no template, and an unresolved question about what you may charge for the electricity.

Do the load calculation, ask the utility, bill at cost until somebody tells you otherwise, insist on load management where capacity is tight, and write the policy down before the second resident asks. That is a defensible position today, and it puts you ahead of a market that has not yet decided this matters.

Frequently asked questions

Q1. Can a manufactured home lot support a Level 2 charger?
It depends on the pedestal service and the home's existing load. California requires new lots to be rated at not less than 100 amps, and does not require older lots to be upgraded. EV supply equipment is calculated at 7,200 VA or nameplate, whichever is larger, and treated as a continuous load. It is a site-specific calculation.

Q2. Do I have to allow a resident to install a charger?
Almost certainly not. No state right-to-charge law names manufactured housing communities. California's statutes cover common interest developments and lessors of a dwelling, and a land-lease resident is neither. Colorado's law applies to residential rental property generally, which arguably reaches a community, but no decision has tested it.

Q3. Can I avoid upgrading the electrical service?
Often, yes. The NEC permits an automatic load management system, in which case the maximum load on the service is the maximum the system allows. That is the code-sanctioned alternative to rebuilding distribution, and it should be priced before any service upgrade.

Q4. Can I charge residents for the electricity?
Carefully. Five states have clarified that EV charging is not a utility sale. But where a community is master-metered, at-cost resale rules may still apply — California requires master-meter customers to charge the rate the resident would have paid the utility directly, and whether the EV carve-out overrides that is unresolved. Billing at cost is the safe default.

Q5. Is there funding available?
Rarely, and for a structural reason. NEVI is corridor-only. The federal 30C credit expired for property placed in service after 30 June 2026. Utility make-ready programmes typically define a multi-unit dwelling as a residential building with five or more units, which a community of detached homes cannot satisfy. Ask your utility directly.

Q6. What does it cost?
Per DOE and NREL: Level 2 hardware $400–$6,500, installation $600–$12,700 averaging around $3,000, and about 72% of commercial Level 2 installations required electrical panel work. Trenching runs $10–$20 per foot through soil but $100–$150 through asphalt or concrete, which usually decides whether you go shared or per-lot.