Your Mobile Home Park’s Private Water System Might Be Your Biggest Liability — Here’s What Every Operator Needs to Know

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If you own a mobile home park with a private water system — a shared well, a private treatment plant, or a community water system serving your residents — you are operating a regulated public utility. And the data suggests most operators don’t fully realize what that means.

Here’s the number that should get your attention: nearly 70% of mobile home parks operating their own water systems have violated Safe Drinking Water Act (SDWA) rules in the past five years. That’s not a fringe statistic. It’s the industry average.

And enforcement isn’t getting lighter.

What “Private Water System” Actually Means Under Federal Law

The Safe Drinking Water Act defines any water system serving 25 or more people — or 15 or more service connections — as a “public water system,” subject to federal and state drinking water regulations. It doesn’t matter that it’s privately owned. If your park serves that many residents, you’re legally a public water provider.

That means:

  • Regular testing for dozens of contaminants
  • Proper sampling protocols
  • Timely reporting to state regulators
  • Certified water system operator on file in many states
  • Emergency response plans

Most mom-and-pop park owners never knew this when they bought their properties. Many still don’t. The parks pass from seller to buyer, and the compliance obligation transfers with the deed — whether or not it was disclosed.

What Violations Actually Look Like (And Cost)

The consequences range from serious to catastrophic.

In January 2025, operators of Oasis Mobile Home Park agreed to a $50,000 penalty and mandatory system upgrades after persistent violations including arsenic levels exceeding federal limits. The EPA had filed multiple enforcement actions against the property over years of non-compliance.

In a historic Pennsylvania case, a park owner was fined $1.3 million for violations across 17 counties. That wasn’t a single bad actor — it was systematic neglect compounded over time.

In Michigan, Colorado, and other states, residents are living with discolored water, odors, and health impacts — and they’re filing complaints, contacting local media, and organizing politically. The result is new state legislation that creates additional compliance layers on top of federal requirements. Colorado’s new Mobile Home Park Water Quality Act (March 2026) tested 200+ parks and found 28 failing health-based standards — and that’s just one state.

Beyond the fines, there’s the operational reality: if the EPA issues an emergency order, you may be required to provide bottled water to every resident while you remediate. On a 100-space park, that’s not cheap — and it’s the kind of news story that follows a property for years.

The New Threat Most Operators Don’t Know About: PFAS

PFAS — per- and polyfluoroalkyl substances, often called “forever chemicals” — are now regulated under new national primary drinking water standards. The compliance deadline for most public water systems, including private mobile home park water systems, is April 2029.

That sounds like a long time. It isn’t.

PFAS testing takes time. If contamination is detected, remediation requires design, permitting, engineering, and construction. For parks in areas near military bases, industrial sites, or heavy agricultural use, PFAS contamination is a real possibility that operators should test for now — not when the deadline is six months away.

The EPA is also ramping up enforcement around cybersecurity requirements under SDWA Section 1433, which requires water systems to conduct risk and resilience assessments and maintain emergency response plans. Most small park operators have never heard of this requirement. Many are already technically in violation.

Five Things You Should Do Right Now

If your park operates a private water system, here are five concrete steps:

1. Get a compliance audit. Hire a licensed water system operator or environmental consultant to review your current compliance status: Is testing current? Are reports filed? Do you have a certified operator on record? This should cost $500–$2,500 and will tell you exactly where you stand.

2. Order a PFAS screen. Run a baseline test for PFOA and PFOS at minimum. It’s inexpensive, it gives you data, and it demonstrates good faith if a regulatory issue emerges later. Don’t wait until 2028.

3. Review your monitoring schedule. Every contaminant has a testing frequency requirement — some quarterly, some annually, some every 3 years. Know your schedule. Missing a required test is its own separate violation, even if your water is clean.

4. Research municipal connection. If you’re on a private system, understand what it would cost to connect to the municipal water supply. This is a long-term capital project, but it permanently removes your single largest operational liability. In many markets, it’s more achievable than operators assume.

5. Know your state program. Several states (Colorado, Michigan, New Jersey) have enacted mobile home park-specific water quality legislation that creates requirements beyond federal minimums. If you operate in these states, know the specific state rules.

The Acquisition Angle: Buying Parks With Compliance Problems

There’s a flip side to this problem.

Parks currently struggling with water system compliance issues often trade at steep discounts. An operator who understands the regulatory path to compliance, has relationships with licensed water system operators, and can model the remediation cost with confidence can acquire these properties at prices that don’t reflect their stabilized value.

Identifying which problems are fixable — and at what cost — is exactly the kind of analysis we cover in the Keel Team Mobile Home Park Due Diligence Playbook. Understanding infrastructure risk before you close is what separates operators who find opportunity in distress from those who inherit it unknowingly.

It’s not for the faint of heart — but for experienced operators who price it correctly, it’s a real opportunity.

Why Keel Team Buys City Water and City Sewer Only

This is one of the reasons Keel Team’s acquisition criteria specifically requires city water and city sewer connections. Private water and sewer is the single biggest operational liability in mobile home park ownership — the compliance burden, the capital exposure, the EPA enforcement risk, and the resident relations fallout are all avoidable if you simply don’t buy them.

For parks we already own on private systems, we proactively research municipal connection feasibility. Even a multi-year capital project to connect is preferable to ongoing regulatory risk.

The Bottom Line

Private water system compliance is one of the most underappreciated operational risks in mobile home park ownership. It’s also one of the most preventable.

A $1,500 annual audit is not a large line item in a park’s budget. A $50,000 EPA fine — plus mandatory upgrades, legal fees, resident relations fallout, and potentially a state enforcement action on top — is a different story entirely.

Know what you own. Stay compliant. Protect your residents and your investment.

Keel Team acquires and operates mobile home parks across the Southeast and Midwest. Our acquisition criteria specifically targets city water and city sewer connections to eliminate private system risk. For more on our investment approach, visit keelteam.com.

Picture of Andrew Keel

Andrew Keel

Andrew is a passionate commercial real estate investor, husband, father and fitness fanatic. His specialty is in acquiring and operating manufactured housing communities. Visit AndrewKeel.com for more details on Andrew's story.

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