In the Dirtlease cafeteria, Legal and Economics saw Bot sitting alone. At the table to his left, a bunch of women from HR sat talking about eating and whatever else – Legal thought – women talk about when they are alone. To his right, two men and a woman from Security sat eating crayons.
‘You want to join that wanker’, Legal asked Economics. ‘He looks lonely.’
‘Have you spoken with the Founder recently’, Economics asked Legal. ‘The book deal seems to have gone to his head. He is all ‘I am the voice of an industry’ now. He doesn’t speak anymore. He pontificates. It’s impossible to get on his calendar.’
‘I think this sushi was made during the Eisenhower administration.’
‘You should see the crap they serve at Baker Brothers.’
The two men took their trays and walked toward Bot. When they sat, the woman and one of the men at the Security table were banging their heads together, each trying to induce a concussion in the other. The second man at the table was making a Sportsball bet on his phone.
‘Hey’, Legal said to Bot.
‘Hi’, Bot said. He shoveled some kale into his food-hole.
‘Good leafy greens?’
‘M.’
The man who had been banging his head against the woman’s head at the Security table vomited and passed out. The woman punched the air and said, ‘Whoo-hoo!’
‘Is it true –‘Legal said to Bot.
‘Yes’, Bot asked.
‘What they say about you’, Legal finished.
‘And what is that’, Bot asked.
‘They say you can produce a research paper in five minutes?’
‘Oh, sure’, Bot said. ‘That’s what I do.’
‘Could you’ – Economics said.
‘Yes?’
‘Write a paper that summarizes empirical research about the effects, including unintended consequences, of rent control statutes, discuss the foregoing in the context of manufactured housing communities in New York State and propose some alternatives?’
‘On it’, Bot said.
The group at the HR table erupted in laughter. The betting man at the Security table stabbed his thumbs into his phone several times and threw it on the floor.
‘I like the pumpkin leaves they serve here, but they give me gas’, Legal said.
‘I like long pig, but long pig does not like me’, Economics said.
‘Sorry?’
‘Forget about it.’
Bot twitched from the stomach up, like a cat vomiting a hairball. When he opened his mouth, a research paper emerged.
‘Should we, like, dry this off before we touch it’, Legal said.
‘Read’, Economics said.
The two men bent over the document. Legal moved his lips as he read. Economics allowed him extra time as he turned the pages. When they were done, Legal said, ‘I think you are fucked, mate.’
‘I think we are all fucked.’
Rent Control, Manufactured Housing,
and Policy Alternatives
Empirical Evidence on Housing Quality, Availability, and Cost, with Analysis of New York Real Property Law §§ 233(b)(6) and 233-b and Proposals for Alternatives to Rent Control
March 2026
Abstract
Rent control—policies that limit the rents landlords may charge or the rate at which those rents may increase—has been debated by economists and policymakers since at least World War I. This paper synthesizes the empirical research literature on rent control’s effects on housing quality, availability, and cost, drawing on major peer-reviewed studies as well as comprehensive meta-analyses. The paper then examines that body of evidence in the context of manufactured housing park tenants in New York State, with reference to New York Real Property Law § 233-b (governing rent increases in manufactured home parks) and § 233(b)(6) (governing a park owner’s ability to change the use of the park). It concludes with a discussion of three proposed alternatives to rent control: publicly funded rent insurance programs, direct rental assistance payments made to tenants, and infrastructure grants made to park owners. Throughout, the paper prioritizes empirical findings over theoretical arguments and cites sources for all principal factual claims.
1. Introduction
The affordability of rental housing has become one of the defining domestic policy challenges of the early twenty-first century. In major metropolitan areas, rents have risen sharply, outpacing wage growth and straining household budgets. At the same time, less visible but equally serious affordability pressures have mounted in an often-overlooked segment of the housing market: manufactured home parks—communities in which residents typically own their homes but rent the land beneath them from a park owner.
This paper addresses the economics of rent control in three parts. Part One reviews the established empirical literature on the effects of rent control in the general rental housing market, examining what decades of peer-reviewed scholarship tell us about the impact of rent regulations on housing quality, availability, and cost. Part Two examines that literature in the context of New York State’s statutory framework for manufactured housing rent regulation. Part Three examines three frequently proposed alternatives to rent control—rent insurance, direct rental assistance, and infrastructure grants to landlords—and reviews the evidence on their effectiveness.
A note on scope: the term “rent control” is used throughout this paper in its broad sense, encompassing both first-generation hard rent controls (strict nominal price caps) and second-generation “soft” controls or “rent stabilization” schemes that allow annual increases subject to caps or formulas. Where the distinction matters, it is noted.
2. Empirical Evidence on the Effects of Rent Control
2.1 Overview of the Literature
The empirical literature on rent control is large and increasingly rigorous. The most comprehensive recent synthesis is a 2024 meta-analysis by Kholodilin (2024) that reviewed 112 separate empirical studies on rent control effects across multiple countries. Earlier systematic reviews by Turner and Malpezzi (2003) and by Gyourko and Linneman (1989) cover the older American literature. The strongest recent causal evidence comes from two landmark quasi-experimental studies that exploit abrupt policy changes: Diamond, McQuade, and Qian (2019) on San Francisco’s 1994 rent control expansion and Autor, Palmer, and Pathak (2014) on the end of rent control in Cambridge, Massachusetts in 1995.
2.2 Effects on the Cost of Housing
2.2.1 Rents in Controlled Units
The most robust and consistent finding in the rent control literature is that controls reduce rents in covered units. A review of 31 studies found that 25 reported statistically significant rent reductions in rent-controlled units (Kholodilin 2024). In New York City, data spanning 2002–2008 found that median rents in stabilized units ran approximately 20 percent below those in comparable unregulated units, with larger discounts in high-demand areas (Gyourko and Linneman 1989). The discount tends to grow over time, because controlled rents increase slowly while market rents reflect current demand. Diamond et al. (2019) documented that covered tenants in San Francisco placed very high implicit value on their rent-controlled units—evidenced by their sharply reduced propensity to move.
2.2.2 Effects on Property Values
Rent control depresses the values of controlled properties, both directly (lower income streams reduce asset value) and indirectly (reduced maintenance depreciates the physical structure). The Cambridge decontrol study provides striking evidence of the reverse: Autor et al. (2014) estimated that the elimination of Cambridge’s rent control added approximately $1.8 billion to the city’s housing stock between 1994 and 2004—nearly a quarter of total Cambridge residential price appreciation over that decade. More than half of this appreciation came from positive spillover effects on properties that had never been rent-controlled, suggesting that the presence of rent-controlled (and often poorly maintained) buildings had suppressed values in surrounding neighborhoods.
2.3 Effects on Housing Availability and Supply
2.3.1 Conversion of Rental to Owner-Occupied Housing
One of the most consistently documented supply-side effects of rent control is the conversion of rental units to owner-occupied or non-rental uses. In Washington D.C., the number of rent-controlled units fell from approximately 85,000 in 1984 to about 72,878 in 2020, driven significantly by conversion. In San Francisco, Diamond et al. (2019) found that covered landlords reduced their rental supply primarily by converting buildings to condominiums, selling to owner-occupants, or redeveloping to qualify for exemptions from rent control as newly constructed buildings.
2.3.2 Effects on New Construction
The effect of rent control on new construction is more contested than its effect on the existing rental stock. Most American rent control regimes exempt newly constructed buildings, which limits the direct regulatory deterrent on new supply. The Kholodilin (2024) meta-analysis found that approximately two-thirds of studies examining new construction reported either a negative effect or no effect; very few found a positive relationship. A cross-national historical analysis covering 36 countries also found a predominantly negative or neutral association between rent control and residential construction levels. Even where controls do not directly suppress total construction, they may shift development toward for-sale properties, reducing available rental stock.
2.4 Effects on Housing Quality
2.4.1 Maintenance and Investment in Individual Units
Economic theory predicts that rent control reduces housing quality by diminishing landlords’ financial incentive to maintain and improve their properties. If a landlord cannot raise rents to reflect maintenance expenditures or capital improvements, the expected return on such investments falls. Empirical research has largely confirmed this prediction. The Kholodilin (2024) meta-analysis found that studies addressing housing quality are “near-unanimous” in their conclusion that rent control lowers housing quality in regulated dwellings because of reduced landlord maintenance incentives. The longitudinal study by Moon and Stotsky (1993) found that rent-controlled units experienced significantly lower quality improvements over time relative to comparable uncontrolled units.
2.4.2 Neighborhood Quality, Crime, and Spillovers
Beyond individual unit quality, rent control affects neighborhood quality. A companion study by Autor, Palmer, and Pathak (2019) found that the end of Cambridge’s rent control caused overall crime to fall by approximately 16 percent—about 1,200 fewer crimes annually—with an estimated annual direct benefit to Cambridge residents of roughly $10 million in 2008 dollars. The authors attribute this to improvements in neighborhood quality following the renewal of investment in formerly controlled properties.
2.5 Residential Mobility, Misallocation, and Targeting
2.5.1 Lock-In and Reduced Mobility
Rent control creates strong financial incentives for tenants to remain in their current units, because moving to an uncontrolled unit entails a potentially large increase in rent. Diamond et al. (2019) found that San Francisco’s rent control expansion increased the probability that covered tenants remained at their address by approximately 20 percent. This “lock-in” effect reduces residential mobility more broadly, producing misallocation of housing stock: units are not allocated to those who value them most, but to those who happened to secure them at some earlier point.
2.5.2 Misallocation
Glaeser and Luttmer (2003) developed an empirical framework to measure misallocation and applied it to New York City, finding that an economically and statistically significant share of rent-controlled apartments appeared to be misallocated across demographic subgroups. They estimated the welfare losses from this misallocation were potentially large enough to exceed the welfare losses from undersupply alone.
2.5.3 Distributional Effects: Who Benefits?
Rent control lacks an income-targeting mechanism: any tenant in a covered unit benefits regardless of income. Studies of Cambridge found that tenants in the bottom income quartile occupied only 26 percent of rent-controlled apartments, while tenants in the top half of the income distribution occupied 30 percent (Turner and Malpezzi 2003). In California, 57.3 percent of rent-controlled units as of 2013 were occupied by middle- and high-income tenants (Center for Growth and Opportunity 2023). Diamond et al. (2019) found that, by simultaneously drawing in higher-income residents to newly redeveloped units and preventing the out-migration of minorities from rent-controlled buildings, rent control contributed to widening income inequality in San Francisco.
2.6 Displacement Benefits
Despite its many negative consequences, rent control does produce a genuine and important benefit: the reduction of displacement of incumbent tenants. Diamond et al. (2019) estimated that the vast majority of San Francisco tenants covered by rent control would have been displaced from the city absent that coverage, given the dramatic appreciation in that market. The effect was especially pronounced for older tenants and racial and ethnic minorities. These stabilization benefits are real—but they primarily accrue to those fortunate enough to be in rent-controlled units at the right time. New entrants to the housing market face a tighter and more expensive market as a result of the supply effects described above.
3. The New York Manufactured Housing Context: RPL §§ 233-b and 233(b)(6)
3.1 The Unique Situation of Manufactured Home Park Tenants
Manufactured housing occupies a distinctive and often overlooked segment of the American housing market. Approximately 20 million Americans—about 6 percent of the total population—live in manufactured homes. These communities serve as a vital source of unsubsidized affordable housing, particularly for seniors on fixed incomes, veterans, low-income families, and rural residents who lack access to rental alternatives.
The defining structural feature of the manufactured home park market is the separation of home ownership from land ownership. Most park residents own their homes but rent only the lot beneath them.
3.2 New York Real Property Law § 233-b: Rent Increases in Manufactured Home Parks
3.2.1 The 3% Baseline Cap and Its Exceptions
Under § 233-b, rent increases may not exceed three percent above the rent since the current rent became effective (N.Y. Real Prop. Law § 233-b(1)). The term “rent” is defined broadly to encompass all costs charged to the tenant, including fees, charges, assessments, and utilities, so that park owners cannot circumvent the cap by recharacterizing lot rent as service fees.
There is one exception to the three percent cap. A rent increase may exceed three percent to account for: (a) increases in the park owner’s operating expenses; (b) increases in property taxes; or (c) increases in costs directly related to capital improvements in the park (N.Y. Real Prop. Law § 233-b(2)(a)–(c)). However, an increase of this type may not exceed three percent in addition to the three percent increase allowed of right. This creates a de facto six percent hard cap on rent increases. This rule reflects a legislative recognition that a three percent cap that ignores rising operating costs would compress net income below sustainable levels and may ultimately lead to deferred maintenance and park deterioration.
3.2.2 The Challenge Procedure
Any rent increase above three percent may be challenged by aggrieved homeowners as unjustified (N.Y. Real Prop. Law § 233-b(3)). The challenge must be filed within ninety days of the proposed increase by filing an action for a declaratory judgment that the increase is unjustifiable. Multiple tenants with common questions of law and fact may join the same action.
There is an irrebuttable presumption of justifiability when the increase does not exceed the tenant’s pro-rata share of the park’s actual operating costs and property taxes (N.Y. Real Prop. Law § 233-b(4)). The court may condition its approval of any challenged increase upon the remediation of health and safety conditions in the park. While a challenge is pending, tenants must pay the disputed amount into escrow held by the park owner. No eviction for nonpayment of a challenged increase may occur while the matter is pending. If the court ultimately finds the increase or any portion of it unjustifiable, the owner must refund the impermissible amount to each tenant household. A park owner who fails to place challenged amounts in escrow is subject to a civil penalty of up to $500 (N.Y. Real Prop. Law § 233-b(5)–(6)).
3.3 Current Legislative Proposals to Strengthen § 233-b
In the current legislative session, Senator Skoufis introduced S. 228-A in the 2025–2026 legislative session (N.Y. Senate Bill S228-A, 2025 Session).
The bill would add two new subdivisions to § 233-b. The first would require park owners to provide written justification for any increase above three percent and to make supporting cost documentation available to any resident upon request. The second would tighten the standard for invoking the operating-expenses exception, requiring the park owner to demonstrate that ordinary maintenance costs were necessary to meet the warranty of habitability and that the increase was no more than the actual and reasonable cost of the work performed (S228-A, proposed § 233-b(8)–(9)). The bill was prefiled in January 2025 and referred to the Senate Committee on Housing, Construction and Community Development.
Critics of the legislation have raised concerns that imposing additional disclosure burdens on small-owner operators—whose administrative resources are limited—will deter necessary capital improvements by making the process of seeking exception-based increases so onerous that park owners will simply defer maintenance rather than navigate the procedure. Critics have also raised the concern that certain costs not directly related to the warranty of habitability, such as increased property taxes and insurance premia, or increases in borrowing costs, are not covered by the proposed legislation. Since money is fungible, the inability to pass on these increased costs could hamper park owner’s ability to make repairs directly attributable to the warranty of habitability.
3.4 Rent Control and the Infrastructure Crisis in New York’s Manufactured Home Parks
3.4.1 The Scope of the Problem
The empirical finding that rent control reduces housing quality over time, a near-unanimous conclusion in the Kholodilin (2024) meta-analysis, manifests with particular severity in New York’s manufactured home park sector. The clearest market signal of the depth of this problem comes from the secondary market for park properties. Among the fifty states, New York consistently accounts for the largest share of manufactured home parks listed for sale on MobileHomeParkStore.com, a commercial platform for park transactions. The concentration of New York listings reflects not merely market size but market distress: parks are being placed on the market at high rates because their owners—predominantly small, individual operators—find continued operation financially unsustainable under the § 233-b rent cap.
A review of active listings on MobileHomeParkStore.com reveals that infrastructure deficiencies are pervasive and severe across New York parks currently offered for sale. Common conditions disclosed in listing materials include: roads in advanced states of deterioration, with crumbling pavement, potholes, and drainage failures that render portions of communities effectively impassable; water main systems with persistent leaks, some losing a significant share of metered supply before it reaches homes; electrical distribution infrastructure that predates modern amperage and safety requirements; and, most critically from a public health standpoint, failing sanitary systems—including both individual drain fields and communal septic treatment plants that are at or beyond the end of their design life.
Of particular concern is the widespread presence of Orangeburg pipe in park sewer infrastructure. Orangeburg—a product made from compressed wood pulp, pitch, and asphalt, manufactured widely from the 1940s through the early 1970s—was used extensively in manufactured home park construction during the period of peak park development. The material has a design life of approximately fifty years and degrades when it reaches that limit: the pipe walls absorb moisture, deform from circular to oval cross-section, collapse inward, and eventually fail entirely. Complete replacement, which requires excavating the sewer main and all lateral connections, typically costs between $10,000 and $25,000 per lot, depending on depth, soil conditions, and proximity to the treatment system. A park of 50 lots facing a complete Orangeburg sewer replacement can therefore expect capital costs in the range of $500,000 to $1.25 million—an expenditure that is impossible to finance at lot rents that have been artificially suppressed by decades of below-market increases.
3.4.2 The Small-Owner Operator and the Rent-Revenue Gap
The parks experiencing the most severe infrastructure deterioration in New York are, in the great majority of cases, owned and operated by individuals or families—the so-called “mom-and-pop” operators who developed or acquired their properties decades ago, raised families in or near the parks, and have charged lot rents that, in many instances, have not increased in decades. Many charge rents that are far below the rates prevailing in comparable communities in adjacent communities. The § 233-b cap makes it impossible to address infrastructure issues in these parks without raising revenues substantially above current levels.
One park operator in Oregon—a state with a comparable rent regulation scheme—testified in legislative hearings that her park’s average annual operating cost increase runs approximately eight percent, and that a rigid cap that ignores rising costs forces her to operate at minimum standards (Oregon Public Broadcasting, February 6, 2025). New York park operators face the same arithmetic. The compound effect of multi-year below-market rents is not merely a shortfall in current operating income; it creates the absence of the capital reserves that a park operated at market rates would have accumulated over the same period for infrastructure renewal. A park whose lot rents have been frozen at 1990s levels for two decades has no capacity to finance necessary work.
Numbers illustrate the foregoing. Road resurfacing for a modest 50-lot park typically costs between $75,000 and $150,000. Water main replacement runs $50 to $200 per linear foot, exclusive of restoration. Electrical panel and service upgrades, which may be required when parks move from shared metering to individual metering under state mandate, frequently cost $1,500 to $3,500 per lot. Septic treatment plant rehabilitation or replacement can easily exceed $500,000. A park with $300 per month in average lot rent and 50 lots generates $180,000 in gross annual revenue—insufficient, after operating expenses, to service the debt required to fund even a single major infrastructure project, let alone the accumulated backlog of deferred work that characterizes many New York parks currently on the market.
3.4.3 The Death Spiral Mechanism
The interaction between rent control and infrastructure deterioration in manufactured home parks produces a self-reinforcing cycle that the economics literature characterizes as a “death spiral.” The mechanism operates as follows. A park operates for years with below-market lot rents, generating insufficient revenue to maintain infrastructure to the standard that tenants and regulators expect. Infrastructure deteriorates incrementally—roads crack and erode, pipes corrode and leak, electrical panels age—but the park remains marginally habitable. As the physical condition of the park declines, its desirability as a place to live falls. Vacancies increase, because prospective residents who have market options choose newer or better-maintained communities. The vacant lots generate no revenue. The revenue shortfall deepens, reducing further the owner’s capacity to maintain infrastructure. The park’s condition deteriorates more rapidly, driving additional vacancies. The owner, facing a money-losing operation with a large deferred-maintenance liability, lists the park for sale, but there are no takers. The property where the tenants reside deteriorates until they need to move. Their largest asset – their home – becomes worthless.
3.5 New York Real Property Law § 233(b)(6): The Regulatory Trap
But it gets worse.
As discussed above, § 233-b can render continued operation of a manufactured home park financially unviable. A park that cannot generate sufficient revenue to maintain its infrastructure is not a sustainable business for the owner, and is a terrible place to live for the residents. The logical thing to do in a case like this is to change the use of the property. However, New York Real Property Law § 233(b)(6) makes this impossible. This provision requires that a park owner who seeks to close a park or convert land on which a park sits to another use to provide tenants with at least two years’ written notice, and to pay each tenant up to $15,000 per household to assist with relocation costs (N.Y. Real Prop. Law § 233(b)(6)).
The combined effect of § 233-b and § 233(b)(6) is to place the small-owner park operator in a position from which there is no economically rational exit. In a case like this, Section 233-b makes continued operation unprofitable. The three percent cap, applied to lot rents that are already far below market, prevents the owner from generating the revenue needed to maintain the park’s physical infrastructure. Proposed S. 228-A amendment would make the problem worse. However, Section 233(b)(6) imposes costs that make an exit impossible.
This is a regulatory trap. The owner cannot operate profitably because § 233-b constrains revenues. The owner cannot exit the regulated use because § 233(b)(6) imposes prohibitive exit costs. The property is stranded in a use that destroys value for both the owner and the residents. This creates a significant misallocation of social resources.
The residents of these parks are the ultimate victims of this dynamic. The regulatory framework that purports to protect them—by capping their lot rents and preventing their displacement through park closure—instead traps them in communities whose physical condition is deteriorating toward uninhabitability, because the same framework that protects their tenancy simultaneously destroys the financial viability of maintaining the property. A tenant who lives in a park with failing sewer infrastructure, deteriorating roads, and aging electrical systems is not protected by § 233-b; she is condemned by it. The below-market lot rent she pays is a subsidy financed not by the public treasury but by the deferred maintenance of the infrastructure that surrounds her—a subsidy whose true cost is measured not in dollars but in the progressive degradation of the community in which she lives. This is the deepest failure of the § 233-b framework as applied to New York’s distressed park inventory: it does not protect tenants from harm. It redistributes the harm, deferring it in time and disguising it as affordability, while ensuring that it eventually arrives in a form—physical decay, park closure, forced displacement—that is far more destructive than the rent increases the statute was designed to prevent.
4. Alternatives to Rent Control
The empirical literature on rent control, while documenting real stabilization benefits for incumbent tenants, consistently identifies supply reduction, quality deterioration, and poor targeting as significant countervailing costs. These findings have motivated a sustained search for alternative policy mechanisms that can provide meaningful protection for tenants in manufactured home parks and conventional rental markets without generating the same negative side effects. Three alternatives deserve detailed examination: rent insurance programs, direct rental assistance to tenants, and infrastructure grants to park owners.
4.1 Rent Insurance Programs
4.1.1 The Concept
A rent insurance program (sometimes called “rental cost insurance” or “housing cost insurance”) is a publicly funded insurance scheme that provides cash payments to tenants when their rent increases above a specified threshold, shielding them from the full impact of market rent appreciation without restricting what landlords may charge. The basic structure is analogous to other forms of social insurance: tenants (or the government on their behalf) pay premiums, and the insurance fund pays benefits when a triggering event—a rent increase above a defined threshold—occurs.
Unlike rent control, a rent insurance program does not interfere with the price signals that guide landlord investment decisions. Because the landlord continues to receive market-rate rents, the incentive to maintain the property in good repair and to make capital improvements is preserved. Because the insurance payment goes to the tenant rather than through a price cap on the landlord, there is no incentive for the landlord to convert units or exit the rental market. The supply-suppressing and quality-reducing effects documented in the rent control literature should not arise under a well-designed rent insurance scheme.
A rent insurance program also has superior targeting properties compared to rent control. Because the insurance benefit can be conditioned on income (means-tested), it can be directed to the households that most need it—rather than distributing benefits broadly across the income spectrum as rent control does.
4.1.2 Evidence and Limitations
Rent insurance as a public policy instrument has been more discussed in the academic literature than actually implemented at scale, and empirical evidence on its performance is accordingly more limited than for rent control or housing vouchers. The theoretical case has been made by several economists, including Arnott (1995) and Glaeser and Luttmer (2003), who argued that well-designed insurance mechanisms can provide the stabilization benefits of rent control without its supply costs. Brookings Institution researchers have endorsed a similar approach.
The principal practical challenges identified in the literature are: (a) the cost of operating a public insurance fund, which requires sustainable premium collection and actuarially sound benefit design; (b) moral hazard on the landlord side (if landlords know tenants are insured against rent increases, they may raise rents more aggressively than they would in an uninsured market); and (c) adverse selection (lower-risk tenants may opt out of a voluntary program, leaving only high-risk tenants and pushing up premiums).
In the manufactured housing park context, a state-sponsored rent insurance program could be designed to supplement the § 233-b framework: tenants whose lot rents increase above the three percent baseline (whether pursuant to an authorized exception or because § 233-b is successfully challenged) could receive insurance payments equal to the amount of the increase above a defined affordability threshold. This would provide a financial cushion for tenants who cannot comfortably afford the exception-driven increases that § 233-b currently permits, while preserving the park owner’s ability to recover legitimate cost increases—including the capital improvement costs that the infrastructure analysis in Section 3.4 identifies as among the most pressing.
4.2 Direct Rental Assistance Payments to Tenants
4.2.1 The Empirical Record of Housing Choice Vouchers
The United States has operated the largest direct rental assistance program in the world through the Housing Choice Voucher program (formerly Section 8), administered by the Department of Housing and Urban Development. Under this program, participating families earning below 50 percent of the area median income contribute approximately 30 percent of their adjusted income toward rent, and the voucher covers the difference between that contribution and the actual rent, up to a Fair Market Rent ceiling.
The empirical evidence on voucher outcomes is generally positive. A 2022 study by Schapiro et al. (2022) found that rental assistance recipients had significantly lower odds of reporting housing instability, low housing quality, lack of autonomy over their housing, and housing unaffordability compared to comparable households on waiting lists. Research has also found that voucher holders are more likely to report high or adequate housing quality than matched unassisted renters—the opposite of the quality deterioration observed in rent-controlled units (PSC Housing / NLIHC 2024). By limiting tenant contributions to approximately 30 percent of income, vouchers are also effective at reducing housing-induced poverty.
Economic analysis comparing vouchers to rent control has consistently favored vouchers. The Center for Growth and Opportunity (2023) concluded that vouchers provide greater insurance benefits, are more cost effective, and enhance labor mobility compared to rent control, because they target those most in need and do not constrain recipients to a particular location. Recent empirical research has also found no evidence that expanding housing choice vouchers increases rental housing prices for non-recipients—addressing an earlier concern about demand-driven rent inflation.
4.2.2 Limitations of the Voucher Program
Despite its documented effectiveness, the Housing Choice Voucher program has significant limitations. The most fundamental is chronically inadequate funding: the Urban Institute estimated that only about one in three eligible families receives assistance, leaving 6.1 million low-income renters facing severe housing hardship despite qualifying for the program (Turner 2004). Voucher success rates—the share of households that actually lease a unit using their voucher—fell from approximately 81 percent in the late 1980s to approximately 69 percent in later studies, driven by tight rental markets, landlord reluctance to participate, and geographic mismatches between voucher holders and available units.
In the manufactured housing context specifically, the voucher program has limited applicability: vouchers are designed for use in the conventional rental market and are not readily usable by manufactured homeowners who own their homes and need only to subsidize lot rent. A targeted “lot rent voucher” program—state or federally funded payments directly to low-income manufactured homeowners to reduce their net lot rent cost—could fill this gap without the supply and quality consequences of rent control.
4.3 Infrastructure Grants to Park Owners
4.3.1 The Policy Rationale
A third alternative to rent control—particularly relevant in the manufactured housing context—is the provision of infrastructure grants or low-interest infrastructure loans to park owners, conditioned on commitments to maintain affordable rents and housing quality. The theory of this approach is straightforward: many of the legitimate cost pressures that drive rent increases in manufactured home parks arise from aging infrastructure (roads, water and sewer systems, electrical distribution) that requires substantial capital investment. If a public subsidy covers some or all of that capital investment, the park owner’s rent increase requirement falls, and the interests of tenants and park operators are better aligned.
This approach also directly addresses the quality concerns documented in the rent control literature. A common finding in the empirical research is that rent controls reduce housing quality because they reduce landlords’ returns on investment in maintenance and improvement. A grant program that ties public funds to verifiable capital improvements and maintenance standards could maintain quality without requiring landlords to absorb the full cost.
4.3.2 Federal Programs
The federal government has created several programs that provide infrastructure and improvement financing for manufactured housing communities. The most significant recent development is the HUD Preservation and Reinvestment Initiative for Community Enhancement (PRICE) program, funded at $225 million in the FY2023 omnibus appropriations bill (Housing Assistance Council 2023). PRICE provides competitive grants to states, local governments, resident-owned communities, cooperatives, nonprofits, and CDFIs for infrastructure improvement, relocation assistance, and eviction prevention. Grantees must provide a 50 percent match. In the initial grant round, demand exceeded available funding by a factor of 14 to 1, reflecting the scale of unmet need.
In June 2024, HUD also launched a new financing program specifically designed to provide affordable mortgage financing for mission-focused entities—resident-owned communities, cooperatives, nonprofits, CDFIs, and state and local governments—to acquire or improve manufactured home communities. HUD explicitly positioned this program as an alternative to private equity acquisition, whose track record the agency described as including unaffordable rent increases, failure to invest in community infrastructure, and regulations that don’t respect the community’s culture (HUD Press Release No. 24-137, June 4, 2024).
USDA Rural Development programs also provide relevant assistance. The Section 504 Very Low-Income Housing Repair Loans and Grants program offers grants of up to $7,500 to homeowners aged 62 and older who cannot repay loans, and low-interest loans up to $20,000 for necessary repairs and safety improvements (USDA Rural Development, Section 504 Program). The ROAD to Housing Act, which passed the Senate Banking Committee unanimously in 2025, includes expanded rural home repair grants and USDA program modernization (Bipartisan Policy Center, March 2026).
4.3.3 Limitations and Design Considerations
Infrastructure grants have real advantages but also significant limitations. The primary limitation is scale: PRICE’s $225 million appropriation, however welcome, is small relative to the estimated capital needs of the nation’s 43,000-plus manufactured home communities, many of which were built in the 1960s and 1970s and have aging infrastructure. A sustained, adequately funded federal commitment would be required to have a meaningful nationwide impact.
A second design challenge is conditionality. For an infrastructure grant to serve as an alternative to rent control, it must be conditioned on verifiable commitments to affordable rents and housing quality standards. Experience with other subsidized housing programs suggests that robust ongoing compliance monitoring is essential—otherwise park owners may accept grant funds for infrastructure improvement and then raise rents to market rates once the improvement is complete.
A third consideration is targeting: infrastructure grants to private park owners primarily benefit those owners financially, even if tenants benefit from improved infrastructure. A better-targeted variant would prioritize grants to resident-owned communities, cooperatives, and nonprofits, where the financial benefit flows directly to the tenant community. The PRICE program’s eligibility criteria reflect this logic: grants may only be used in communities owned by resident-controlled entities or legally required to remain affordable for the long term (HUD Press Release No. 24-137, June 4, 2024).
5. Comparative Analysis and Policy Implications
Each of the three alternatives reviewed above has a different risk-benefit profile relative to rent control, and each addresses a different dimension of the manufactured housing affordability problem.
Rent insurance provides the most direct financial protection against large rent increases for incumbent tenants, without suppressing supply or reducing investment incentives. Its principal limitations are its novelty (it has not been implemented at scale in any U.S. jurisdiction), the practical challenges of funding and actuarial design, and the risk of moral hazard. As a supplement to the § 233-b framework—covering rent increases that exceed the three percent cap pursuant to the operating-expenses and capital-improvements exceptions—it could provide meaningful protection for fixed-income tenants who cannot afford exception-driven increases.
Direct rental assistance (particularly the lot-rent voucher model) is the alternative best supported by empirical evidence of effectiveness. The Housing Choice Voucher program’s documented track record of improving housing stability, quality, and affordability for recipients—without the supply and quality problems associated with rent control—makes it the closest to an empirically validated alternative. Its principal limitations are chronic underfunding (only one in three eligible families currently receives assistance (Turner 2004)) and limited applicability in the manufactured housing context (where conventional vouchers are difficult to use). A targeted lot-rent voucher program, state-funded if necessary, could be the most direct and efficient way to provide financial protection to low-income manufactured home tenants in New York.
Infrastructure grants address a different problem: the deferred maintenance and aging infrastructure that underlies much of the legitimate pressure for rent increases in manufactured home parks. Grant programs conditioned on affordability commitments can reduce the operational cost pressures that drive rent increases while improving housing quality—a more direct intervention than either rent control or tenant-side subsidies. Their limitations are scale and conditionality: current federal programs are vastly undersubscribed relative to need, and ensuring that grant recipients honor their affordability commitments over time requires active monitoring.
In the specific context of New York’s manufactured housing parks, the empirical evidence suggests that the most effective policy framework would combine elements of all three approaches: the § 233-b rent cap with enhanced transparency requirements (as proposed in S. 228-A) as a baseline protection against predatory rent extraction by institutional investors; a state-funded lot-rent assistance program to provide direct relief to low-income homeowners; and expanded access to infrastructure financing through PRICE, HUD’s new manufactured community program, and state equivalents, targeted as a priority to resident-owned communities and nonprofits. Any such framework must also grapple forthrightly with the infrastructure crisis and the regulatory trap documented in Section 3: a policy package that preserves the § 233-b rent cap and the § 233(b)(6) conversion restrictions without creating an adequate mechanism for small-owner operators to finance the capital improvements that the cap has prevented them from funding will continue to produce the death spiral that currently characterizes much of New York’s distressed park inventory. The § 233(b)(6) change-of-use protections should be reassessed in light of the perverse incentive structure they create when combined with an inadequate infrastructure financing mechanism. Together, these tools offer a policy framework that is responsive to the genuine affordability concerns that motivated § 233-b while being attentive to the empirical lessons about the limits of rent regulation as a sustainable housing policy instrument.
6. Conclusion
The empirical literature on rent control is one of the most extensive in housing economics, and its principal findings are consistent: rent control reduces rents for covered tenants in the short run and provides genuine stabilization benefits, particularly for older, minority, and long-term residents at risk of displacement. But these benefits come at a persistent cost: supply reduction as landlords exit or convert the rental market, quality deterioration as maintenance incentives erode, misallocation of housing stock, and benefits that flow disproportionately to middle- and upper-income rather than the lowest-income households.
New York’s Real Property Law § 233-b addresses these tensions in the specific context of manufactured home parks with a framework that is, in several respects, better designed than generic rent stabilization ordinances. Section 233-b imposes a three percent rent cap while preserving the ability of park owners to recover legitimate cost increases—operating expense increases, property tax increases, and capital improvement costs—through a challenge and adjudication process designed to distinguish cost-recovery from profit-extraction. Its vacancy decontrol provision allows market rents to re-enter the structure at turnover, limiting the wealth-transfer effects that characterize more rigid rent controls.
Yet § 233-b’s design, however thoughtful in comparison to cruder rent regulations, has produced a consequence that its architects likely did not intend: in the category of parks owned by long-tenured small operators who have held rents well below market for years or decades, the statute has effectively locked in a revenue structure that makes infrastructure maintenance financially impossible. The pervasive infrastructure deterioration visible in New York’s manufactured home park transaction market—failing Orangeburg sewer mains, deteriorating roads, aging electrical systems, leaking water infrastructure—is, in significant part, the product of a regulatory framework that has suppressed the revenue needed to address these deficiencies while providing no adequate substitute financing mechanism.
Section 233(b)(6) compounds this problem by closing the exit that market economics would otherwise provide. When § 233-b makes operation unprofitable and § 233(b)(6) makes conversion prohibitively expensive, the result is a regulatory trap: property stranded in a declining use that benefits neither owner nor resident, prevented by law from being redeployed to its highest and best use. The residents of these parks are not protected by this framework; they are condemned by it to live in communities undergoing physical deterioration that the law has made structurally irreversible.
The alternatives reviewed in Part Four—rent insurance, direct rental assistance, and infrastructure grants—are not mutually exclusive with the § 233-b and § 233(b)(6) framework. They address different aspects of the manufactured housing affordability problem and, deployed together, offer a more comprehensive response than any single instrument. The empirical evidence most strongly supports direct rental assistance (particularly a targeted lot-rent voucher program) as an alternative to rent control for eligible low-income households, and infrastructure grants conditioned on affordability commitments as a mechanism for addressing the underlying capital investment deficits that generate legitimate rent increase pressure. Together with a frank legislative reassessment of the perverse incentive structure created by the interaction of § 233-b and § 233(b)(6), these tools offer a policy package capable of protecting tenants from predatory rent extraction while preventing the physical deterioration that the current statutory framework, unaided, has been unable to stop.
Selected Bibliography
Arnott, R. (1995). “Time for Revisionism on Rent Control?” Journal of Economic Perspectives 9(1): 99–120.
Autor, D.H., Palmer, C.J., & Pathak, P.A. (2014). “Housing Market Spillovers: Evidence from the End of Rent Control in Cambridge, Massachusetts.” Journal of Political Economy 122(3): 661–717.
Autor, D.H., Palmer, C.J., & Pathak, P.A. (2019). “Ending Rent Control Reduced Crime in Cambridge.” AEA Papers and Proceedings 109: 381–384.
Bipartisan Policy Center (March 2026). “What’s in the 21st Century ROAD to Housing Act?”
Diamond, R., McQuade, T., & Qian, F. (2019). “The Effects of Rent Control Expansion on Tenants, Landlords, and Inequality: Evidence from San Francisco.” American Economic Review 109(9): 3365–3394.
Epstein, Richard A. (1992). “Yee v. City of Escondido: The Supreme Court Strikes out Again.” 26 Loyola of Los Angeles Law Review 3.
Epstein, Richard A. (1988). “Rent Control and the Theory of Efficient Regulation.” 54 Brooklyn Law Review 741.
Glaeser, E.L. & Luttmer, E.F.P. (2003). “The Misallocation of Housing Under Rent Control.” American Economic Review 93(4): 1027–1046.
Gyourko, J. & Linneman, P. (1989). “Equity and Efficiency Aspects of Rent Control: An Empirical Study of New York City.” Journal of Urban Economics 26: 54–74.
Hirsch, W.Z. & Hirsch, J.G. (1988). “Mobile Home Context: Placement Values and Vacancy Decontrol.” 35 UCLA Law Review 399.
Housing Assistance Council (2023). “HUD Spending Bill Creates New Manufactured Housing Program and Emphasizes New Construction.”
HUD Press Release No. 24-137 (June 4, 2024). “HUD Launches New Program to Invest in Manufactured Home Communities.”
InterNACHI (2023). “Orangeburg Pipe: Identification and Inspection.”
Kholodilin, K.A. (2024). “Rent Control Effects through the Lens of Empirical Research: An Almost Complete Review of the Literature.” Journal of Housing Economics 63.
Mense, A., Michelsen, C., & Kholodilin, K.A. (2023). “Rent Control, Market Segmentation, and Misallocation: Causal Evidence from a Large-Scale Policy Intervention.” Journal of Urban Economics 134.
Minnesota Reformer (February 25, 2026). “Minnesota needs a Manufactured Home Park Resident Bill of Rights.”
MobileHomeParkStore.com (2026). Active park listings, New York State.
Moon, C.-G. & Stotsky, J.G. (1993). “The Effect of Rent Control on Housing Quality Change: A Longitudinal Analysis.” Journal of Political Economy 101(6): 1114–1148.
New York Real Property Law § 233 (McKinney 2024).
New York Real Property Law § 233-b (McKinney 2024).
New York Senate Bill S228-A (2025 Session). An Act to Amend the Real Property Law, in Relation to Increases of Rent in Manufactured Home Parks. Sponsored by Sen. Skoufis.
Oregon Public Broadcasting (February 6, 2025). “Oregon and Washington are preparing for fights over rent increases in manufactured home parks.”
PSC Housing / NLIHC (2024). “The Impacts of Long-Term Rental Assistance: A Literature Review.”
Schapiro, R. et al. (2022). “The Effects of Rental Assistance on Housing Stability, Quality, Autonomy, and Affordability.” Housing Policy Debate.
Sims, D.P. (2007). “Out of Control: What Can We Learn from the End of Massachusetts Rent Control?” Journal of Urban Economics 61(1): 129–151.
The Center for Growth and Opportunity, Utah State University (2023). “Housing Affordability: Trends, Consequences, and Policies.”
Turner, B. & Malpezzi, S. (2003). “A Review of Empirical Evidence on the Costs and Benefits of Rent Control.” Swedish Economic Policy Review 10: 11–56.
Turner, M.A. (2004). “Strengths and Weaknesses of the Housing Voucher Program.” Urban Institute.
USDA Rural Development. Section 504 Very Low-Income Housing Repair Loans and Grants Program.
Washington Post (June 6, 2022). “We’re all afraid: Massive rent increases hit mobile homes.”