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When Millard’s Apple Park was platted in Nacogdoches, TX, in 2002, the 69-lot subdivision was designed to accommodate both traditional houses and manufactured homes.
But only two years later, the city stopped allowing new manufactured homes by right in its residential districts. Homes already there could remain, but they became legally nonconforming—limiting owners’ ability to replace or expand them.
It’s a common pattern across the state: 33% of cities don’t explicitly allow manufactured housing and an additional 11% subject it to a special permit or public hearing, according to a recent analysis from the National Zoning Atlas.
Nacogdoches, for its part, understood the trade-off at the time. Its 2003 comprehensive plan called manufactured housing “one of the most affordable means of entering into homeownership,” but seemed to put more stock in the concerns from local residents about its potential effect on neighboring property values.
Then, in early August, Nacogdoches reversed course.
The City Council unanimously created a new residential district where manufactured homes are permitted by right—including all 69 lots of Millard’s Apple Park.
It was a win for affordability advocates, and especially for owners of the manufactured houses that had been built before the laws changed.
“They don’t have to wait till it just completely falls apart to replace it,” Mike Neu, the city’s executive director of development and infrastructure, told council members. “This gives them options. They didn’t have that before.”
But Nacogdoches was not acting entirely by choice. Beginning on Sept. 1, a new state law (Senate Bill 785) requires Texas municipalities with zoning to allow new HUD-code manufactured homes by right in at least one residential district.
The change will require nearly 400 cities to update their codes to comply, according to an estimate from the Texas Manufactured Housing Association—making Nacogdoches an early glimpse at what could soon play out across the state.
Why Texas is betting on manufactured housing
The city offers a clear case for why state lawmakers are betting on manufactured housing to deliver mass affordability.
By national standards, the city looks relatively inexpensive. But buying remains badly mismatched with what local residents earn.
The median home was listed for about $325,500 in August, according to data from Realtor.com®, while the median household income of $39,281 is roughly half of what someone would need to qualify for a mortgage that size. As a result, fewer than four in 10 households own their homes.
Renting doesn’t offer residents much relief, either. City officials have described the rental market as “tight,” while Realtor.com data shows the median asking rent reached $962 in August—up 13% in three years.
Manufactured housing, meanwhile, could offer a much lower entry price. A new single-section manufactured home sold for an average of $87,300 in 2025, while a multi-section home averaged $151,500.
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Those figures exclude land and taxes, so they don’t offer a perfect comparison to a site-built home. But further research suggests that a new manufactured home installed on a foundation can cost roughly 35% to 73% as much as comparable site-built construction.
Texas has already adopted manufactured housing at an enormous scale, too. The state received 17,458 manufactured homes in 2025, more than 2.5 times the number sent to second-place Florida.
But despite the clear need and demand for wider adoption, manufactured housing has run headlong into a patchwork of local rules that can make them legal in one community, discretionary in the next, and outright impossible in another.
And while SB785 is designed to close that gap, it’s also where the limits of the law are already beginning to show.
Cities can still keep the door mostly closed
While an earlier version of the legislation required cities to allow manufactured homes across a “substantial area of land” and prohibited other regulations that directly or indirectly amounted to a citywide ban, neither provision survived intact.
The final law requires only that the qualifying district apply to “an area of land,” without quantifying how much.
In Nacogdoches, city planners identified three areas that could potentially receive its new R-3M manufactured-home zoning. But only Millard’s Apple Park was actually rezoned. For the changes to span more widely, property owners would have to request the change themselves.
“Theoretically, there could be no other property owners requesting a change to R-3M beyond tonight,” Neu told council members in May.
That means Apple Park’s 69 lots could conceivably represent the full extent of the city’s response—a drop in the bucket compared to the 1,300 units the city needs in the next five years to adequately address demand.
Bellmead, a small city outside Waco, offers an even sharper example. The city created a new manufactured-housing district but requires a tract to contain five contiguous acres before it can be rezoned into it.
For Amber Haliburton, that was the difference between building new housing on her family’s property or moving on.
“Because we have chosen a manufactured home, there is currently no clear or practical path for us to move forward in Bellmead,” she told the City Council in February.
Haliburton also questioned why a rule ostensibly intended to open the city to manufactured housing seemed better suited to developers assembling subdivisions than someone trying to place a single home.
City staff acknowledged some of that tension. The new district, Community Development director Fred Morris said, was intended to comply with state law and facilitate development projects, “not to address individual residential lots.”
Bellmead eventually identified a 13.98-acre tract beside an existing manufactured-home development as appropriate for the new zoning. But even that didn’t automatically open the land to manufactured homes. The city’s own memo emphasized that the designation “does NOT rezone the property.” Its owner still has to request the change.
The NZA analysis warned about that possibility before SB785 was passed. Researchers recommended requiring cities to rezone in “good faith,” noting that a municipality could otherwise satisfy the law with land unlikely ever to host a manufactured home.
All eyes will be on Texas
How the complications play out will matter far beyond the Lone Star State.
By September 2025, the Pew Charitable Trusts had identified nine states that had enacted zoning reforms designed to expand manufactured housing. Some have gone further than Texas, requiring qualifying manufactured homes across single-family residential zones rather than guaranteeing them a foothold in only one district.
At the same time, Washington is attacking other pieces of the problem.
The bipartisan 21st Century Road to Housing Act, which became law in July, includes a series of reforms intended to expand manufactured and modular housing. But it stops short of overriding local zoning, leaving opponents with a powerful tool to continue to limit where manufactured homes can be built.
The resistance is rooted in part in an outdated stigma. Manufactured homes have long been treated as a lesser form of homeownership—cheaper to buy, but also assumed to be a worse investment.
The numbers tell a different story. Realtor.com research found that manufactured homes sold with land appreciated 70.1% from 2019 to early 2026, compared with 58.6% for single-family homes. Even manufactured homes sold without land appreciated 51.6%.
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