A fatal fire Thursday morning brings renewed attention to a problem Troy officials publicly acknowledged more than a year ago: the private water system inside Troy Villa is not sufficient to supply fire hoses. The question now is not simply whether that’s legal. It’s who is responsible for it, what the State has been inspecting, and why residents still don’t have a clear answer.

Earlier in 2025, following a fire at Troy Villa, residents began asking an entirely reasonable question:

Why couldn’t firefighters use the hydrants located inside the community?

According to information circulated following that incident, crews instead had to establish water from a City-owned hydrant on Stephenson Highway, requiring roughly 1,100 feet of hose to be stretched into the park. Residents brought those concerns to Troy City Council. And on March 17, 2025, the issue stopped being rumor or neighborhood speculation.

The City of Troy publicly confirmed the fundamental problem. Then, on the morning of September 3, 2026, Troy firefighters returned to Troy Villa for another structure fire. This time, the outcome was tragic.

According to the Troy Fire Department release issued Thursday, firefighters were dispatched at 7:58 a.m. for flames and smoke coming from a residence. Crews encountered heavy fire and smoke and a structure that had sustained a partial collapse. After extinguishing most of the fire, firefighters entered the structure and found a deceased individual.

The cause and origin remain under investigation.

That requires an important distinction right at the beginning: There is currently no evidence that Troy Villa’s hydrant situation caused Thursday’s fire, caused the fatality, or adversely affected firefighting operations during this particular incident. I am not making that allegation.

But a fatal fire occurring in a residential community where the City had already publicly acknowledged a firefighting-water problem makes answering the underlying questions considerably more important. This isn’t an argument that the hydrants caused a death. It’s an argument that fire-protection infrastructure shouldn’t remain an unanswered question until the next emergency.

What Troy Said Publicly in March 2025

The strongest evidence in this story comes directly from the City of Troy. At the March 17, 2025 City Council meeting, a resident raised concerns regarding Troy Villa’s hydrants and the earlier fire. The City’s official minutes summarize his concern as involving “malfunctioning fire hydrants” and a fire during which firefighters were unable to obtain water from inside the park.

The Public Works Director responded. He explained that Troy Villa has its own privately owned water main and hydrant system and that the State of Michigan limits the City’s authority over land and utilities inside manufactured-home communities. Then he stated the critical fact:

the water main is “not sufficient to draw water from for fire hoses.”

He also told Council that Troy was not permitted to inspect the privately owned hydrants. And then came perhaps the most revealing part.

He said Troy had purposefully installed City-owned hydrants immediately outside the park so firefighters would have water available for fire suppression.

Council did not simply acknowledge the issue and move on. The minutes say there was a consensus directing City Administration to investigate the issue and contact the State to determine what could be done about the water and hydrant problems.

That is an extraordinary set of facts:

• The City knew the internal system could not supply its fire hoses.
• The City installed an external water source to compensate for that deficiency.
• The City said its own ability to inspect the internal hydrants was restricted.
• And City Council specifically directed the administration to take the matter to the State.

That was March 2025.

So What Happened After Council Asked the State?

This is one of the first things I tried to answer. I searched Troy’s publicly available City Council records looking for a subsequent report, resolution, presentation or other public response explaining what happened after administration was directed to contact the State.

I haven’t found one.

That doesn’t establish that the City did nothing. There may be emails. There may have been phone calls with State regulators. There may have been correspondence with the park owner. There could be an engineering determination or legal opinion that never appeared on a Council agenda. The State may even have told Troy that the existing arrangement is perfectly lawful and that the City hydrants outside the park constitute the accepted firefighting-water solution.

But if any of that occurred, I haven’t found a public report explaining it. And that’s a significant missing piece. Because Council asked the question publicly.

What answer did the City receive?

The Most Important Point: I’m Not Saying These Hydrants Are Illegal

This distinction matters. The easy headline would be: “Illegal hydrants at Troy Villa.” I cannot substantiate that. And, based on the laws and regulations I’ve reviewed, the actual story appears considerably more complicated. The stronger question is this:

How can a licensed residential community have private fire hydrants connected to a water system that the responding municipality says is not sufficient to supply fire hoses?

That may ultimately turn out to be completely lawful. It may involve grandfathered infrastructure. It may involve a regulatory classification that treats the City’s outside hydrants as the actual firefighting supply. It may involve an old approval issued under standards very different from today’s. Or it may reveal a gap between multiple agencies’ responsibilities.

That’s what needs to be established from the records.

Michigan’s Manufactured-Home Fire Rule Is Surprisingly Thin

Michigan Administrative Rule R 125.1702a governs fire safety in manufactured-home communities. Its hydrant provision says:

“Fire hydrants shall be placed within a community according to local city or township ordinances.”

And that’s essentially where the manufactured-home-specific hydrant provision stops.

• It does not itself specify a required number of gallons per minute.
• It doesn’t specify minimum residual pressure.
• It doesn’t provide a minimum pipe diameter.
• And it doesn’t establish an explicit hydrant flow-testing schedule in that provision.

That initially looks like a remarkable regulatory hole. But it gets more complicated because manufactured-home rules aren’t the only Michigan regulations potentially relevant to the water system.

Troy’s Standards Are Much More Specific

Compare Michigan’s short manufactured-home hydrant rule with Troy’s current standards. Troy’s Fire Prevention Code states that fire-flow requirements are determined under Appendix B and the City of Troy Development Standards. Troy’s engineering standards define fire flow as water available for firefighting measured at 20 psi residual pressure. For current one- and two-family dwellings with a fire area of no more than 3,600 square feet, Troy’s standards require 1,000 gallons per minute, subject to permitted reductions such as approved sprinkler protection.

The same development standards say:

• public water mains are required for fire-protection purposes;
• fire-protection lines must be sized to provide the necessary flow;
• and eight-inch minimum mains are generally required in single-family residential areas.

That’s a completely different level of specificity. There is one major caveat:

I have not established that Troy’s current standards apply retroactively to Troy Villa.

They may not. And Michigan law is structured in a way that can limit a municipality’s ability to impose standards on manufactured-home communities that exceed the State code.

Michigan Limits What Local Governments Can Impose

Under MCL 125.2307, if a local government wants to impose a standard related to mobile-home parks that is higher than the state standard, the proposed higher standard generally must be submitted to the Michigan Manufactured Housing Commission. The Commission reviews the proposal, and after approval the local government can adopt it by ordinance.

That matters because Troy Villa isn’t simply an ordinary subdivision whose private infrastructure is automatically governed in every respect by whatever subdivision standards Troy has today. Michigan has created a separate regulatory framework for manufactured-home communities. That appears to be at least part of what Troy’s Public Works Director was describing when he told Council that the State regulates how much involvement Troy can have inside the park.

But again, that’s only part of the story.

“Troy Can’t Inspect It” Is More Complicated Than It Sounds

The March 2025 minutes say DPW told Council that Troy isn’t allowed to inspect the privately owned hydrants. There is clearly statutory support for restrictions on municipal inspections of manufactured-home communities. But Michigan law does not literally say a municipality may never conduct an inspection.

MCL 125.2317 says the State or its authorized representative conducts the physical inspection of the park and must prepare a report documenting its findings. It then says a local government generally cannot inspect a manufactured-home park outside the licensing process unless the local government has reason to believe the Mobile Home Commission Act, code or rules have been violated.

That’s a meaningful exception.

It doesn’t automatically mean Troy DPW can walk into Troy Villa tomorrow and conduct hydrant-flow testing. Water-supply regulation may belong to another agency. Property rights, testing authority and the scope of the statute all matter. But it means I want a much more precise answer than:

“It’s private, so Troy can’t inspect it.”

The questions should be:

• What exactly is Troy prohibited from inspecting?
• Who is authorized to inspect the hydrants?
• Who can order a flow test?
• Could Troy formally request one from the State?

And once Troy had reason to believe there might be a deficiency, especially once its Public Works Director publicly acknowledged the system couldn’t supply fire hoses, what options were legally available?

These Parks Actually Are Inspected Every Year

This is where the story becomes particularly difficult to reconcile. Michigan’s rules explicitly require an annual inspection of a manufactured-home park.

• Rule R 125.1701 says an annual inspection must be conducted and that an inspection report must document the findings.
• Rule R 125.1701a, requires the community’s compliance status to be reviewed annually based upon that completed inspection report and other information.

That certification produces one of three conclusions:

• the community is eligible for license renewal;
• it is eligible subject to conditions;
• or it is not eligible because of noncompliance.

State law adds another layer. Under MCL 125.2316, a mobile-home park cannot operate without a license, and one of the conditions for issuance is that the park was found in substantial compliance after its most recent inspection. And LARA itself identifies annual inspections of mobile-home parks as one of the responsibilities of its Bureau of Construction Codes.

In January 2025, LARA even announced a dedicated team specifically focused on inspecting Michigan mobile-home communities and ensuring compliance with state standards. Which brings us to one of the most important questions in this entire investigation:

If Troy says the private water system cannot supply fire hoses, what exactly has the State been inspecting and certifying every year?

There may be a perfectly reasonable answer.

• Maybe fire-flow testing isn’t part of that particular LARA inspection.
• Maybe another agency handles it.
• Maybe Troy Villa’s hydrants are legally outside the scope of what LARA inspectors examine.

But that’s precisely the point: An annual park inspection is not necessarily the same thing as an annual fire-hydrant flow test.

We need to know what the annual inspection actually covers.

And “The State” Turns Out to Mean More Than One Agency

This is one of the most important things I discovered. LARA does not appear to have sole responsibility for this problem. Michigan publishes a document specifically explaining how responsibilities for manufactured-home communities are divided between agencies. According to that document:

LARA’s Bureau of Construction Codes handles mobile-home park licensing, construction plan review and annual park inspections.

But water supply is assigned to the Michigan Department of Environment, Great Lakes, and Energy, EGLE under the Mobile Home Commission Act and the Safe Drinking Water Act.

That dramatically changes the investigative question. It isn’t merely:

What has LARA been inspecting?

It is also:

What does EGLE know about Troy Villa’s water system?

EGLE says its drinking-water oversight can include sanitary surveys, inspections of distribution systems, construction permitting for major system alterations, monitoring, recordkeeping and emergency-response planning. So the record request needs to go to both agencies.

Michigan Actually Has a Fire-Flow Rule

This is another reason I don’t want to oversimplify the story. The manufactured-home fire-safety provision itself doesn’t establish a numerical flow requirement. But Michigan’s Safe Drinking Water Act regulations do contain a rule specifically addressing distribution capacity and fire hydrants. Rule R 325.11105 says distribution systems must have sufficient capacity to meet peak demand, including fire-flow demands where fire protection is provided. The rule requires systems to maintain at least 35 psi during normal operation and 20 psi during emergencies such as firefighting.

It also says the department may prohibit hydrants when the water main, water source, storage or pressure cannot sustain fire-flow demand along with normal consumption. And it prohibits replacing an inadequately sized water main with another inadequately sized main of the same size. That is hugely important.

It means the accurate story isn’t: “Michigan has no fire-flow requirements.”

That’s too broad. The more accurate statement is:

Michigan’s manufactured-home fire-safety rule doesn’t itself establish numerical hydrant-performance requirements, while Michigan’s separate drinking-water rules do regulate distribution capacity and fire flow where fire protection is being provided.

And that creates perhaps the most important technical/legal question in this whole story:

What exactly are Troy Villa’s internal hydrants legally intended to do?

• Were they approved as a firefighting water source?
• Were they once capable of supplying fire flow?
• Are they essentially flushing or utility hydrants that residents understandably perceive as fire hydrants?
• Were they installed before the modern rules?
• Have they been altered?
• Does an existing State approval expressly recognize the City-owned hydrants outside the park as the required firefighting supply?

We cannot answer those questions without the plans and regulatory files.

Troy Villa’s Age May Be the Key

And this is where the age of the park suddenly matters. Oakland County records identify Troy Villa as a 282-site community built in 1962.

Michigan’s drinking-water rule R 325.11104 says the Part 11 distribution-system rules are not retroactive for systems and storage tanks constructed before January 12, 1978, unless EGLE determines continued use poses a health hazard.

Troy Villa predates that date by about sixteen years. That could be extremely significant. It could potentially explain why an old private distribution system doesn’t satisfy modern fire-flow rules. But this is not the same as proving:

“Troy Villa is grandfathered.”

We don’t know that yet. A park being built in 1962 does not prove every pipe and hydrant there today was installed in 1962. We need to know:

• when the existing water main was installed;
• when the hydrants were installed;
• whether portions have been replaced;
• whether mains were extended or reconstructed;
• whether modifications occurred after 1978;
• what permits were issued;
• and whether any later alteration triggered newer requirements.

That’s why the original plans and later construction records are so important.

“Grandfathered” Might Explain It, But It Shouldn’t End the Conversation

Suppose the records eventually establish that Troy Villa’s water system is entirely lawful because it predates modern standards. That would answer one question. It would not answer every question. There’s an important difference between: legal and adequate for modern fire protection.

An old regulation may explain why the State cannot force wholesale reconstruction of infrastructure installed decades ago. That’s a legitimate legal issue. But if hundreds of residents live in a community where the internal hydrants cannot supply Troy Fire’s hoses, policymakers can still ask whether the law remains adequate.

A grandfather clause may explain the situation. It doesn’t automatically make the situation desirable.

The PVC Isn’t the Important Part

One misconception from the earlier discussion deserves clarification too. The fact that some portion of the private water system may be PVC does not, by itself, mean there is anything wrong with it. PVC is commonly used in water distribution.

The engineering questions are things like:

• pipe diameter;
• pressure;
• available volume;
• system configuration;
• source capacity;
• storage;
• valves;
• looping;
• and actual tested hydrant flow.

The important statement isn’t: “It’s PVC.” The important statement is Troy’s: the water main isn’t sufficient to supply fire hoses. That’s the performance issue.

Who Owns and Operates Troy Villa?

Michigan Court of Appeals records identify Sun Troy Villa, LLC as the owner/operator of the Troy manufactured-home community.

A 2026 Sun Communities SEC filing also lists Sun Troy Villa LLC as a Michigan subsidiary. Sun Communities currently markets Troy Villa at 2100 Stephenson Highway as a family-friendly community in a safe suburban neighborhood. That doesn’t mean Sun has done anything unlawful. But it establishes who needs to be part of the discussion. If the private infrastructure belongs to the community, we need to determine what the approved plans require its owner to maintain.

If the hydrants were originally approved to provide a particular fire-flow capacity, are they maintaining that capacity? If they weren’t, what was the approved fire-protection plan? Again, the documents decide that question, not assumptions.

Thursday’s Fatality Changes the Urgency, Not the Evidence

This is a line I think we need to walk carefully. It would be unfair and irresponsible to use Thursday’s death as proof that the hydrant system failed. We do not know that. The fire remains under investigation. There may have been plenty of water. Firefighters may have immediately established their planned municipal water source without any meaningful delay. The victim’s death may have occurred before firefighters were even dispatched. There are countless possibilities. So I’m not going to invent one.

But Thursday’s fatality absolutely changes the urgency of answering a question that already existed. The sequence is now:

• There was an earlier fire.
• Residents raised concerns about the hydrants.
• Those residents went to City Council.
• Troy publicly confirmed the internal water system was insufficient for fire hoses.
• Council instructed administration to contact the State.
• More than a year later, another serious fire occurred in the same community.
• This time, someone died.

That doesn’t prove causation. It proves the issue deserves an answer.

What We Still Don’t Know

After digging through the public rules and records, I think these are the questions that actually matter:

• Were Troy Villa’s hydrants originally approved to provide firefighting water?
• What flow were they originally designed to provide?
• What can they provide today?
• Has anybody flow-tested them? If so, when and what were the results?
• Does LARA’s annual inspection include the hydrant system?
• Does EGLE inspect or approve the distribution system separately?
• Is the system grandfathered because of its age?
• If portions have been reconstructed since 1978, which modern requirements applied?
• Has EGLE issued any variance or written deviation?
• What did the State tell Troy after the March 17, 2025 Council meeting?
• Does Troy have a formal pre-incident water-supply plan for fires inside Troy Villa?
• Are residents informed that the private hydrants cannot supply Troy Fire’s apparatus?

And this is a question I think residents are completely justified in asking:

If I see a fire hydrant 100 feet from my house, would I reasonably know that firefighters may need to obtain their water from outside the development instead?

The Documents That Can Answer This

This is now a records investigation. The next step should include requests to Troy, LARA and EGLE.

From Troy, I want:

• all correspondence regarding Troy Villa’s hydrants and water-main capacity;
• everything generated following the March 17, 2025 Council direction;
• correspondence with LARA, EGLE, Sun Troy Villa or Sun Communities;
• Troy Fire pre-incident plans for Troy Villa;
• water-supply maps;
• records identifying the municipal hydrants used for the development;
• available fire-flow testing;
• and records relating to the earlier fire and the approximately 1,100-foot hose stretch.
• From LARA, I want:
• Troy Villa’s annual inspection reports;
• annual compliance certifications;
• current and historical licenses;
• complaints regarding water or hydrants;
• construction permits;
• approved park plans;
• water-main/hydrant plans in its files;
• notices of violation;
• variances;
• and correspondence with Troy and Sun.

From EGLE, I want:

• the water-supply file;
• construction permits;
• distribution-system plans;
• as-builts;
• sanitary surveys;
• hydrant/fire-flow information;
• pressure tests;
• water-main alteration records;
• variances or deviations;
• correspondence with LARA;
• correspondence with Troy;
• and communications with Troy Villa or Sun Communities.
• Those records should tell us whether we’re looking at:
• an entirely legal grandfathered system;
• an old approved system that simply was never intended to supply fire apparatus;
• a system that once provided acceptable flow but has deteriorated;
• a later-modified system subject to newer requirements;
• an approved alternative arrangement relying on Troy’s exterior hydrants;
• or an actual regulatory problem.

Right now I am not going to pretend to know which one it is.

The Bigger Problem: A Jurisdictional Maze

Maybe the most troubling part of this is how difficult the answer is to obtain.

1. Troy says it’s private infrastructure and State-regulated.
2. LARA regulates the manufactured-home community and conducts annual inspections.
3. EGLE has responsibility for water supply.
4. Michigan law limits the standards Troy can impose.
5. Michigan law also contains an exception allowing certain local inspections when violations are suspected.
6. State manufactured-home rules mention hydrants but do not provide numerical fire-flow requirements.
7. Separate drinking-water rules do address fire flow.
8. And those drinking-water rules may not apply retroactively to infrastructure built before 1978.

Meanwhile, Troy has had to put municipal hydrants outside the park so its firefighters have a usable water source. If that sounds confusing, that’s because it is. And residents shouldn’t need a law degree, a fire-protection engineer and three FOIA requests just to understand what the hydrant outside their home can do.

This Isn’t a Criticism of Troy Fire

One point should be absolutely clear. Nothing I’ve found suggests the firefighters created this problem. Quite the opposite. Firefighters work with whatever water supply exists when they arrive. If the closest hydrant won’t feed an engine, crews find one that will.

• They establish supply.
• They stretch additional hose.
• They call for more equipment if necessary.
• They adapt.
• The roughly 1,100-foot stretch described following the earlier fire is a story about firefighters solving a water-supply problem.

The legitimate public-policy question is:

Why should firefighters have to solve an infrastructure problem during a fire if it could be addressed before the fire ever occurs?

The middle of a structure fire is the worst possible time to discover the limitations of a water system. Those limitations should already be known, tested, documented and incorporated into response plans.

A Fire Hydrant Should Mean Something

Most people drive past fire hydrants without giving them a second thought. We assume someone has tested them. We assume they’re connected to a water main capable of supporting firefighting. We assume a fire engine can pull up, connect a supply line and get water.

Residents aren’t expected to know what residual pressure means:

• They aren’t expected to calculate pipe diameter or system friction loss.
• That’s why we have engineers.
• That’s why we have codes.
• That’s why we have inspections.
• That’s why we license residential communities.
• And that’s why Troy Villa residents deserve a clear explanation.

The strongest conclusion I can make today is not that Troy Villa is breaking the law. It’s something much narrower, and, in my view, harder to dismiss:

The City of Troy has publicly stated that Troy Villa’s private water main is not sufficient to supply fire hoses, yet Troy Villa remains a licensed residential community with private hydrants throughout the park.

The State performs annual inspections. EGLE has jurisdiction over the water supply. Troy installed its own hydrants outside the community to provide firefighting water. And in March 2025, City Council specifically directed the administration to ask the State what could be done about it.

Residents deserve to know what happened next:

• They deserve to know what those hydrants were designed to do.
• They deserve to know who tests them.
• They deserve to know whether they’re grandfathered.
• They deserve to know whether this arrangement meets every applicable State requirement.

And if the answer ultimately turns out to be: “Yes. This is completely legal.”

Then perhaps the next question is the most important one: Should it be?