A COLLABORATIVE EFFORT TOWARD
SUSTAINABLE REDEVELOPMENT AT
THE MONA TERRACE SITE IN
MUSKEGON HEIGHTS, MICHIGAN
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April 2008
EPA Publication No. 330-F-08-003
C

Muskegon Heights, Michigan, is poised to enhance its livability by
sustainably redeveloping one of its toughest brownfields as part of EPA's
Environmentally Responsible Redevelopment and Reuse (ER3) Initiative.
Muskegon Heights had a thriving economy during most of the 20th
century. However, like many other manufacturing communities of the
rust belt, when the industrial jobs left the community went through a
transformation from working class homeowners to a larger percentage
of underemployed renters. Muskegon Heights saw a corresponding
erosion of its tax base. Meanwhile, a county-wide wastewater treatment
system was constructed in 1972 and the Muskegon wastewater plant
became obsolete. The City was left with a contaminated wastewater
treatment plant and minimal funds to clean it up. This disadvantaged
City is working creatively with local developers, the State of Michigan, EPA, and other stakeholders to transform
this idle property and adjacent properties into a moderately priced residential development. This project
provides an exciting opportunity to showcase sustainable approaches that can be incorporated into a
moderately priced residential development.
Former water treatment plant
Background
The Mona Terrace Development (MTD) project includes four properties,
comprising 51 acres, currently owned by the City of Muskegon Heights. One
property was used as a municipal wastewater treatment plant from the 1920s
to the 1970s. The City subsequently leased a portion of the wastewater
treatment plant property to a series of companies that operated the property
under the Resource Conservation and Recovery Act (RCRA) as a hazardous
waste treatment facility untii 1991. The Michigan Department of
Environmental Quality (DEQ) issued a closure certification in 1995 for the
active treatment units. The State is working with the City of Muskegon
Heights on a plan for corrective action. The proposed development also
includes the City's active Department of Public Works (DPW), an adjacent
property that has been contaminated by leaking underground storage tanks.
The city plans to relocate the DPW to another brownfield site, making the
current DPW property available for the MTD project.
CONTACTS
EPA Region 5
Ann Wentz
312-886-8097
Michigan Department
of Environmental
Quality
Susan Wenzlick-Sandell
231-775-3960 x 6312
The City has been approached by a developer to purchase the property and construct residential homes and a
recreation area on the site. The City fully supports the redevelopment proposal, but securing financing for
assessment, demolition of existing structures, and cleanup has posed a particular challenge. To gain focus and
resources to address the wastewater treatment plant, the City applied to make the project a RCRA Brownfields
Prevention Pilot in 2001. Since being selected as a pilot under this program, the pilot team, comprised of the
City, State, EPA, and other stakeholders, has been working to complete the assessment, generate interest, and
leverage resources for the demolition and cleanup since 2001. In 2007, the DEQ awarded the City of Muskegon
Heights a grant of $1 million and a loan of $1 million to pay for demolition of the concrete holding tanks and
structures on the former RCRA facility and structures at the DPW; implementation of the RCRA Corrective
Measures Implementation Plan (CMIP); sampling and removal of contaminated foundry sands; and other
investigation and due care activities required for redevelopment of the site.

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Environmentally Responsible Redevelopment and
Reuse (ER3)
The ER3 Initiative is an EPA Office of Enforcement and
Compliance Assurance program that recognizes the value of
reusing once-contaminated land. The program also
recognizes the significant impact that development has on
the environment. ER3 provides enforcement and liability
relief incentives to encourage developers of contaminated
land to redevelop it in a sustainable manner. By
incorporating sustainable practices and principles into their
projects, developers of contaminated sites can minimize the
environmental impact of their projects without sacrificing
profitability.
As the developers behind the proposed MTD project would inherit RCRA liability by purchasing the wastewater
treatment plant site, they are seeking liability protection for that property. Michigan is authorized to implement
the RCRA corrective action program. The Michigan Department of Attorney General has begun discussions with
the developers to provide a Covenant Not to Sue, a legal agreement recognized by the EPA as protection
against Federal as well as State liability. The State would agree not to sue the developers for any
contamination attributable to prior owners or operators of the wastewater treatment plant, provided that the
developers contribute to environmental cleanup costs. To address potential concerns about Federal liability,
EPA envisions issuing the developers a comfort/status letter.
For more information on ER3, please visit the Web site at:
http://www.epa.gov/compliance/cleanup/revitalization/er3
Site Cleanup
¦	Contaminated foundry sand was used across the site as fill, and
sediments of a creek that bisects the site are contaminated with
plating wastes from an upstream Superfund site.
¦	Despite closures the DEQ approved on the areas used by the RCRA
operators some years back, a RCRA Corrective Measures
Implementation Plan (CMIP) is required and is currently being
completed. The CMIP is subject to a public commenting process.
¦	Further environmental investigations will be required to ensure the
entire site is safe for residential reuse. Further response activities
wili be required to close the site in compliance with State and
Federal regulations.
Proposed Redevelopment
The developers of the MTD project are local business owners and long-
time residents of the area who recognize the need for quality housing in
the City of Muskegon Heights. The property is located in a
predominantly African-American community where the poverty rate is
about 33%. To address the need for mixed-income housing, it is
anticipated that this project will result in the construction of
approximately 95 single and multi-family homes. The City is
encouraging the project be constructed using the local workforce.
The developers and the City are interested in incorporating social and
environmental sustainability concepts into the plans, including "green"
building, enhanced stormwater management, and recycled materials
from the demolition. The preliminary design for the site is based on the
principles of New Urbanism, and envisions single-family and multi-unit row houses inspired by traditional
designs. The neighborhood will be designed to integrate into the surrounding area and will be a pedestrian-
friendly, walkable environment with tree-lined streets and rear alleys for garage entrances. The initial plan was
developed through a design charrette that included community and local government participants.
[uskegon Heights Urban In Fill Redevelopment
Artist's rendering of the Muskegon
Heights redevelopment
Lessons Learned To Date
¦	Reuse potential can help move an
inactive site toward cleanup.
¦	Using a team approach, difficult
regulatory issues can be
successfully addressed, A team
benefits from strong and
committed champions from
stakeholder groups and needs their
continued support to be successful,
¦	Creative approaches can be found
to address liability concerns and
funding needs at RCRA facilities.
¦	A clear understanding of the reuse
and redevelopment plans for a
property is useful in focusing
sampling, investigation, and
cleanup activities.
RCRA Brownfields Pilot Team
meeting to discuss cleanup
and redevelopment

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