A COLLABORATIVE EFFORT TOWARD 

SUSTAINABLE REDEVELOPMENT AT 

THE MONA TERRACE SITE IN 

MUSKEGON HEIGHTS, MICHIGAN

April 2008 EPA Publication No. 330-F-08-003 

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 residen

Former water treatment plant

tial development. 

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 until 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. 
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.

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

will 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 longtime 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 pedestrianfriendly, 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.

For more information on ER3, please visit the Web site at: 

http://www.epa.gov/compliance/cleanup/revitalization/er3

Artist’s rendering of the Muskegon 

Heights redevelopment

Muskegon Heights Urban In Fill Redevelopment

RCRA Brownfields Pilot Team

meeting to discuss cleanup 

and 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.