Two recently acquired facilities—a 470,044-sq-ft logistics center in Roxbury Township, N.J., and a 249,090-sq-ft warehouse in Romulus, Mich.—illustrate how adaptive reuse of modern distribution space for detention purposes can trigger regulatory review well beyond interior fit-out.

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From Warehouse to Institutional Occupancy

In Roxbury Township located in western Morris County, the department paid a reported $129.3 million for the warehouse at 1879 Route 46, according to public records cited by news outlet NJ.com. The transaction amounts to roughly $275 per sq ft.

With a stated capacity to hold up to 1,500 detainees, the facility acquisition alone implies a capital outlay of about $86,000 per bed before any conversion work begins.

Completed in 2023, the building was delivered as a Class A logistics facility featuring 40-ft clear heights, an early suppression fast-response sprinkler system, 3,000-amp, 480-volt three-phase power supply and underground plumbing laterals along the office wall, according to marketing materials from seller Dalfen Industries. Those specifications reflect distribution-center design—not institutional detention occupancy.

Under the International Building Code as adopted in both New Jersey and Michigan, warehouse space is typically classified as Group S occupancy, while detention facilities fall under Group I-3 institutional occupancy—defined as facilities where occupants are restrained and not free to evacuate. 

The distinction significantly impacts life safety, egress and fire-resistance requirements. A change between these classifications can require re-evaluation of fire-protection zoning, compartmentation, egress capacity and smoke-control measures, even when the exterior shell is newly built.

The existing early-suppression, fast-response sprinkler system, designed for high-rack storage hazards, would require evaluation against institutional standards. The 40-ft clear height offers volumetric flexibility but requires significant interior modifications to add housing units, medical rooms, intake processing areas, kitchen facilities, recreation areas and controlled circulation within what was originally intended as open storage space. The 3,000-amp industrial power service supports HVAC loads, security systems and commercial kitchen equipment—potentially reducing need for extensive electrical upgrades. Plumbing distribution, however, presents a more complex retrofit.

Warehouse restroom density is minimal compared to detention standards that require showers, toilets and medical fixtures at specified ratios.

Retrofitting slab-on-grade space for distributed wet areas may involve trenching, slab demolition and re-pouring unless existing lateral capacity is sufficient. Local officials in New Jersey have questioned whether water and sewer systems can support detention-scale demand. Whether Roxbury municipal infrastructure can accommodate sustained institutional loads remains a central engineering question.

Floodplain Permitting Adds Site-Level Risk

Similar conversion dynamics apply in Romulus, Mich., where Homeland Security acquired the warehouse at 7525 Cogswell St. for potential use as a holding facility. Crain’s Detroit Business reported in February that the previous owner confirmed the building is now owned by the U.S. government but declined to disclose the purchase price due to a claimed nondisclosure agreement.

Public records indicate the 27-acre site was encumbered by a $58.5-million mortgage before transfer. While this amount does not reveal the sale price, it shows the level of prior financing on the property. As in Roxbury, the building was designed for industrial use rather than continuous residential detention.

In Romulus, however, the analysis goes beyond interior retrofit. The department has publicly stated that the property is located within a Federal Emergency Management Agency-mapped Zone AE floodplain, a special flood hazard area having a 1% annual chance of flooding with designated base flood elevations. The notice outlines exterior security fencing, recreation courts, generator replacement and possible sanitary sewer modifications.

Michigan Attorney General Dana Nessel, in a Feb. 27 letter to U.S. Immigration and Customs Enforcement leadership, wrote that “permits for activities in the floodplain will assuredly be required,” adding that the federal agency had not applied for such permits or contacted state regulators as of the date of her letter.

Floodplain development in Zone AE can trigger local floodplain development permits and state-level review tied to elevation, stormwater management and site disturbance under Michigan environmental law, even where a federal agency has issued notice under Executive Order 11988.

Whether the proposed site work—including fencing, recreation courts and generator replacement—requires additional permits from the Michigan Dept. of Environment, Great Lakes and Energy may affect both the schedule and scope.

Permitting and Zoning Become Pressure Points

New Jersey Gov. Mikie Sherrill criticized the Roxbury acquisition in a letter to Homeland Security leadership, citing projected infrastructure strain and compliance concerns.

“The placement of a massive immigration detention center in Roxbury raises environmental and quality of life concerns, including increased wastewater and trash, increased strain on municipal services, and increased traffic in the vicinity of the site,” she wrote, adding that there are “concerns about potential conflicts with state and local building codes and zoning laws.”

Michigan’s two Democratic U.S. senators, Gary Peters and Elissa Slotkin, sent a letter to Homeland Security Secretary Kristi Noem urging cancellation of the Romulus plan. They wrote that “This warehouse facility is not zoned for or developed to house individuals,” according to reporting by the Detroit News.

In Maryland, Prince George’s County officials are working to prevent similar federal acquisitions through permitting controls. County Executive Aisha Braveboy signed an executive order directing the Prince George’s Dept. of Permitting, Inspections and Enforcement not to issue use and occupancy permits to ICE for detention facilities, according to reporting by WTOP News.

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Braveboy said she plans to have the order officially codified into legislation by the County Council.

“We are taking decisive action to protect our diversity and those residents who chose to call America and Prince George’s County home,” she said, adding that county buildings and facilities would be designated as “spaces … safe from ICE operations,” WTOP reported.

Without a local use and occupancy permit, a completed retrofit could not legally open for operation. If challenged by Homeland Security, the directive could test boundaries between local permitting authority and federal supremacy in siting and operating detention facilities. 

The combination of municipal resolutions, state executive opposition, permitting controls and environmental review shows how detention conversions can develop from adaptive reuse projects into complex regulatory processes.

Nor are Roxbury and Romulus isolated cases. National reporting indicates that Homeland Security has acquired or is targeting at least one dozen large industrial warehouse properties across several states as part of a multimillion-dollar expansion of detention capacity.

The department strategy appears to favor quickly acquiring modern logistics facilities rather than building from the ground up—shortening timelines but adding complexity through adaptive reuse—such as occupancy reclassification, plumbing redistribution, fire protection redesign, and, in some jurisdictions, environmental or floodplain permitting.

For contractors, engineers and municipal authorities, the central question is not whether a warehouse can be repurposed, but rather the extent of system reconfiguration, infrastructure needs and regulatory triggers necessary to convert a code-compliant distribution center into an operational detention facility.