A proposal to convert a large logistics warehouse in Merrimack, NH, into a federal immigration processing center highlights how delivery risks for contractors and designers can arise long before a project reaches purchase.
Documents released through public records requests show that U.S. Immigration and Customs Enforcement, which operates under the Department of Homeland Security, notified state historic preservation officials on Jan. 9 that it was considering plans to “purchase, occupy and rehabilitate” a warehouse property at 50 Robert Milligan Parkway for ICE operations. The correspondence initiated a federal review under Section 106 of the National Historic Preservation Act, but did not identify the project’s cost, contractor, designer or construction schedule.
At the municipal level, officials say they have not received any formal documentation related to the proposal.
“My office has not received anything,” Casey Wolfe-Smith, Merrimack’s planning and zoning administrator, said in a phone interview with ENR. “We don’t have any kind of permit application. There’s nothing on file, no general contractor or architect attached to it. Absolutely nothing.”
This absence of disclosure underscores a recurring challenge in federally driven adaptive reuse projects: Federal agencies can begin an environmental or historical review while local land use processes, and the construction crews that depend on them, remain completely uncommitted.
A floor plan and interior view illustrate the scale of the logistics warehouse in Merrimack, NH, showing a wide dock front and spacious interior designed for high-volume distribution rather than detention or processing use.
Image courtesy of Cushman & Wakefield
A class A logistics facility
Marketing materials for the site illustrate the scale of potential conversion. According to a Cushman & Wakefield prospectus, the property totals about 324,000 square feet, including approximately 321,000 square feet of warehouse space and 3,400 square feet of office space, on a 43-acre site in the Merrimack Technology Park. The Class A facility features 36 feet of headroom, 55 backboard loading docks, two entry doors, ESFR sprinklers, a 7-inch concrete slab, and 6,000 amps of electrical service.
The building was designed for high-volume logistics and advanced manufacturing users, suggesting that any detention or processing use would require extensive interior reconfiguration, a change in occupancy classification, and new medical and security infrastructure.
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The Department of Homeland Security correspondence describes a potential scope that could include “interior modifications” to processing and waiting areas, administrative offices, restrooms, cafeterias and health care spaces, as well as exterior work such as fencing, cameras and access control features.
The New Hampshire Division of Historic Resources ultimately determined that the proposal would have “no adverse effect” on historic properties, eliminating a first step of federal review. This determination, however, does not supersede local approvals related to zoning, building codes, utilities, traffic and emergency services.
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Local opposition and fiscal concerns
Merrimack officials have made it clear that the city opposes the establishment of an ICE facility without local consultation. In a Jan. 23 letter to the Department of Homeland Security, the city warned of fiscal and operational impacts if the federal government acquires the property.
“If the federal government purchases the potential unverified warehouse, there would be a $529,000 decrease in tax revenue,” the letter states. “This would mean an increase in the tax rate for our citizens.”
The council also cited public safety concerns, writing that “potential hardship and civil protest would require police and fire/rescue department services,” creating “a potential financial impact on those departments and their budgets.”
Gov. Kelly Ayotte (D) has publicly urged federal officials to consult with Merrimack leaders, stressing that while immigration enforcement is a federal responsibility, the impacts of large facilities are felt locally.
City officials have said they first learned of the proposal through media reports rather than direct federal disclosure, adding to uncertainty about the timing and scope. For now, Merrimack continues to treat the site as an empty warehouse. Wolfe-Smith said there have been no pre-application meetings or informal discussions indicating who might deliver the project.
“We have not had any direct contact with DHS,” he said.
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This lack of commitment leaves contractors and designers with little visibility into the procurement schedule or delivery structure. Nationally, ICE has been exploring warehouse conversions as part of a broader arrest and prosecution strategy, but formal requests tied to specific locations have not yet been issued.
For the construction industry, Merrimack’s proposal illustrates how adaptive reuse can speed up federal planning on paper, but leave unresolved local approvals and construction risk.
