Gas stations

    Gas Station Feasibility Study: Fuel Margin, Tanks, Inside Sales and Financing

    By Sarrah Allen, MAI, Principal · Updated

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    A gas station feasibility study tells a lender whether one fuel and convenience site, built or bought at a stated cost, can earn enough gross profit from fuel, the store and any side businesses to pay its operating costs and its debt at the coverage the capital source requires. It answers with evidence from the site, the tank record and public data, not with the sponsor's hopes, because a station is a thin-margin business that runs on very large sales.

    Three facts frame almost every gas station loan file:

    • The fuel margin moves month to month. In the Energy Information Administration's breakdown of the pump price, the distribution and marketing share of a gallon of regular gasoline was worth about 69 cents in December 2025 and about 28 cents in March 2026, three months later [1]. Debt service does not move with it.
    • The tank record can stop a loan. SBA requires a gas station loan secured by the station's real estate or fuel equipment to start with a Phase I environmental site assessment by an independent environmental professional, and a loan may not be disbursed until tank and equipment testing is in full compliance [2]. Across the country, 52,859 confirmed tank releases were still awaiting cleanup in March 2026 [3].
    • Most stations are small businesses. In 2023, 65,123 of the 96,002 gasoline stations with convenience stores had fewer than 10 employees [4].

    This page sets out what the study must prove, the federal and state data it draws on, and how each capital source reads it. For state rules, see the state pages for Georgia, Pennsylvania, Illinois and the other states listed below. For a worked example of a fuel site on an interstate, see the I-80 truck stop and convenience store model study.

    Every study ends in one of three conclusions: feasible as proposed; feasible with stated conditions, such as a smaller loan, a funded reserve or completed tank work; or not feasible as proposed, with the changes that would make it work. The fee is fixed before work starts and does not depend on the conclusion.

    What is a gas station feasibility study?

    It is an independent analysis, written for a lender's credit file, of whether a proposed or existing fuel site can support the financing requested. USDA's rule defines a feasibility study as a report by an independent qualified consultant "evaluating the economic, market, technical, financial, and management feasibility of the proposed project" [5]. Those five parts make a sound outline for any lender, and this page follows them.

    Federal statistics split the business in two. Gasoline stations with convenience stores (NAICS 457110) sell fuel "in combination with a limited line of groceries", while other gasoline stations (NAICS 457120) include stations without convenience stores and truck stops [6]. The difference matters. A convenience store with fuel earns much of its gross profit inside the building; a high-volume fuel site or truck stop earns most of it at the pump and the diesel island. A study has to start by naming the format, because the format decides which evidence counts.

    A feasibility study is not an appraisal. An appraisal estimates value at a date. A feasibility study tests whether the project works, under what conditions, and what would have to change if it does not. Lenders often need both, and for an SBA change of ownership involving special purpose property the lender must also order a business valuation [2]. The study reports income in a form the appraiser can use, but it does not give an opinion of value. The feasibility study versus appraisal page explains the split in more detail.

    Exhibit 1. Formats the study must tell apart

    FormatMain source of gross profitWhat the study tests firstRule or data it leans on
    Convenience store with fuelFuel plus inside sales and foodInside sales build, food program, fuel marginNAICS 457110 definition and Census ratios [6][7]
    Fuel-only or kiosk siteFuel margin on high volumeVolume against nearby competitors, margin stressNAICS 457120 definition [6]; EIA price components [1]
    Truck stop or travel centerDiesel, parking-driven store and food salesTruck counts, diesel margin, where drivers must stopHours-of-service limits [8]; state traffic counts [9]
    Station with car washFuel, store and washWash volume and its own cost lineA separate wash model; see the car wash feasibility study page
    Station with EV chargingFuel and store, with charging as a side lineCharger use, power cost, program standardsFederal charging standards [10]; public charger counts [11]
    Acquisition of an operating stationThe seller's actual historyRecords tied to tax returns, gallons by grade, tank logsSBA change of ownership rules [2]

    Source: U.S. Census Bureau, 2022 NAICS descriptions and 2022 Economic Census; EIA; 49 CFR 395.3; Nebraska Department of Transportation; 23 CFR 680.106; Alternative Fuels Data Center; SBA SOP 50 10 8.1, as cited in each row.

    What does a lender need the study to prove?

    A lender needs proof that the site's own cash flow will repay the loan under the program's rules, and that nothing about the tanks, the supply contract or the operator breaks those rules. For an SBA start-up or construction loan, the projections must show debt service coverage of at least 1.15 within 2 years of funding or of the end of construction [2]. For a change of ownership, historical coverage must reach 1.25 on an initial acquisition [2]. USDA requires an independent feasibility study for a Business and Industry guarantee of more than $1,000,000 to a new business [5].

    Exhibit 2. What the lender asks and what the study shows

    Lender questionWhat the study showsRule or test
    Can cash flow carry the debt?Monthly gross profit by line, expenses and debt service through stabilizationSBA: coverage of at least 1.15 on projections within 2 years [2]
    Is an acquisition priced on real earnings?Seller's records tied to tax returns, gallons and tank logsSBA: 1.25 historical coverage and 10% equity on an initial acquisition [2]
    Is the equity enough?Sources and usesSBA 504: 15% for special purpose property, 20% if also a new business [2]. USDA: 10%, 20% or 25% [5]
    Are the tanks clean and compliant?Phase I findings, testing records, release history, state fund statusSBA Appendix 7 [2]; 40 CFR Part 280 [12]
    Is a study required?A scope matched to the programSBA may require one [13]. USDA requires one above $1,000,000 to a new business [5]
    Can the margin fall and the loan still pay?Coverage at a stress margin taken from the public recordEIA pump price components [1][14]
    Can this operator run it?Experience, staffing, supply terms, tank operator trainingManagement feasibility [5]; operator classes [12]

    Source: SBA SOP 50 10 8.1 and Appendix 15; 13 CFR Part 120; 7 CFR Part 5001; 40 CFR Part 280; EIA, as cited in each row.

    SBA does not require a study on every loan. Its regulation says SBA "may require professional appraisals of the applicant's and principals' assets, a survey, or a feasibility study" [13]. The SOP lists conditions that may lead SBA to ask for one, including "Market saturation by industry type and location", a highly specialized project property, and a project size disproportionate to the community it will serve [2]. A new station at a busy interchange that already has three competitors can meet the first test, and every station meets the second, because SBA lists gas stations among its examples of limited or special purpose property [2].

    USDA is stricter. Above $1,000,000 to a new business, the study must come from "an independent qualified consultant acceptable to the Agency", and the Agency sets its scope [5]. Even where a study is optional, the Agency weighs "the strength of the feasibility study and experience of management" when it judges whether a loan carries higher risk [5]. For what makes a study usable in a credit file, see what makes a feasibility study bankable.

    How large is the U.S. gas station industry?

    It is a $722 billion industry by sales, spread across about 114,000 establishments. The 2022 Economic Census counted 113,729 gasoline station establishments run by 64,783 firms, with sales of $721.7 billion, annual payroll of $27.1 billion and 1,028,079 employees [7]. Stations with convenience stores were 99,620 of those establishments and $533.8 billion of the sales [7].

    Exhibit 3. Gasoline stations in the 2022 Economic Census

    Industry (2022 NAICS)FirmsEstablishmentsSales ($ billions)Annual payroll ($ billions)Employees
    457 Gasoline stations and fuel dealers68,576121,320765.031.11,101,757
    4571 Gasoline stations64,783113,729721.727.11,028,079
    457110 Gasoline stations with convenience stores56,50299,620533.821.8858,390
    457120 Other gasoline stations8,98614,109187.85.2169,689
    4572 Fuel dealers3,9847,59143.34.073,678

    Source: U.S. Census Bureau, 2022 Economic Census, Retail Trade: Summary Statistics for the U.S. (EC2244BASIC). Sales and payroll converted from thousands of dollars and rounded.

    The averages show how different the two station types are. A gasoline station with a convenience store averaged $5.36 million in sales, 8.6 employees and $25,433 of payroll per employee in 2022. An establishment in the other gasoline station group averaged $13.31 million in sales and 12.0 employees, with payroll of $30,832 per employee [7]. Payroll was 4.1% of sales at convenience-store stations and 2.8% at the other group [7]. Sales here include fuel, so these ratios are a check on a budget, not a target.

    Exhibit 4. Operating ratios by station type, 2022

    MeasureWith convenience store (457110)Other gasoline stations (457120)
    Sales per establishment$5.36 million$13.31 million
    Employees per establishment8.612.0
    Annual payroll per employee$25,433$30,832
    Payroll as a share of sales4.1%2.8%
    Establishments per firm1.761.57

    Source: calculated by FSC from U.S. Census Bureau, 2022 Economic Census (EC2244BASIC), U.S. rows for NAICS 457110 and 457120.

    Most operators are small. County Business Patterns, which still uses the 2017 industry codes (447110 and 447190), counted 96,002 gasoline stations with convenience stores in 2023, with 848,306 employees and $23.7 billion of annual payroll [4]. Of those, 34,065 had fewer than five employees and only 87 had 100 to 499 employees [4]. The small-operator profile matters for the management part of the study: one owner often runs the store, manages the supply contract and holds the tank operator duties.

    Exhibit 5. Gas station establishments by employment size, 2023

    EmployeesWith convenience store (447110)Other gasoline stations (447190)
    Fewer than 534,0655,800
    5 to 931,0583,049
    10 to 1922,9661,925
    20 to 497,1071,494
    50 to 99717831
    100 to 2496372
    250 to 49924Not shown
    All establishments96,00213,172

    Source: U.S. Census Bureau, County Business Patterns 2023, U.S. file (cbp23us), all legal forms of organization. "Not shown" marks a cell the file leaves blank.

    Sales are spread unevenly across states. Texas had 10,299 convenience-store stations in 2022, more than any other state, but California's stations sold more per site, $7.02 million against $5.07 million in Texas [7]. These differences carry into the study: a sales-per-site figure that is normal in one state can be an outlier in the next.

    Exhibit 6. Gasoline stations with convenience stores, largest states, 2022

    StateEstablishmentsSales ($ billions)Sales per establishment ($ millions)Employees
    Texas10,29952.35.0782,843
    California6,95148.87.0261,650
    Florida5,99333.15.5253,378
    Georgia4,97020.44.1128,020
    North Carolina4,20520.94.9629,507
    New York3,80417.34.5427,999
    Ohio3,52420.75.8631,107
    Illinois3,43017.55.1127,985
    Tennessee3,28413.84.2019,819
    Michigan3,25516.65.0922,657
    Pennsylvania3,18121.26.6740,030
    Alabama2,95910.03.3715,837

    Source: U.S. Census Bureau, 2022 Economic Census (EC2244BASIC), state rows for NAICS 457110; sales per establishment calculated by FSC. Ranked by establishments.

    Station sales follow the pump price

    Gas station sales track fuel prices more than they track customers. Census monthly retail data put gasoline station sales at $509.5 billion in 2019, $423.6 billion in 2020, $721.7 billion in 2022 and $633.7 billion in 2025 [15]. For January to August 2026, sales were 15.6% above the same months of 2025 [15], a year when EIA expected the retail gasoline price to average $3.89 a gallon against $3.10 in 2025 [16].

    Exhibit 7. U.S. gasoline station sales, 2017 to 2025

    YearSales ($ billions)Change from prior year
    2017475.1
    2018521.09.7%
    2019509.5-2.2%
    2020423.6-16.9%
    2021563.533.0%
    2022721.728.1%
    2023650.1-9.9%
    2024641.0-1.4%
    2025633.7-1.1%

    Source: U.S. Census Bureau, Monthly Retail Trade, annual totals not adjusted, NAICS 447 gasoline stations (mrtssales92-present); changes calculated by FSC.

    Because sales swing with price, a lender should not read sales growth as business growth. The useful measures are gallons, cents of gross profit per gallon, and inside gross profit. The Census Bureau's Annual Retail Trade Survey shows why. For gasoline station firms, gross margin as a share of sales ran between 16.1% and 19.6% from 2017 to 2021 [17], while operating expenses ran between 12.5% and 15.2% of sales [18][19]. What is left over was a thin band, between about 3% and 5% of sales.

    Exhibit 8. Gasoline station firms: margin and expenses, 2017 to 2022

    YearSales ($ millions)Gross margin (% of sales)Operating expenses ($ millions)Expenses (% of sales)Gross margin less expenses (% of sales)
    2017476,15216.662,68513.23.4
    2018523,43616.165,26112.53.6
    2019513,68617.267,06413.14.1
    2020429,35319.665,24015.24.4
    2021572,65418.676,61713.45.2
    2022736,082Not published89,48512.2Not available

    Source: U.S. Census Bureau, Annual Retail Trade Survey 2022 tables (sales.xlsx, gmper.xlsx, exp.xlsx), NAICS 447, employer firms; percentages of sales and the last column calculated by FSC. The Census Bureau withheld the 2022 gross margin rate because it did not meet publication standards.

    Two lessons follow for a projection. First, the margin as a share of sales rises when prices fall, as in 2020, and falls when prices rise; so a cents-per-gallon margin is a better planning unit than a percentage. Second, a projection that shows a station keeping 10% or more of sales after operating costs is far outside the industry's own record and needs strong site evidence.

    Is fuel demand growing or shrinking?

    National gasoline demand has been flat since 2021, while the miles driven keep rising. EIA's annual data show finished motor gasoline product supplied of 8,816 thousand barrels a day in 2021 and 8,935 thousand barrels a day in 2025 [20]. Americans used about 136.53 billion gallons of finished motor gasoline in 2025, about 374.05 million gallons a day [21]. Light-duty vehicles account for about 91% of gasoline use [21], so cars and light trucks, not freight, decide most station volume.

    Exhibit 9. U.S. product supplied, 2020 to 2025 (thousand barrels per day)

    YearFinished motor gasolineDistillate fuel oilTotal petroleum products
    20208,0493,78618,186
    20218,8163,97219,890
    20228,8104,02620,010
    20238,9453,91620,275
    20248,9673,79220,464
    20258,9353,90820,736

    Source: U.S. Energy Information Administration, Product Supplied for Crude Oil and Petroleum Products, annual, thousand barrels per day. Distillate fuel oil includes on-road diesel and other distillates.

    Efficiency is the reason miles and gallons can part ways. FHWA's Highway Statistics show vehicle-miles of travel rising from 3,246,817 million in 2023 to 3,294,031 million in 2024, while fuel consumed fell from 176.8 billion gallons to 171.8 billion gallons [22]. Average fuel economy across all vehicles rose from 18.4 to 19.2 miles per gallon [22]. A light-duty vehicle used 460 gallons on average in 2024 and a combination truck 7,771 gallons [22]. That gap is why one truck customer is worth many car customers to a diesel site.

    Exhibit 10. Travel and fuel use, 2023 and 2024

    Measure20232024
    Vehicle-miles of travel, all vehicles (millions)3,246,8173,294,031
    Fuel consumed, all vehicles (thousand gallons)176,795,288171,812,062
    Average miles per gallon, all vehicles18.419.2
    Registered motor vehicles284,614,269297,525,836
    Average fuel per light-duty vehicle (gallons)492460
    Average fuel per combination truck (gallons)8,8137,771
    Average miles per gallon, combination trucks6.77.1

    Source: Federal Highway Administration, Highway Statistics 2024, Table VM-1 (updated February 2026).

    For a feasibility study, three practical points follow.

    1. Mature-site volume should not grow with traffic alone. If miles rise about 1.5% while fuel use falls, as it did from 2023 to 2024 [22], a projection that grows gallons in line with traffic overstates fuel sales. The study holds mature gallons flat or declining unless the site has a specific cause for growth, such as a new interchange or new housing.
    2. Price changes move dollars, not gallons. EIA expected the retail gasoline price to average $3.89 a gallon in 2026 and $3.73 in 2027, with diesel at $5.25 and $5.03 [16]. Those prices change sales, card fees and working capital. They do not, by themselves, change cents of margin.
    3. Electric vehicles are a long-run sensitivity. The Alternative Fuels Data Center listed 83,995 public electric charging station locations with 263,961 charging ports, 79,827 of them DC fast ports, on November 11, 2026 [11]. That is a real network, but national gasoline use was still near its post-2021 level in 2025 [20]. The study tests a slower-volume case over the loan term instead of building a decline into the base case without local evidence.

    How should the study set the fuel margin?

    It should set a normalized margin and a stress margin, both in cents per gallon, both net of card fees, and both tied to the station's supply terms. The public record shows why a single average is not enough. EIA's breakdown of the retail price puts the "distribution and marketing" share of a gallon of regular gasoline at an average of 55.0 cents in 2025, but it ranged from 27.6 cents in March 2026 to 72.1 cents in June 2026 [1].

    EIA describes this component as covering "Distribution, marketing, and retail dealer costs and profits" [23]. It is wider than a station's gross margin: it also pays for terminals, trucking and wholesale marketing. So the study uses it as a public index of how the whole downstream margin moves, not as the station's own number. The station's margin comes from its supply contract, its posted prices and, for an operating site, its own records.

    Exhibit 11. Distribution and marketing component of the pump price, annual averages

    YearRegular gasoline retail price ($/gal)Gasoline distribution and marketing (cents/gal)Lowest month (cents)Highest month (cents)Diesel distribution and marketing (cents/gal)
    20192.6038.421.148.963.0
    20202.1753.840.892.778.1
    20213.0043.530.567.866.1
    20223.9648.120.077.089.3
    20233.5250.034.777.785.1
    20243.3153.835.664.377.7
    20253.1055.048.169.276.9
    2026, January to August3.7548.127.672.181.3

    Source: calculated by FSC from U.S. Energy Information Administration, Gasoline Pump Components History and Diesel Pump Components History (release of November 10, 2026). Each month's cents equal the retail price times EIA's distribution and marketing percentage; annual figures are simple averages of the months.

    The monthly pattern is the part a lender should study. When wholesale prices jump, retail prices lag and the station's margin is squeezed; when wholesale prices fall, the margin widens for a while. Early 2026 showed both in a few months.

    Exhibit 12. Monthly swings, December 2025 to August 2026

    MonthRegular gasoline ($/gal)Distribution and marketing shareGasoline cents per gallonDiesel ($/gal)Diesel cents per gallon
    December 20252.89423.9%69.23.61594.4
    January 20262.80911.4%32.03.52384.2
    February 20262.90813.3%38.73.72276.7
    March 20263.6387.6%27.64.92158.1
    April 20264.10313.7%56.25.50182.0
    May 20264.47914.8%66.35.600126.0
    June 20264.05017.8%72.15.024105.5
    July 20263.93210.5%41.34.95555.5
    August 20264.05812.5%50.75.46262.3

    Source: U.S. Energy Information Administration, Gasoline Pump Components History and Diesel Pump Components History; cents per gallon calculated by FSC (retail price times the distribution and marketing percentage).

    From those records the study builds its margin in four steps:

    1. Start from the contract. A branded supply agreement, an unbranded rack purchase and a dealer or commission arrangement each leave the station a different share of the downstream margin. The study models the terms actually offered, including volume minimums, rebates and image obligations.
    2. Normalize over a full cycle. The base case uses the station's own history or a local price survey across several years, not the best recent year. The EIA series shows why: 2025 averaged 55.0 cents downstream, but 2019 averaged 38.4 [1].
    3. Stress the opening years. The stress case takes the margin down to a level the public record has actually reached, and holds it there through the ramp, when coverage is thinnest.
    4. Net out card fees and shrink. Card fees are charged on the full pump price, including taxes, so they rise with price even when the margin does not. Federal tax alone is 18.4 cents a gallon on gasoline (18.3 cents plus the 0.1-cent Leaking Underground Storage Tank Trust Fund rate) and 24.4 cents on diesel [24]. As of January 2026, state taxes and fees on gasoline averaged 33.55 cents a gallon [23].

    Exhibit 1

    The margin you model versus the margin operators earn

    The industry gasoline margin has held near 39 to 40 cents a gallon since 2022, roughly double the 12 to 22 cents still common in pro formas. It fell to 29.9 cents as recently as 2021, so a study needs both a normalized base and a stress case.

    U.S. gasoline gross margin, cents per gallon; labels show share of pump price. Five-year average: 38.3 cents.

    View data
    YearGross margin, cents per gallonShare of pump price
    202129.910.2%
    202242.910.8%
    202339.411.2%
    202439.711.9%
    202539.712.7%
    OperatorPeriodRetail fuel margin, cents per gallon
    Casey'sFY2026 (to April 30, 2026)42.6 (Q4: 46.9)
    ARKO202542.8 (Q4: 44.5)
    Murphy USA202528.1 retail (30.7 including product supply and wholesale)

    Gross margin is not profit. NACS puts retailers' fuel-selling costs at about 20 to 25 cents a gallon, including about 8 cents of card fees, which leaves roughly 10 to 15 cents net. Retail prices also rise faster than they fall when wholesale costs move (Borenstein, Cameron and Gilbert, Quarterly Journal of Economics, 1997). Margins therefore compress when wholesale prices rise and widen when they fall, and annual averages hide swings that hit monthly coverage tests.

    Source: NACS, "Key Facts About Fueling" (OPIS MarginPro data, 2026); Casey's Form 8-K (June 9, 2026); ARKO Q4 and FY2025 release (February 25, 2026); Murphy USA 2025 Annual Report.

    Margin stress check

    The margin check below tests one question: how much annual fuel gross profit a station loses if its margin falls from a base level to a stress level. Enter monthly gallons, a base margin and a stress margin, all in the units shown; it returns annual fuel gross profit at each margin and the difference. Its starting values are illustrative only, not market data and not a finding for any site. A study replaces them with the gallons and margins its evidence supports, and then carries the stress result into the coverage test.

    Annual fuel gross profit at base margin

    $630,000

    Annual fuel gross profit at stress margin

    $450,000

    At the stress margin, fuel gross profit falls by $180,000 a year (28.6%).

    Both margins are illustrative inputs, not market data: replace them with the station's own fuel margin history. Gross profit before fuel-selling costs. Illustrative only; not a feasibility conclusion.

    As an illustration only: a station selling an assumed 150,000 gallons a month earns $900,000 a year of fuel gross profit at an assumed 50 cents a gallon, and $496,800 at 27.6 cents, the lowest monthly downstream level in EIA's 2026 data [1]. Card fees and other fuel selling costs come out of both figures.

    How are fuel volume and traffic capture estimated?

    Volume starts with the vehicles that pass the site and ends with the share that can and will stop. State transportation departments publish annual average daily traffic (AADT) counts by road segment, and many publish truck counts as well. Those counts are the base of the demand model, but a count is not a sale.

    The study works through five filters:

    1. Direction and access. Traffic on the far side of a divided road may not be able to turn in. The study maps which directions can reach the pumps without a U-turn, and at what speed.
    2. Trip purpose. Commuters, local errands, through travelers and trucks behave differently. A commuter fills up near home or work; a long-distance driver stops where the trip and the rules on driving hours say to stop.
    3. Competition. Each station within the trade area is mapped with its fueling positions, price posture and store format. The study asks what share the new site can win from that set, not what share of the road it can "capture" in the abstract.
    4. Visibility and price. Drivers compare posted prices. A site that must price above the corner to cover a higher rent or a bigger loan will sell fewer gallons than one that can match.
    5. Calibration. Where an operating station is close by and comparable, its volume is the best check. For an acquisition, the seller's monthly gallons by grade are the base and the model explains every change from them.

    Truck stops add a sixth filter: where drivers must stop. Federal hours-of-service rules let a property-carrying driver drive up to 11 hours after 10 consecutive hours off duty, within a 14-hour window, and require a 30-minute break after 8 hours of driving [8]. Those limits put rest stops at fairly predictable distances from freight origins.

    The I-80 corridor in Lincoln County, Nebraska shows what a public count series looks like. FSC's model study averaged the Nebraska Department of Transportation counts for five interstate segments.

    Exhibit 13. I-80 traffic in Lincoln County, Nebraska (mean of five segments)

    YearAll vehicles (AADT)TrucksTruck share
    201617,0197,21042.4%
    201917,0536,96240.8%
    202016,6367,24843.6%
    202218,9918,01842.2%
    202418,1278,00844.2%
    202518,4118,27444.9%

    Source: Nebraska Department of Transportation, Annual Average Daily Traffic Segments layer; means of the five I-80 segments wholly inside Lincoln County, calculated in FSC's Lincoln County model study.

    Two points stand out. Traffic and trucks did not move together year to year, and the truck share rose from 42.4% to 44.9% over the decade. A truck stop study built on one year's total count would miss both. Truck parking matters too: FHWA's national truck parking work counted about 313,000 truck parking spaces, about 40,000 of them at public rest areas, and 98 percent of drivers reported problems finding safe parking [25]. For a travel center, parking capacity drives diesel share, so the study counts spaces at every competing site.

    The study then converts stops to gallons. It uses the site's own data or comparable sites for gallons per transaction and transactions per hour by daypart, and it checks the result against dispenser capacity at the peak hour. A forecast that needs more transactions at 7 a.m. than the islands can serve is a forecast the site cannot deliver.

    Exhibit 2

    Chain averages bracket the forecast

    Public operators' per-store volumes run from about 100,000 to about 236,000 gallons a month, and inside sales from about $2.2 million to $3.0 million a year. The format behind a benchmark matters as much as the number.

    BenchmarkFuel gallons per store per monthInside sales per store per yearInside / merchandise margin
    Casey's, FY2026 (rural and small-town heavy)≈100,200≈$2.17M42.2% (prepared food and dispensed beverage 58.6%; grocery and general merchandise 35.8%)
    Murphy USA, 2025 (high-volume value format)235,751≈$2.44M20.2%
    ARKO, 2025n/an/a33.7%
    NACS national average, 2025 (derived)≈157,500≈$3.0Mn/a

    Murphy USA gallons per store per month by year: 2021 229,404 · 2022 244,582 · 2024 240,632 · 2025 235,751.

    Casey's and NACS figures are firm arithmetic. Casey's figures divide reported totals by the average store count. The NACS averages are back-calculated from NACS's regional figures.

    NACS also reports 322 fueling transactions a day at 8.4 gallons each, about 82,000 gallons a month. Its survey sample is weighted toward larger chains, which is why the two NACS-based figures differ. A study states which benchmark it uses and why.

    Source: Casey's Form 8-K Ex. 99.1 (June 9, 2026); Murphy USA 2025 Annual Report and Q4 2025 release; ARKO FY2025 release and 10-K; NACS State of the Industry release (April 15, 2026) and "Key Facts About Fueling."

    Exhibit 3

    New stores take three years

    New Murphy USA stores outperform the chain average once mature, but their returns are still climbing in year three. Management says merchandise takes about 36 months to reach maturity, so year-one coverage, not the stabilized year, is the binding test.

    2025 unlevered after-tax return on invested capital by build class

    View data
    Build classReturn on invested capital
    2021 class16%
    2022 class15%
    2023 class12%
    2024 class7%

    2021 to 2023 build classes, 74 stores, against the chain average, per month:

    $45K vs $41K

    Merchandise contribution

    $76K vs $66K

    Fuel contribution

    $54K vs $48K

    Adjusted EBITDA

    Source: Murphy USA Form 8-K investor presentation (March 2, 2026); Murphy USA Q4 2025 prepared remarks.

    Exhibit 4

    Same-store gallons are drifting down

    Chain gallons are growing through new stores while same-store volume at mature stores is flat to falling. After maturity, a projection should assume flat to slightly declining gallons.

    −2.6%

    Murphy USA same-store gallons, 2025

    −3.0% to −1.0%

    Murphy USA 2026 same-store guidance (233,000 to 237,000 gallons per store per month)

    +1.4%

    Casey's same-store gallons, FY2026

    −1% to +1%

    Casey's FY2027 guidance

    ~600

    Chain stores opened within three miles of Murphy USA sites since 2020

    Murphy USA's data show fuel volume and contribution dipping after a competitor opens nearby, then recovering over three to five years. That is the clearest public evidence that competitive entry, not only traffic count, drives realized volume.

    Source: Murphy USA 2025 Annual Report, Q4 2025 release and Form 8-K investor presentation (March 2, 2026); Casey's Form 8-K (June 9, 2026).

    The competitor survey

    Every competing station in the trade area is visited, not just found on a map. The survey records fueling positions, diesel lanes, posted prices on the survey date, brand, store size, food offer, car wash and charging, and hours. State tank registries help find sites and show their tank ages; a site with old single-walled tanks may close or rebuild, which changes the competitive set. Planned stations count too: the study checks local permit and zoning records for approved sites that have not opened yet.

    How is the inside store and food program modeled?

    Category by category, with each category's own margin, labor and rules. Inside sales do not follow gallons in a fixed ratio; they follow the store's size, its food offer, the daytime population near the site and the time customers can spend. A truck driver on a 30-minute break [8] buys differently from a commuter who stops for two minutes.

    The study builds inside revenue from the merchandise plan the operator will actually run, then checks it against the Census ratios for the format. A convenience-store station averaged $5.36 million of total sales, fuel included, in 2022 [7]; a projection far above the state's own average in Exhibit 6 needs site-specific support.

    Exhibit 14. Inside categories the study builds separately

    CategoryWhat drives salesWhat the study checksRule or risk
    Prepared food and dispensed drinksKitchen size, menu, daypart trafficLabor, waste, equipment and hood costLocal health permits; staffing at peak hours
    Packaged drinks and snacksStore size and cooler spaceSupplier terms and rebatesLow risk, modest margin
    Tobacco and nicotineLocal demand and nearby competitionAge-check procedures and penaltiesFederal minimum age of 21 for cigarettes and smokeless tobacco [26]
    Beer and wineState and local licensingWhether a license can be obtained or transferredLicense rules vary by state and county
    Lottery and servicesState lottery contractsCommission income only, not gross salesCommission rates set by each state
    Car wash, air and vacuumWash type and climateSeparate revenue and cost lineWater and wastewater permits

    Source: FSC method; 21 CFR 1140.14 for the federal tobacco age rule.

    Tobacco shows why the study works category by category. Federal rules bar retailers from selling cigarettes or smokeless tobacco to anyone under 21, require a photo ID check for buyers under 30, and limit sales to face-to-face exchanges except in narrow cases [26]. A store whose sales lean on tobacco carries more compliance risk than one that leans on food, and a study should say so.

    Exhibit 6

    Foodservice carries the inside P&L

    Foodservice is under a third of in-store sales but nearly 40% of in-store gross profit, at margins near 56% to 59%. The quality of the food program now does as much for coverage as the fuel island.

    28.5%

    Foodservice share of in-store sales, 2025 (NACS)

    38.9%

    Foodservice share of in-store gross profit, 2025 (NACS)

    $72,061

    Foodservice sales per store per month, 2025 (NACS)

    56.41% / 58.6%

    Prepared-food margin: NACS 2024 / Casey's FY2026

    27.44%

    Cigarettes and other tobacco as a share of in-store sales, 2024 (NACS)

    Cigarettes were the only top-10 in-store category with negative sales and gross-profit growth in 2024. Nicotine's weight in the mix varies widely by format: at Murphy USA it ranges from 73% of merchandise margin at kiosk stores to 14% at QuickChek stores. A study projects the category mix by format, not from a national average.

    Source: NACS State of the Industry (April 15, 2026) and 2024 category data; Casey's Form 8-K (June 9, 2026); Murphy USA Form 8-K investor presentation (March 2, 2026).

    What environmental and tank rules decide a gas station loan?

    The tank record decides whether a station loan can close at all. SBA's rules for gas station loans apply to any loan secured by real estate or by equipment such as tanks, pumps and lines used to run a gas station or commercial fueling facility [2]. For those loans, the environmental investigation must:

    • begin with a Phase I environmental site assessment conducted by an independent environmental professional [2];
    • include a determination of whether the station complies with the rules on tank and equipment testing, and "A loan may not be disbursed until full compliance is achieved" [2];
    • include any Phase II the professional recommends, performed by an independent professional engineer or professional geologist with the equivalent of 3 years of full-time relevant experience [2];
    • describe and price the cleanup if the property is contaminated [2].

    Any leaking or defective equipment must be repaired or replaced before disbursement [2]. If an oil company or anyone else holds a right to indemnification from later owners, it must sign SBA's indemnification agreement or a recorded waiver and release [2]. And the borrower must register for any available petroleum storage tank fund that would reimburse cleanup costs, even a voluntary one [2].

    The feasibility study does not replace the Phase I. It reads it, along with the tank registration, testing and release records, and turns the findings into money and time: a repair budget, a closing condition, a reserve, a delay to opening, or a conclusion that the site does not work.

    Exhibit 15. SBA environmental requirements for gas station loans

    RequirementWhat it means for the projectWhere it sits
    Phase I by an independent environmental professionalRequired for every gas station loan, including equipment-only loansSOP 50 10 8.1, Appendix 7 [2]
    Tank and equipment testing complianceNo disbursement until full compliance is achievedAppendix 7, paragraph B [2]
    Phase II when recommendedDone by a licensed engineer or geologist with 3 years of relevant experienceAppendix 7, paragraph A [2]
    Contamination foundLender may decline, or follow SBA's contamination rules with indemnitiesAppendix 7, paragraph C [2]
    Prior indemnification rightsHolder signs SBA's agreement or a recorded waiver and releaseAppendix 7, paragraph D [2]
    State tank fundBorrower registers for any available reimbursement programSBA indemnification terms [2]
    Equipment condition on a purchaseDispensing equipment tested by an independent contractor within the preceding twelve monthsIndemnitor warranty [2]

    Source: U.S. Small Business Administration, SOP 50 10 8.1, Appendix 7 and related environmental provisions.

    Federal tank rules the study checks

    Federal tank rules apply to nearly every station. Tanks and piping installed or replaced after April 11, 2016 must be secondarily contained and use interstitial monitoring [12]. Owners must check spill prevention and release detection equipment every 30 days [12], and test spill prevention equipment and certain containment sumps at least once every three years unless they are double walled and monitored [12]. Suspected releases must be reported within 24 hours [12].

    Exhibit 16. Federal UST requirements and what the study documents

    RequirementFederal ruleWhat the study documents
    Secondary containment for tanks and piping installed or replaced after April 11, 201640 CFR 280.20 [12]Install dates of each tank and piping run; replacement plans and cost
    Release detection at least every 30 days40 CFR 280.41 [12]Monitoring method, alarm history, records
    Spill prevention and sump testing at least once every three years40 CFR 280.35 [12]Last test dates and results; next tests due
    Walkthrough inspections every 30 days and annually40 CFR 280.36 [12]Inspection logs kept for one year
    Class A, B and C operator training40 CFR 280.242 [12]Who holds each role after closing
    Reporting a suspected release within 24 hours40 CFR 280.50 [12]Any open reports, and how they were closed
    Financial responsibility of $1 million per occurrence for petroleum marketing facilities40 CFR 280.93 [12]State fund, insurance or other mechanism, and its limits
    Annual aggregate of $1 million (1 to 100 tanks) or $2 million (101 or more)40 CFR 280.93 [12]Whether the owner's portfolio crosses the threshold

    Source: 40 CFR Part 280 (GovInfo annual edition revised as of July 1, 2025).

    The national record shows why lenders insist. EPA counted 534,189 active regulated tanks at about 190,224 facilities in March 2026 [3]. Between April 2025 and March 2026, facilities met all technical compliance measures at a rate of 60.9%, and walkthrough requirements at 83.2% [3]. Cumulative confirmed releases since the program began reached 583,313, with 530,454 cleanups completed [3]. When the program started there were about 2.1 million regulated tank systems [27], so most of the substandard tanks of the 1980s are gone, but a station's history can still hold an open case. In fiscal year 2025 alone, states confirmed 4,307 new releases and completed 5,920 cleanups, leaving 53,777 releases awaiting cleanup at the end of September 2025 [28].

    Exhibit 17. National UST program measures

    MeasureEnd of fiscal year 2025Mid fiscal year 2026
    Confirmed releases in the period4,3071,997
    Cumulative confirmed releases since 1984581,676583,313
    Cleanups completed in the period5,9202,947
    Cumulative cleanups completed527,899530,454
    Releases remaining to be cleaned up53,77752,859
    Technical compliance rate62.9%60.9%
    Financial responsibility compliance90.3%90.4%
    Operator training compliance88.6%89.7%

    Source: U.S. Environmental Protection Agency, Semiannual Reports of UST Performance Measures, end of fiscal year 2025 (October 2024 to September 2025) and mid fiscal year 2026 (October 2025 to March 2026; compliance rates for April 2025 to March 2026).

    The backlog is not spread evenly. Florida and Michigan each had more than 7,000 releases awaiting cleanup in March 2026, while New York had 239 [3]. A state with a large backlog is a state where an old release near the site, or on it, is more likely to still be open.

    Exhibit 18. Tanks and releases in selected states, March 2026

    StateActive petroleum USTsCumulative confirmed releasesCumulative cleanups completedReleases awaiting cleanup
    Texas47,19129,76528,6751,090
    California36,91444,67843,3341,344
    Georgia30,41115,83515,365470
    North Carolina23,38328,14327,601542
    Florida23,03934,13326,3957,738
    New York21,60531,11630,877239
    Ohio21,33535,23233,3031,929
    Pennsylvania20,71919,23916,6142,625
    Illinois17,95526,90522,3074,598
    Michigan16,35224,94917,4417,508
    New Jersey11,41719,44214,7314,711
    South Carolina11,04211,1649,2051,959

    Source: U.S. Environmental Protection Agency, Semiannual Report of UST Performance Measures, Mid Fiscal Year 2026, state tables (cumulative through March 31, 2026).

    Environmental timing on a purchase

    Timing matters on an acquisition. Under the federal "all appropriate inquiries" rule, the inquiry must be conducted within one year before the acquisition, and several parts, including interviews, lien searches, government record reviews and the site visit, must be done or updated within 180 days before it [29]. A study that relies on an older Phase I should flag the update as a closing condition.

    State tank funds and what they leave the owner

    Most states run a fund that reimburses cleanup costs above a deductible, up to a cap. The fund's terms decide how much of a release the owner still pays, so the study reads them for the site's state. Several states pay for the fund with a per-gallon fee, which is one more cost inside the fuel margin.

    Exhibit 19. State tank fund terms in selected states

    StateOwner's deductibleFund limitHow the fund is paid for
    ArizonaSet by statuteReimbursement up to $1,000,000 per facility; not a financial assurance mechanism [30]Tank excise of one cent per gallon [31]
    Arkansas$7,500 per occurrence [32]$2,000,000 corrective action; $1,000,000 third party [33]Fee of $.003 per gallon [34]
    ColoradoLesser of the remediation amount or $10,000 [35]$2 million per occurrence; $3 million aggregate a year [35]Registration fee of $35 per tank a year, among other sources [35]
    Georgia$10,000, unchanged since 1988 [36]Set by program rulesEnvironmental Assurance Fee of $0.0075 per gallon [36]
    Illinois$5,000 for releases reported on or after June 8, 2010 [37]Set by statute$500 registration fee per tank, among other sources [38]
    KentuckyNo deductibles for SOTRA tank removal reimbursements [39]Set by program rulesFee of 1.4 cents per gallon [40]
    Massachusetts$5,000 at one site, $7,500 at two, $10,000 at three or more [41]$2,500,000 per tank in the aggregate, less the deductible [41]Set by statute
    Missouri$10,000 per release [42]$1 million per occurrence; $2 million aggregate a year [42]Set by statute
    NevadaOwner share capped at $50,000 for small businesses [43]90% of the first $1,000,000 per tank; $1,800,000 a year per operator for other operators [43]Set by statute
    New Mexico$10,000, or $5,000 on proof of inability to pay [44]Set by ruleSet by statute
    OklahomaSet by rule$26,762,586.03 paid on 1,374 claims in fiscal year 2026 [45]Assessment of $0.01 per gallon [46]
    Pennsylvania$5,000 per tank per occurrence [47]$1.5 million per tank per occurrence; $1.5 million or $3 million aggregate by tank count [47]Capacity fee of $0.0825 per gallon of tank capacity a year [47]

    Source: state statutes, rules and fund agencies as cited in each row; "Set by" entries mark terms this table does not quantify.

    Fund coverage is not automatic. Eligibility usually depends on paying tank fees on time, registering before a release and cooperating with the agency, and some funds cover only releases discovered after a set date. Michigan's cleanup fund, for example, reimburses owners for petroleum leaks "originating after 2014" [48]. The study states which fund applies, whether the seller's eligibility transfers, and what the owner would pay out of pocket for one release at the deductible.

    Which air quality rules apply to fuel throughput?

    Federal air rules for gasoline dispensing facilities scale with monthly gasoline throughput, so the projected gallons decide the equipment the site needs. Under EPA's area-source rule, a facility with monthly throughput under 10,000 gallons follows basic work practices; one at 10,000 gallons or more must load its tanks by submerged filling; and one at 100,000 gallons or more must also follow the management practices in Table 1 of the subpart, or meet the rule's vapor balance alternative [49][50][51][52]. States and local air districts can add stricter rules.

    Exhibit 20. Gasoline dispensing facility rules by monthly throughput

    Monthly gasoline throughputFederal requirementSection
    Under 10,000 gallonsMinimize spills, clean them up, cover open containers and fill pipes; keep throughput records available within 24 hours of a request40 CFR 63.11116 [50]
    10,000 gallons or moreAll of the above plus submerged filling; fill pipes installed after November 9, 2006 no more than 6 inches from the tank bottom40 CFR 63.11117 [51]
    100,000 gallons or moreAll of the above plus the management practices in Table 1 of the subpart, or a qualifying vapor balance system in place before January 10, 200840 CFR 63.11118 [52]
    Tanks under 250 gallonsExempt from submerged fill, but must follow the basic work practices40 CFR 63.11117(c) [51]
    All tiersRecords of monthly throughput kept for 5 years40 CFR 63.11111(e) [49]

    Source: 40 CFR Part 63, Subpart CCCCCC (GovInfo annual edition revised as of July 1, 2025).

    The thresholds matter for the volume forecast. A station projected at 120,000 gallons a month crosses the 100,000-gallon line in the model, and the budget must carry the vapor control equipment and testing that come with it. The study checks that the gallons and the equipment agree.

    How do fuel taxes and supply agreements affect the projection?

    Taxes are a pass-through in the price, but they still shape the business. They raise the price on which card fees are charged, they change when a state changes its rate, and they create price gaps at state lines that move volume. The federal excise is 18.3 cents a gallon on gasoline and 24.3 cents on diesel, each plus the 0.1-cent Leaking Underground Storage Tank Trust Fund rate [24]. State rates differ widely.

    Exhibit 21. State gasoline taxes in selected states

    StateGasoline taxPeriod or statusNote
    Arizona$.18 per gallonCurrent statuteUse fuel for use class vehicles $.26 [53]
    Arkansas$.247 per gallonOctober 1, 2026 to September 30, 2027Includes $.032 wholesale tax [34]
    Colorado22 centsFrom January 1, 2019 [54]Plus fees that change with fund balances [55]
    Georgia$0.333 per gallon2026$0.344 from January 1, 2027 [56][57]
    Illinois48.3 centsJuly 1 to December 31, 2026Diesel 55.8 cents [58]
    Indiana$0.37 per gallonJuly 1, 2026 to June 30, 2027Plus gasoline use tax; collection paused August 7 to December 4, 2026 [59][60]
    Kentucky$0.264 per gallonFrom July 1, 2026Special fuel $0.234 [61]
    Louisiana$.20 per gallonCurrentGasoline, diesel and most special fuels [62]
    Massachusetts24 centsCurrent statute[63]
    MichiganAt least 51.0 centsFrom January 1, 2026Up from 31.0 cents [64]
    Mississippi24 centsJuly 1, 2026 to June 30, 202727 cents from July 1, 2027 [65]
    Missouri$0.295 per gallonFrom July 1, 2025[66]
    Nebraska31.8 centsJuly 1 to December 31, 2026[67]
    New Jersey49.1 cents combinedFrom January 1, 2026Diesel 56.1 cents [68]
    New Mexico$0.17 per gallonCurrent page[69]
    Oklahoma$0.19 per gallonCurrent pagePlus $0.01 indemnity fund assessment [46]
    Pennsylvania$0.576 per gallonJanuary 1, 2026Plus 1.1-cent tank fund fee [70]

    Source: state statutes, revenue departments and legislative fiscal offices as cited in each row. Rates change often; the study confirms the rate in force for the site's state at the date of the report.

    Two recent changes show why. Michigan raised its motor fuel tax from 31.0 cents to at least 51.0 cents a gallon effective January 1, 2026 [64]. Under an energy emergency declaration, Indiana's revenue department will not collect its gas use tax or gasoline excise tax from August 7 through December 4, 2026 [60]. Either change moves pump prices and can move volume at a site near a state line.

    Supply agreements and the franchise law

    The supply agreement is part of the collateral. The Petroleum Marketing Practices Act bars a motor fuel franchisor from terminating a franchise before the end of its stated term, or from failing to renew it, except on the grounds and with the notice the Act allows [71]. SBA treats agreements covered by that Act, such as distributor, fuel supply, dealer or jobber agreements, as franchises for its own eligibility review [2]. A study therefore reads the agreement for:

    • the remaining term and renewal rights;
    • volume minimums and the cost of missing them;
    • who sets the retail price, and who keeps which part of the margin;
    • image, rebranding and equipment obligations, with their cost and timing;
    • assignment and transfer terms on a sale;
    • any right of first refusal held by the supplier.

    A branded agreement can bring a recognized sign, card programs and supply security, but it usually comes with volume commitments and image costs. An unbranded supply arrangement gives price freedom and exposes the station to rack price swings. The study does not assume either is better. It models the terms on the table and shows coverage under each when the sponsor is still choosing.

    Should the study model EV charging and other side businesses?

    Yes, each on its own line, with its own revenue, cost and capital, because a blended "other income" line cannot be tested. Electric vehicle charging is the side business lenders now ask about most.

    Charging economics differ from fuel economics. The station pays for power, demand charges and network fees, and the charger may sit idle for long stretches. Where federal highway money is involved, the National Electric Vehicle Infrastructure standards in 23 CFR Part 680 apply: a DC fast charging station serving a designated alternative fuel corridor must have at least four network-connected ports able to charge four vehicles at once, supply up to 150 kW to each port at the same time, and stay open to the public 24 hours a day, year-round [10]. Those standards raise the capital cost and the power demand of a qualifying site.

    Exhibit 22. Side businesses and how the study tests each

    LineRevenue driverCost and capital the study addsPublic anchor
    EV chargingSessions per port, energy sold, time at the storePower, demand charges, network fees, equipment, utility upgrade79,827 public DC fast ports nationally [11]; corridor standards of 4 ports and 150 kW [10]
    Diesel and truck lanesTruck counts and stopping patternsSeparate tanks, high-flow dispensers, larger lotHours-of-service limits [8]; truck share of traffic [9]
    Truck parkingParking capacity relative to nearby sitesPaving, lighting, securityNational parking shortage findings [25]
    Car washWash type, climate, membership shareWater, chemicals, equipment, maintenanceSee the car wash feasibility study page
    Quick-service restaurantBrand, daypart, drive-through capacityFranchise fees, kitchen, laborFranchise terms and local health rules
    Propane exchange, air and servicesLocal demandSmall capital, small marginSupplier terms

    Source: Alternative Fuels Data Center (station counts by state, public access, November 11, 2026); 23 CFR 680.106; 49 CFR 395.3; Nebraska Department of Transportation; FHWA; FSC method.

    For a charger, the study models utilization by hour and month from local evidence: registered electric vehicles nearby, the corridor's traffic, and the use of the nearest existing chargers. It treats the extra time a charging driver spends at the store as an inside sales effect only where the store is built to capture it. And it states the capital and power cost even if a grant pays part of it, because a grant can carry its own operating conditions.

    Which financing paths fit a gas station?

    Four paths cover most loans: SBA 7(a), SBA 504, USDA Business and Industry guarantees, and conventional bank loans. Net lease buyers and private lenders finance stations too, on their own terms. The right path depends on location, loan size, equity and whether the borrower is buying a going business or building a new one.

    Exhibit 23. Financing paths compared

    FeatureSBA 7(a)SBA 504USDA Business and IndustryConventional
    Maximum$5,000,000 per loan [13]SBA lists a $5.5 million maximum for a 504 loan [72]Fee table covers loans of $5 million to $25 million [73]Bank policy
    Guarantee85% on loans of $150,000 or less; 75% above [13]Bank first lien plus a debenture of no more than 35% of the project for special purpose property [2]85% under $5 million; 80% from $5 million to $25 million (fiscal year 2026) [73]None
    Equity10% for a start-up [2]; 10% on an initial acquisition [2]15% for special purpose property; 20% if also a new business [2]10%, 20% or 25% by business type [5]Bank policy
    Coverage1.15 within 2 years on projections [2]; 1.25 on an initial acquisition [2]1.15 on historical cash flow [2]Lender's credit evaluation, including a written evaluation of the feasibility study [5]Bank policy
    Feasibility studySBA may require one [13]SBA may require one [13]Required above $1,000,000 to a new business [5]Bank policy
    LocationProgram eligibilityProgram eligibilityRural only: outside cities of more than 50,000 and their adjacent urbanized areas [5]None
    TermUp to 25 years, plus construction time for real estate [13]10, 20 and 25-year terms [72]Useful life, not over 40 years [5]Bank policy
    FeesSBA guaranty fees set each fiscal yearCDC and SBA fees3.0% guarantee fee and 0.55% annual retention fee (fiscal year 2026) [73]Bank policy

    Source: 13 CFR Part 120 (revised as of January 1, 2026); SBA SOP 50 10 8.1 and Appendix 15; SBA 504 loans page; 7 CFR Part 5001 (revised as of January 1, 2026); USDA fiscal year 2026 OneRD notice, 91 FR 11272. Confirm current fees and guarantee percentages with the lender, CDC or USDA State Office.

    SBA 7(a)

    The 7(a) loan fits owner-operators who buy or build a single station or a small group. SBA counts a business as a start-up if it has operated for one year or less, and every 7(a) loan to a start-up requires an equity injection of 10% of the project cost [2]. Projections for a start-up or construction project must show coverage of at least 1.15 within 2 years [2], and the projected coverage may not include rental income from the project property [2]. For a station that leases its kitchen to a restaurant brand, that rent helps only the global analysis.

    SBA's guaranty to one borrower and its affiliates is capped at $3,750,000 [13]. The 7(a) term can reach 25 years, and the part used to buy or improve real estate can add the time needed to finish construction [13]. More on SBA files is on the SBA feasibility study consultant page, and the SBA DSCR calculator shows the coverage tests.

    SBA 504

    The 504 loan fits a borrower who wants long-term fixed-rate financing for the land and building. SBA describes it as "long-term, fixed rate financing for major fixed assets that promote business growth and job creation" [72], with 10, 20 and 25-year terms and a rate pegged to an increment above 10-year Treasury issues [72]. Because SBA lists gas stations as limited or special purpose property, the borrower contributes at least 15%, or 20% if the project also involves a new business, and the CDC must address the property type in its credit memorandum [2]. A 504 repayment analysis must address debt service coverage of at least 1.15, calculated on historical cash flow [2]. A new station has no history, so the projections, and the evidence behind them, carry most of the weight in the CDC's credit memorandum.

    USDA Business and Industry

    The B&I guarantee fits rural stations and travel centers, including loans larger than SBA can make. The project must be in a rural area, defined as outside any city or town of more than 50,000 people and the urbanized area next to it [5]. For a new business, the borrower needs 20% balance sheet equity, or 25% if the lender wants the guarantee issued before construction is complete [5]. The loan term follows the useful life of the assets and cannot exceed 40 years [5]. For fiscal year 2026, the guarantee fee is 3.0% and the annual retention fee 0.55%, with an 85% guarantee below $5 million and 80% from $5 million to $25 million [73].

    For loans of $1,000,000 or less, the Agency may still require a study when the lender's analysis does not show technical feasibility or economic viability [5]. The lender must also obtain appraisals for real estate collateral worth more than $250,000 [5]. The USDA feasibility study consultant page covers the program in more detail.

    Conventional bank loans

    Without a federal guarantee, the terms come from each bank's credit policy. The study is built to the strictest test likely to apply: annual and monthly coverage, a margin stress case, a ramp case and a rate case. The Federal Reserve's H.15 release showed a bank prime loan rate of 7.00% in November 2026 [74], a useful reference point for floating-rate stress. A study written to the USDA five-part standard, with SBA's environmental items added, usually serves a bank as well, and the lender requirements matrix compares the tests side by side.

    Exhibit 8

    Coverage moves with margin

    The largest net-lease owner of convenience and gas properties reports tenant rent coverage edging down from 2.6x to 2.5x as fuel margins came off their highs. Its own history shows what happens when operator credit fails.

    2.6x → 2.5x

    Trailing-12-month tenant rent coverage, Q2 and Q3 2025 to Q4 2025 and Q1 2026 (site-level financials covering about 73% to 74% of rent)

    1,191

    Properties; $225M annual base rent; 99.7% occupied; 10.1-year weighted lease term (March 31, 2026)

    ~30%

    Share of rent now from non-convenience assets

    "The master lease lesson." On December 5, 2011, Getty Realty's master-lease tenant filed for Chapter 11. At that point 797 of Getty's 1,149 properties (69%) were under the master lease, which had produced 55% of 2011 revenue. The lease ended April 30, 2012, and the tenant was liquidated. A 2013 creditor settlement of $93 million included $32 million for Getty Realty.

    Source: Getty Realty quarterly results and earnings calls (2025 to 2026) and Form 8-K supplements; Getty Realty FY2011 Form 10-K; CSP Daily News (July 2013).

    What does a gas station acquisition study test?

    It tests whether the price is supported by what the station actually earns, and whether that history will hold under a new owner. SBA's change of ownership rules set the frame. A business valuation is required [2]. For special purpose property, the valuation must allocate separate values to land, building, equipment and intangible assets, and the real property appraiser must have completed at least four going concern appraisals of equivalent special use property within the last 36 months [2].

    Gas stations get one important flexibility. For the purchase of an owner-occupied special purpose property that is already operating, the lender may rely on projections to meet the coverage requirement when the appraised value fully secures the loan, and the projections must meet the required ratio within two years from loan funding [2]. The lender must still calculate the historical coverage and explain the difference between history and projection [2]. A Quality of Earnings report, otherwise required on larger purchases, is not required for these special purpose acquisitions [2]. That puts more weight on the feasibility study: it is the document that explains why the projection departs from the seller's results.

    Exhibit 24. SBA change of ownership rules that shape a station purchase

    ItemRuleWhat the study supplies
    Debt service coverage1.25 for an initial acquisition, on the last year-end or the average of the last two [2]Seller's history rebuilt from statements, tax transcripts and gallon logs
    Equity10% for an initial acquisition [2]Sources and uses tied to the purchase agreement
    Quality of EarningsRequired at a purchase price of $3 million or more, but not for owner-occupied special purpose property [2]A reconciliation of reported and supportable earnings
    Projections in place of historyAllowed for operating special purpose property when the appraisal fully secures the loan; ratio met within two years [2]Projections with a written variance analysis against history
    Business valuationSeparate values for land, building, equipment and intangibles on special purpose property [2]Income by line that the valuer and appraiser can use
    Financial recordsThree most recent year-ends, ranked from audited statements down to tax returns [2]Notes on which records were relied on and why

    Source: U.S. Small Business Administration, SOP 50 10 8.1, Appendix 15, Changes of Ownership.

    For a station purchase, the study adds the items a valuation alone does not cover:

    1. Gallons by grade by month for at least three years, tied to supplier invoices and tank inventory records. Gallons are harder to inflate than dollars.
    2. Margin by month, rebuilt from purchase costs and posted prices, set against the public margin record in Exhibits 11 and 12.
    3. Inside sales by category, tied to sales tax returns where the state requires them.
    4. The tank file: registration, testing, release reports and the state fund status. Under SBA's rules, the dispensing equipment must have been tested by an independent contractor within the preceding twelve months [2].
    5. The supply agreement: term, transfer rights and the supplier's consent. The Petroleum Marketing Practices Act limits when a franchisor may end or refuse to renew a franchise [71], but a sale can still require consent.
    6. Owner labor: if the seller worked 70 hours a week unpaid, the study charges a market wage for that work before it measures coverage.

    How does the study test coverage under stress?

    It moves one variable at a time, then several together, and reports the coverage at each step against the program's threshold. The aim is to show where the project stops covering its debt, and how likely that point is on the public record. The tests below use public anchors rather than arbitrary percentages.

    Exhibit 25. Stress tests and their public anchors

    TestWhat movesPublic anchor for the size of the move
    MarginFuel cents per gallon fall to a level the record has reachedEIA downstream component as low as 27.6 cents in March 2026, against a 2025 average of 55.0 cents [1]
    Diesel marginDiesel cents per gallon fallEIA diesel downstream component as low as 55.5 cents in July 2026, against a 2025 average of 76.9 cents [14]
    VolumeMature gallons held flat or reducedFuel use fell 2.8% from 2023 to 2024 while miles rose [22]
    RampOpening-year volume and inside sales below planThe project's own ramp assumptions, tested at slower rates
    RateFloating rate risesPrime at 7.00% in November 2026 [74]
    Tax or price shockCard fees and working capital rise with priceEIA forecast of $3.89 gasoline in 2026 and $5.25 diesel [16]; state rate changes in Exhibit 21
    EnvironmentalA release, a failed test or a repair delays opening or adds costState fund deductibles in Exhibit 19 [32][42][47]

    Source: EIA; FHWA; Federal Reserve H.15; state fund statutes and rules, as cited in each row. The stress levels a study uses are its assumptions, chosen and stated for each site.

    The order of the results matters to a lender. The study reports coverage for each year from opening through stabilization under the base case, then the year with the lowest coverage under each stress case, then the margin or volume at which coverage falls to the program's threshold. A project that needs both a strong margin and a fast ramp to reach 1.15 is a project that should carry a funded reserve or a smaller loan.

    FSC's Lincoln County truck stop model study shows the method on an illustrative interstate site. Its model assumes a 30-cent diesel margin in the opening year and finds a year-three break-even of 25.7 cents, a cushion the study itself calls the thinnest number in the file. Those are model results, not market facts, but they show why a single base case is never enough.

    Exhibit 10

    What federal auditors keep finding

    No federal audit specific to gas station loans was found, but early-default and guarantee reviews keep identifying the same defects in projection-based credits. Each maps to a test the study runs.

    FindingSourceWhat the study does
    A lender showed 1.29x coverage from two months of unaudited data; audited figures showed −1.56x.USDA OIG Audit 34601-15-Te (September 2003)Tests coverage on a stabilized year, with a margin stress case.
    Equity stated at 14% was under 2%, leading to a $12.1M loss; job projections were overstated by 44%.Same auditTraces equity and supports job counts with a staffing plan.
    Projected net income was about 30% of sales against a 2% industry norm; 95% of projected sales were unverified.SBA OIG Report 18-21 (August 15, 2018)Benchmarks volume, margin and inside sales to public-operator evidence.
    A franchise loan's 1.98x coverage fell to 1.03x when recomputed on actual sales.Same reportRecomputes coverage on verified sales for acquisitions.

    Source: USDA Office of Inspector General, Audit 34601-15-Te; SBA Office of Inspector General, Report 18-21.

    What the public record means for your study

    1. Fuel margin is normalized and stressed. The base case uses the trailing five-year industry average by product, adjusted to the local market. The stress case uses the 2021 level for at least the first 24 months. Margins are shown net of card fees and fuel-selling costs.
    2. Volume and inside sales are benchmarked to a stated format. The study names which public operator or NACS benchmark it uses and why, because chain averages range from about 100,000 to about 236,000 gallons a month.
    3. The ramp is analyzed honestly. Fuel reaches near-mature volume by year two; inside sales mature over 30 to 36 months; year-one coverage is reported as the binding test.
    4. Mature volume is flat to declining. After maturity, same-store gallons are projected flat to down 1% to 3% a year, with competitive entry modeled explicitly.
    5. EVs are handled as a long-run sensitivity, not a headline. The study reports fleet share and local adoption, and tests a slower-volume case over the loan term.
    6. The inside P&L is built by category, with foodservice and tobacco projected for the specific format and market.
    7. The tank record gates the deal. Tank and line testing, release history and state-fund coverage are documented before the projection is relied on.

    After closing

    The study's assumptions also make a monitoring baseline. When the station opens, the lender can compare monthly gallons, cents of margin and inside gross profit against the study's ramp, and see early whether the project is tracking the base case or a stress case. That comparison is far more useful than a covenant test run once a year on audited statements.

    What does it cost to build and operate a gas station?

    The cost depends on the site plan, the tank system and the store, and no federal source publishes a reliable cost per station, so the study prices the plan from bids, quotes and the engineer's estimate and labels anything it cannot support as an assumption. Census data give operating anchors, such as payroll at 4.1% of sales for convenience-store stations in 2022 [7] and operating expenses of 12.2% to 15.2% of sales for gasoline station firms from 2017 to 2022 [18][19].

    Development budget. Land; entitlement, traffic study and permits; site work, paving, stormwater and access; tanks, piping, dispensers, canopy and leak detection; the store building, kitchen and coolers; car wash or charging equipment if planned; point of sale and fuel controls; signs; and contingency, interest during construction, pre-opening costs, opening inventory (fuel and merchandise), working capital and reserves. New tanks and piping must be secondarily contained [12], and a site expected to sell 100,000 gallons of gasoline a month or more must budget for the vapor controls the federal rule requires [52].

    Operating budget. Wages and benefits for each shift, card fees on fuel and inside sales, utilities, repairs and maintenance, tank testing and inspection, insurance, property tax, tank fund fees, franchise or brand fees, food waste and shrink, and a replacement reserve for dispensers, tanks and the roof. The study splits fixed from variable costs, because the fixed share sets the break-even margin.

    Exhibit 26. Operating cost lines and how the study supports them

    Cost lineHow it movesEvidence the study uses
    LaborHours open, shifts, food programStaffing plan, local wage data, Census payroll ratios [7]
    Card feesPump price, including taxes, and inside salesProcessor terms; price forecasts [16]
    Tank complianceTesting cycles, inspections, trainingFederal test and inspection intervals [12]; state fees [35][47]
    Tank fund fees and taxesGallons sold or tank capacityState statutes [36][46][47]
    Air complianceMonthly gasoline throughput tierFederal dispensing facility rule [49]
    Repairs and replacementEquipment ageInstall dates and the tank file [12]
    Insurance and financial responsibilityTank count and coverage needsFederal minimums of $1 million per occurrence [12]

    Source: as cited in each row; budget amounts come from the site's own quotes and records.

    Entitlement and local bans

    Some jurisdictions now restrict new fuel retail outright:

    • Petaluma, California prohibited the creation, expansion, reconstruction and relocation of gas stations in March 2021.
    • Warren, Michigan adopted a moratorium of up to eight months on new gas stations and car washes in May 2026, citing 69 stations in 35 square miles.

    The study documents zoning and any moratorium for the site.

    What does a gas station feasibility study cost, and how long does it take?

    The fee for a gas station, convenience store or travel center study is fixed in a band of $5,500 to $9,000, and the study takes 3 to 6 weeks from a complete document set. The fee is set in the engagement letter before work starts, is never a percentage of the loan, and does not change with the conclusion. The fee estimator gives a quick range for other assets.

    Documents that start the clock:

    • site plan, survey and access plan;
    • format: dispensers, tanks, store size, food program and any car wash or chargers;
    • supply agreement or proposal, with brand terms;
    • development budget or purchase agreement;
    • proposed loan structure and the lender, CDC or USDA State Office;
    • for an operating station, three years of statements and tax returns, monthly gallons by grade, purchase invoices, inside sales by category, and the tank registration, testing and release records;
    • zoning status and any traffic study;
    • the operator's experience in fuel retail.

    What must a gas station feasibility study contain?

    1. A conclusion first: feasible, feasible with stated conditions, or not feasible, with the conditions or changes spelled out.
    2. The project defined: format, dispensers, tanks, store, food program and side businesses.
    3. Program fit: SBA special purpose treatment and equity, or USDA rural eligibility, and the coverage test that applies.
    4. The trade area by customer type: commuters, local residents, through travelers and trucks.
    5. Traffic evidence with count years, directions and truck shares, and the access analysis.
    6. A survey of every competing station, with fueling positions, price posture and store format.
    7. Fuel volume by grade and month through stabilization, with the ramp.
    8. Fuel margin by product: contract terms, a normalized base, a stress case and card fees.
    9. Inside sales by category, with margins and the food program's labor.
    10. Side businesses on separate lines.
    11. An operating budget from quotes and a staffing plan, checked against Census ratios.
    12. A development budget with sources and uses, contingency, interest during construction, working capital and reserves.
    13. The environmental record: Phase I findings, tank compliance, release history and state fund status.
    14. Air and tank compliance tied to the projected gallons.
    15. Coverage by year at the program's threshold, with margin, volume, ramp and rate stress cases.
    16. A management assessment, including who holds the tank operator classes.
    17. Every source and assumption listed, with model outputs labeled as such.

    How the study runs

    1. Scoping: confirm the capital source, program, loan size and the tests that apply.
    2. Document intake: site plan, budget, supply terms, the tank file and, for an operating station, the financial and gallon records.
    3. Field and market research: site visit, access review, competitor and price survey, traffic and demand evidence.
    4. Model: monthly by revenue line through stabilization, with base and stress cases, coverage and reserve sizing.
    5. Review: the draft is checked against the lender's questions and revised only for new facts.
    6. Final report: signed by Sarrah Allen, MAI, with written answers to the lender's follow-up questions. More about the practice is on the about page.

    The study is independent of the sponsor, the supplier and the seller. SBA's own guidance notes that reports "prepared independently of the small business may be beneficial in mitigating any weaknesses identified in the credit analysis" [2], and USDA requires an independent qualified consultant when a study is mandatory [5]. A lender reading a study needs to know that nobody involved gains if the answer is yes.

    State pages

    State rules on tank funds, fuel taxes and permits change the numbers. FSC's state pages cover Arkansas, Colorado, Georgia, Indiana, Kentucky, Louisiana, Massachusetts, Michigan, Mississippi, Missouri, Nevada, New Jersey, New Mexico, New York, Oklahoma, Tennessee and Arizona, along with Texas, Pennsylvania and Illinois linked above. For the profit side line by line, see how profitable is a gas station.

    Download the evidence behind this page's exhibits (CSV, 612 data points with sources)

    Case studies

    Gas station feasibility, applied

    All case studies →

    Gas station engagements

    View all engagements →

    Who signs your study

    FSC Consulting, Inc. is led by Sarrah Allen, MAI, a Member of the Appraisal Institute, who signs every study the practice issues. The certification page names the lead analyst and the senior reviewer, the data used and the independence representations, and both sign. The person who signs answers the credit officer's questions after delivery, as part of the fee.

    Independence on a fuel-retail file

    • No ownership or operating interest in any site evaluated.
    • No referral fees from fuel suppliers, jobbers, brands, equipment vendors or brokers.
    • No advisory work for the operator of any site evaluated within the prior 24 months.
    • Conflicts disclosed in the engagement letter before work begins. The sponsor or lender may terminate at that point with a full retainer refund.
    • No advocacy work.

    Quality

    • Four-pass review.
    • $1 million errors and omissions coverage, with a certificate available before signing.
    • Licensed data: CoStar, IBISWorld, RMA Annual Statement Studies, Esri Business Analyst and Moody's Analytics. More about the practice →

    Building, buying or refinancing a fuel site?

    A 30-minute scoping call, then a fixed-fee engagement letter within 24 hours naming the capital sources the study must satisfy and the analyst and reviewer who will sign it.

    Frequently Asked Questions

    Does SBA require a feasibility study for a gas station loan?
    Not on every loan. SBA "may require" a feasibility study under 13 CFR 120.160 [13], and its SOP lists triggers such as market saturation and a highly specialized project property [2]. Lenders often ask for one on new construction and start-ups.
    Does USDA require a feasibility study for a gas station or travel center?
    Yes, for a Business and Industry guarantee of more than $1,000,000 to a new business, prepared by an independent qualified consultant acceptable to the Agency [5]. Below that, the Agency may still require one.
    Is a gas station special purpose property for SBA?
    Yes. SBA's list of limited or special purpose properties names gas stations [2]. For a 504 loan that means a borrower contribution of at least 15%, or 20% if the project also involves a new business [2].
    How much equity does a new gas station need for an SBA 7(a) loan?
    At least 10% of total project costs for a start-up, meaning a business that has operated for one year or less [2]. Lenders can ask for more.
    What coverage ratio does a gas station acquisition need?
    For an SBA initial acquisition, 1.25 on the last year-end or the average of the last two [2]. For an operating special purpose property fully secured by the appraisal, the lender may rely on projections that reach the ratio within two years [2].
    What environmental review does an SBA gas station loan need?
    A Phase I environmental site assessment by an independent environmental professional, a determination of tank and equipment testing compliance, and any Phase II the professional recommends [2]. The loan cannot be disbursed until full compliance is achieved [2].
    What fuel margin should the study assume?
    One the site's supply terms and records support, with a stress case. EIA's downstream component of the gasoline price averaged 55.0 cents in 2025 but fell to 27.6 cents in March 2026 [1], so a single average is not enough.
    Is EIA's distribution and marketing figure the same as a station's margin?
    No. It covers distribution, marketing and retail dealer costs and profits [23], so it is wider than a station's gross margin. The study uses it to show how margins move, not as the station's own number.
    How are gallons projected for a new station?
    From traffic counts by direction, access, the competitive set, trip purpose and comparable stations, checked against what the dispensers can serve at the peak hour. Mature volume is held flat unless the site has a specific reason to grow.
    Will electric vehicles cut a station's fuel volume?
    Over time they may, but national gasoline use was still 8,935 thousand barrels a day in 2025, near its post-2021 level [20]. The study tests a slower-volume case over the loan term rather than assuming a decline without local evidence.
    Should EV charging be part of the projection?
    Only as its own line, with power cost, demand charges and equipment. Corridor chargers built under federal standards need at least four DC fast ports and up to 150 kW per port [10], which raises cost and power needs.
    How do fuel taxes affect a station's projection?
    Taxes pass through the pump price but raise card fees and working capital, and rate gaps at state lines move volume. The federal tax is 18.4 cents a gallon on gasoline and 24.4 cents on diesel [24], and state rates differ widely.
    What federal tank rules does the study check?
    Secondary containment for tanks and piping installed after April 11, 2016, monthly release detection, three-year spill and sump testing, walkthrough inspections, operator training and financial responsibility [12].
    How much financial responsibility must a station owner carry for its tanks?
    At least $1 million per occurrence for petroleum marketing facilities, and an annual aggregate of $1 million for 1 to 100 tanks or $2 million for 101 or more [12]. Many owners use a state fund.
    Do state tank funds cover the whole cost of a release?
    No. Owners pay a deductible, such as $10,000 in Missouri [42] or $5,000 per tank per occurrence in Pennsylvania [47], and funds have caps and eligibility rules.
    Which air rules depend on the station's gallons?
    EPA's gasoline dispensing facility rule. At 10,000 gallons a month or more, tanks must be loaded by submerged filling; at 100,000 gallons or more, added management practices apply [51][52].
    Can a supplier end a station's fuel supply agreement at will?
    Generally no. The Petroleum Marketing Practices Act limits termination and nonrenewal of a motor fuel franchise to stated grounds with notice [71]. The study still reads the agreement for term, volume minimums and transfer consent.
    How does the study handle a branded versus unbranded station?
    It models the terms on the table: brand fees, image costs, volume commitments and card programs for a branded deal, and rack price exposure for unbranded supply, with coverage shown under each when the choice is open.
    What does the study do with tobacco sales?
    It models them as their own category, with the compliance burden that comes with them. Federal rules bar sales of cigarettes and smokeless tobacco to anyone under 21 and require a photo ID check for buyers under 30 [26].
    Does a truck stop study differ from a convenience store study?
    Yes. A truck stop depends on truck counts, diesel margin, parking and where hours-of-service rules make drivers stop, such as the 30-minute break after 8 hours of driving [8]. Census places truck stops in a separate industry code [6].
    How many gas stations are there in the United States?
    The 2022 Economic Census counted 113,729 gasoline station establishments, 99,620 of them with convenience stores [7].
    How does the study test the projection under stress?
    It lowers the margin, volume and ramp one at a time and together, raises the rate, and reports the coverage in each case and the point at which coverage falls below the program's threshold.
    Can one study serve SBA, USDA and a bank?
    Usually, if it is built to USDA's five-part standard of economic, market, technical, financial and management feasibility [5] and adds SBA's environmental and special purpose items. The program is still chosen at scoping, because each one sets its own tests.
    How much does a gas station feasibility study cost, and how long does it take?
    The fixed fee is $5,500 to $9,000, and the study takes 3 to 6 weeks from a complete document set. The fee is set before work starts and does not depend on the conclusion.
    Will the study say a site is not feasible?
    Yes, when the evidence requires it, and the fee stays the same. A negative conclusion names what would have to change, such as a smaller loan, more equity, a different format or completed tank work.

    Sources

    1. 1.U.S. Energy Information Administration. "Gasoline Pump Components History (Gasoline and Diesel Fuel Update, release of November 10, 2026)." https://www.eia.gov/petroleum/gasdiesel/gaspump_hist.php (accessed 2026-11-11)
    2. 2.U.S. Small Business Administration. "SOP 50 10 8.1, Lender and Development Company Loan Programs, effective October 1, 2026, including Appendix 7 and Appendix 15." https://www.sba.gov/document/sop-50-10-lender-development-company-loan-programs (accessed 2026-11-11)
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    38. 38.Illinois General Assembly. "430 ILCS 15/4, Gasoline Storage Act, Underground Storage Tank Program." https://www.ilga.gov/Documents/legislation/ilcs/documents/043000150K4.htm (accessed 2026-11-11)
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