Gas Station & Convenience Store Feasibility Study Consultants for SBA 7(a) and 504 Loans

What a gas station feasibility study consultant does for an SBA loan

SBA gas station loan performance: the SBA Gas Station Lending Ledger

SBA does not publish loan performance by industry. The firm computes it from SBA’s loan-level FOIA files and publishes the results, so a credit reviewer can test a fuel file against the record of its class. The same method underlies the SBA Feasibility Risk Meter and the SBA 7(a) charge-off rates by industry.

Methodology. Disbursed loans only. Adverse resolution means purchased by SBA, liquidated or charged off. Seasoned means approved FY2010–FY2021, allowing at least four years of performance. The charge-off rate is by count on mature 7(a) cohorts. Source: SBA 7(a) and 504 FOIA loan-level data as of March 31, 2026; firm analysis. Full data methodology.

What the record does and does not say. The seasoned cohort performed through a fuel-margin regime that averaged about 27 cents per gallon from 2014 to 2022. Today’s margins of over 40 cents are a cushion, not a baseline. A class-level loss rate is a reason a well-built fuel file can be approved, not evidence that a given station will perform. Loss given default by collateral type is covered in SBA loan loss severity by property type.

SBA environmental requirements for gas station loans

For a gas station, the environmental file decides eligibility before the financial analysis begins. SBA’s gas station rules (SOP Appendix 7) require a Phase I Environmental Site Assessment for any loan secured by real estate or personal property used to operate a gas station, regardless of loan amount. An Environmental Questionnaire or Records Search with Risk Assessment will not suffice. SOP 50 10 8.1 left these rules unchanged in substance; the only edit replaced references to E-Tran with “the SBA Loan System.”

The study aligns its capital budget with the Phase I findings. Tank age, construction and warranty are carried as capital-expenditure risk and priced from contractor quotes, so the lender, appraiser and environmental professional work from the same facts. Wider scope is set out in environmental due diligence for SBA feasibility studies and the site and regulatory assessment.

When an SBA lender orders a gas station feasibility study

No SBA rule makes a feasibility study mandatory for a gas station loan. 13 CFR 120.160(b) provides only that “SBA may require professional appraisals of the applicant’s and principals’ assets, a survey, or a feasibility study.” The decision rests with SBA, the lender or the CDC, and lenders commonly order a study in four situations, consistent with when SBA requires a feasibility study.

• A seller note counts toward equity only if subordinated and on full standby for the life of the 7(a) loan.
• Seller standby debt, other standby debt and outside investor equity combined cannot exceed 50 percent of the required injection.
• A non-standby seller note is amortized over no more than ten years for coverage.
• The goodwill portion is limited to a ten-year amortization.
• Seller consultancy is allowed for up to 24 months.
• A reported internal-valuation carve-out at $350,000 or less is confirmed in the September 25, 2026 technical update text before it is relied on.

What this means for a station acquisition. The study reconciles the seller’s gallon reports, state fuel-tax filings, inventory records and point-of-sale data to the tax returns the cash proof relies on. It separates fuel, inside, car wash and foodservice gross profit, and normalizes margins that reflect an unusual year. It then identifies the loan amount the historical earnings support. Fuel-tax and gallon reconciliation is analyst best practice rather than a stated SBA rule; the cash proof is the SBA mechanism. Equity structure is covered in SBA equity injection sources and seller notes in SBA acquisitions.

How to choose a gas station feasibility study consultant

A lender reads a gas station feasibility study to decide whether it can rely on it. Seven tests separate a study that survives credit committee and SBA review from one that comes back with questions. They apply to any consultant, including this firm, and expand on the general guide to choosing a feasibility consultant.

1. 1. Revenue pillars modeled separately.

   Fuel, inside sales by category, car wash and foodservice each have their own volume, margin and competitive drivers. A single blended revenue line is a red flag.

2. 2. Fuel volume triangulated.

   Traffic capture, comparable stations, trade-area market share and fueling-position throughput are cross-checked. Where they diverge, the most conservative estimate carries the base case.

3. 3. Margins stressed against history.

   The base case sits below the 2025 margin peak. Coverage is reported at the 2014–2022 average and the pre-2020 range, and the study states the break-even margin.

4. 4. Every deduction carried.

   Card fees (including fees on taxes collected), environmental compliance, tank testing and tank replacement are carried explicitly. The actual supply agreement, branded or unbranded, is modeled with its rebates, minimums and repayment terms.

5. 5. The environmental record aligned with Appendix 7.

   Phase I, tank-testing documentation, any Phase II, indemnity waiver and report age are checked against the study’s assumptions.

6. 6. Current SBA rule fluency.

   SOP 50 10 8.1 acquisition tests and the quality-of-earnings cash proof; 504 contribution rules; the Franchise Directory for branded fuel and foodservice; and the legal-gambling revenue test where lottery or gaming revenue is material.

7. 7. Independence, a named signatory, and willingness to say no.

   The study is addressed to the lender. One accountable professional signs, with the analyst and reviewer named. The published record includes findings of not feasible, or feasible only with conditions.

Who prepares your gas station feasibility study

David Jones, MAI, CCIM, Principal of SBA Feasibility Study LLC, is the author and signatory of every study the firm issues. Over his career he has completed more than 4,300 feasibility studies across fuel and convenience, car washes, hotels, RV parks, self-storage, multifamily and healthcare. The firm’s studies have been accepted by 534 SBA 7(a) lenders and 107 Certified Development Companies across 50 states.

Every study is signed by the firm, with the analyst and reviewer identified. There is no white-labelling and no unsigned draft that later becomes the basis for a credit decision. The firm is not a lender, broker, fuel supplier, jobber, franchisor or station operator. The approach follows the firm’s three-pillar methodology.

Fuel and convenience engagement record

Determinations are the firm’s independent findings. Credit and eligibility decisions rest with the lender, the CDC and SBA. Related work: the Denver auto repair and Miami laundromat case studies, and the full engagement library.

What a gas station feasibility study consultant analyzes

Gas stations, with or without a convenience store, are named special-purpose property examples. SBA SOP 50 10 8.1 governs loans that receive an SBA loan number on or after October 1, 2026 (Information Notice 5000-882227, September 25, 2026). Lenders and CDCs commonly order an independent feasibility study for gas station start-ups, ground-up builds, major renovations and most acquisitions, because the special-purpose designation, the going-concern appraisal and the environmental exposure all raise the bar for proving that projected cash flow is real. Converting a gas station to a non-fuel use requires removing USTs (closure cost quoted for the site), remediating any contamination, and demolishing or repurposing fixed infrastructure.

The four revenue pillars

A gas station feasibility study must model each revenue stream independently. Aggregating all revenue into a single line item is a red flag that signals a low-quality study. Each pillar has different margins, different competitive drivers, and different growth trajectories.

In 2025, fuel produced 65.0% of U.S. convenience industry sales but only 38.8% of gross profit, while merchandise and foodservice produced 35.0% of store sales and 57.4% of gross profit (NACS). The margin disparity between fuel and non-fuel revenue is the central insight of gas station economics. Fuel drives traffic but generates thin margins. Inside sales, car wash, and QSR generate substantially higher margins on the traffic that fuel attracts. A feasibility study that projects strong fuel volume but weak inside sales will produce a DSCR that understates the station’s true earnings potential. Conversely, a study that assumes aggressive c-store revenue without validating the traffic base will overstate viability.

Fuel volume projection methodology

Fuel volume is the anchor of the entire financial model. The methodology builds the projection from four independent methods that are cross-referenced against each other, under the firm’s market analysis methodology.

Traffic-based projection. We start with the daily traffic count on the road(s) fronting the site, sourced from state DOT or municipal traffic data. We apply a capture rate (the firm’s planning range is 1% to 4% of daily traffic for a well-positioned station; no published standard exists) to estimate daily fuel customers, then multiply by average fill-up volume (from comparable-site transaction data, adjusted for the site’s mix of commuter, local and commercial traffic). This produces a bottom-up daily gallon estimate that is grounded in observable traffic data rather than operator assumptions. Research on retail gasoline demand models station demand over drivers’ commuting paths rather than home location alone (Houde, American Economic Review, 2012), which is why we model traffic flows, not residential radius alone.

Comparable station benchmarking. We benchmark the projected volume against actual performance of comparable stations in the market. OPIS (Oil Price Information Service) provides rack and retail pricing and margin history for the market, and site-level volume data from providers such as Kalibrate and state fuel-tax records is used where available. For branded stations, franchisor disclosure documents may include average unit volumes. For unbranded stations, we rely on industry benchmarks from NACS, which publishes annual surveys reporting median fuel volumes by region and store format.

Market share analysis. We calculate the total fuel demand within the trade area (using population, vehicle registrations, FHWA state motor-fuel statistics, and EIA consumption data) and estimate the subject station’s capture of that total demand based on its competitive position: location quality, brand affiliation, pricing strategy, and amenity package relative to competitors. This is a fair-share analysis: the subject’s capture is set above or below its pro-rata share of the trade area’s fueling positions according to how its location, brand, price, and amenities compare.

Gravity model and fueling-position throughput. For new construction and rebrands, we add a gravity-model check that allocates corridor demand among competing stations by relative attractiveness and travel time, and we test cannibalization of the operator’s own nearby sites. Annual gallons are then translated into throughput per fueling position per month and compared with comparable stations. A projection implying throughput well above local comparables is flagged and reduced before it reaches the DSCR.

When the methods converge on a similar volume range, confidence in the projection is high. When they diverge, the feasibility study documents the discrepancy and uses the most conservative estimate for the base case DSCR calculation.

Fuel margin regimes, and the break-even margin

Fuel margins have moved to a new regime. OPIS data show annual rack-to-retail margins of about 22 to 24 cents per gallon in 2014–2019 and an average of 26.94 cents from 2014 to 2022. NACS reports that 2025 margins averaged over 40 cents. A loan sized on today’s margin without a reversion test is a bet that the new regime holds. The study states the margin at which coverage falls to 1.0x and to the lender’s standard, and reports coverage at historical margins. In the illustrative case below, a station covering 1.66x at a 40-cent margin needs 28.2 cents just to meet debt service, above the 26.94-cent average of 2014–2022. Coverage thresholds are set out in the DSCR guide for SBA loans.

C-store revenue analysis

Convenience store revenue is projected using NACS benchmark data, which provides category-level sales-per-square-foot metrics for stores of comparable size and format. The key variables are store square footage (most SBA-financed c-stores range from 1,500 to 4,000 SF), product category mix, and the percentage of fuel customers who enter the store (the “conversion rate”). We calibrate the site-specific inside conversion rate to store format, pump-to-door layout, and competition.

We model c-store revenue by product category: foodservice (the largest category at 28.5% of U.S. in-store sales in 2025, with prepared food at 73.9% of it), packaged beverages (18.7%), cigarettes and other tobacco and nicotine products, beer and wine (where permitted), snacks and candy, and general merchandise. Each category has different margin profiles, regulatory considerations (age-restricted products, lottery), and competitive vulnerability. A station competing with a Dollar General within a quarter mile will see different general merchandise performance than one with no nearby competition. The convenience store feasibility study page covers stores without fuel.

EV charging: the long-term demand risk

Any gas station feasibility study prepared in 2025 or 2026 that does not address electric vehicle adoption is incomplete. EVs were 8.1% of U.S. new vehicle sales in 2024 and 7.8% in 2025. Share peaked at 10.5 percent in Q3 2025 (later restated as 10.6 percent), then fell to 5.8% after the federal EV tax credit expired on September 30, 2025, and has run about 5.8% to 6.4% through the first three quarters of 2026 (about 6.4 percent in Q3 2026, 262,649 units, down 39.5 percent year over year), while hybrids reached a record 16.3 percent (Cox Automotive / Kelley Blue Book). Adoption varies sharply by state, so the study uses the subject state’s registration data.

Our studies address EV impact through two lenses. First, we model the near-term effect on fuel volume over the projection period (3 to 5 years), which for most markets remains modest. EIA’s October 2026 Short-Term Energy Outlook describes declining motor gasoline consumption and forecasts retail gasoline at $3.91 per gallon in 2026 and $3.56 in 2027, against $3.10 in 2025. EV adoption accelerates this trend in select markets. Second, we assess the long-term strategic risk to the property’s residual value and the business model’s sustainability beyond the loan term. For 504 loans with 20 or 25-year debentures, this long-term perspective is directly relevant.

We also evaluate whether the subject station is positioned to integrate EV charging as a complementary revenue stream. Stations with adequate electrical infrastructure, sufficient parking, and proximity to highway corridors may benefit from the transition rather than being disrupted by it. This analysis is increasingly important to forward-looking lenders.

Financial modeling: fuel margins, inside sales and DSCR

The financial model integrates all four revenue streams and projects them forward over a 3 to 5 year horizon, following the financial projection and DSCR methodology. Key modeling considerations specific to gas stations:

Fuel margin volatility. Rack-to-retail margins fluctuate with crude oil prices, refinery capacity, seasonal demand, and competitive pricing pressure. We model margins using historical OPIS data for the specific region and stress-test the DSCR against margin compression scenarios. OPIS data show annual rack-to-retail margins of about 22 to 24 cents per gallon in 2014–2019 and an average of 26.94 cents from 2014 to 2022; NACS reports that 2025 margins averaged over 40 cents. We underwrite the base case below recent highs and stress it toward the lower end of that range.

Credit card processing fees. Card fees typically consume $0.08 to $0.12 per gallon of the gross fuel margin (the firm’s planning range). With 82 percent of industry sales dollars transacted on a card in 2025 and card fees reaching a record $21.3 billion, including $4.6 billion charged on taxes collected (NACS), and NACS estimating 8.4 cents per gallon in 2023, the net margin after card fees is the relevant figure for DSCR calculation. Studies that use gross margins without deducting card fees overstate profitability.

Operating expense benchmarks. Gas station operating expenses include labor (typically the largest single expense), rent/mortgage, utilities, insurance (higher than standard retail due to environmental liability), maintenance, inventory shrinkage, and environmental compliance costs. We benchmark each category against NACS survey data and adjust for local wage rates and utility costs, under the operating expense rationalization standard.

Environmental compliance costs. UST monitoring, leak detection testing, spill prevention/countermeasure plans, and periodic tank integrity testing represent ongoing regulatory costs that are unique to fuel retail. These are not optional and must be included in the operating expense model.

Sensitivity and stress testing. Every study includes a DSCR sensitivity matrix that flexes the variables that actually break gas station loans: fuel margin per gallon, gallon volume, inside sales, and payroll. A typical matrix tests margin at the base case, minus 5 cents, and minus 10 cents; volume at minus 10% and minus 20%; and inside sales at minus 10%, alone and combined. The base case must clear the lender’s coverage threshold, and the combined downside shows how much cushion remains. For changes of ownership under SOP 50 10 8.1, we also reconcile our normalized earnings to the historical figures the lender will use for coverage.

Branded versus unbranded economics. Branded supply agreements bring image funding, rebates, and card programs, but also volume minimums, brand standards, and repayment of unamortized incentives if the dealer debrands early. Unbranded supply typically allows wider margins with less traffic support. The study models the actual supply terms and flags covenants in jobber, brand, or franchise agreements that could conflict with SBA eligibility. Brand-level context appears in the best SBA franchises for gas stations and car washes.

Market radius analysis

Gas station trade areas are defined differently than most commercial properties. Rather than concentric radius circles, the trade area follows traffic corridors. A station on a major highway interchange draws from a corridor that may extend 5 to 10 miles in each direction along the highway but only 0.5 miles perpendicular to it. A neighborhood station in a suburban grid draws from a tighter radius of 1 to 3 miles but captures a higher percentage of local residents.

We inventory every competing fuel station within the defined trade area, documenting brand affiliation, fuel pricing (observed at the pump and cross-referenced against GasBuddy data), store format and size, car wash presence, QSR components, and observable condition. Planned stations in the permitting pipeline are identified through local planning department records. This competitive inventory directly informs the capture rate assumptions in the fuel volume model.

Gas station and convenience store feasibility by format

• Single-site fuel and convenience store. The core SBA format. The credit turns on corridor position, fueling positions, inside conversion and the supply agreement, and it competes with large-format chains that price fuel to drive inside sales. The Buda fuel station and c-store case study is an example.
• New-to-industry and large-format stores. Larger footprints and foodservice programs raise both project cost and inside-sales dependence, and the study tests whether the corridor supports the format.
• Convenience store without fuel: the convenience store feasibility study. Inside sales carry the whole credit, so category mix, basket and local competition from dollar and grocery formats decide it.
• Station with car wash. The wash is modeled as a separate profit center with its own capture and membership economics (see the car wash feasibility study). Environmental review follows the fuel-station rules.
• Station with a franchised foodservice brand. The brand must be on the SBA Franchise Directory with the required certification, and its fees, daypart sales and labor are modeled separately, following the franchise feasibility study approach.
• Rebrands and conversions. The study models the incoming supply agreement’s image funding, rebates, volume minimums and repayment of unamortized incentives on debranding, and flags covenants that conflict with SBA eligibility.
• Acquisitions. Tested on the seller’s history under SOP 50 10 8.1 (Exhibit 3). See also acquisition versus start-up studies.

2025–2026 market evidence for fuel and convenience credits

Every figure carries its source and period. The firm updates this section when a primary release changes the answer. Longer-form analysis appears in the US gas station market report 2026 and the analysis of what gas stations earn.

Gas station feasibility study vs market study vs appraisal

See also feasibility study vs appraisal vs market study and feasibility study vs business plan.

The standards behind a gas station feasibility study and appraisal

An SBA gas station file is reviewed against four layers of standards. A credible feasibility study is written so each reviewer, from the credit officer to the appraiser to the SBA, can trace its conclusions back to them.

SOP 50 10 8.1 and 13 CFR Part 120. The SOP sets appraiser qualifications for special-purpose property, requires the land, building, equipment, and intangible allocation, and makes Appendix 7 (Requirements Pertaining to Gas Station Loans) part of every fuel file. Version 8.1 also places every change of ownership into one of four Appendix 15 categories (initial acquisition, business expansion, owner buyout, ESOP or cooperative), requires a quality of earnings report for initial acquisitions and business expansions priced at $3 million or more, and sets acquisition coverage at 1.25:1 on the last fiscal year or a two-year average (1.15:1 for business expansions), with projections not permitted, and requires the quality-of-earnings report to include a cash proof reconciling bank statements to tax returns. That makes a rigorous, independently tested view of the station’s actual performance more important than ever.

USPAP. The Uniform Standards of Professional Appraisal Practice (2024 edition, which has no fixed expiration date) govern the appraisal. Standards 1 and 2 control how value is developed and reported, and Standards Rule 1-4(g) requires the appraiser to analyze personal property, trade fixtures, and intangible items when they are included in the appraisal, which is always the case for an operating station. Our studies document assumptions, sources, and stabilized income in a form a USPAP appraiser can rely on.

Interagency Appraisal and Evaluation Guidelines. For federally regulated lenders, value opinions such as going concern value or value in use may not be used as market value. An appraisal may report them separately, so long as they are clearly identified and disclosed. Market value of the real property, as-is and, where relevant, prospective as-complete and as-stabilized, must stand on its own. This is why the going-concern value of a station is always broken into components, and why the feasibility study’s income must reconcile with that allocation.

Appraisal Institute definitions. The profession distinguishes a market analysis (the demand for and supply of a property type), a marketability study (how a specific property is expected to perform in a specific market), and a feasibility analysis (a study of the cost-benefit relationship of an economic endeavor). An SBA gas station study needs all three, and it supplies the financially feasible test in the appraiser’s highest and best use analysis.

How gas stations are valued: appraisal methodology and theory

The feasibility study and the appraisal answer different questions, but in an SBA file they have to agree. The study tests whether the project can generate its projected cash flow; the appraisal converts that cash flow into value, allocates it, and sets the collateral position.

Value definitions that matter for SBA. Market value as defined by the federal banking agencies (the most probable price in a competitive and open market); market value of the going concern (real property, FF&E, and business intangibles together); and the as-is, prospective as-complete, and prospective as-stabilized dates of value. For new construction, the study’s ramp-up schedule drives the as-stabilized date. For an acquisition, the as-is going-concern value is the anchor, and the property interest (fee simple, leased fee, or leasehold) changes the comparables and the multiples entirely.

Income approach. The primary approach for an operating station. Stabilized net operating income is built from separately modeled fuel gross profit, inside gross profit, and ancillary income, less operating expenses, a market management fee, and a reserve for replacing tanks, dispensers, and equipment. Capitalization rates are derived by market extraction from comparable going-concern sales and checked with the band-of-investment method (Ro = M × Rm + (1 − M) × Re) and the debt coverage formula (Ro = DCR × M × Rm). A common error is applying net-lease c-store cap rates to an owner-operated station: The Boulder Group’s Q3 2026 asking cap rates were 4.80 to 5.15 percent for 7-Eleven 15-year leases and 4.90 to 5.20 percent for Wawa (Circle K was 5.35 to 5.65 percent in Q1 2026), while the overall net-lease market reached a decade-high 6.92 percent, but those rates price a corporate lease guarantee, not operating risk. New construction and repositioned sites use a discounted cash flow that captures the ramp-up to stabilization.

Sales comparison approach. Comparable sales are analyzed on several units of comparison at once: price per annual gallon, price per fueling position, gross profit multiplier, price per square foot of store, and EBITDA multiple. Each has limits; price per pump, for example, ignores throughput and inside sales. Adjustments address fuel volume, brand and supply agreement, tank age and construction (single-wall versus double-wall), environmental status, corner position and access, lot size, car wash and food service components, and property rights conveyed. Business-only leasehold sales trade at a fraction of fee-simple multiples, so mixing them without adjustment distorts value.

Cost approach. Land value plus the replacement cost new of the store, canopy, tanks, piping, and dispensers, less physical deterioration, functional obsolescence (undersized stores, too few fueling positions, poor layout), and external obsolescence (oversupply, road realignments, falling demand). It carries most weight for new construction and serves as a ceiling test. When the income-based value falls below depreciated cost, the gap measures external obsolescence, and the study’s competitive inventory is the evidence for it.

Reconciliation and allocation. The appraiser reconciles the approaches into a going-concern value and allocates it among land, building and site improvements, FF&E, and intangible assets such as business enterprise value and brand affiliation. Accepted allocation techniques include the residual method, management and franchise fee methods, and contributory asset charges (see ASA course RP401, which addresses fueling stations specifically, and The Appraisal Foundation’s VFR Valuation Advisory 1). Practice differs on whether USTs and dispensers are real property fixtures or equipment, so the appraisal should state its treatment explicitly. The allocation directly shapes the SBA loan: real estate supports up to a 25-year term while equipment and goodwill carry shorter terms, and under SOP 50 10 8.1 change-of-ownership loans use a blended weighted-average maturity. Our studies report stabilized income in the format the appraiser allocates, so the two documents tie out.

Highest and best use. Every appraisal tests highest and best use as vacant and as improved: legally permissible, physically possible, financially feasible, and maximally productive. For a fuel site, the as-improved test weighs continued operation against conversion, net of tank removal and any remediation. The feasibility study is the evidence for the financially feasible test, which is why lenders read the two reports together.

SBA eligibility and structure checklist for gas station loans

Compare program structures in the SBA 7(a) vs 504 feasibility guide, the CDC guide for 504 projects and the October 2026 SBA feasibility monitor.

Engaging the firm: process, fee and timeline

Gas station feasibility studies range from $4,900 to $12,000, fixed before work begins, depending on the complexity of the station format (single-purpose fuel vs multi-concept with car wash and QSR), the density of the competitive environment, and data availability in the market. The fee does not depend on the conclusion or on whether the loan closes. Multi-concept stations with three or four revenue streams require more detailed modeling and push toward the upper end of the range. Delivery runs 7 to 12 business days from a complete data response; rush delivery in 5 to 7 business days is available at a premium. For pricing across all property types, see the cost and timeline guide and what to expect in the report.

Data request checklist

• Site address and parcel; traffic counts if held; site plan with fueling positions, store square footage, car wash and foodservice.
• Supply agreement or brand proposal (incentives, rebates, minimums, repayment terms).
• Development budget or purchase contract.
• Proposed loan structure, SBA program, and lender or CDC.
• For existing stations:
  • three years of P&L and tax returns;
  • monthly gallon reports by grade;
  • state fuel-tax filings;
  • point-of-sale inside sales by category;
  • card-processing statements;
  • lottery and gaming commission statements.
• Tank registration, age, construction, testing records and any Phase I or Phase II.
• Any appraisal already in the file.
• Sponsor’s fuel retail experience.

Gas station feasibility study FAQ

More answers: SBA feasibility study FAQ and the glossary. Background: inside a gas station feasibility study and SBA loan default rates by industry.

How this page is verified

Program rules are checked against 13 CFR Parts 120 and 121, 40 CFR Part 280 and SBA SOP 50 10 8 and 8.1. Every market figure names its source and date. Last verified October 26, 2026.

Sources

• eCFR, 13 CFR 120.110, 120.151, 120.160, 120.212 and 120.910 (current) — https://www.ecfr.gov/current/title-13/chapter-I/part-120
• eCFR, 40 CFR Part 280 and 280.93, underground storage tanks — https://www.ecfr.gov/current/title-40/part-280
• U.S. Small Business Administration, Information Notices 5000-1340, 5000-880695 (August 14, 2026) and 5000-882227 (September 25, 2026) — https://www.sba.gov/document/information-notice
• U.S. Small Business Administration, Policy Notice 5000-879058; SBA Franchise Directory — https://www.sba.gov
• Federal Register, 91 FR 53741, proposed size standards (August 20, 2026) — https://www.federalregister.gov
• NAGGL, SOP 50 10 8.1 summaries (2026) — https://www.naggl.org
• A3 Environmental, SOP 50 10 8.1 environmental note (September 8, 2026)
• Partner ESI, SBA environmental policy summaries — https://www.partneresi.com
• Starfield & Smith, SBA gas station requirements (June 2024) — https://www.starfieldsmith.com
• Sundance FG; Cantrell Firm; Jaken Finance, SOP 50 10 8.1 commentary (August–September 2026)
• NACS, State of the Industry (April 15, 2026); NACS Magazine (June 2026); NACS / NIQ TDLinx store count (January 26, 2026); NACS, “Who Makes Money Selling Gas?” — https://www.convenience.org
• OPIS, rack-to-retail margin history — https://www.opisnet.com
• U.S. Energy Information Administration, Short-Term Energy Outlook (October 6, 2026) — https://www.eia.gov/outlooks/steo
• California Energy Commission, branded and unbranded price analysis using OPIS (October 2025) — https://www.energy.ca.gov
• Cox Automotive / Kelley Blue Book, EV and hybrid sales reports (January 13, 2026 to October 13, 2026) — https://www.coxautoinc.com
• The Boulder Group, Tenant Profiles and Net Lease Reports (March, September and October 2026) — https://www.bouldergroup.com
• CSP; C-Store Dive; NACS Magazine Top 100 (March 2026)
• Vicente LLP; Foley Hoag, hemp redefinition updates (September–October 2026)
• Merchants Payments Coalition, citing The Nilson Report (March 18, 2026) — https://merchantspaymentscoalition.com
• Houde, “Spatial Differentiation and Vertical Mergers in Retail Markets for Gasoline,” American Economic Review (2012)
• U.S. Small Business Administration, 7(a) and 504 FOIA loan-level data (as of March 31, 2026) — https://data.sba.gov

Changelog