Texas Feasibility Studies

The population figure most studies quote is still impressive: 31,709,821 Texans on July 1, 2025, up from an estimates base of 29,149,498 in April 2020 ¹. The one-year gain of 391,243 was the largest of any state, but in percentage terms Texas slipped from first to fourth ¹. The reason is migration. Net international migration into Texas fell to 167,475, a drop of 48% from 319,569 the year before, as the national figure fell by more than half ². The domestic stream, which carried much of the 2021 to 2023 absorption story, came in at 67,299, behind North Carolina, and against 222,154 in 2022 ³. Texas 2036, reading the state demographer's figures, describes about 184 net domestic arrivals a day, against more than 500 a day two years earlier ⁴.

What remains is natural increase and jobs. Texas recorded 390,203 births and 232,492 deaths in the year ³; the source's own net figure does not match that subtraction, so we cite the components rather than the net. Employment is the stronger story. Total nonfarm jobs reached 14,469,300 in August 2026 ⁶, and the twelve-month gain of 159,400, or 1.1%, was the largest of any state and 0.7 points ahead of the national rate ⁵. The August month alone added 5,600 jobs, led by leisure and hospitality at 4,900 and professional and business services at 4,500 ⁸. Two readings temper that. Unemployment sat at 4.4% against 4.1% nationally, and manufacturing employment of 982,800 was slightly below a year earlier ⁷.

Two federal series describe the households behind that demand. The American Community Survey's 2020 to 2024 five-year estimates put the median gross rent in Texas at $1,403 a month and the median value of an owner-occupied home at $283,800 ¹²⁴. The Bureau of Economic Analysis counted $2,184,833.3 million of personal income in Texas in 2024, or $69,823 per resident ¹²⁵. Rent and home value bound what a multifamily or build-to-rent pro forma can charge, and income per head is the base a retail or service trade area draws on. Rent and home value are statewide medians and income per resident a statewide average, each taken across metros that sit far apart.

What this means for a Texas demand model

A study written in 2023 could reasonably project household formation from the in-migration of the prior two years. A study written now cannot. Any model that converts population growth into demand, whether apartments, storage units, retail square feet, school seats or rooftops for a convenience store, should be re-based on the Vintage 2025 numbers and should say which vintage it used. Where a metro's growth still leans on in-migration, the study should run a case at the lower migration rate and show the loan still works. Where growth leans on jobs, the study should name the employers and the sectors, because a jobs-led market behaves differently in a downturn from a retirement-led or migration-led one.

The slowdown is also uneven. The large metros in the east of the state still led the nation in numeric growth, while a border metro posted a decline in the same Census release. That is one more reason the useful unit of analysis is the metro, and below it the trade area, not the state.

The governing text is SOP 50 10 8.1 with Technical Policy Updates, effective October 1, 2026 ⁵⁷. It did not create a feasibility study mandate. The regulation is unchanged: 13 CFR 120.160(b): SBA may require professional appraisals, a survey, or a feasibility study ⁵⁶. Lenders ask for one when they cannot underwrite repayment from history, which in Texas describes a large share of the pipeline: ground-up gas stations and travel centers on new interchanges, express car washes, limited-service hotels and the other special purpose properties SBA lists. Our note on the SBA feasibility study myth sets out the regulation in full, and the SOP 50 10 8.1 note covers what changed this month.

Four rules decide most Texas files. A start-up borrowing under 7(a) must inject 10% of total project cost, and its projections must reach 1.15x coverage within two years. An acquisition is a change of ownership: coverage of 1.25x measured on the seller's historical cash flow, which a study cannot manufacture from projections. Under 504, a new business or a special purpose property needs 15% and a new business in a special purpose property needs 20%, which catches most new Texas car washes, hotels and fuel stations. The 504 debenture is capped at $5 million, and a borrower who takes 7(a) first and 504 second can now reach $10 million combined.

One FY2027 fee rule reaches rural Texas directly. The upfront 7(a) guaranty fee is 0% on loans of $700,000 or less to businesses in a rural area, defined as a county that the U.S. Census Bureau has defined as at least 30 percent rural ⁵⁸. A study for a small project in a rural county should state the county's Census rural share, because the waiver changes the sources and uses. Our Texas cases test these rules on real towns: the Seguin express car wash and the Terrell truck stop both carry the 20% tier, and the Weatherford dealership shows what happens when a proposal runs into the debenture limit.

For senior housing and multifamily in Texas, the agency programs set the bar the study has to clear, and they changed in both directions over the last two years. HUD made refinancing existing Section 232 facilities faster: the Express Lane accepts low-leverage deals with strong trailing coverage and has cut processing from months to weeks ²², and Section 232 firm commitments doubled to a record $8.1 billion in FY2025 ²⁴. New construction did not get the same treatment. In HUD's draft Section 232 valuation chapter the market study sits inside the appraisal, written by the same person, ordered and paid for by the lender, with a requirement to map every competing facility in the primary market area, which the draft expects to supply 60% to 80% of demand ⁶⁴⁶⁵. For multifamily under the MAP Guide, the market study ages out 120 days after the pre-application and 180 days after the firm commitment, and the market analyst must analyze rents independently of the appraiser ⁶⁴⁶⁵.

The credit record explains why reviewers are careful. HUD's Inspector General found 167 of 3,670 Section 232 borrowers in default in June 2024, with more than $1.1 billion of unpaid principal, while the office overseeing those loans shrank from 61 to 38 staff ²⁵. Fannie Mae's seniors housing book carried a serious delinquency rate of 4.09% against 0.63% for its whole multifamily book ²⁸. A Texas senior housing study therefore has to show stabilized occupancy and rents from named competitors, not from a national benchmark. Our Boerne assisted living and memory care case works through a Section 232 new construction file in Kendall County.

On the conventional side, the Federal Housing Finance Agency raised each Enterprise's 2026 multifamily purchase cap to $88 billion ²⁶, so agency appetite for Texas apartments is not the constraint. The constraint is the market: a lender sizing to 1.25x or more on stabilized income still needs a supportable rent and absorption schedule for the specific submarket, which is where the Texas metro pages begin.

The pattern across asset classes is that Texas leaves supply to the market and to local government. The state sets no quota on liquor licenses; availability follows local wet and dry elections ³³. It has not preempted city short-term rental rules, and the online-marketplace bill of the 2025 session cleared a House committee without a recorded final outcome ³⁵. It no longer reimburses petroleum storage tank cleanups: the fund stopped paying owners on September 1, 2012 and now finances only state-led cleanups, so every fuel retailer in Texas carries federal financial responsibility through private coverage ³⁴. For a gas station or travel center study that means the environmental section prices insurance and a Phase I, not a state backstop; our gas station and convenience store page covers the full document list.

Senior housing licensing is the one area where state rules shape the product directly. Texas licenses assisted living as Type A, for residents who can evacuate on their own, or Type B, for residents who may need help or night attendance, and it stopped issuing Type C ²⁹. A memory care unit marketed for Alzheimer's care needs certification and a Type B license ³⁰. The license type sets staffing, and staffing sets the operating budget, so a study that prices a Type A budget for a building that will admit Type B residents understates expenses. The assisted living and memory care page explains the staffing test.

For lodging, the tax structure matters to the revenue line. The state tax is 6% on rooms of $15 a night or more, cities may generally add up to 7%, and venue taxes up to 2% apply in some places, with a combined cap that is generally 17% ³⁶³⁷. Occupancy tax receipts are also one of the few public demand series for a Texas hotel study, because cities report them; our hotel page and the Bastrop hotel case use them that way.

Some rules a lender will ask about are not in any source we could date. The scope of Texas Certificate of Need review, campground and RV park licensing, car wash water recycling rules, the sales tax treatment of construction materials and the primary text of child-care center ratios were all not found in the research behind this page, so a study should confirm each one with the agency for the specific project rather than rely on a summary.

The numbers in the table are not a forecast of what will be built. They are requests. ERCOT reported about 474 gigawatts of large loads seeking interconnection in June 2026, roughly nine-tenths of them data centers, against a queue of 63 gigawatts at the end of 2024 ⁴⁶⁴⁸. Only about 205 gigawatts were eligible for its Batch Zero study, and 315 projects had no qualifying study at all ⁴⁶. The generation side is crowded too, with 2,008 requests totaling 453,562 megawatts, led by storage and solar ⁴⁷.

The state's response came in steps. Senate Bill 6, signed in June 2025, set interconnection standards for loads of 75 megawatts or more, and the Public Utility Commission's draft rule of March 2026 proposed a non-refundable fee of $50,000 per megawatt, with a final rule due by year-end ⁴⁹. On August 3, 2026 the Governor directed an audit and paused data center interconnection; ERCOT then missed its Batch Zero deadline ⁵⁰. On September 21 the environmental agency paused air and water permits for infrastructure serving data centers while a survey of more than 400 facilities runs to December ⁵¹, and the state water board was told to compel water-use reporting by major users ⁵².

Why it reaches other projects

A hotel, a distribution building or an assisted living community does not need a 75-megawatt interconnection. It does need its utility to commit to serve it, sometimes with a new feeder or substation, and in the same territories where data centers queued for capacity, those commitments now come later and with more conditions. Water is the same. Where a city or water district is being asked to account for large users, a new connection for a car wash, a meat processing plant or a 200-unit apartment building can take longer to confirm. A Texas study should therefore carry will-serve letters for electricity, water and sewer dated after August 2026, or a lender condition that requires them before closing. For a project that is itself a large load, the study must model the interconnection timeline and the draft fee as part of the cost.

The research behind this page looked for statewide counts of apartments under construction, self-storage per capita, hotel rooms and pipeline, industrial vacancy, senior housing occupancy, RV parks, convenience stores, licensed child care capacity and hospitals, and found none it could date and source to an acceptable standard. Within the research, the one statewide supply series with a primary source is ERCOT's large-load queue, which is a proxy for data center supply and is shown above. We think that absence is the honest finding, and we would rather say so than reprint a vendor's statewide total that mixes metros moving in opposite directions.

Supply evidence for a Texas study therefore lives at the metro and trade-area level, where the metro pages carry what brokers and agencies reported. One federal count does reach the whole state on a single definition: County Business Patterns, which counts operating establishments rather than rooms, units or square feet. For 2023 it counted 5,643 hotel and motel establishments in Texas, and 5,463 employees at self-storage operators ¹²⁶. Those counts say how many operators exist, not how much space they hold or how full it is, so they bound a competitor census rather than replace one. County building permits, which would show what is coming, could not be retrieved for the register behind this page. A study should still build its own census of competing properties within the trade area, by name and address, which is what every one of our Texas cases does. Our note on why the trade area is the study explains the method.

Traffic: the station, its year and its position

The research behind our Texas pages holds almost no station-level traffic counts for the large metros, so a study has to pull its own. TxDOT publishes annual average daily traffic by count station on a statewide map layer ⁸³, a second layer for freeway ramps ¹²¹, and count maps that carry vehicle classification where the truck share drives revenue ¹²². For every count it relies on, the study should report three facts: the station ID, the year the count was taken, and where the station sits against the parcel (mainlanes, frontage road, ramp or cross street). A volume without those three facts is a listing-flyer number, and a reviewer will weigh it as one.

Position usually matters more than volume. A site on a frontage road sees only the traffic that has already exited, and a station on a tolled mainlane counts drivers who cannot reach the parcel without leaving the toll road. On a state frontage road the TxDOT district also reviews driveway spacing before it permits an entrance (our Houston page shows that district\'s application), which can leave a parcel fewer driveways than the broker's plan shows. The traffic section of a study therefore pairs the count with the access the district is likely to approve; each metro page names the corridors and forms that apply there.

Eligibility: rural, Opportunity Zone and HUBZone status belong to the parcel

None of the three program tests can be read off a city name. A USDA Business and Industry guarantee needs a site outside any city or town of more than 50,000 people ¹⁸, and USDA's eligibility tool answers the question by address ⁸⁴; inside the large metros the qualifying land is unincorporated or sits in the small towns at the edge. Where the guarantee exceeds $1,000,000 and the borrower is a new business, the rule calls for a feasibility study by an independent consultant the Agency accepts ⁸⁵. Opportunity Zone status follows the census tract, so the study matches the tract to the designated list ⁸⁶. HUBZone status comes from the SBA's map, which changes with tract updates and states when the next one is due ⁸⁷. An EB-5 raise adds a fourth lookup, the targeted employment area finding for the site, described in the EB-5 section above ⁸⁸.

Each test belongs at the start of the engagement, when the program is chosen, and each result needs its date, because a map read in the first week can change before closing. Three local items the research found for none of the four large metros (impact fee schedules, utility capacity and the terms of short-term rental ordinances) become written conditions in the same way: a fee estimate from the city, a will-serve letter from the utility or district, and the ordinance as adopted.

Economic base

The McAllen-Edinburg-Mission metro is Hidalgo County alone, and its largest employers are institutions rather than plants. HUD's July 2025 market analysis, which leaves school districts out, lists Doctors Hospital at Renaissance with 6,423 workers, the University of Texas Rio Grande Valley with 5,247, U.S. Customs and Border Protection with 3,700, Hidalgo County with 3,579 and H-E-B with 3,150 ⁷⁶. That payroll does not follow the retail cycle, and a border inspection force of that size shows how much of the economy rides on the crossing.

The crossing is large. In 2024 the Hidalgo port of entry handled $15.3 billion of exports, more than 779,500 trucks entered through it, and Foreign Trade Zone No. 12 counted more than 410 member companies ⁷⁶. A truck stop, warehouse, cold storage or fleet service project should tie its revenue to those volumes and show debt coverage at lower ones. HUD also records Driscoll Children's Hospital in Edinburg, a $100 million facility, as built and hiring in 2024 to 2025, and a $24.8 million Sam's Club distribution center in Weslaco for 2026; no Valley project above $50 million was found for 2025 to 2026 ⁷⁶.

Growth, seasonality and supply

Census estimates carried in the St. Louis Fed's ALFRED archive put the metro at 921,549 residents on July 1, 2025 ⁷⁷; HUD's own estimate for that date is 927,000 ⁷⁶. The city of McAllen held 150,640 residents ⁷⁸, so most of the market lives in Edinburg, Mission, Weslaco and smaller towns, and a trade area drawn around McAllen alone misses most of its customers. HUD counted 2,225 for-sale homes and 2,375 rental units under construction on July 1, 2025 ⁷⁶. The research holds no Census-published 2020 base and no verified payroll count, so no five-year or job-growth rate is given for the Valley.

HUD names the Winter Texans, retirees who spend the cold months in the Valley, as a source of seasonal demand, but it gives no count ⁷⁶. RV parks, senior housing, restaurants and clinics swell in winter and thin out in summer, so a study for any of them has to build revenue month by month, compute coverage on the full year rather than the peak, and cite a dated count of seasonal residents instead of a figure repeated in marketing material.

Apartments are the only property type with published supply evidence. HUD, citing CoStar, measured vacancy at 11.2% in the second quarter of 2025, up from 10.6% a year earlier, with an average rent of $986, down $6, and estimated demand for 5,400 units over three years against the 2,375 under way ⁷⁶. The pipeline is absorbable, but vacancy rose while it was being built, so new units lease on price. A multifamily study should underwrite concessions and bring those mid-2025 readings current. Hotels, storage, industrial space, retail, senior housing, RV parks and convenience stores have no Valley figure in the research; each needs a competitor census.

Rules, lenders and eligibility

No hotel tax rate, impact fee, zoning change, short-term rental rule or utility capacity limit is documented for the Valley's cities, so each must come from the city in writing. Wind insurance divides the region: Cameron and Willacy counties are first-tier coastal counties in the Texas Windstorm Insurance Association's designated catastrophe area, and Hidalgo County is not ⁸². In Cameron County, the U.S. Department of Transportation awarded $9 million on October 14, 2026 for an access road to a public truck-parking lot of about 305 spaces at Los Indios ⁸¹, a future competitor for overnight parking at any Valley truck stop.

The SBA's Lower Rio Grande Valley District made nearly $103 million of 7(a) and 504 loans to more than 180 companies in fiscal 2025, and Lone Star National Bank of McAllen led the district in 7(a) loans by count ⁷⁹. The district office is in Harlingen, and the partial county list the research found omits Hidalgo, so the assignment should be confirmed ⁸⁰. In fiscal 2027, 7(a) loans up to $700,000 to rural-area businesses carry an upfront fee of 0%, a rural area being a county that the U.S. Census Bureau has defined as at least 30 percent rural ⁵⁸; whether Hidalgo, Starr or Willacy County qualifies is a lookup to record. McAllen is above the 50,000-person ceiling for USDA Business and Industry loans ¹⁸, while smaller Valley towns can be tested by address in USDA's OneRD tool ⁸⁴. Opportunity Zone, HUBZone and EB-5 status were not found for any Valley site and must be looked up ⁸⁶⁸⁷⁸⁸.

What a lender should verify

• Revenue at lower crossing volumes, built on a dated federal crossing series.
• A monthly revenue curve for any seasonal use, with coverage computed on the full year.
• Apartment deliveries, concessions and effective rents since July 2025.
• The metro payroll series and a 2020 Census base, taken from the federal sources.
• A written wind quote, TxDOT station counts for the frontage ⁸³, a will-serve letter and every program lookup, each dated.

Closest worked case

No worked case sits in the Valley. The Arizona RV resort under USDA B&I shows how a snowbird season sets revenue, the pattern a Winter Texan park faces, and the Texas truck stop under SBA 504 shows how freight volumes become fuel and inside sales.

Economic base

Lubbock is the service center of the South Plains: a university town, a regional medical hub and the market town for a wide farm economy. HUD's 2022 market analysis, reporting 2018 data, ranks Texas Tech University first with 6,635 employees, with the City of Lubbock at 2,700 and Lubbock County at 1,355 ¹⁰³. The Dallas Fed names Covenant Health and UMC Health System as the major health care employers and describes Texas Tech and agriculture as the two forces behind the plains economy ¹⁰⁴. The state is adding to the medical base: in June 2024 the Governor announced a 50-bed maximum-security psychiatric unit in Lubbock budgeted at $121 million, roughly $2.4 million a bed ¹⁰⁵. Its opening date should be confirmed before a study counts its staff as demand.

Agriculture is the part of the base the research could not quantify; it holds no crop, acreage or farm income figure for the region. Retail, fuel, equipment and processing businesses in the surrounding towns rise and fall with harvests, so their studies should show a weak crop year as well as a strong one. Texas Tech adds a calendar of its own: leases, storage rentals and restaurant traffic follow the academic year, and hotels near campus fill on football weekends and at graduation. The research holds no current enrollment, student-bed or event figure, so a student housing or lodging study must source them from the university and show occupancy by month.

Growth and supply

Census estimates carried in FRED put the Lubbock metro at 368,431 residents on July 1, 2025, a gain of 3,767 from 364,664 a year earlier ¹⁰². The research holds no Census 2020 base for the metro, no verified payroll count and no reliable city population, so no growth rate beyond that one year is given here. Steady growth suits uses that serve every household, such as medical office, child care, grocery and everyday retail, provided the study shows the subject's own trade area adding residents.

Storage is where a Lubbock study has to do the most work. The research found no current self-storage supply reading for Lubbock, and none for apartments, hotels, industrial space, retail, senior housing, RV parks or convenience stores either. A self-storage or RV and boat storage study must therefore build its own census: every facility in the subject's trade area with its size, unit mix, posted rates and the date each was read, plus any facility under construction. Demand should be argued as share taken from named competitors, with lease-up and break-even occupancy tested at flat or falling rates, because there is no published evidence that Lubbock's growth alone will fill new space. Car washes show consolidation: Mister Car Wash reported buying five Whistle Express sites in Lubbock in its third-quarter 2025 results ¹⁰⁶, so a new express car wash competes against a national operator's membership base. HUD's 2022 analysis is the last federal market reading ¹⁰³.

Rules, lenders and eligibility

No hotel tax rate, impact fee, zoning change, short-term rental rule or utility capacity limit is documented for Lubbock in the research, which is a gap in the record rather than evidence that no rules apply. Zoning, the permitted use and a will-serve letter belong in writing in every file, and a water-heavy use should document its supply and any drought rules in force.

Lubbock sits in the SBA's West Texas District, which covers 71 counties including Lubbock, Midland, Ector, Potter, Randall and Taylor ⁶⁷; the district's dollars span the Permian Basin, Amarillo and Abilene as well, so they say little about Lubbock alone ⁹. The latest lender recognition the research found dates from 2018, when Southwest Bank of Odessa was honored as a top-volume lender in the region ¹⁰⁷; a current ranking was not found. Self-storage is not on the SBA's special purpose list, so a 504 loan for an existing storage business needs 10% equity, rising to 15% for a new business, and a 7(a) start-up needs 10% ⁵⁷. In a market without a supply reading, the loan should still be sized on the study's lease-up rather than the equity floor.

The city exceeds USDA's 50,000-person ceiling ¹⁸, but towns such as Idalou and the communities of Crosby and Lynn counties may qualify by address in OneRD ⁸⁴. USDA raised the Business and Industry guarantee to 85% for projects under $5 million in March 2026 ¹⁸, and a guaranteed loan above $1,000,000 to a new business requires an independent feasibility study under 7 CFR 5001.306(a)(3)(i) ⁸⁵. Opportunity Zone and HUBZone status were not found for any Lubbock address ⁸⁶⁸⁷.

What a lender should verify

• A dated competitor census for the subject's trade area, including facilities under construction.
• A share-based demand case with lease-up at flat or falling rates.
• Current headcounts for Texas Tech and the health systems, and enrollment and bed counts for student housing.
• The metro payroll series and a 2020 Census base, TxDOT counts for the frontage ⁸³, and the USDA and zone lookups.

Closest worked case

No worked case sits in Lubbock. The Texas meat processing plant under USDA B&I is the nearest model for a South Plains agricultural processor, and the Texas RV and boat storage case under SBA 504 shows how a competitor survey sets rate and lease-up.

Austin's region carries five of the eleven. On the metro's southern edge, the Lockhart gas station and convenience store tests an SBA 7(a) start-up against a commuter corridor that is filling in with rooftops. East of the city, Bastrop County holds three: the Bastrop limited-service hotel on SBA 504, the Bastrop RV park on a USDA Business and Industry guarantee, and the Elgin meat and poultry processing plant, a small manufacturer on the same USDA program. West of the metro in Blanco County, the Johnson City lodging and retreat shows how Hill Country leisure demand is underwritten under 7(a).

Dallas-Fort Worth carries three on its edges, all on SBA 504. The Terrell truck stop and travel center sits on I-20 east of Dallas, where the logistics pipeline drives diesel demand and a specific use permit decides whether the use can open. On the Fort Worth side, the Granbury RV and boat storage facility tests a lake market's storage demand, and the Weatherford franchised dealership shows a proposal that runs into the debenture limit. The site's Texas multifamily case works an apartment project through agency and conventional terms.

San Antonio's region carries two. In Guadalupe County, the Seguin express car wash is a new special purpose business, which puts it in the top 504 equity tier. Northwest of the city in Kendall County, the Boerne assisted living and memory care community is a HUD Section 232 new construction file. Houston's region carries one: the Hankamer I-10 travel center in Chambers County, a rural site on the corridor to Beaumont financed with a USDA guarantee. The four smaller metros have no case yet; their sections on this page point to the closest comparable.