Dry-Stack Boat Storage Feasibility Study for SBA 504, SBA 7(a) and Bank Loans

A dry-stack storage facility is a special-purpose building with a forklift fleet, financed as real estate on SBA 504 and tested on the one rule that most sponsors have never read: SBA's requirement that more than half of a marina's revenue come from transients staying 30 days or less. MMCG Invest prepares dry-stack and rack storage feasibility studies for SBA 504, SBA 7(a), USDA Business and Industry and conventional financing that build rack demand from county registrations by length class, price racks from the few posted schedules and the subject's quotes, cost the building from public contract awards, design the file to the Florida Building Code wind map and the sprinkler standard, and report the debt service coverage ratio (DSCR) by year on each reading of the transient rule.

Dry-stack is the simplest marina revenue model and the one most exposed to SBA's eligibility test. Revenue is rack rent by boat length, launch service that Gulf Coast operators bundle into the rent rather than bill, fuel and a ship store. The capital is a building, racks and forklifts. The problem is that rack contracts are long-term rentals, and SOP 50 10 8, carried into 8.1 for applications received on or after October 1, 2026, makes a marina eligible only if more than 50 percent of the business's revenue for the prior year comes from transients who stay 30 days or less at a time, with a start-up tested on projections. Whether SBA counts a month-to-month rack contract as a stay of 30 days or less, and whether launch-based club memberships and boat rentals count as transient revenue, are questions SBA has not answered in writing, and the study presents the result on each reading rather than assuming the answer.

The demand case is strong where the fleet is. Lee County, Florida, the deepest dry-stack market on the Gulf Coast, registered 49,452 vessels in 2024, including 7,284 pleasure boats of 26 to 40 feet, up 10.3 percent from 2019 while the total fleet was flat, has added no public boat ramp since 2005 and is buying marinas to convert into ramps, approved a taller dry-stack building at Hancock Bridge Marina in February 2026, and has no operator that posts a per-foot rack rate. Pinellas holds a slightly larger 26 to 40 foot fleet, Manatee's registrations grew 34.5 percent from 2019 to 2024 on the state's own files. The general marina method and the SOP 50 10 8.1 rules are on the marina feasibility study hub; land-side RV and boat storage, a different asset with a different rule set, is on the RV park feasibility study page and in MMCG's U.S. RV and Boat Storage Market: 2026 Outlook.

A dry-stack building on owned land is a 504 project. Marinas are on SBA's example list of limited or single purpose property, so the borrower contribution is 15 percent and 20 percent for a borrower operating two years or less, under 13 CFR 120.910; a rack building could be argued to be a general-purpose warehouse at 10 percent, and the study underwrites at 15 or 20 until the CDC rules otherwise in writing. The debenture is capped at $5 million, or $5.5 million for a public policy project, and runs 20 or 25 years on the building and 10 years on the forklifts, with the third-party lender's first mortgage at least 50 percent of project cost; the October 2026 debenture priced at an effective 6.97 percent on the 25-year term. Occupancy is 60 percent of new construction under 13 CFR 120.131, and the queuing docks and launch well count as rentable property under SOP 50 10 8.1. Every marina loan needs a Phase I under SOP Appendix 6, and a fuel dock needs one twice. The rules are on the SBA regulatory spine and the SBA 504 feasibility study page; the leased-land version runs on SBA 7(a) with the lease term matched to the loan, and the Seasonal CAPLine covers the pre-season inventory and labor build-up on a 10-year maximum maturity.

The structure is an Eligible Passive Company holding the building and any sovereignty submerged lands lease for the queuing docks, leasing the whole of it to an Operating Company that runs the racks, fuel and store under a lease that runs at least the loan term. A rural dry-stack facility is a USDA Business and Industry borrower with no transient rule, 20 to 25 percent equity and a 40-year maximum term, and the study shows that program where the county qualifies; see the USDA feasibility study page. No public SBA 504 or USDA financing of a ground-up Florida dry-stack facility was found in MMCG's research, and the study says so; the public precedents are marina purchases and refinances.

Rack demand is built from the county registration file by length class, from the ramp and slip shortage, and from the competitive set's posted limits. Lee County's operators cap boats at 30 feet indoors at one facility, 40 feet at two, and 45 feet and 27,000 pounds on four rack levels at another; Fish-Tale's rebuild puts 434 boats on 68,000 square feet, Vero Beach's new municipal barn 120 boats to 33 feet on 21,355 square feet, and a Port St. Joe building 252 boats on 63,200 square feet, which brackets rack density at about 157 to 251 square feet of building per boat. Rack levels run two to four, maximum lengths 30 to 45 feet, and forklift capacity at Vero Beach is 20,000 pounds with the delivery delay on that machine slowing the opening.

Rates are the thinnest public number in the marina business. Virginia and South Carolina yards post $8.50 to $22.00 per foot per month with unlimited launches bundled; Sarasota posts $27 for a prepaid year, $28 for six months and $30 month to month, plus $3 for a T-top or catamaran; Homosassa posts $17.50 for boats of 8 foot 6 inch beam or less and $25 for wider; Vero Beach's barn was reported at $20 to $30 per foot per month by vessel size with half its capacity reserved before opening in 2026, the only Florida municipal rate and pre-leasing benchmark found. No Lee County operator posts a rate, and the study obtains written quotes and labels them. The monthly premium over the annual rate, 11 to 43 percent in the posted schedules, is the number that matters for the transient reading, because an operator that converts annual contracts to month-to-month gives up prepaid cash to approach the rule.

The revenue lines are classified from the first draft. Rack rent by contract term; launch and valet fees where billed separately, which in Lee County they are not; fuel at the 12 to 17 percent of revenue and 20 to 38 percent gross margin the public port records show; ship store; club and rental concessions, which exist alongside the racks at Fish-Tale through a Freedom Boat Club agreement and at Salty Sam's through boat rentals. Launches per rack per month, the figure that sizes the forklift fleet and the labor line, is not published anywhere MMCG found and is carried from the operator's logs as a flagged assumption. Staffing scales from Vero Beach, which runs 120 racks with two forklift drivers and a dockhand inside a marina staff of eight. The occupancy ramp is modeled at about 40, 65 and 85 percent in years one to three and 90 percent stabilized, labeled as an assumption, because no Lee County occupancy is public and the only signals are marketing copy on both sides: one operator expecting to fill within months, another advertising spots available today.

The 2022 hurricane season rewrote the dry-stack file. Hurricane Ian's surge exceeded 15 feet at Fort Myers Beach. Snook Bight took about eight feet of water in its office, store and storage barn, lost its forklifts, and reopened the barn by appointment on November 17, 2022, seven weeks later; Salty Sam's had racks operating about six months later; Fish-Tale's buildings were damaged extensively and its rebuild was approved by the Town Council in August 2025, about three years on; Legacy Harbour's wet slips were left in ruins and reopened in 2026 after a $15 million redevelopment. The structures largely stood; the ground floors, forklifts and lowest rack tier flooded. The study therefore budgets flood-elevated equipment storage, a spare forklift plan and twelve months of business interruption cover, and it runs a storm year with downtime from seven weeks to three years.

The building is designed to the code in force at permit application. The 2023 Florida Building Code, eighth edition, took effect December 31, 2023 and adopts the ASCE 7-22 wind maps; contractor sources put the ninth edition at December 31, 2026 with the maps unchanged, and the study confirms the edition at floridabuilding.org. The ultimate design wind speed is read for the parcel from the hazard tool, not from a county average, and coastal Lee County sits inside the wind-borne debris region. Vero Beach's barn has a sprinkler system designed to protect racks individually, the only public example of the NFPA 13 treatment, and NFPA 303 applies to the marina. Marine underwriters name dry-stack accumulation as a high-hazard exposure, Risk Strategies forecast marina premiums rising 12 to 18 percent a year, and the study escalates a broker indication rather than carrying a national average. Lee County's land development code counts dry slips toward the manatee protection plan's slip determination, Charlotte County exempts courtesy slips at dry storage facilities used only for launch and retrieval, and whether Lee treats queuing docks the same way is a question the study puts to the county's GIS siting evaluation. The Florida state page carries the state requirements.

The one dependable public cost is Vero Beach. The city awarded a $5.9 million contract, the lowest of six bids, for a 120-rack, 21,355 square foot building for boats to 33 feet with a 20,000-pound forklift, flood protection and stormwater controls, about $49,000 per rack and $276 per square foot, inside about $6.4 million for the upland portion and about $9.5 million for the phase including docks, with $1,534,000 of Florida Inland Navigation District grants; the 2021 design options had ranged from $3.0 million to $7.1 million. Scaled to 300 racks the building and upland work run about $14.7 million to $16.0 million before land, marine works, fuel system, forklifts, soft costs and contingency, and the total project plausibly exceeds $22 million. Lee County paid $4.4 million for the 5.21-acre Mullock Creek Marina with 78 wet slips, a ramp and a fuel dock in 2025, about $845,000 an acre improved, and $1.9 million for the inactive Olsen Marina on Fort Myers Beach, the two public land anchors. A fuel system runs $358,575 for a single tank to $2 million for two 30,000-gallon underground tanks on the public port records, and queuing docks follow the in-water slip costs on the coastal marina feasibility study page. Design and permitting ran about 10 percent of a Florida marina wall award, Berkeley carried a 10 percent contingency and needed 18, and the study assumes 18 to 36 months from application to certificate of occupancy for a ground-up facility: Hancock Bridge went from hearing examiner to Board approval in about ten weeks for the zoning step alone, and Vero Beach took seven years in all.

At that size the 504 debenture cap covers about a quarter of the project and the bank's first lien carries more than half, which is the reason the study models the project in phases of 150 to 200 racks with the second phase financed on the first's history. The capital stack is written at 20 percent for a start-up on special purpose property, with the forklifts on the 10-year equipment term and a Seasonal CAPLine or funded reserve covering the ramp. Lee County's general fund millage was 3.7623 mills in fiscal 2025-26 with school, municipal and district levies on top, and the study carries the parcel's TRIM notice rather than an aggregate.

The study reports DSCR by year against 1.15 times on a 504 or standard 7(a) loan, with the year the floor is first met stated for a start-up and the reserve that carries the project to it. The cases are the format's own: rate per foot by length class, occupancy ramp, launches per rack, fuel gallons, insurance at the escalated premium and a doubled named-storm deductible, the storm year, and the three transient readings, annual contracts only, a month-to-month majority, and a club and rental-heavy mix. Break-even is stated in racks at the contract rate. Where the file passes on one reading and fails on another, the determination says which reading it rests on and conditions the loan on the CDC's and SBA's written confirmation of how each revenue line is treated.

A MMCG dry-stack study includes the eligibility analysis with the transient share on each reading, the registration and ramp-shortage market by length class, the competitive census with posted limits and rates, the manatee siting determination, the FEMA and CBRS screens, the wind and fire design basis for the engineer's letter, the rack projection with launches and staffing, the building and site cost tested against the public award record, the capital stack by phase, the DSCR schedule by year, the storm and insurance cases, the collateral discussion on racks and forklifts, and a signed conclusion. Standard delivery is nine to sixteen business days; expedited delivery in five to seven is available. Fees begin at $4,900 for a single-site SBA 7(a) study and run $7,500 to $15,000 for 504 and USDA studies. Revisions required by the lender or agency are made at no additional cost under MMCG's written acceptance guarantee. See MMCG's feasibility study methodology and where we work.

Gulf Coast dry-stack storage on SBA 504, Lee County, Florida: a 300-rack ground-up facility, not supportable as proposed at 10 percent equity on annual rack contracts, feasible as restructured at a 25 percent contribution with the site contributed, with revenue classified against the transient rule. The wet-slip version is on the coastal marina feasibility study page and the service-yard version on the boatyard and service yard feasibility study page.