Model Case: Gulf Coast Dry-Stack Boat Storage, 300 Racks, Lee County, Florida, SBA 504

A model feasibility case built only from public data. The site, borrower and facility are hypothetical; no client file or engagement data is used. The case follows the house format: at a glance, determination, program eligibility, site and regulatory pathway, market analysis, full cost table, operating assumptions, ten-year pro forma, DSCR by year, break-even, sensitivities, valuation indication and conditions. Figures are as of October 9, 2026. Part of the marina feasibility study cluster; format detail on the dry-stack boat storage feasibility study page, program detail on the SBA 504 feasibility study page and the SBA underwriting and regulatory spine, and the state frame on the Florida feasibility study page.

The project is not feasible as proposed, and it is not eligible as proposed. A 300-rack ground-up dry-stack facility on a purchased waterfront parcel costs $24,361,409 inside the 504 project and $24,611,409 in all. The sponsor plans 10 percent equity; 13 CFR 120.910 requires 15 percent from a borrower that has operated two years or less, 15 percent on a limited or single-purpose property, and 20 percent where both apply, and marinas are on SBA's special-purpose list. At 10 percent the project borrows $21,925,268, and because the debenture stops at $5,000,000 the bank's first lien is $16,925,268, 69 percent of the project rather than the program's 50 percent. Debt service is $1,890,964. The facility earns $339,894 in year 1 on a 55 percent occupancy ramp, $1,223,950 in year 2 and $2,041,836 at stabilization, and covers 0.18x, 0.65x and 1.08x; it reaches 1.15x in year 5 and the first two years leave a $2,218,084 cash shortfall that nothing in the plan funds. Ahead of the arithmetic sits the eligibility rule: a marina is eligible for SBA financing only if more than 50 percent of its prior-year revenue, or of its projected revenue for a start-up, comes from transients staying 30 days or less, and the sponsor's revenue is annual rack contracts. On that revenue the project is not a loan SBA can guarantee at any equity level.

The project is feasible as restructured on the projection, subject to the conditions at the end of this page, and the first condition is a written SBA reading of the transient rule. The restructure keeps the 300 racks, the fuel system, the store and the boat club concession, and changes four things. The sponsor contributes a marine-commercial parcel it already owns, with its seawall and basin, at a $3,000,000 appraised value, which counts toward the contribution and raises it to 25 percent. The building is specified to the site's ultimate wind speed with racks sprinklered individually and the forklifts, switchgear and office above the base flood elevation plus freeboard, which is what the Ian record on Fort Myers Beach says the lender should require. The contingency rises from 5 to 10 percent and the forklifts are bought new, because the public cost record for the building is a single municipal contract on the Atlantic coast. A $1,450,000 reserve is funded outside the project, sized to the modeled shortfalls of $1,190,102 in year 1 and $235,275 in year 2. The 504 project rises to $25,868,584 and total cost to $27,618,584; debt falls to $19,401,438 and debt service to $1,672,055; the bank's lien falls to 56 percent of the project. On rack rent at $32 per foot at 92 percent on a 35-foot boat, the top of the posted Gulf Coast range, the facility covers 0.29x in year 1, 0.86x in year 2, 1.39x in year 3 and 1.70x in year 10, and holds 1.15x down to revenue 9.4 percent below plan.

Two warnings go with the determination. The rate is the case. No Lee County operator posts a rack rate; the model's $32 sits above Sarasota's posted $27 prepaid annual and $30 monthly and below Miami's $32 to $45, and at the Sarasota $27 the restructured facility covers 1.03x in year 3, at the Virginia and South Carolina top of $22 it covers 0.68x. The study for a real parcel replaces the rate with written quotes from the nine Lee County facilities before the loan is sized. And the eligibility is a reading, not a rule: the rule is silent on which revenue lines count as transient, rack rent is 71.5 percent of revenue, and the facility passes only if SBA counts month-to-month rack contracts as stays of 30 days or less and about 70 percent of racks are on them (30 percent if fuel, store, club and fee income count too). A 150-rack first phase was tested outside the workbook and rejected: the land, fuel system, queuing docks, store and seawall do not halve, the project costs about $112,700 per rack against $86,229 for 300, and year-3 coverage falls to 0.84x. The study carries 300 racks and the funded reserve instead.

A 7(a) loan was considered and rejected: the debt exceeds the $5 million 7(a) maximum and the 504 structure prices the real estate at a fixed rate; the $10 million combined 7(a) and 504 limit effective July 4, 2026 does not help a project that needs $19.4 million. USDA Business and Industry does not apply in Lee County's urbanized area.

Lee County had 49,452 registered vessels in 2024 by the state's count, 48,139 of them pleasure boats, and the 26-foot to 39-foot-11-inch pleasure class that fills a dry-stack grew from 6,606 to 7,284 between 2019 and 2024, about 10 percent, while the total stock stayed flat; only Pinellas has more boats in that class on the Gulf Coast. The county's population was 875,607 in the Census Bureau's 2025 estimate, up 15 percent from 2020, or 839,223 in the University of Florida's April 2025 estimate, the largest gap between the two series of any Florida county, and the study states which series it uses. The county has not added a public boat ramp since 2005 and is buying marinas to convert into ramps, $4,400,000 for 5.21 improved acres with 78 wet slips at Mullock Creek in May 2025 and $1,900,000 for the inactive Olsen Marina in September 2025, which brackets the land value the model carries at $2,500,000 purchased and $3,000,000 contributed.

The model fixes the county and the parcel type, not the address: 3.5 acres of marine-commercial land with a basin, an existing seawall and road access, in unincorporated North Fort Myers, on San Carlos Island or in the Town of Fort Myers Beach. Entitlement is a Commercial Planned Development amendment with a height approval, which is the path Hancock Bridge Marina took: a hearing examiner in December 2025, a Board of County Commissioners approval on February 18, 2026 of a taller dry-storage building with fewer vested wet slips to conform with manatee protection, about ten weeks for the zoning step. The Land Development Code defines a slip to include wet or dry slips, so the 300 racks enter the county's Manatee Protection Plan GIS siting evaluation, and the slip count the evaluation returns is the first number the study needs; Charlotte County exempts courtesy launch slips at dry storage and whether Lee treats the queuing docks the same way is a condition. The launch well, queuing docks and fuel float need a Florida Department of Environmental Protection environmental resource permit, a sovereignty submerged lands lease on the preempted area under Chapter 18-21, and Corps of Engineers authorization; Fish-Tale's post-Ian rebuild on Fort Myers Beach ran about 35 months from storm to town approvals with FDEP issued and the Corps pending. The model carries 18 to 36 months from application to certificate of occupancy and 14 months of construction, and the parcel is screened against the FEMA flood map and the CBRS mapper before anything else is spent.

The submerged lands lease fee is the greater of the base rate, $0.156623 per square foot in March 2026, or 6 percent of the income from the sovereign lands. The model carries $12,000, the base fee on about 1.75 acres of preempted area, and tests the 6 percent reading as a condition: if the state counts the fuel float's sales, 6 percent of year-3 fuel sales is $76,385, $63,654 more than the base fee, and year-3 coverage falls from 1.39x to 1.35x. The building is designed to the 2023 Florida Building Code, 8th Edition, on the ASCE 7-22 wind maps, with the 9th Edition reported to take effect December 31, 2026; the site's Risk Category II ultimate wind speed comes from the ASCE Hazard Tool and coastal Lee County is in the wind-borne debris region. Vero Beach's new municipal barn has a sprinkler system designed to protect racks individually, and the model's building line assumes the same. Property tax is modeled at about 15 mills on the assessed value of the building, site and tangible personal property, $270,000 in year 1, against the county general fund rate of 3.7623 mills for fiscal 2025-26 plus school, municipal and district levies; the parcel's TRIM notice replaces the estimate.

The competitive set. Nine Lee County facilities and two regional benchmarks frame the subject. On Fort Myers Beach and San Carlos Island: Gulf Star (up to 115 racks in an automated stacker system, boats to 40 feet, quote only, its launch release said from $20 per foot), Salty Sam's (about 250 racks, 45 feet and 27,000 pounds, four levels, operating about six months after Ian), Moss Marina (150-plus indoor racks to 30 feet), Fish-Tale (441 racks before Ian, a 434-rack rebuild on 68,000 SF approved in August 2025, 157 SF per rack) and Snook Bight (160 racks to 43 feet, barn reopened November 17, 2022, seven weeks after Ian). On the river and in Cape Coral: Hinckley Sweetwater (about 275 racks, a 2016 barn of 54,020 SF adding 108, the only marina at full capacity six months after Ian), MarineMax Fort Myers (300-plus racks to 44 feet, advertising spots available) and Safe Harbor Cape Harbour (boats to 34 feet). In Charlotte County, Safe Harbor Burnt Store (nearly 300 racks). None of the nine posts a per-foot rate; all bundle unlimited launches into the rack rent, so there is no separable launch line in local practice. The regional benchmarks that do post: Sara Bay in Sarasota at $27 per foot per month on a 12-month prepaid contract, $28 on six months and $30 monthly, plus $3 for T-tops and catamarans; Riverhaven in Homosassa at $17.50 for beams to 8 feet 6 inches and $25 wider. Vero Beach's municipal barn opened in March 2026 at $20 to $30 per foot per month by vessel size with half its capacity reserved before opening.

What the record says. Lee County dry-stack demand is evidenced by the boat stock, the ramp shortage and the rebuild approvals, not by a published waitlist or occupancy series; the only occupancy signals are marketing copy (Gulf Star expected to fill within months; MarineMax advertising space). The surge record from Ian is the other half of the market: Fort Myers Beach saw more than 15 feet of surge, the ground floors, forklifts and lowest rack tiers of the barns flooded while the structures largely stood, and downtime ran from seven weeks at Snook Bight to about three years at Fish-Tale. The study for a fixed parcel would report drive-time boat registrations by class, written rate quotes from the nine facilities, the pipeline including Hancock Bridge and the Fish-Tale rebuild, and an insurance indication with and without named-storm cover. For the model case these are conditions and the revenue is built by line.

The ramp is 55 percent of stabilized revenue in year 1, 80 percent in year 2 and stabilized from year 3, against Vero Beach's half-reserved opening; prices and costs escalate 3 percent a year (Sun Communities guided marina rate growth of 5.6 percent in 2024; Shilshole's 2026 tariff moved 0 to 8 percent by size). The sponsor's pro forma uses $30 at 95 percent on a 33-foot boat, $3,385,800 of rack rent and $4,865,800 in all.

The building line rests on one public contract, Vero Beach's $5,900,000 award for 120 racks, the lowest of six bids, and on the density of the Fish-Tale rebuild; no Florida unit cost for a launch well, queuing dock or fuel float from 2020 to 2026 was found, and the marine lines borrow from Washington, Michigan and Sarasota records. The executed contracts replace every line. At 20 percent equity, the regulatory minimum, the project covers 1.29x in year 3; the restructure carries 25 percent because the contributed site is worth more than 20 percent of the project and because the bank's first lien, above the program's half under the capped debenture, needs the cushion.

Debt service is $1,249,135 on the bank loan and $422,920 on the debenture. The years 1 and 2 shortfall of $1,425,377 is what the $1,450,000 reserve is for; cumulative cash flow after debt service over ten years is $5,791,543.

The two structures differ in year 3 by $274,019 of EBITDA, which is the rate and the boat length, and by $218,909 of debt service, which is the equity. The proposed build runs a $2,218,084 cash shortfall in its first two years with a $250,000 pre-opening budget to meet it, and does not reach 1.15x until year 5.

On the stabilized year-3 statement with all five streams scaled and the fixed lines held, the restructured facility covers debt service at $4,390,140 of revenue in year-1 dollars (15.4 percent below plan), reaches 1.15x at $4,701,527 (9.4 percent below) and 1.25x at $4,909,119 (5.4 percent below). As proposed, break-even is $4,677,847, 3.9 percent below the sponsor's plan, 1.15x needs $5,031,205 (3.4 percent above) and 1.25x needs $5,266,777 (8.2 percent above). Stated in rack rent alone with the other lines held, the restructured facility holds 1.15x down to about $28.65 per foot at 92 percent, and the cushion is the difference between the model's $32 and the rate the quotes come back at.

All rows start from the restructured base unless labeled otherwise.

The rack rate and the boat length are the binding variables and the operating lines are secondary: the restructured facility absorbs a 30 percent fuel miss, a five-point fuel margin move, a 10 percent payroll move, a 15 percent fixed-cost move, an 18 percent construction overrun, a rate move and the 20 percent contribution tier, each at or above the floor in year 3, and it does not absorb a $27 rate (1.03x) or a 30-foot average boat (1.06x) with any cushion, and a $27 rate with a fixed-cost move takes it to 0.87x. The slower ramp costs nothing at stabilization and $393,992 of EBITDA in year 1 and $405,811 in year 2, which takes the two-year shortfall to $2,225,179 and exhausts the $1,450,000 reserve; the ramp is the reserve's risk, and the conditions tie the reserve's release to coverage rather than to a date. The month-to-month row is the eligibility case: Sarasota prices monthly storage 11 percent above its prepaid annual rate, and at 85 percent occupancy on monthly contracts the facility covers 1.44x, so the reading that makes the project eligible does not cost it coverage.

No Gulf Coast dry-stack sale with a published capitalization rate exists in the public record, and the only recent dry-stack-led transaction price is the Kent Narrows Boatel in Maryland, reported by an aggregator at $16,000,000 for 375 spaces, about $43,000 per space, for a 2017 building with 12,000 SF of commercial space, a price the buyers did not confirm. The restructured project costs $86,229 per rack inside the 504 project and $92,062 all-in, about twice the boatel's reported price per space, and that gap is the lender's warning: a new building costs more than a used one trades for. On the income approach, stabilized EBITDA of $2,315,855 capitalized at 8.5 to 9.5 percent, the range a buyer of a single Gulf Coast storage facility might apply, indicates $24.4 million to $27.2 million, at or just above cost, so the bank's $14,401,438 first lien is 53 to 59 percent of stabilized value and the combined liens are 71 to 80 percent. Before stabilization the as-complete value is lower and the special-purpose building has no alternative use at its cost, which is why the CDC and the bank underwrite the contribution, the reserve and the quoted rate rather than the collateral. The appraisal reports the real estate on the cost and income approaches separately, with the racks and forklifts as equipment on their own lives.

Prepared by Michal Mohelsky, J.D., FMVA, Practicing Affiliate of the Appraisal Institute. Model case aligned with SBA SOP 50 10 8.1, under USPAP discipline. MMCG Invest, LLC, 27 Maiden Lane, Suite 625, San Francisco, CA 94108.