SBA 504 Feasibility Study Case Study: A Destination RV Resort on Old Gate Road in Pigeon Forge, Tennessee, Feasible as Resized

A 220-site RV resort with 20 cabins proposed on a 16.22-acre wooded parcel at 820 Old Gate Road in Pigeon Forge, Sevier County, Tennessee, beside an operating branded resort and a short walk from the Parkway, on land marketed at $5,900,000 after a 40 percent reduction. The parcel is zoned R-2, where the city's ordinance does not list travel trailer parks, and a travel trailer park in Pigeon Forge is a planned unit development whose occupants may not stay more than 30 days. The 240-unit program does not fit the parcel's developable area with the amenity core and setbacks the ordinance requires, and at a $22,600,000 cost it covers at 1.14x in Year 3. Resized to 150 sites and 12 cabins at a $16,700,000 cost, under a 504 structure with a $8,350,000 bank first lien, a $5,500,000 debenture at the energy public policy cap and $2,850,000 of equity, the resort covers at 1.62x in Year 3 and 1.82x in Year 5. Determination: not feasible as proposed; feasible as resized, conditioned on a rezoning to C-2.

Model study prepared by MMCG Invest | Michal Mohelsky, J.D., FMVA | October 1, 2026

MMCG concludes that the proposed 240-unit resort at 820 Old Gate Road in Pigeon Forge, Tennessee is not feasible as proposed and is feasible as resized. The proposal fails on two independent grounds. The parcel is zoned R-2, and the Pigeon Forge Zoning Ordinance lists travel trailer parks as a permitted use only in the C-2 Tourist Commercial district, so the project cannot proceed on the parcel as zoned; and even on a rezoned parcel, 220 sites and 20 cabins at 14.8 units per acre on a sloped, wooded 16.22-acre tract with a stream buffer exceed what the site holds once the ordinance's 25-foot perimeter setbacks, the amenity core, the roads and the bathhouses are drawn, which MMCG's site-fit test puts at about 214 sites with no amenities at all. The economics agree with the site plan: at a $22,600,000 cost and an absorption-constrained 42 percent stabilized occupancy, the proposal covers at 1.14x in Year 3, below the 1.25x the bank and the CDC require.

The resized program of 150 RV sites and 12 cabins at 10.0 units per acre fits the parcel with the amenity core the Pigeon Forge market expects, and at a $16,700,000 total project cost it covers at 1.62x in Year 3 and 1.82x in Year 5 on a stabilized rate of $92 nightly at 52 percent occupancy across the year, inside the band of $50 to $160 the competing resorts publish on their own websites. The structure is a 504 with a $8,350,000 bank first lien, a $5,500,000 CDC debenture at the cap available where the project meets the energy public policy goal, and $2,850,000 of borrower equity, 17.1 percent of cost, above the 15 percent the program requires of a new business. The stay-length question that governs SBA eligibility is answered by the ordinance itself: the 30-day maximum stay on a Pigeon Forge travel trailer park makes every site transient by law. The determination is conditioned on a rezoning to C-2 and PUD approval, the CDC's classification of the property and its acceptance of the energy goal, a bound insurance quote and the city's confirmation of sewer capacity.

This is an MMCG model study: a complete feasibility analysis performed on a real, publicly marketed parcel using public data, prepared to show 504 lenders, certified development companies and sponsors how MMCG tests a ground-up destination resort against the parcel, the ordinance and the program before the site plan is drawn. It is not a client engagement, MMCG has no relationship with the landowner, the listing broker or any prospective buyer, and the analysis does not represent an offer, an appraisal or a recommendation to buy the parcel. Figures drawn from the listing, the City of Pigeon Forge's ordinance, the National Park Service, the Tennessee Department of Tourist Development and competing resorts' own websites are identified as such. Figures labeled MMCG assumption are underwriting inputs set by MMCG from industry benchmarks, and items that could not be verified from a primary source at the study date are listed in the Conditions and Limitations section rather than estimated silently. In particular, the rates and site counts of several competing resorts from their own websites, the city's sewer capacity, the Sevier County and Pigeon Forge property tax rates and the assessment practice for RV resorts, any RV resort approved or under construction in Sevier County since 2024, and the CDC's classification of the property were not confirmed from primary sources at the study date and are carried as stated assumptions.

The Project will operate as a destination RV resort with cabins on the 16.22-acre parcel at 820 Old Gate Road in Pigeon Forge, Sevier County, Tennessee, immediately beside Camp Margaritaville RV Resort and Lodge and within walking distance of the Parkway, the city's tourism spine. The physical program as resized comprises 150 RV sites, 90 of them pull-through sites of 65 to 80 feet and 60 back-in sites of 55 to 65 feet, all full-hookup with 50-amp service, concrete pads and patios, and 12 rental cabins of 450 to 600 square feet, for 162 units on about 13.8 developable acres at 10.0 units per acre, together with a clubhouse of 4,500 square feet containing the office, a camp store, a lounge and a kitchen, a pool with a splash pad, two bathhouses with laundries, a playground, a dog park, and paved internal roads with a stream buffer along the parcel's creek frontage. The resort will be operated by the sponsor with a general manager, a resident maintenance lead and seasonal front desk, housekeeping and grounds staff of about 14 full-time equivalents in season, open year-round with reduced winter staffing, and every RV site will be rented on a transient basis with a 28-day maximum stay inside the ordinance's 30-day limit. The sponsor will hold the land, improvements and business in a single operating entity that borrows the bank first lien and the 504 debenture, with the sponsor's principals providing the personal guarantees the program requires. The Project is positioned between the Pigeon Forge resorts that publish $50 to $75 and the premium resort that publishes $89 to $160, at $92 nightly on a blended annual basis and $185 nightly for a cabin at stabilization, with seasonal pricing that runs from $65 in January to $135 in October.

Marketing and Sales Strategy

Pre-opening marketing begins six months before the first season from a temporary office on the site and the resort's own booking site, with the resort listed on the commercial reservation platforms and the two membership directories that Smokies travelers use. The primary channel is the destination itself: Great Smoky Mountains National Park drew 11.5 million recreation visits in 2025 and Sevier County's visitors spent $3.9 billion in 2024, and the resort's walking distance to the Parkway is its own channel. The second channel is the adjacency: Camp Margaritaville's guests and overflow are next door, and a resort beside a branded resort inherits its drive-by and its search traffic. The third channel is events: Pigeon Forge's rod runs, the fall color season and the Christmas season fill the city's parks months ahead, and the resort prices those weeks at the top of its card. Retention runs through a returning-guest program and through the cabins, which carry the shoulder seasons when RV occupancy falls.

Amenities

The parcel is a 16.22-acre sloped and wooded tract at 820 Old Gate Road in Pigeon Forge, Sevier County, Tennessee, listed through REALTRACS MLS 3306884 at $5,900,000, or $363,748 per acre, with public water, public sewer and electric on site, two occupied long-term rental cabins, an agricultural tax classification and recent property taxes of $1,922. The listing's price history is itself a market fact: $9,900,000 in February 2024, $8,900,000 in May 2024, $7,500,000 in September 2024 and $5,900,000 in January 2026, a 40 percent reduction over two years. The parcel sits directly beside Camp Margaritaville RV Resort and Lodge, and the listing describes a short walk to the Parkway.

Pigeon Forge is the tourism center of Sevier County, which the Tennessee Department of Tourist Development's economic impact series ranks third among Tennessee's 95 counties with $3,929,693,370 of visitor spending in 2024, up 2.03 percent from $3,851,460,800 in 2023, generating $251.69 million of state and $187 million of local tax revenue. Great Smoky Mountains National Park, the country's most visited national park, recorded 11,527,939 recreation visits in 2025 and 12,191,834 in 2024, a decline of about 5.4 percent, and operates ten campgrounds with about 1,000 sites that recorded more than 420,000 camper nights in calendar 2024. The park's visitor spending exceeded $2.2 billion in 2023 and supported 33,748 jobs.

The site's two liabilities are its zoning and its topography. The parcel is R-2, and the city's ordinance does not list travel trailer parks in that district; the entitlement path is a rezoning to C-2 and a PUD approval, which is the first condition precedent and the reason the determination carries an entitlement contingency. The slope and the tree cover raise the site work budget and reduce the developable area, which MMCG carries at 85 percent of the gross parcel after the stream buffer, the perimeter setbacks and the retaining walls the grade requires.

The City of Pigeon Forge Zoning Ordinance, updated through July 2023, governs. Section 340.1 defines a travel trailer park as a plot of land approved as a planned unit development, and provides that the occupants of such parks may not remain in the same trailer park more than 30 days. Section 407.2 lists travel trailer parks among the planned unit developments, which may be developed in any district provided that the uses permitted and the density requirements of the district allow the development. Section 702.3 lists the uses permitted in the R-2 district, including residential planned unit developments and mobile home parks, and does not list travel trailer parks; Section 704.2 lists travel trailer parks among the uses permitted in C-2 Tourist Commercial. The municipal code's trailer camp chapter, Title 14, Chapter 3, requires that all trailer camps be located in an industrial or commercial zone. The parcel must therefore be rezoned to C-2 before a travel trailer park PUD can be approved on it.

The PUD standards shape the site plan. Section 407.3.1 requires a setback of not less than 25 feet where the development adjoins a residential district, and Section 407.3.2.2 requires freestanding buildings to be 30 feet apart and 25 feet from exterior boundaries. Section 406 prohibits structures within 15 feet of a stream's top of bank and requires Planning Commission approval within 50 feet. Section 407.4 sets a four-step approval of preliminary PUD plan, final PUD plan with preliminary plat, and final plat, and Section 407.7.3 expires the special conditions permit in 12 months with one one-year extension. The ordinance sets no travel-trailer-specific minimum site size or density in the sections retrieved, and the study carries the site count from the physical fit rather than from a density cap.

The 30-day stay limit is the project's SBA eligibility finding written into the ordinance. A travel trailer park in Pigeon Forge cannot hold a monthly or seasonal guest, so every site is transient by law and the more-than-50-percent test of SOP 50 10 8 is met by projection without a stay-length covenant; the resort's 28-day operating maximum sits inside the limit.

The Tennessee Department of Health permits organized camps and travel campsites under Rule Chapter 1200-01-05 and Tennessee Code Annotated 68-110-103, with a site plan at not less than one inch to 100 feet showing camping spaces, structures, water supply, sewage disposal, roads and firefighting equipment, and a 2023 enactment defines a campground as five or more campsites and requires a posted policy on curfew, alcohol, tobacco and pets. The resort connects to public sewer, which removes the state's subsurface sewage permit from the path; the city's confirmation of sewer capacity for 162 units is the fourth condition precedent.

Water, sewer and electric service are on the site, and the budget carries $780,000 for mains and laterals to the public systems and the resort's internal distribution, with the city's tap and capacity fees inside that line as a stated allowance. Electrical distribution and 50-amp pedestals at every site are carried at $720,000, or $4,800 per site, on the 2023 National Electrical Code basis of 12,000 volt-amperes per 50-amp site and a 41 percent demand factor at 36 or more sites.

Property tax is carried at $98,000 in Year 1, or $605 per unit, as an MMCG assumption that reflects Tennessee's 40 percent assessment ratio on commercial property and the combined Sevier County and City of Pigeon Forge rates on an appraised value near $14,500,000, escalating 2 percent per year; the certified rates and the assessor's practice for RV resorts are to be confirmed before closing. Sevier County's lodging tax applies to the resort's cabin and site revenue from transient guests and is collected from the guest.

The trade area for a destination resort is the destination's draw, not the county's population. Sevier County holds about 100,000 residents on Census Bureau estimates, and its own demographics describe the labor pool, which the county's 33,748 park-supported jobs and its hospitality employment base supply at the regional wage. The resort's guest is the Smokies visitor: 11.5 million recreation visits a year to the national park, a drive market that reaches Atlanta, Nashville, Charlotte and Cincinnati within five hours, and a camping segment that the park's own campgrounds, at about 1,000 sites and 420,000 camper nights, cannot hold. Visitor spending of $3.9 billion in the county in 2024 is the demand that reaches the Parkway, and the subject sits a short walk from it.

The demand model counts the competitive set's capacity and the subject's share of it. The seven private resorts and parks MMCG identified in Pigeon Forge and Sevierville hold roughly 1,200 RV sites on the site counts MMCG could locate, several of them from aggregators and flagged as such, and the national park holds a further 1,000 campground sites. The resized subject's 150 RV sites are about 12 percent of the private supply; the proposed 220 sites would have been about 18 percent, which is the absorption pressure the as-proposed case carries in its lower stabilized occupancy.

The penetration test is the set's own occupancy. The Pigeon Forge resorts fill in the fall color and Christmas seasons months ahead, run near capacity on summer weekends and empty in January and February, and the published winter specials, a $300 weekly rate at one resort and 28 to 89 night seasonal stays at another, show where the winter floor sits. MMCG carries the resized subject at 52 percent annual occupancy at stabilization, built from a monthly curve that runs from 20 percent in January to 85 percent in October, and the cabins at 58 percent. On that curve the resort needs about 78 occupied RV sites a night on average across the year, which at 12 percent of the private supply in a market with $3.9 billion of visitor spending is a conservative capture.

MMCG identified seven competing resorts and parks in Pigeon Forge and Sevierville. Three publish rates on their own websites and are quoted; the others were located through aggregators, which are flagged.

Competitor Number 1 Camp Margaritaville RV Resort and Lodge This branded resort is located immediately beside the subject in Pigeon Forge, TN. Its site count and rates were not retrieved from its own website at the study date. It is the subject's adjacency and its most direct comparable in positioning.

Competitor Number 2 The Ridge Outdoor Resort This resort is located at 1250 Middle Creek Road, Sevierville, TN 37876 and is listed by an aggregator at 133 RV sites and 6 tiny houses. Its own website publishes premier sites at $88.99 to $159.99 per night on pads of 62 to 100 feet. It is the top of the market and the subject's premium reference.

Competitor Number 3 Pigeon Forge Landing RV Resort This resort is located at 455 Lonesome Valley Road, Sevierville, TN 37876 and is operated within the RVC Outdoors and Thousand Trails systems; the operator's page lists 237 sites. Its own site publishes rates starting at $50, offers annual, three-month, six-month and monthly rates on request, runs a Flock South seasonal program of 28 to 89 nights from October to April, and caps stays at 14 days per site from April 15 to September 15.

Competitor Number 4 Creekside RV Park This park is located on Walden's Creek in Pigeon Forge, TN and is listed by an aggregator at 108 sites. Its own website publishes 2026 rates of $55 for 30-amp sites and $75 for 50-amp sites, with pull-through and creekside sites at $5 more, nightly only with no monthly or annual rates.

Competitor Number 5 Pigeon Forge RV Resort This resort is located in Pigeon Forge, TN and is listed by an aggregator at 182 sites. Its own website shows creekside partial-hookup sites at an average of $72 per night.

Competitor Number 6 Camp Riverslanding This park is located at 304 Day Springs Road, Pigeon Forge, TN 37863 and is listed by aggregators at 117 to 122 sites. Its own website publishes a winter special of $300 per week for RV sites for the 2027 season, up from $225 per week in 2026; its nightly rates were not posted on the page retrieved.

Competitor Number 7 Sun Outdoors Pigeon Forge This resort is located at 1004 Parkway, Sevierville, TN 37876 and is listed by an aggregator at 194 RV sites and 23 cabins and cottages. Its own rates were not retrieved at the study date.

Mill Creek Resort, Smoky Mountain Premier RV Resort, Two Rivers Landing and Riveredge RV Park are also in the trade area and were not retrieved. No RV resort approved or under construction in Sevier County since 2024 was identified at the study date; the Sevierville Planning Commission's August 2026 approval at The 407 near Buc-ee's was a hotel, timeshare and indoor waterpark, not RV supply.

The subject's rate card is set inside the verified band. The resized resort opens at a blended annual RV rate of $92 at stabilization, above the $50 to $75 the volume resorts publish and inside The Ridge's $89 to $160 premier sites, for a new resort with full hookups, 50-amp service, concrete pads, a pool and a clubhouse beside a branded neighbor; the as-proposed case is carried at $80 because 220 sites in a 1,200-site market price as a volume product. Cabins are carried at $185 nightly at stabilization. The blended rate is built from a seasonal card that runs from $65 in January to $135 in October, with weekend and holiday premiums, and rates escalate 3 percent per year. Other income, which comprises the camp store, laundry, golf cart rentals, firewood and fees, is carried at 6 percent of site and cabin revenue.

Lease-up concessions are not carried, because a destination resort fills on its season and its platform listings rather than on price; the first season is carried at a lower occupancy instead.

Construction runs 14 months from a 2027 rezoning and PUD approval, and the resort opens for the 2028 fall season with its first full year in 2029.

The as-proposed case carries 220 sites at $80 and 29, 38, 42, 43 and 44 percent occupancy, and 20 cabins at $180 and 35, 46, 50, 51 and 52 percent, for revenue of $2,462,232 in Year 1 and $3,772,969 in Year 3. The Year 1 shortfall of the resized case against debt service, $249,649, is funded from the interest and operating reserve.

Location: 820 Old Gate Road, Pigeon Forge, TN 37863 Units: 162 (150 RV sites and 12 cabins)

Source: Marshall & Swift CoreLogic, MMCG

Total project cost of $103,086 per unit is dominated by land at $36,790 per unit, a figure that no RV park in MMCG's reference set carries and that only a Pigeon Forge location a short walk from the Parkway can support; hard cost of $55,944 per unit, with the cabins, the pool, the clubhouse and the slope work inside it, sits at the mid-tier of the firm's new-build comparables, between the $47,000 to $54,000 per site of the clean private builds and the $88,000 and higher of the full-amenity public resorts. The reserve of $339,350 funds the Year 1 shortfall of $249,649 against debt service with $90,000 of margin. The as-proposed program is carried at $22,600,000: the same land, $14,100,000 of hard cost for 220 sites and 20 cabins with a larger pool and clubhouse, $650,000 of equipment and $1,890,000 of financial cost including a $700,000 reserve.

Loan Assumptions (resized)

The debenture is capped. The standard 504 structure for a new business is 50 percent bank, 35 percent CDC and 15 percent borrower, and 35 percent of $16,700,000 is $5,845,000, above the $5,000,000 debenture maximum; the $5,500,000 maximum applies where the project meets an energy public policy goal, which the study carries on the basis of a design that reduces energy consumption by at least 10 percent against the applicable code baseline, to be confirmed by the CDC. The borrower's equity therefore rises to $2,850,000, or 17.1 percent. If the CDC classifies the property as a limited or special purpose property, the required contribution rises to 20 percent and the structure is $8,350,000 bank, $5,010,000 debenture and $3,340,000 equity, under which Year 3 coverage is 1.67x. As proposed, the structure is $11,300,000 bank, $5,500,000 debenture and $5,800,000 equity, 25.7 percent, with annual debt service of $1,481,965.

The Project is an eligible business under SOP 50 10 8 because the Pigeon Forge ordinance limits a stay in a travel trailer park to 30 days, so more than 50 percent of revenue is derived from transients who stay 30 days or less by law as well as by projection; the resort carries no monthly, seasonal or annual product, and no mobile home or park model lots. The 504 project finances the land, the site work, the buildings and the long-lived equipment of an owner-operated business, and the sponsor occupies and operates the resort.

The borrower contribution is 15 percent for a business in operation for two years or less, 20 percent if the CDC also classifies the property as limited or special purpose; the study carries 17.1 percent at the capped debenture and states the 20 percent case. The job opportunity standard is one job per $95,000 of debenture under SBA's notice for loans approved on or after October 1, 2025, which at $5,500,000 is about 58 jobs against the resort's 14 full-time equivalents in season; the project therefore qualifies under the public policy goal of reducing energy consumption by at least 10 percent, which also lifts the debenture maximum to $5,500,000, and the CDC's acceptance of that goal is the second condition precedent. The debenture is fixed-rate over 25 years; the bank first lien is carried at a 25-year amortization with the bank's own term, and the study runs a sensitivity at 100 basis points above both rates.

The Year 3 operating budget at 52 percent RV and 58 percent cabin occupancy is built by line for a 162-unit destination resort in Sevier County.

The expense ratio of 43.5 percent is below the 54 to 56 percent MMCG carries for a stabilized park from Newmark's expense analysis because the resort's revenue per unit of $21,621 is more than four times the Newmark average of $4,645 and the fixed lines do not scale with it; payroll at $2,947 per unit and 13.6 percent of revenue, marketing and reservation costs at 8.5 percent of revenue and insurance at $939 per unit are each above the Newmark proportions, which is how a resort budget differs from a park budget. Insurance is carried at $800 per RV site and $1,500 per cabin in Year 1, escalating 5 percent per year, in a market without wind or wildfire loading but with flood exposure along the creek that the bound quote must price. The replacement reserve is carried at $150 per unit on new construction.

The Year 1 shortfall of $249,649 is funded from the reserve. The resort covers from Year 2 at 1.34x, reaches 1.62x in Year 3 and builds to 1.82x by Year 5, and its Year 3 yield on total project cost of 11.8 percent is the return a destination resort earns at a $92 rate on land that cost $36,790 per unit. As proposed, the same model produces net operating income of $1,723,787 in Year 3 against debt service of $1,481,965, coverage of 0.91x in Year 2, 1.14x in Year 3, 1.23x in Year 4 and 1.32x in Year 5, and a Year 1 shortfall of $855,890 against a $700,000 reserve; the proposal does not reach 1.25x until Year 5 and does not fit the parcel.

At Year 3 rates, the resized resort's fixed operating cost is $1,146,433 including the replacement reserve, and its variable cost is 11.5 percent of revenue for marketing, reservation and administrative lines. Occupancy is stated on a blended basis across all 162 units.

The 1.25x threshold at 45.3 percent blended sits seven points under the forecast, and the 1.0x threshold at 40.2 percent is near the platform-wide annual occupancy that RV resorts record on the industry's booking data, which is the honest statement of the credit: a Pigeon Forge resort that performs like an average RV resort covers its debt, and one that performs like a Pigeon Forge resort covers it with room.

The resized resort holds coverage above 1.25x in every single-factor case except a stabilized occupancy of 42 percent, which is the as-proposed case's occupancy applied to the smaller resort, and the combined case of a lower rate and 46 percent occupancy holds 1.13x. The as-proposed row is the determination.

The determination of not feasible as proposed and feasible as resized is subject to the following conditions precedent on the resized program:

The following items could not be verified from a primary source at the study date and are disclosed: the rates and site counts of Camp Margaritaville, Sun Outdoors Pigeon Forge, Pigeon Forge RV Resort, Camp Riverslanding, Mill Creek Resort, Smoky Mountain Premier RV Resort, Two Rivers Landing and Riveredge RV Park from their own websites, in place of which the study carries the three published cards and the aggregator counts flagged above; any RV resort approved or under construction in Sevier County since 2024; the Sevier County and City of Pigeon Forge property tax rates and the assessor's practice for RV resorts; the city's sewer capacity and connection fees; the Sevier County population estimate; the two rental cabins' leases and the cost of terminating them; the 85 percent developable area assumption, which depends on the survey and the geotechnical report; and the CDC's classification of the property.

This model study applies the methodology described on MMCG's RV park feasibility study and SBA RV park feasibility study pages. MMCG prepares RV park and campground feasibility studies for SBA 7(a) and 504, USDA Business and Industry and REAP, and conventional lenders nationwide, with engagements from $4,900 and delivery in 9 to 16 business days.