A new independent travel center proposed on 16 acres at the I-40 and US-183 interchange in Clinton, Custer County, Oklahoma, on a stretch of Interstate 40 where a single national chain holds the fueling nodes roughly every 30 miles and no competing travel center is in the pipeline. The sponsor's original concept, a 12,000 SF building with a three-bay truck shop and 120 truck parking spaces at a $22,400,000 cost, covers at 0.62x in Year 3 at the diesel volume an independent can win at this exit. Sized to 9,500 SF, six diesel lanes, 12 auto positions and 90 truck parking spaces at a $15,135,900 total project cost, financed with an $11,351,925 USDA Business and Industry guaranteed loan and $3,783,975 of equity, the travel center covers at 1.35x in Year 3, 1.46x in Year 4 and 1.54x in Year 5 on 4,600,000 diesel gallons and $5,240,000 of nonfuel sales. Determination: feasible as sized, conditioned on an ODOT classified count, a fuel supply agreement, the interchange reconstruction schedule and the parcel's entitlement.
Model study prepared by MMCG Invest | Michal Mohelsky, J.D., FMVA | October 2, 2026
Study at a Glance
| Item | Finding |
|---|---|
| Subject | Model parcel of 16.0 acres in the southeast quadrant of I-40 and US-183 (Exit 65A), Clinton, Custer County, Oklahoma |
| Site | Interchange frontage on an I-40 segment that ODOT's 2023 county map carries at 21,400 to 31,000 vehicles per day; land carried at $55,000 per acre against listings of $31,000 to $102,000 per acre |
| Program as sized | 9,500 SF travel center with convenience store, franchised quick-service restaurant, driver lounge and eight showers; six high-flow diesel lanes; 12 auto fueling positions; 90 truck parking spaces, 18 of them reserved; DEF at the pumps; CAT scale |
| Program as originally proposed | 12,000 SF building with a three-bay truck service shop and 120 truck parking spaces at a $22,400,000 total project cost |
| Loan program | USDA Business and Industry guaranteed loan, new business, loan note guarantee requested before completion of construction, 25 percent equity of total project cost, 80 percent guarantee |
| Total Subject Project Cost (as sized) | $15,135,900 ($1,593 per SF of building; $945,994 per acre) |
| Stabilized revenue (Year 3) | $29,340,000, of which $24,100,000 fuel and $5,240,000 nonfuel |
| Stabilized diesel volume (Year 3) | 4,600,000 gallons, 12,603 gallons per day, 133 fueling trucks per day, 1.97 percent of passing trucks |
| Debt service coverage (as sized) | 0.52x Year 1 (reserve funded), 1.02x Year 2, 1.35x Year 3, 1.46x Year 4, 1.54x Year 5 |
| Debt service coverage (as originally proposed) | 0.62x in Year 3 |
| Break-even (Year 3) | 57.9 percent of forecast gallons before debt, 89.5 percent at 1.0x coverage, 97.0 percent at 1.25x |
| Determination | Feasible as sized, conditioned on an ODOT classified count at Exit 65A at or above the underwriting basis, an executed fuel supply agreement, a construction schedule reconciled to ODOT's Exit 65 and 65A reconstruction, and the City of Clinton's zoning verification |
Determination
MMCG concludes that the proposed travel center at the I-40 and US-183 interchange in Clinton, Oklahoma is feasible as sized and is not feasible as originally proposed. The sponsor's concept of a 12,000 SF building with a three-bay truck service shop and 120 truck parking spaces carries a $22,400,000 total project cost, and at the diesel volume an independent can win at this exit, which MMCG sets at 4,600,000 gallons at stabilization, it covers its debt at 0.62x in Year 3; the shop and the additional 30 spaces add $7,300,000 of cost and about $400,000 of gross margin before the labor to run them. Sized to 9,500 SF, six diesel lanes, 12 auto positions and 90 truck parking spaces at a $15,135,900 total project cost, the travel center covers at 1.02x in Year 2, 1.35x in Year 3, 1.46x in Year 4 and 1.54x in Year 5, on a Year 3 base of 4,600,000 diesel gallons at a 22 cent margin, 1,400,000 gasoline gallons at a 31 cent margin and $5,240,000 of nonfuel sales at a 47.5 percent gross margin. The structure is an $11,351,925 Business and Industry guaranteed loan at 75 percent of cost, amortized over 30 years within the program's 40-year maximum, and $3,783,975 of equity, exactly the 25 percent of total project cost the program requires of a new business whose lender requests the loan note guarantee before construction is complete. The margin above 1.25x in Year 3 is thin, 3 percent of forecast gallons, and widens to about 6 percent by Year 4 and 8 percent by Year 5, which is why the determination is conditioned on an ODOT classified count at the interchange at or above the 21,000 vehicles per day and 32 percent trucks used as the underwriting basis, an executed fuel supply agreement with fleet card acceptance, a construction schedule reconciled to ODOT's reconstruction of the Exit 65 and 65A interchanges, and the City of Clinton's written zoning verification for the parcel.
Scope and Basis of This Model Study
This is an MMCG model study: a complete feasibility analysis of a travel center on a model parcel at a real interchange, prepared with public data to show USDA guaranteed lenders and sponsors how MMCG tests a new-build travel center against the corridor, the competitive set, the program and the regulation before the site plan is drawn. It is not a client engagement. The parcel is a model site described by its acreage, quadrant and interchange; MMCG has no relationship with any landowner, broker or sponsor at the exit, and the analysis does not represent an offer, an appraisal or a recommendation to buy any parcel. Figures drawn from the Oklahoma Department of Transportation, the U.S. Census Bureau, Oklahoma State University Extension's compilation of certified mill levies, the Federal Highway Administration, the Federal Motor Carrier Safety Administration, TravelCenters of America's last public filings and the operators' own location pages are identified as such. Figures labeled MMCG assumption or MMCG estimate 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 ODOT classified count at Exit 65A, the asking price of any specific interchange parcel, the City of Clinton's zoning of the quadrant, the current truck parking counts at the competing stops after their 2025 rebuilds, and the open-to-traffic date of ODOT's interchange reconstruction were not confirmed from primary sources at the study date and are carried as stated assumptions.
Project Business Plan
The Project will operate as a 24-hour independent travel center on 16.0 acres in the southeast quadrant of the I-40 and US-183 interchange in Clinton, Custer County, Oklahoma, roughly 85 road miles west of Oklahoma City and 175 road miles east of Amarillo on the main east-west freight lane between the Southern California ports and the Southeast. The physical program comprises a single-story 9,500 SF masonry building housing a 4,200 SF convenience store with a walk-in beer cave, a fountain and coffee program and a hot grab-and-go case, a 1,900 SF franchised quick-service restaurant with a drive-through, a driver lounge with eight private showers, laundry, a TV room and a fuel desk, restrooms sized for a truck stop, a manager's office and back-of-house, together with a six-lane diesel canopy carrying dual-sided high-flow dispensers with diesel exhaust fluid at every lane and satellite dispensers for saddle tanks, a 12-position auto fueling canopy, a 90-space heavy-duty truck court with 18 reserved spaces under a paid reservation program, a CAT scale, a six-tank double-wall underground storage system holding 160,000 gallons with interstitial monitoring, and a lighted pylon sign visible from both directions of I-40. The travel center will operate 24 hours a day, seven days a week, with a general manager, two assistant managers and 25 full-time-equivalent store, restaurant, fuel desk and porter staff for 28 FTE. The sponsor will hold the land, improvements and business in a single operating company that borrows the B&I guaranteed loan, with the principals providing the personal guarantees the program requires. The Project is positioned as the independent full-service stop between the national chain's nodes at Elk City and Hinton, roughly 30 miles in each direction, with diesel priced at or within two cents of the chain's posted cash price, fleet card acceptance on the major networks, a parking lot that does not fill by early evening, and a food and shower program the fuel-only stops on the corridor do not offer.
Marketing and Sales Strategy
The launch is anchored on the fleet card networks and the driver apps: enrollment with the major fleet card processors before opening so that the site appears in fleet routing and discount programs from the first day, listing on the truck stop directories and parking apps with photographs and the reservation program live at opening, and a 90-day opening promotion of free showers with a 50-gallon fill and a loyalty card that credits inside purchases against fuel. The reserved parking program is sold through the parking apps and the fuel desk at $18 a night. Business outreach targets the regional carriers, grain haulers and oilfield service fleets that run US-183 and US-281 across I-40, offering direct-bill fuel accounts and a parking agreement for drivers resetting in Clinton, and the agricultural cooperatives and feedlots in Custer and Washita counties for bulk DEF and fuel desk accounts. The quick-service restaurant carries its own national brand marketing and drive-through traffic from Clinton's 8,300 residents and the US-183 cross traffic. Retention runs on the loyalty program, clean showers and the reliability of the diesel price position against the chain nodes.
Amenities
- Six-lane high-flow diesel canopy with dual-sided dispensers, satellite dispensers and diesel exhaust fluid at every lane
- 12-position auto fueling canopy with gasoline, premium and diesel
- 90-space heavy-duty truck court with 18 reserved spaces, LED lighting and a one-way circulation pattern
- Eight private showers with towel service, laundry, driver lounge and TV room
- 4,200 SF convenience store with beer cave, fountain, coffee and hot grab-and-go program
- Franchised quick-service restaurant with drive-through, open to the travel center and to the street
- CAT scale
- Six-tank double-wall underground storage system with interstitial monitoring and automatic tank gauging
- Fleet card acceptance on the major networks and a loyalty program
- Lighted pylon sign visible from both directions of I-40
Site and Location Analysis
The subject is a model 16.0-acre parcel in the southeast quadrant of the I-40 and US-183 interchange in Clinton, carried at $55,000 per acre, or $880,000, inside the range of commercial land offered near Clinton's interchanges, where listings run from about $31,000 per acre for a tract on Commerce Road at Exit 62 to about $102,000 per acre for 2.9 acres with I-40 frontage, and the average of the five commercial listings MMCG located is about $36,000 per acre. Clinton is the county seat area's commercial center on I-40 between Weatherford and Elk City, with a 2020 Census population of 8,521 and a 2025 estimate of 8,302, in a county of 28,513, and it sits well inside the rural definition of 7 CFR 5001.3.
Interstate 40 through Custer County is the corridor fact. ODOT's 2023 county map carries I-40 segments at 21,400 to 31,000 vehicles per day across the county, with the 23,600 to 29,600 values clustered around Clinton and Weatherford; the map marks continuous classification sites on the corridor but publishes no truck share, and MMCG's underwriting basis of 21,000 vehicles per day with 32 percent trucks is a deliberate floor against those counts and against the 21.8 percent combination-truck share and 26.4 percent all-truck share that the Federal Highway Administration reports for rural interstates nationally in 2024. On that basis 6,720 trucks and 14,280 passenger vehicles pass the exit each day.
The exit itself is under reconstruction. ODOT's Transportation Commission was briefed in January 2026 on a $76,000,000 project that rebuilds the Gary Boulevard and Neptune Drive interchanges and replaces four bridges over about two years, delivered with the City of Clinton, and ODOT's contract documents carry an estimated open-to-traffic date in 2028. The Project's construction in 2027 and opening in mid-2028 overlap that work. MMCG carries the overlap in the Year 1 ramp of 72 percent of stabilized volume, which is below the 80 percent a travel center on an undisturbed interchange would reach, and the determination is conditioned on a construction schedule reconciled to ODOT's phasing so that the diesel lanes open to a finished ramp.
Freight Demand and Truck Traffic
A travel center's customer is the truck that must stop near the site, and the hours-of-service rules fix where that happens. A property-carrying driver may drive a maximum of 11 hours after 10 consecutive hours off duty, may not drive beyond the 14th consecutive hour after coming on duty, and must take a 30-minute break after 8 cumulative hours of driving. At the speeds I-40 allows, an 11-hour day covers 550 to 650 miles, which places Clinton one driving day west of Memphis and the Mississippi River distribution hubs, one driving day east of Albuquerque, and inside the reset band for trucks that loaded in Oklahoma City or Amarillo that morning. Federal freight forecasts project tonnage growth of about 46 percent between 2017 and 2050, and the New Mexico corridor study of the same interstate found that more than 80 percent of its commercial truck trips are through trips, which is the demand a travel center captures.
The demand model takes the 6,720 trucks a day on the underwriting basis, separates them into Federal Highway Administration classes so that the Class 9 tractor-semitrailer that buys 95 gallons and parks overnight is modeled apart from the single-unit trucks that do neither, and applies a capture rate by direction and by hour. Stabilized diesel volume of 4,600,000 gallons a year is 12,603 gallons a day, 133 fueling trucks at an average fill of 95 gallons, and 1.97 percent of the trucks passing the exit; the Year 1 figure of 3,312,000 gallons is 96 trucks and 1.42 percent. A national chain node captures several times that share through fleet contracts and loyalty routing. The independent's share is set by the gap between the chain nodes at Exit 41 and Exit 101, by parking availability in the evening when the chain lots fill, and by price position, and 2 percent is the share MMCG carries for an independent with a full driver program at a mid-corridor interchange. Gasoline is modeled at 1,400,000 gallons at stabilization, 349 cars a day at 11 gallons and 2.44 percent of passing passenger vehicles, with Clinton's residents and the US-183 cross traffic inside that figure.
Competitive Supply and Truck Parking
MMCG identified one national chain operating the I-40 fueling nodes on both sides of the subject and three independents on the corridor. Truck parking counts are taken from directories that in two cases predate 2025 rebuilds and are flagged.
Competitor Number 1 Love's Travel Stop, Clinton This travel stop is located at I-40 Exit 71, Custer City Road, Clinton, OK, about six miles east of the subject. It was rebuilt and reopened in 2025. The directory count of 18 truck parking spaces predates the rebuild and is not relied on. It is the subject's nearest chain competitor and the reason the subject's position rests on parking and the driver program rather than on being first to the exit.
Competitor Number 2 Love's Travel Stop, Elk City This travel stop is located at I-40 Exit 41, Elk City, OK, about 30 miles west of the subject. It is the chain's node west of Clinton and the westbound driver's last chain stop before the subject.
Competitor Number 3 Love's Travel Stop, Hinton This travel stop is located at I-40 Exit 101, Hinton, OK, about 30 miles east of the subject. It is the chain's node east of Clinton.
Competitor Number 4 Love's Travel Stop, Erick This travel stop is located at I-40 Exit 7, Erick, OK, about 64 miles west of the subject near the Texas line. It bounds the corridor on the west.
Competitor Number 5 Love's Travel Stop, El Reno This travel stop is located at I-40 Exit 127, El Reno, OK, about 60 miles east of the subject. It bounds the corridor on the east.
Competitor Number 6 Domino Food and Fuel This independent fuel stop is located on the I-40 corridor about six miles from the subject, per directory listings. Its diesel lanes, parking and amenities were not verified from an operator source and it is carried as a fuel-only competitor.
Competitor Number 7 Fast Lane Travel Plaza This independent travel plaza is located on the I-40 corridor about 12 miles from the subject near Weatherford, per directory listings. Its program was not verified from an operator source.
Competitor Number 8 Pendletons Truck Stop This independent truck stop is located on the I-40 corridor about 18 miles from the subject, per directory listings. Its program was not verified from an operator source.
No travel center announced, permitted or under construction within 30 miles of the subject was identified in chain newsrooms, local news or planning agendas between 2024 and 2026; the nearest pipeline item on the corridor is a proposed large-format travel center on the west side of Oklahoma City, about 85 miles east, which is outside the subject's market. The pattern on this stretch of I-40 is one chain holding the nodes at roughly 30-mile spacing, which leaves the mid-corridor interchange to an independent that can offer what the nodes cannot at 7:00 p.m.: an open parking space. Truck parking is a corridor-wide shortage, with 98 percent of drivers reporting difficulty finding parking and the national inventory at roughly one space for every 11 drivers, and the subject's 90 spaces, 18 of them reservable, are the amenity that converts a passing truck into a fueling customer.
Rural Eligibility and Program Fit
Clinton's 2020 Census population of 8,521 is far below the 50,000 threshold in 7 CFR 5001.3, Custer County holds 28,513 residents, and the parcel is not inside any urbanized area contiguous to a city of more than 50,000, so the site is rural without a petition. A travel center is an eligible commercial enterprise under 7 CFR 5001.105, and the Project carries no gaming, so the 15 percent gambling revenue test in 7 CFR 5001.127(b) does not arise. The borrower is a new business under 7 CFR 5001.3, which makes the independent feasibility study a requirement of 7 CFR 5001.306(a)(3)(i) for a guaranteed loan greater than $1,000,000, and sets the equity requirement under 7 CFR 5001.105 at 20 percent balance sheet equity or 25 percent of total project cost, rising to 25 percent balance sheet equity where the lender requests the loan note guarantee before construction is complete, which the lender does here. The guaranteed loan of $11,351,925 falls in the $5,000,000 to $25,000,000 tier that USDA guarantees at 80 percent in fiscal year 2026, with a 3 percent initial guarantee fee on the guaranteed amount and a 0.55 percent annual retention fee, and because the loan exceeds the $10,000,000 maximum State Director authority under RD Instruction 1901-A it is approved at the National Office. The 28 jobs created are below the 50-job threshold that triggers Department of Labor concurrence. The feasibility study, the appraisal and the lender's fees are eligible uses of loan funds under 7 CFR 5001.121(c)(10).
Zoning and Entitlement
The model parcel lies in the southeast quadrant of the interchange within or adjacent to the City of Clinton's corporate limits. Clinton's zoning of the quadrant, the permitted-use status of a travel center with fuel sales and truck parking, and any site plan review, access permit or annexation step were not verified from the city's ordinance at the study date, and the determination is conditioned on the city's written zoning verification. Access is the second entitlement question: the parcel's driveway onto US-183 or the frontage road falls inside ODOT's reconstruction limits, and the access permit must be coordinated with the interchange design so that the truck entrance, the auto entrance and the queue for the diesel lanes work with the finished ramp geometry. MMCG carries 90 days of entitlement and access coordination ahead of the 12-month construction schedule, and the land contract should be contingent on both.
Utilities, Environmental and Property Tax
Water and sewer service are carried as municipal connections with tap and capacity fees inside the $1,300,000 site work line, together with a three-phase electrical service sized for the canopies, the refrigeration and the restaurant, and natural gas for the building. The underground storage system is six double-wall fiberglass tanks of 160,000 gallons total with secondary containment, interstitial monitoring and automatic tank gauging under the 2015 federal UST rule, carried at $860,000 installed. The site disturbs more than one acre and requires construction stormwater permit coverage under Oklahoma's construction general permit, and the truck court drains through oil-water separation to a detention basin. A Phase I Environmental Site Assessment under ASTM E1527-21 is carried in the land cost line; the parcel has no reported prior fuel use, and a finding to the contrary would escalate the review to a Phase II. Property tax is carried at $118,000 in Year 1 as an MMCG estimate built from the Clinton I-99 school district's certified levy of 96.02 mills for fiscal year 2023, which is identical for the urban and rural rows and includes the county, library, health department, school and career-tech levies, applied at Custer County's 11 percent assessment ratio on real property and 10 percent on business personal property, for an effective rate of about 1.06 percent of market value on the improvements and equipment, escalating 2 percent a year. Oklahoma taxes the equipment and inventory as business personal property, and the fuel inventory is carried inside that estimate.
Trade Area Demographics
The travel center's customer is the through truck and the through car, and the local trade area supplies the gasoline, the restaurant drive-through and the labor pool rather than the diesel.
| Measure | Value |
|---|---|
| City of Clinton population, 2020 Census | 8,521 |
| City of Clinton population, 2025 estimate | 8,302 |
| Custer County population, 2020 Census | 28,513 |
| I-40 traffic at the subject, underwriting basis | 21,000 vehicles per day, 32 percent trucks |
| Trucks passing the exit per day, underwriting basis | 6,720 |
| Passenger vehicles passing the exit per day, underwriting basis | 14,280 |
| Distance to Oklahoma City | About 85 road miles |
| Distance to Amarillo | About 175 road miles |
Source: U.S. Census Bureau, QuickFacts; Oklahoma Department of Transportation, 2023 Custer County AADT map; MMCG estimates.
Clinton's population has drifted down since 2020, which is why the model carries local gasoline and restaurant demand flat and places the growth in the corridor, where truck volume on I-40 follows the national freight forecast rather than the county's population.
Fuel Volume, Margin and Pricing Position
Diesel is modeled at 4,600,000 gallons at stabilization in Year 3, ramping from 3,312,000 gallons in Year 1 and 4,140,000 in Year 2 and growing 3 percent and 2 percent in Years 4 and 5. At six dual-sided high-flow lanes that is about 64,000 gallons a lane a month, above the 25,000 to 45,000 gallon band MMCG carries for an independent and well below the chain nodes, and it is the figure that defines the credit: the site must run its lanes at an independent's upper bound to cover at 1.35x. Gasoline is modeled at 1,400,000 gallons at stabilization.
Margin is modeled in cents per gallon, not as a share of pump price. At TravelCenters of America, the last travel center chain to file public financials before bp acquired it in May 2023, fuel gross margin per gallon ran from 14 cents in the first quarter of 2021 to 27 cents in the second quarter of 2022, averaged about 25 cents for 2022 and about 17 cents for 2021, and fell back to about 18 cents in the first quarter of 2023. MMCG carries diesel at 20 cents in Year 1, 21 cents in Year 2 and 22 cents from Year 3, and gasoline at 29, 30 and 31 cents, against the 35.7 cent average gasoline retail margin that the industry's price service reported in January 2025. Pump prices are normalized at $4.25 for diesel and $3.25 for gasoline for the revenue and card fee lines; U.S. on-highway diesel stood at $6.382 on September 28, 2026 and the Midwest average at $6.526, against a 2025 annual average of $3.660, and because the margin is carried in cents the price level affects the revenue total and the card fees rather than the gross margin. Fleet card fees on diesel are carried at 1.0 percent of sales and consumer card fees on gasoline at 2.5 percent, indexed to the pump price, which is why the card line rises with fuel prices even when the margin does not. At Year 3 the fuel lines earn $1,446,000 of gross margin and pay $309,250 of card fees, a net of $1,136,750, which is 31 percent of the Project's total gross margin; the other 69 percent is nonfuel, the same proportion the public chain reported.
Nonfuel Revenue
Nonfuel sales are modeled at $5,240,000 at stabilization: $3,300,000 of convenience store sales at a 36 percent margin, $1,300,000 of quick-service restaurant sales at a 68 percent margin after food cost with the restaurant's labor carried in payroll, $280,000 of diesel exhaust fluid at a 33 percent margin, and $360,000 of showers, reserved parking, scale, ATM and lottery commission at a 90 percent margin, for $2,488,400 of nonfuel gross margin at a blended 47.5 percent. Store sales of $9,041 a day equal $18.76 per fueling customer across the 133 trucks and 349 cars that fuel on an average Year 3 day, with the balance from drivers parking without fueling and from the local drive-through and store trade. The industry's 2025 survey puts foodservice at 28.5 percent of inside sales and 38.9 percent of inside gross profit and reports that the typical store's inside basket lost money after expenses in 2025, so the model carries the store at a 36 percent margin and does not assume that inside sales grow faster than fuel. Reserved parking is carried at 18 spaces at $18 a night and 50 percent paid occupancy, about $59,000 a year, inside the other income line; free parking runs near 90 percent occupancy on the industry's utilization surveys, and paid conversion is weak, so the paid line is small by design. Diesel exhaust fluid is modeled at 3 percent of diesel gallons at $2.03 a gallon net.
Project Cost Estimate
Location: Southeast quadrant of I-40 and US-183 (Exit 65A), Clinton, OK 73601 Size in SF (Gross): 9,500
| Item | Cost | Cost in % | Cost per SF |
|---|---|---|---|
| Land Cost | |||
| Land Acquisition (16.0 acres at I-40 and US-183) | $880,000 | 5.8% | $92.63 |
| Closing, Survey, Geotechnical and Phase I ESA | $60,000 | 0.4% | $6.32 |
| Total Land Cost | $940,000 | 6.2% | $98.95 |
| Hard Cost | |||
| Base Cost (9,500 SF travel center building) | $2,565,000 | 16.9% | $270.00 |
| Exterior Walls | $200,000 | 1.3% | $21.05 |
| Heating & Cooling | $240,000 | 1.6% | $25.26 |
| Plumbing, Showers and Grease Interceptor | $280,000 | 1.8% | $29.47 |
| Electrical Service, Lighting and Controls | $330,000 | 2.2% | $34.74 |
| Diesel Canopy (6 lanes) and Auto Canopy (12 positions) | $1,000,000 | 6.6% | $105.26 |
| Dispensers, Islands, DEF and Fuel Controls | $820,000 | 5.4% | $86.32 |
| Underground Storage Tank System (6 double-wall tanks, 160,000 gallons) | $860,000 | 5.7% | $90.53 |
| Truck Court, Heavy-Duty Paving and Lighting (90 spaces) | $2,000,000 | 13.2% | $210.53 |
| Site Work, Grading, Utilities and Stormwater | $1,300,000 | 8.6% | $136.84 |
| CAT Scale | $120,000 | 0.8% | $12.63 |
| Landscaping, Fencing and Sign Foundations | $130,000 | 0.9% | $13.68 |
| Architecture, Engineering and Permits | $420,000 | 2.8% | $44.21 |
| Hard Cost Contingency (6%) | $615,900 | 4.1% | $64.83 |
| Total Hard Cost | $10,880,900 | 71.9% | $1,145.36 |
| Improvements | |||
| Store Fixtures, Refrigeration and Foodservice Equipment | $760,000 | 5.0% | $80.00 |
| Point of Sale, Fuel Controller, Loyalty and Parking Reservation Systems | $180,000 | 1.2% | $18.95 |
| Pylon and Building Signage | $230,000 | 1.5% | $24.21 |
| Fuel Inventory and Opening Inventory | $380,000 | 2.5% | $40.00 |
| Total Equipment | $1,550,000 | 10.2% | $163.16 |
| Financial Cost | |||
| Construction Period Interest (12 months) | $515,000 | 3.4% | $54.21 |
| USDA B&I Guarantee Fee (3% of the 80% guaranteed amount) | $272,000 | 1.8% | $28.63 |
| Lender Origination Fee (1%) | $114,000 | 0.8% | $12.00 |
| Legal, Title, Appraisal and Closing | $95,000 | 0.6% | $10.00 |
| Pre-Opening Payroll, Training and Marketing | $180,000 | 1.2% | $18.95 |
| Interest and Operating Reserve | $589,000 | 3.9% | $62.00 |
| Total Financial Cost | $1,765,000 | 11.7% | $185.79 |
| Total Subject Project Cost | $15,135,900 | 100.0% | $1,593.25 |
Source: Marshall & Swift CoreLogic, MMCG
The truck court is the largest single line after the building: 90 heavy-duty spaces with fuel apron, lighting and drainage at about $22,000 a space, which is a fraction of the $113,395 average per space that state departments of transportation reported for public truck parking in 2025, because a private operator paves stalls on a graded commercial site without right-of-way or rest area buildings. The six-tank system at $860,000 and the dispensers, islands and controls at $820,000 are inside the contractor cost guides' 2026 ranges for a 16-position fueling program with high-flow diesel. The reserve of $589,000 funds the Year 1 shortfall of $486,682 against debt service with about $100,000 of margin, and construction interest is carried on an average 55 percent draw over 12 months at the loan rate. The originally proposed program carried the same land and a $22,400,000 total: a 12,000 SF building, a three-bay truck service shop at $1,290,000 with $240,000 of shop equipment, 120 spaces, a seven-tank system and a $2,169,000 reserve sized to its own Year 1 and Year 2 shortfalls.
Loan Assumptions
| Item | Value |
|---|---|
| LTC Ratio | 75.0% |
| Loan | $11,351,925 USDA B&I guaranteed loan, 80 percent guaranteed ($9,081,540) |
| Equity | $3,783,975 (25.0% of total project cost, the requirement where the loan note guarantee is issued before completion of construction) |
| Interest Rate | 8.25% fixed (MMCG assumption: the Wall Street Journal prime rate of 7.00% effective September 17, 2026 plus 1.25%) |
| Amortization | 30 years, within the program's 40-year maximum, no balloon |
| Annual Debt Service | $1,023,399 |
The loan is structured as a single B&I guaranteed term loan with a 12-month construction period, interest paid from the construction interest line, and the first installment within three years of the note as the regulation requires. The lender requests the loan note guarantee before completion of construction, which sets equity at 25 percent of total project cost and adds the 0.5 percent pre-completion fee to the guarantee fee line as carried. At 25 years the same loan would carry debt service of $1,074,051 and Year 3 coverage of 1.28x; the 30-year amortization is inside the useful life of the improvements and the program's term, and it is the amortization the determination relies on.
USDA B&I Program Compliance
The Project is an eligible commercial enterprise in a rural area under 7 CFR 5001.105 and 5001.3, and the borrower is a new business whose guaranteed loan exceeds $1,000,000, so the independent feasibility study is required by 7 CFR 5001.306(a)(3)(i) and the lender's credit evaluation must contain a written evaluation of it under 7 CFR 5001.202. Equity of 25 percent of total project cost meets 7 CFR 5001.105(d) for a loan note guarantee requested before completion of construction. The loan is collateralized by the land, the improvements, the equipment and the inventory, all fixed assets in the United States, and the personal guarantees of the principals are carried under 7 CFR 5001.204. The study presents projected balance sheets, income statements and cash flows through two years of stable operations with a stated assumption list and a pro forma balance sheet at closing, as 7 CFR 5001.303 requires, and the lender's global historical and projected debt service coverage analysis under 7 CFR 5001.315 is written from them. The fiscal year 2026 guarantee of 80 percent for a loan in the $5,000,000 to $25,000,000 tier, the 3 percent initial guarantee fee and the 0.55 percent annual retention fee are carried; the retention fee is the lender's cost and is priced into the rate. The loan is above the $10,000,000 maximum State Director authority and is approved at the National Office. No gaming revenue is projected, and no revenue from any activity listed as ineligible in 7 CFR 5001.127 is included.
Operating Expenses
| Expense | Year 1 | Year 2 | Year 3 | Year 4 | Year 5 |
|---|---|---|---|---|---|
| Payroll and burden (28 FTE, 24-hour operation) | $860,000 | $950,000 | $1,000,000 | $1,030,000 | $1,060,900 |
| Utilities | $198,000 | $213,400 | $220,000 | $226,600 | $233,200 |
| Repairs and maintenance | $104,500 | $110,000 | $110,000 | $113,300 | $116,699 |
| Insurance (property, liability, pollution) | $114,000 | $120,000 | $120,000 | $123,600 | $127,308 |
| Property tax (real and personal, Clinton I-99 levy) | $118,000 | $118,000 | $118,000 | $120,360 | $122,767 |
| QSR franchise royalty and advertising fund (9% of QSR sales) | $84,240 | $105,300 | $117,000 | $124,125 | $130,332 |
| Marketing and loyalty | $66,500 | $70,000 | $70,000 | $72,100 | $74,263 |
| Supplies, uniforms, laundry and shower consumables | $85,500 | $90,000 | $90,000 | $92,700 | $95,481 |
| Administrative, accounting, payroll service and licenses | $114,000 | $120,000 | $120,000 | $123,600 | $127,308 |
| UST compliance, monitoring and environmental | $33,250 | $35,000 | $35,000 | $36,050 | $37,132 |
| Card and bank fees on nonfuel sales (2.2%) | $83,002 | $103,752 | $115,280 | $122,301 | $128,416 |
| Other operating | $76,000 | $80,000 | $80,000 | $82,400 | $84,872 |
| Total operating expenses | $1,936,992 | $2,115,452 | $2,195,280 | $2,267,136 | $2,338,677 |
Payroll of $1,000,000 at stabilization covers a general manager at $72,000, two assistant managers at $48,000 and 25 FTE at an average of $15.75 an hour, with an 18 percent burden, for an average of $35,714 per FTE across 28 positions over three shifts, escalating 3 percent a year. Year 3 operating expenses of $2,195,280 are 41.9 percent of nonfuel revenue, below the 49.8 percent of nonfuel revenue the public chain reported for its site-level operating expenses in 2022, because the subject carries no truck service shop, no full-service restaurant and a franchised restaurant whose labor is leaner than a chain's company kitchen; the ratio falls to 40.1 percent by Year 5. Insurance is carried at $120,000 for property, general liability and the pollution legal liability policy that a fuel storage site requires, and the UST line carries the monitoring, testing and Oklahoma Corporation Commission compliance program.
Five-Year Pro Forma and Debt Service Coverage
| Line | Year 1 | Year 2 | Year 3 | Year 4 | Year 5 |
|---|---|---|---|---|---|
| Diesel gallons | 3,312,000 | 4,140,000 | 4,600,000 | 4,738,000 | 4,830,000 |
| Gasoline gallons | 1,008,000 | 1,260,000 | 1,400,000 | 1,442,000 | 1,470,000 |
| Fuel revenue | $17,352,000 | $21,690,000 | $24,100,000 | $24,823,000 | $25,305,000 |
| Nonfuel revenue | $3,772,800 | $4,716,000 | $5,240,000 | $5,559,116 | $5,837,072 |
| Total revenue | $21,124,800 | $26,406,000 | $29,340,000 | $30,382,116 | $31,142,072 |
| Fuel gross margin | $954,720 | $1,247,400 | $1,446,000 | $1,489,380 | $1,518,300 |
| Less fuel card fees | ($222,660) | ($278,325) | ($309,250) | ($318,528) | ($324,712) |
| Nonfuel gross margin | $1,791,648 | $2,239,560 | $2,488,400 | $2,639,944 | $2,771,941 |
| Total gross margin | $2,523,708 | $3,208,635 | $3,625,150 | $3,810,796 | $3,965,528 |
| Total operating expenses | $1,936,992 | $2,115,452 | $2,195,280 | $2,267,136 | $2,338,677 |
| EBITDA | $586,716 | $1,093,183 | $1,429,870 | $1,543,660 | $1,626,851 |
| EBITDA margin on total gross margin | 23.2% | 34.1% | 39.4% | 40.5% | 41.0% |
| Replacement reserve | $50,000 | $50,000 | $50,000 | $50,000 | $50,000 |
| Cash flow available for debt service | $536,716 | $1,043,183 | $1,379,870 | $1,493,660 | $1,576,851 |
| Annual debt service | $1,023,399 | $1,023,399 | $1,023,399 | $1,023,399 | $1,023,399 |
| Cash flow after debt service | ($486,682) | $19,784 | $356,471 | $470,262 | $553,452 |
| Debt service coverage | 0.52x | 1.02x | 1.35x | 1.46x | 1.54x |
The Year 1 shortfall of $486,682 is funded from the reserve. The Project covers from Year 2 at 1.02x, reaches 1.35x in Year 3 and builds to 1.54x by Year 5, and its Year 3 EBITDA of $1,429,870 is a 9.4 percent yield on total project cost, rising to 10.7 percent in Year 5. Total revenue of $29,340,000 at stabilization is 82 percent fuel by sales and 31 percent fuel by gross margin, the structure of every travel center: the pumps bring the trucks, and the store, the restaurant, the showers and the parking earn the coverage. As originally proposed, the same demand produces Year 3 EBITDA of $1,002,385 against debt service of $1,511,578 on a $16,767,000 loan, coverage of 0.62x, because the shop and the larger building add $7,300,000 of cost, about $400,000 of gross margin and the labor of four technicians and an enlarged store crew.
Break-Even Analysis
At Year 3 margins, the Project's fixed operating cost is $2,013,000 including the replacement reserve, and its contribution after card fees, franchise fees and cost of goods is 56.6 cents for every gallon of fuel sold with the nonfuel sales that gallon pulls into the store. Thresholds are stated as a share of the Year 3 forecast of 6,000,000 total gallons.
| Threshold | Total gallons | Share of forecast | Diesel gallons per day |
|---|---|---|---|
| EBITDA break-even | 3,471,397 | 57.9 percent | 7,292 |
| 1.00x debt service coverage | 5,369,611 | 89.5 percent | 11,279 |
| 1.25x debt service coverage | 5,822,059 | 97.0 percent | 12,229 |
| Year 3 forecast | 6,000,000 | 100.0 percent | 12,603 |
The 1.25x threshold at 97 percent of forecast gallons is the credit's honest statement at Year 3: the site must run close to its stabilized forecast to reach the coverage most B&I lenders write into the conditional commitment, and the margin widens to about 6 percent of forecast by Year 4 and 8 percent by Year 5 as nonfuel sales grow and the fixed lines do not. The 1.0x threshold at 89.5 percent of forecast, 11,279 diesel gallons a day and 119 fueling trucks, is the volume an independent at this interchange reaches in Year 2.
Sensitivity Analysis
| Case (Year 3) | Total revenue | EBITDA | Debt service coverage |
|---|---|---|---|
| Base case | $29,340,000 | $1,429,870 | 1.35x |
| Diesel margin of 16 cents per gallon | $29,340,000 | $1,153,870 | 1.08x |
| Diesel gallons 15 percent below forecast | $26,407,500 | $1,307,395 | 1.23x |
| Nonfuel sales 15 percent below forecast | $28,554,000 | $1,091,452 | 1.02x |
| Operating expenses 10 percent above budget | $29,340,000 | $1,233,570 | 1.16x |
| Interest rate 100 basis points higher | $29,340,000 | $1,429,870 | 1.23x |
| Combined: 16 cent margin and diesel gallons 15 percent below | $26,407,500 | $1,072,795 | 1.00x |
| Combined: nonfuel 15 percent below and operating expenses 10 percent above | $28,554,000 | $895,152 | 0.83x |
| Amortization of 25 years instead of 30 | $29,340,000 | $1,429,870 | 1.28x |
| As originally proposed: 12,000 SF with truck shop and 120 spaces at $22,400,000 | $32,045,000 | $1,002,385 | 0.62x |
The Project holds coverage above 1.0x in every single-factor case. The two cases that bite are a diesel margin reset to 16 cents, which is below every full-year figure the public chain reported from 2021 through 2023 and takes coverage to 1.08x, and a 15 percent shortfall in nonfuel sales, which takes it to 1.02x and shows where the risk sits: a travel center that sells the diesel but not the store does not cover. The combined downside of a 16 cent margin and gallons 15 percent short holds 1.00x, and the combined nonfuel and expense case falls to 0.83x. The as-proposed row is the reason the Project is sized as it is.
Risk Factors and Mitigants
- Traffic basis. The ODOT classified count at Exit 65A was not retrieved; the underwriting basis of 21,000 vehicles per day and 32 percent trucks sits at the bottom of the 2023 county map's range for the corridor, and the determination is conditioned on the count.
- Interchange reconstruction. ODOT's $76,000,000 rebuild of the Exit 65 and 65A interchanges runs through about 2028. The Year 1 ramp carries a construction-period haircut, the reserve covers the Year 1 shortfall, and the construction schedule and access permit must be reconciled to ODOT's phasing.
- Chain competition. One national chain holds the nodes at Exits 41, 71 and 101 with fleet contracts and loyalty routing. The subject's 2 percent capture is set against that, and the sensitivity table shows 1.23x with gallons 15 percent short.
- Diesel margin. Retail diesel margin is a volatile spread; the 2026 price surge compresses it when wholesale rises. The model carries 22 cents against a public chain record of 17 to 25 cents on annual averages and tests 16 cents.
- Nonfuel dependence. Sixty-nine percent of gross margin is nonfuel. The store, the restaurant and the showers are the credit, and the sponsor's retail and foodservice operating experience is a management-component finding the lender should weigh.
- Thin Year 3 margin. The 1.25x threshold sits at 97 percent of forecast gallons in Year 3 and at 94 percent by Year 4. A lender writing a 1.25x covenant should test it from Year 4, or write 1.10x for Year 3.
- Entitlement and access. The city's zoning verification and the ODOT access permit are conditions, and the land contract should be contingent on both.
- Fuel supply. An unbranded independent needs a jobber supply agreement and fleet card acceptance before opening; the agreement is a condition and its minimum volume and termination terms must fit the ramp.
Conditions and Limitations
The determination of feasible as sized is subject to the following conditions precedent:
- An ODOT classified count at or adjacent to the I-40 and US-183 interchange, with station identifier and count year, at or above the underwriting basis of 21,000 vehicles per day and 32 percent trucks.
- An executed fuel supply agreement with a jobber or distributor for unbranded diesel and gasoline, with fleet card acceptance on the major networks in place at opening and minimum volume terms that do not exceed the Year 1 forecast.
- A construction schedule and an ODOT access permit reconciled to the phasing of the Exit 65 and 65A interchange reconstruction, so that the diesel lanes open to a finished ramp, with the land contract contingent on the permit.
- The City of Clinton's written zoning verification that a travel center with fuel sales and truck parking is a permitted use on the parcel, or approval of any rezoning or site plan the city requires.
The following items could not be verified from a primary source at the study date and are disclosed: the ODOT classified count and truck share at Exit 65A, in place of which the study carries the floor of the 2023 county map's corridor range; the open-to-traffic date of ODOT's Exit 65 and 65A reconstruction, carried as an estimate of 2028 from ODOT's contract documents as reported; the asking price and the zoning of any specific interchange parcel, in place of which the study carries a model parcel at $55,000 per acre inside the listed range; the truck parking counts at the Clinton and Elk City travel stops after their 2025 rebuilds; the diesel lanes, parking and amenities of the three independent stops, carried from directories; the Custer County assessor's current assessment ratio and the fiscal year 2027 levy, in place of which the study carries the fiscal year 2023 certified levy of 96.02 mills and the 2022 ratios of 11 percent real and 10 percent personal; Oklahoma's current construction stormwater permit terms; the May 2025 Oklahoma nonmetropolitan wages for cashiers, food preparation and fuel attendants; and the primary SBA and USDA text of any fiscal year 2027 fee notice, which had not been published at the study date.
What the Study Contains
- The written determination with the as-proposed and as-sized programs stated side by side and the four conditions precedent
- The rural eligibility finding, the new business finding and the 7 CFR 5001.306 trigger
- The freight demand basis: the hours-of-service stop-point logic, the FHWA truck share, the ODOT corridor counts and the capture rate by class
- The competitor census with the chain nodes and the independents placed on the corridor and the directory counts flagged
- The fuel volume and cents-per-gallon margin model with the public chain's margin record and the card fee treatment
- The nonfuel revenue model by line, with the store, restaurant, DEF, showers and reserved parking stated separately
- The project cost estimate and loan assumptions in MMCG's standard format, with the 25 percent equity requirement and the guarantee fee carried
- The operating budget by line with the expense ratio reconciled to the public chain
- The five-year pro forma, debt service coverage by year and break-even gallons at each test
- The sensitivity cases, including the 25-year amortization case and the as-proposed case
- The B&I compliance notes: eligibility, equity, guarantee tier and fee, National Office approval, collateral and guarantees
This model study applies the methodology described on MMCG's truck stop feasibility study and USDA travel center feasibility study pages. MMCG prepares truck stop and travel center feasibility studies for USDA Business and Industry, SBA 7(a) and 504, and conventional lenders nationwide, with engagements from $4,900 and delivery in 9 to 16 business days.
Sources
- Oklahoma Department of Transportation, 2023 Annual Average Daily Traffic, Custer County map
- Oklahoma Department of Transportation, Transportation Commission meeting wrap-up, January 2026, as reported by KECO and Oklahoma Energy Today
- Oklahoma Department of Transportation, I-40 Exit 65 and 65A interchange project in Clinton, public input notice, December 2020
- U.S. Census Bureau, QuickFacts, Clinton city, Oklahoma, Vintage 2025
- Oklahoma State University Extension, AE #24001, Oklahoma Ad Valorem Mill Levies, Fiscal Year 2023, January 2024
- Oklahoma Tax Commission, Ad Valorem Division, Ad Valorem Statistics 2022
- Federal Highway Administration, Highway Statistics 2024, Table VM-1
- Federal Highway Administration, Freight Analysis Framework Version 5, forecast to 2050
- Federal Motor Carrier Safety Administration, Summary of Hours of Service Regulations
- New Mexico Department of Transportation, I-40 Corridor Study Executive Summary, October 2024
- Love's Travel Stops, Clinton, Elk City, Hinton, Erick and El Reno location pages, and CDLLife report on the 2025 Clinton rebuild
- Find Truck Service and AllStays directory listings, truck stops near Clinton, Oklahoma, 2026
- LandSearch, LandWatch and Homes.com, commercial land listings, Clinton, Oklahoma, September 2026
- TravelCenters of America Inc., Form 10-K for fiscal year 2022 and Form 8-K earnings exhibits for 2021 through the first quarter of 2023
- NACS, State of the Industry 2026 release, April 2026, and NACS Magazine, June 2026
- NACS Convenience Corner, Who Makes Money Selling Gas, citing OPIS Retail Fuel Watch, January 30, 2025
- U.S. Energy Information Administration, Gasoline and Diesel Fuel Update, September 29, 2026, and 2025 annual average
- American Transportation Research Institute, State-Level Public Truck Parking Findings, April 2025
- U.S. Department of Transportation, Jason's Law Truck Parking Survey Results and Comparative Analysis
- Terrapin Construction Group, WFO Construction, UST Contractors and CommTank, 2026 fuel retail construction and tank cost guides
- 7 CFR Part 5001, Sections 5001.3, 5001.105, 5001.121, 5001.127, 5001.202, 5001.204, 5001.303, 5001.306 and 5001.315
- USDA Rural Development, OneRD Guaranteed Loan fiscal year 2026 fee and guarantee notice, 91 FR 11272, March 9, 2026
- USDA Rural Development, RD Instruction 1901-A, approval authorities
- Wall Street Journal, U.S. prime rate, effective September 17, 2026
- U.S. Environmental Protection Agency, 2015 revisions to the underground storage tank regulations, 40 CFR Part 280
- ASTM International, E1527-21, Standard Practice for Environmental Site Assessments
- Marshall & Swift CoreLogic, commercial cost data
