Executive Briefing
The Three Gates Every New Texas Car Wash Must Clear: Use, Water and Site
Fewer express car washes are being built, and each one is harder to get approved. The industry added an estimated 943 new express locations in 2022, about...
Executive summary
Fewer express car washes are being built, and each one is harder to get approved. The industry added an estimated 943 new express locations in 2022, about 550 in 2025, and fewer than 450 are expected in 2026 [1]. Capital costs, saturation and lender caution all play a part. For the sites that still go ahead, the questions have changed. Texas cities now ask about water, spacing and drainage before they ask about traffic.

A new wash has to clear three gates before it opens.
- The use gate. Is a car wash allowed on this parcel, and on what conditions? Spacing rules, conditional use permits and the conditions attached to them decide it [3] [4].
- The water gate. Can the utility serve the wash, and does the design show how? Meter and service sizing, backflow protection, sewer capacity, the grit and oil interceptor and the connection to your reclaim system all sit here.
- The site gate. Does the wash fit the ground? Tunnel depth, stacking, the driveway onto the highway and drainage that works with the neighbors decide it.
Each gate can stall a site that already pencils, and a stall is not free. On a project that costs $3.5 million to $10.5 million with land [2], carrying cost runs roughly $20,000 to $80,000 a month at an illustrative 7% to 9% cost of capital. A six-month delay can cost $120,000 to $480,000 before a single membership is sold [2].
This briefing walks through each gate with the public record behind it, then what we have seen on two Texas sites. It closes with a checklist to answer before your letter of intent goes hard, what to send us, and one next step.
Two express car wash sites designed for one North Texas operator. One in a North Texas suburb, through city civil review. One in an East Texas city, in design.
10 days to the first civil review on the first site.
165+ small-footprint sites among 525+ completed projects, licensed in 9 states.
943 new express locations in 2022, fewer than 450 expected in 2026 [1]. Each new site faces harder questions.
What the decision checklist covers
- Is a car wash an allowed use on this parcel, or does it need a conditional or specific use permit?
- Does the city have a spacing rule for car washes, and is the nearest existing or approved wash outside it?
- Is a spacing rule, moratorium or ordinance change on an upcoming agenda?
- What conditions did the city attach to its last two car wash approvals
- Which drought stage is the serving utility in, and what does its drought plan say about car washes?
- Has the utility confirmed the service size, the meter size and model, and the meter vault detail it requires?
- Is the backflow assembly type, location and testing shown on the plans?
- Is the grit and oil interceptor sized, and does the sewer connection show where the reclaim system's reject water goes?
- Can the sewer in front of the parcel take the flow without an extension or a lift station?
- Can you show the council your fresh water per car against the state benchmark of 35 gallons, from your own design?
- Does the parcel have at least 225 feet of depth for the tunnel, stacking and vacuums, drawn to scale with the fire lane?
- Does the stacking hold 12 to 15 or more cars without backing into the street?
- If the driveway is on a state highway, has the driveway permit started alongside the site plan?
- Do you have the neighbors' approved plans and as-built storm records, and does your drainage tie into theirs?
- Is the project registered for accessibility review, with the accessible stall and route in the first site plan?
- Has the fire marshal confirmed the sprinkler threshold, fire line and fire lane?
- The parcel address and the city
- Your letter of intent date and target opening date
- The reclaim system you plan to use
- Whether the driveway is on a state highway
From the full briefing


Sources
- [1] MMCG, "The US Car Wash Industry in 2026: The Gold Rush Meets Its Ceiling," July 2026. https://www.mmcginvest.com/post/the-us-car-wash-industry-in-2026-the-gold-rush-meets-its-ceiling (opens in a new tab)
- [2] Innowave Studio, "Car Wash Development in 2026: A Complete Market and Feasibility Guide," updated October 2026. https://www.innowave-studio.com/post/car-wash-development-in-2026-a-complete-market-and-feasibility-guide (opens in a new tab)
- [3] City of Brownsville, City Commission highlights, March 19, 2024. https://www.brownsvilletx.gov/CivicAlerts.aspx?AID=1859 (opens in a new tab)
- [4] City of McAllen, Unified Development Code, Section 3.2.4.D (Car Wash), adopted February 9, 2026. https://www.mcallen.net/docs/default-source/planning-files/revised-UDC.pdf (opens in a new tab)
- [5] City of Mission, City Council minutes, April 28, 2026 (Ordinances 5806 and 5807). https://mccmeetings.blob.core.usgovcloudapi.net/missiontx-pubu/MEET-Minutes-f0b4f3fbdae14aea94d21dca6820ac7e.pdf (opens in a new tab)
- [6] City of Mission, Ordinance 5794 (moratorium), March 24, 2026, council packet. https://mccmeetings.blob.core.usgovcloudapi.net/missiontx-pubu/MEET-Packet-8a0710743e024198a1f23445113a5c8a.pdf (opens in a new tab)
- [7] Texas Legislature, House Bill 2559, 89th Legislature, enrolled text, 2025. https://capitol.texas.gov/tlodocs/89R/billtext/html/HB02559F.htm (opens in a new tab)
- [8] Texas Local Government Code, Chapter 212, Sections 212.134 and 212.1362, current text cited October 2026. https://statutes.capitol.texas.gov/Docs/LG/htm/LG.212.htm (opens in a new tab)
- [9] Texas Commission on Environmental Quality, Drought Contingency Plans, undated page cited October 2026. https://www.tceq.texas.gov/permitting/water_rights/wr_technical-resources/contingency.html (opens in a new tab)
- [10] Texas Water Code, Section 11.1272, current text cited October 2026. https://statutes.capitol.texas.gov/Docs/WA/htm/WA.11.htm (opens in a new tab)
- [11] Texas Commission on Environmental Quality, Cross-Connection Control (30 TAC 290.44(h)), January 2025. https://www.tceq.texas.gov/downloads/drinking-water/dwawg/2025/1q2025/20250114_dwawg_cross-connection-control.pdf/@@download/file/20250114_DWAWG_Cross%20Connection%20Control.pdf (opens in a new tab)
- [12] Austin Water, Car Wash Grit Trap Sizing Criteria, undated page cited October 2026. https://www.austintexas.gov/department/car-wash-grit-trap-sizing-criteria (opens in a new tab)
- [13] Texas Commission on Environmental Quality, RG-434, vehicle washing guidance, revised June 2026. https://www.tceq.texas.gov/downloads/assistance/publications/rg-434.pdf/@@download/file/rg-434.pdf (opens in a new tab)
- [14] US EPA WaterSense at Work, Section 5.4 Vehicle Washes, posted 2023. https://www.epa.gov/system/files/documents/2023-11/ws-commercial-bmp-watersenseatwork_section5.4_vehiclewashes.pdf (opens in a new tab)
- [15] Texas Water Development Board, Commercial and Institutional Water Conservation Best Management Practices Guidebook, May 2018. https://www.twdb.texas.gov/conservation/BMPs/CI/doc/Commercial%20&%20Institutional%20BMP%20Guidebook.pdf (opens in a new tab)
- [16] Texas Department of Transportation, Access Management Manual, Driveway Permits, undated page cited October 2026. https://www.txdot.gov/manuals/des/acm/chapter-2--access-management-standards/section-4--driveway-permits--design--and-materials/permits.html (opens in a new tab)
- [17] Texas Department of Licensing and Regulation, Architectural Barriers at a Glance, undated, cited October 2026. https://www.tdlr.texas.gov/media/pdf/eab-at-a-glance.pdf (opens in a new tab)
- [18] Texas Department of Licensing and Regulation, 2012 Texas Accessibility Standards. https://www.tdlr.texas.gov/ab/2012abtas2.htm (opens in a new tab)
- [19] International Carwash Association, Water Use, Evaporation and Carryout in Professional Car Washes, 2018. https://www.carwash.org/hubfs/Pulse%20and%20Research/Water+Use%2c+Evaporation+and+Carryout+in+Professional+Car+Washes.pdf (opens in a new tab)
The full briefing has the evidence with its sources, what MES has seen on projects like yours and the whole checklist. It is free: ask for it below and we email you a download link.
Free download
Get the full briefing
The full briefing is a PDF: the evidence with its sources, what MES has seen on projects like yours, and the whole decision checklist. We email you a link to it, and the link works for 7 days.
Next step
Get an answer on your site
The next step is a call with Mike. His team researches your site first, so the call starts with your parcel, not a sales pitch.
Mike's direct line: (719) 781-8734