Truck stop and travel center site plan, Waller County, Texas

A model travel center on I-10 west of Houston

This is a model project: a truck stop and travel center placed on a hypothetical parcel in unincorporated Waller County, Texas, on I-10 between Katy and Sealy, to show how an unzoned county and two state agencies shape a preliminary site plan. Nothing here was built. Every rule, fee and comparable comes from the county's regulations, TxDOT and TCEQ documents, public records and named news reports, cited to the source.

Waller County is the jurisdiction because it publishes a current county rulebook: Subdivision and Development Regulations effective March 15, 2021 and amended December 6, 2023, a fee schedule adopted July 24, 2024, and a county Fire Code on the 2021 International Fire Code with all appendices, effective January 1, 2025 ^{[3, 5, 6, 7]}. Its regulations page also posts a Flood Damage Prevention Ordinance revised 2021, with changes posted as Rev 10-17-2025 ^[1]. The corridor has the traffic for the program: TxDOT's Brookshire-Pattison Mobility Study (March 3, 2025) puts trucks at 24% of I-10 traffic there, against an 18% Texas interstate average, and projects truck traffic growing from 14,000 in 2023 to 30,100 in 2045 ^[8].

The asset in general is covered on the truck stop site plan hub, and its fuel island side on the gas station site plan hub and on gas station site plans in Texas. The state picture is on site plans in Texas and the metro on Houston site plans. How Texas counties regulate land without zoning is set out in RV park approval in Texas counties, and another unzoned Texas county case is the RV and boat storage model in Montgomery County.

At a glance

The county regulates platting, streets, drainage and driveways, floodplain development, the fire code for commercial establishments, and on-site sewage under TCEQ delegation ^{[3, 7]}. It has also taken up "No Thru Trucks" restrictions on county roads after public hearing; one came before the Commissioners Court on January 12, 2022 ^[10].

City lines still matter on I-10. Inside a city's ETJ the plat must carry "Approval of the appropriate jurisdiction when the subdivision is within the extraterritorial jurisdiction (ETJ) of that city" (Section 3.4.22), procedures follow "individual city interlocal agreements" (Section 3.3.6), and variances affecting an ETJ go through the city under "Local Government Code 242.001" (Section 8.3) ^[3]. Since September 1, 2023, SB 2038 has let the owners of a majority in value of an area petition a city for release from its ETJ, and a valid petition obliges the city to release the area at once ^[11]. Inside city limits, city zoning and building codes apply; the City of Waller adopted a new permit fee schedule effective August 21, 2025 ^[12]. In the Brookshire-Katy Drainage District, "the Developer shall obtain written approval from the District of the development plans" before final plat approval (Section 3.5.2), and where the county and district rules differ, "the more stringent of the two shall apply" ^[3].

Approval path

The published county fees that apply to the model come from the July 24, 2024 schedule and the fire code fee schedule; they exclude outside engineering review, TxDOT, TCEQ and the drainage district ^{[5, 22]}:

The regulations and the schedule disagree on two fees. Section 11.7 lists $500 per non-residential variance, while the July 24, 2024 fee schedule lists $1,000; Section 11.1 lists "$50 per lot plus $50 per reserve" for a preliminary plat. The newer fee schedule controls both ^{[3, 5]}.

When a plat is required decides part of the layout. Waller County defines a subdivision as "the division of a tract into two or more parts with any of the tracts being 10 acres or less in area" (Section 2.22) ^[3]. One 25-acre tract that is not divided and lays out no streets takes a plat exemption instead, under Sections 13 and 13.2 ^[3]. Carving off QSR or hotel pads of 10 acres or less triggers a plat, and "No 911 address will be provided for any development type (i.e. residential or commercial) until proof of adherence to platting regulations is confirmed" (Section 9.1) ^[3].

Design standards that shape the layout

The provisions that bind the layout

TxDOT Access Management Manual, frontage roads ^[28]:

"Direct access to the frontage road is prohibited in the vicinity of ramp connections, as described in the TxDOT Roadway Design Manual, Chapter 3."

The note under Table 2-1 ^[28]:

"Distances are for passenger cars on level grade. These distances may be adjusted for downgrades and/or significant truck traffic."

On ramp patterns ^[28]:

"While Table 2-1 gives minimum connection spacing criteria, the critical areas with respect to the ramp pattern may need greater spacing requirements for operational, safety, and weaving efficiencies."

TxDOT Roadway Design Manual 8.1.21 ^[31]:

"In these cases, at least 250-ft of separation should be provided from the intersection of the exit ramp and frontage road travel lanes to the downstream driveway or side street."

Waller S&DR 3.4.15 ^[3]:

"Front building lines shall be 25 feet. Side street building lines shall be 15 feet on local streets, 25 feet on collector streets and 35 feet on arterial streets."

Waller Appendix E, drainage policy and detention ^[3]:

"it shall be the policy of Waller County to maintain zero net increase in storm water runoff rates and to insure no negative impacts attributable to new development."

"developers will provide adequate on-site detention volume to off-set increased runoff rates and must provide compensating storage volume for all fill placed in the 1% annual chance (100-year) and 0.2% annual chance (500-year) floodplain. Development in the delineated 100-year floodway will be restricted by Waller County."

"In no case shall the detention storage rate be less than 0.55 ac-ft per acre."

"This method will not be allowed where the total developed area (either proposed or in the future) will exceed 5 acres for commercial or 10 acres for residential developments."

"They must be designed and constructed with stable slopes (4:1), they must provide adequate access and maintenance berms around the entire perimeter (30' minimum)."

Waller Appendix B, Item 8 ^[3]:

"Structures built on lots in the designated Floodplain shall be elevated to two (2) feet or more above the 500-year floodplain elevation, in the 100-year floodplain. Within the 500-year, these structures must be elevated to one (1) above the 500-year floodplain elevation. No development permits will be issued in a Flood Hazard Area below the base flood elevation (B.F.E.)."

Waller S&DR 3.6.2, pipelines ^[3]:

"If no agreement can be reached on a defined easement, then building setback lines shall be shown at a minimum distance of 25 feet from and parallel to the nearest pipeline or facility."

Waller Appendix A 11.1 and 3.4, county roads ^[3]:

"Minimum driveway spacing on arterial streets without curb and gutter shall be 200 feet."

"County may require an internal street system that minimizes street cuts to existing County streets."

Waller County Fire Marshal ^[7]:

"All architectural plans must include a full site plan that shows all fire lane/fire access roads, fire hydrant locations, and reference the relevant codes."

Constraints that resize the project

Determination: as proposed and as resized

As proposed. The model project assumes the brief's program: 10 to 16 auto fueling positions, 6 to 10 diesel lanes, 80 to 150 truck spaces, and an 8,000 to 15,000 SF store with QSR, scales and an optional truck wash, on 15 to 30 acres.

The corridor sets the yardstick for the truck court. Existing stops on I-10 between Houston and San Antonio, from directories and an operator page:

A 150-space truck court would exceed every stop in that list. Recent Love's openings, two Texas rebuilds on I-20 and the Boerne Buc-ee's show the store and fuel programs operators build now:

What the rules do to it.

• Access. At 50 mph or more, frontage road driveways sit 425 ft (one-way) or 510 ft (two-way) apart, direct access is prohibited near ramp connections, and the constrained case keeps at least 250 ft from the exit ramp to the first downstream driveway ^{[2, 28, 31]}. Table 2-1 distances are for passenger cars and "may be adjusted for downgrades and/or significant truck traffic" ^[28]. The model locates its frontage road driveways against those distances first, brings truck ingress from the cross street or a rear county road, and separates auto and truck circulation, with the county's 200 ft arterial driveway spacing and its internal street system clause governing the county road side ^[3].
• Drainage. Detention is sized to zero net increase in runoff and never below 0.55 ac-ft per acre, with compensating storage for any fill in both the 100-year and the 500-year floodplain. The coefficient method is not allowed above 5 developed acres for a commercial site, ponds need 4:1 slopes and a 30 ft maintenance berm around the whole perimeter, and ponds over 2 acres need 1 ft of freeboard ^[3]. The B-KDD's rule applies where it is the more stringent ^[3]. The preliminary plan carries the detention reserve as a plat reserve; the volume is the engineer of record's.
• Wastewater. On-site sewage stops at 5,000 gallons per day ^[4]. No flow figure for this program was found, so the model plans a utility sewer connection and treats 5,000 gpd as the ceiling for any on-site system; above it, TCEQ asks for permit applications at least 330 days before discharge ^[21].
• Platting. Pads of 10 acres or less trigger a plat, and a 911 address waits on plat compliance ^[3], so the model is platted, with a master plan for phased plats (Section 3.4.18) ^[3].
• Where a use hearing exists. The truck elements are what gets conditioned or cut: Boerne prohibited 18-wheeler fueling except deliveries and required "Dark Sky-compliant lighting with shielded fixtures" ^[46], and the Jefferson County, Florida travel plaza came back with 16 truck spaces instead of 126 after its denial ^[47]. In the unincorporated county, scales and the truck court stay in the program.

As resized. The model project assumes a 25-acre platted site with a 12,000 SF store, one reserve and land outside the flood zone, the inputs of the county fee table above. Frontage road driveways are fixed by Table 2-1 and the 250 ft ramp separation before anything else is drawn; the detention reserve is drawn at the 0.55 ac-ft per acre floor with its 30 ft berms and 4:1 slopes and held at full build-out; the truck court takes the land left inside the 25 ft building lines and the pipeline setbacks, within the model's 80 to 150 space range; and the truck wash and expansion parking move to a second phase.

Site data and yield

The preliminary plat checklist asks for lots, reserves, setbacks, right-of-way, an area table and detention reserves ^[3], so the site data table on the preliminary plan is drawn to feed the plat directly.

Comparable approvals and pushback, 2021 to 2026

The comparables below are the closest county records, followed by host-community cases with documented outcomes in other jurisdictions, each labeled by jurisdiction and source type.

In Waller County. These are plat, variance and state accessibility registry records, not truck stop approvals.

Host-community cases with outcomes.

Boerne in more detail. The city said the project is "vested under 2019 city regulations, based on the date of the travel center's preliminary plat application" ^[69], and opponents asked for a new traffic study and a wall separating the site from neighborhoods ^{[70, 69]}. The city's August 2025 briefing records the conditions in the table and a core preliminary plat of 29.22 acres, and says construction began in 2025 ^[46]. MySA reports a $38 million development, an accessory parking rezoning heard in 2025 and an opening in 2027 ^[71]; the city records $40 million of private investment announced in August 2016 ^[46].

What the record shows. Across these cases the objections are noise, lighting, traffic on local roads and how the process was run. In unincorporated Waller County the formal levers are the plat, variances, "No Thru Trucks" orders and TxDOT access, so the model draws shielded lighting positions, perimeter buffers and an internal truck route that stays off county roads.

Cost and phasing benchmarks

TDLR figures are registrant-declared estimates for the accessibility-reviewed scope; registration applies at $50,000 or more of estimated construction cost ^[23]. Texas UST owners carry their own financial assurance (30 TAC Ch. 37 Subch. I) ^[27].

Phasing. The model project assumes two phases: the store, auto fuel and diesel lanes and the core truck court first, with detention sized for full build-out; expansion truck parking, the truck wash and pad sites second. Waller allows a master plan for phased plats (Section 3.4.18) ^[3]. The clocks that set the sequence: the preliminary plat lapses unless the final plat follows within 1 year (3.5.8), improvements are due within 12 months of the plat, and a drainage approval expires after 1 year without construction ^[3]; each phase files its UST construction notice at least 30 days before construction, and the notice is valid for 180 days ^{[18, 19]}; and a TCEQ wastewater permit needs an application at least 330 days before discharge ^[21].

Submittal anatomy: preliminary plan and engineer of record

The regulations set no seal requirement in Section 3.1, the pre-application procedure ^[3]. Drainage plans and reports and improvement plans are sealed by a Texas PE, the final plat by an RPLS with a PE certification under seal, the TIA by a Texas-licensed engineer, and fire code plans by a licensed design professional ^{[3, 14, 7]}.

Waller County requires no renderings, elevations, landscape plans or photo simulations for unzoned commercial sites; the required drawings are engineering-based ^{[3, 7]}. Landscape plans come in only for landscaping in the public right-of-way (Sections 5.6, 5.7) ^[3]. Where light and noise drive objections, as in Boerne, Jefferson County and at Monument Hill, 3D renderings tied to the plan, including night views and aerial context toward the nearest homes, answer the question the hearing asks.

Conditions and handoff

The county's conditions are financial and procedural rather than design conditions: construction security equal to 100% of the engineer's estimate, a 25% maintenance bond, improvements within 12 months of the plat, no 911 address until the plat is compliant, and permit fees that double if work starts before a permit is issued ^{[3, 16]}. Variances go to the Commissioners Court, at $1,000 for a non-residential variance under the 2024 fee schedule ^[5].

The state conditions run with the tanks, the driveways and the disturbed ground. TCEQ installation standards are 30 TAC 334.45 and 334.46; a licensed installer must be on site at critical junctures; the delivery certificate is renewed annually at least 30 days before it expires; and ownership changes are reported within 30 days ^{[18, 26]}. TxDOT's Houston District treats a driveway serving over 20 vehicles per day as commercial, and the access permit application carries the sealed TIA ^[15]. A site that disturbs 1 acre or more needs TCEQ construction stormwater coverage under TXR150000, which expires March 5, 2028; TCEQ classes 1 to less than 5 acres as small construction and 5 acres or more as large ^{[17, 78]}.

The handoff is a set built on one layout. The preliminary site plan carries the driveway locations against Table 2-1, the one-way truck circulation, the stall and truck court layout, the detention reserve, the tank farm and canopy locations, the phasing master plan and the site data table. The surveyor delivers the boundary and the plat; the engineer of record designs grading, detention volume, pavement, utilities, the TIA and the TxDOT geometric design; the architect of record produces the stamped fire code plans.

Related reading: the case studies index; the Georgia sibling to this case, a gas station and c-store in Gwinnett County; a zoned Texas suburb case, the express car wash in Mansfield; the car wash site plan hub for the truck wash; car wash and gas station regulations by state; preliminary vs final site plans; and, from the studio's journal, truck parking as an asset class, sustainable highway stops and green trucking infrastructure, your site plan was laid out around a truck you will never own and tanks, traffic and regulations in fuel site permitting.

By Viola Sauer, Principal, Innowave Studio