# DFW Kiln Permitting Air rules make a new lime kiln near Dallas-Fort Worth very hard to build. This protects USLM, and it also limits USLM. ## The rule - DFW is a severe nonattainment zone for the 2008 federal ozone standard. - A new kiln needs a New Source Review permit from the Texas Commission on Environmental Quality (TCEQ). - The permit needs three things: proof of no worse air quality, bought emissions offsets, and Best Available Control Technology. - The source says no new DFW lime kiln has been permitted in decades. It also says USLM's Cleburne kilns run on grandfathered permits.^[Colubeat Investment Desk, 28 May 2026, https://colubeatid.substack.com/p/united-states-lime-and-minerals-inc] > [!warning] Verify > Johnson County (Cleburne) is in the DFW ozone area. Check the "grandfathered" claim against TCEQ permit records. A grandfathered permit can be reopened. ## A new entrant needs all of these ```mermaid graph LR A[Find pure limestone<br/>near DFW] --> B[Buy thousands of acres<br/>in a growing county] B --> C[Win NSR permit,<br/>buy offsets] C --> D[Build kiln<br/>~$65M+] D --> E[First ton,<br/>years later] ``` - Each step can fail. Together they make entry unlikely inside a five-year view. ## It cuts both ways - USLM's own new kiln had to pass TCEQ. - A third or fourth Cleburne kiln (2028–2030) may not pass. - Then growth must come from Arkansas, Oklahoma or a new site outside DFW. - Those sites sell a lower-margin product mix. Growth there earns less per ton. See [[Texas Lime Concentration Risk]]. > [!important] The moat caps the growth > The permit wall keeps rivals out. It also keeps USLM's best plant near its present size. ---- tags: #boat #investing links: [[United States Lime and Minerals MOC]] [[Transport-Cost Moat]] [[USLM Investment Thesis]]