How Much Does It Cost to Start a Brewery / Microbrewery in Oklahoma?

Sakshi Udavant Sakshi Udavant Freelance journalist / B2B writer

At a glance

The lease is cheap; the brewery infrastructure is not

For an Oklahoma founder opening one independent production microbrewery with a taproom, the practical planning number is about $683,000 before opening. A disciplined used-equipment/light-build-out version can land near $451,000; a more polished build with additional cellar and packaging capacity can exceed $1.0 million. The model is statewide: rent comes from a three-market Oklahoma industrial/flex basket, wages use Oklahoma labor benchmarks, and alcohol fees come from the issuing state agencies rather than one city.

Decision answer
Base case: one 6,000-square-foot leased site, 10-bbl brewhouse, four 20-bbl unitanks, owner-operated general management/sales, no full kitchen, and an Oklahoma Small Brewer license with self-distribution. Stabilized production is 80 bbl/month, about 64% of a modeled 125-bbl/month practical capacity. At that level, net operating revenue is about $85,760/month, normalized passive-owner cash operating profit is about $10,600/month before D&A, debt and income tax, and working-owner pre-tax business cash benefit is about $17,000/month before maintenance capex. The biggest caveat is the final address: zoning, utility capacity, wastewater, fire/building approvals and local alcohol licensing can move both cost and schedule materially.
$451kLean startup scope
$683kTypical cash before opening
$1.025mPremium startup scope
7 – 10 mo.Modeled launch window
$85,760Base monthly net revenue
$17,000Working-owner monthly benefit
$68,825Sustainable owner break-even revenue
53 mo.Base project payback, working owner

The assumed legal form is one Oklahoma LLC. The state lists a $100 LLC filing cost plus service fee and a $25 annual fee. No debt, landlord allowance, grant or reimbursement is assumed, so founder cash equals project cost unless committed funding is available before the related invoice is due.

FormatProduction microbrewery + taproom; no full kitchen
OwnershipIndependent Oklahoma LLC; owner-operated GM/sales
SiteOne leased 6,000-sq.-ft. industrial/flex site
Capacity10-bbl brewhouse; 125 bbl/month practical ceiling
Core mix70% taproom/to-go volume; 30% self-distributed wholesale
Official fees/rules: high confidence Rent/wage anchors: moderate confidence Build-out, insurance, throughput: model-dependent

Startup scope

A 10-barrel system still needs brewery-grade capital

The steel itself is only part of the check. Current commercial component pricing supports the order of magnitude: Blichmann lists a 20-bbl fermenter at $12,400 and a 10-bbl brite tank at $8,100, while Glacier Tanks lists separate commercial kettles, mash tuns and hot-liquor tanks in the tens of thousands of dollars. A used 10-bbl brewhouse can be much cheaper at auction or resale, but rigging, controls, glycol, pumps, drainage, electrical, gas, ventilation and commissioning remain.

Startup uses – Oklahoma statewide model, 2026 USD, Lean / Typical / Premium
Use of funds Lean Typical Premium
Lease, utility and security deposits $18,000 $24,000 $32,000
Design, engineering, legal and pre-opening professional work $20,000 $32,000 $48,000
Build-out: drains, slab, electrical, gas, HVAC, fire, taproom $95,000 $155,000 $240,000
Brewhouse, cellar, glycol, grain handling and installation $135,000 $190,000 $270,000
Packaging, kegs, cold storage, POS, taproom furniture $45,000 $70,000 $125,000
Registrations, licenses, plan review and inspection allowance $5,000 $9,000 $15,000
Opening inventory, pre-opening payroll, insurance and launch marketing $40,000 $58,000 $80,000
Initial net working capital, excluding listed opening inventory $8,000 $14,000 $20,000
Opening operating-cash reserve $60,000 $91,000 $130,000
Contingency $25,000 $40,000 $65,000
Total project cost / founder cash required $451,000 $683,000 $1,025,000
Startup project scope – Oklahoma statewide model, 2026 USD
Lean
$451k
Typical
$683k
Premium
$1.025m
Takeaway: the Typical scope is two-thirds of the Premium project, but more than half of Typical cash still goes to build-out plus brewing/cellar equipment.

The $9,000 Typical regulatory line is intentionally an allowance, not a claim that Oklahoma charges $9,000 in state alcohol fees. The published statewide core is much smaller: Oklahoma ABLE lists the Small Brewer application at $125 plus a $35 surcharge and, below 15,000 barrels, the Small Brewer Self-Distribution license at $350. Oklahoma's sales-tax permit is $20 plus handling. The balance is a modeled planning allowance for address-specific building, fire, occupancy, local alcohol and utility reviews; obtain local quotes before signing a noncontingent lease.

Cash classification: the $24,000 Typical deposit line is a use of cash but not an operating expense. Opening inventory is listed once and excluded from the $14,000 initial net working-capital line. The $91,000 operating-cash reserve is unrestricted liquidity for ramp losses and the minimum cash floor; it is not contingency, inventory or a refundable deposit.

Critical path

Premises approval, TTB and ABLE must converge before opening

A brewery is not a sequence of independent forms. Site control and a defensible premises diagram feed the federal Brewer's Notice; local zoning, fire, building and occupancy work feed the local alcohol compliance process; the Oklahoma Small Brewer application requires the TTB permit. In June 2026, TTB's median processing time for an original brewery application was 43 calendar days, while the federal agency's customer-service goal is 75 days for 85% of original permits. ABLE does not publish a single statewide processing SLA on the license guide, so the model treats that timing as a risk rather than inventing a number.

Step 1Entity + site due diligenceWeeks 0 – 6; verify use, utilities, drains, landlord rights.
Step 2Design + federal filingWeeks 3 – 12; TTB can run while plans advance.
Step 3Build-out + equipmentWeeks 8 – 28; usually the physical critical path.
Step 4ABLE + local approvalsAfter required upstream documents; timing varies.
Step 5Commission + train + openWeeks 26 – 40; inspections and staff credentials gate launch.
Launch and compliance path – Oklahoma statewide model, current rules reviewed August 2026
Deliverable Prerequisite Authority Timing Fee / basis Gate
LLC, EIN, state sales-tax account Ownership decision Oklahoma Secretary of State; IRS; OTC Early; can run in parallel LLC $100 + service; sales permit $20 + handling; EIN $0 Needed for contracts, payroll and tax setup
Site, zoning and utility-capacity confirmation Target premises City/county, landlord, water/sewer utility 2 – 6 wk. modeled due diligence Varies by city/county Do before noncontingent lease
Building, plumbing, fire and trade-plan approvals Site + design Local permitting authorities 4 – 10 wk. modeled; no statewide SLA Local quote required Required before/through construction
Federal Brewer's Notice Premises information and diagrams TTB 43-day June 2026 median $0 application fee Required before brewing operations
FDA food-facility registration, if required Facility details FDA Before covered food manufacturing begins $0 Confirm exemption/status for exact operation
Oklahoma Small Brewer license TTB permit + entity documents; insurance ABLE Commission Not published $125 + $35 surcharge State manufacturing/direct-consumer authority
Small Brewer Self-Distribution license Small Brewer + TTB permit ABLE Commission Not published $350 under 15,000 bbl Elect self-distribution or distributor, not both simultaneously
Final occupancy, local alcohol approval, employee credentials Build-out + state/federal status Local jurisdiction; ABLE Varies by address Local fees vary; ABLE employee license $30 + $3.50 online convenience Final inspections; employee license and approved training, with training certificate due within 14 days of license issuance

Operating hours also have a state overlay. Oklahoma law provides that alcoholic beverages may not be sold, served or consumed on a small brewer's licensed premises between 2:00 a.m. and 8:00 a.m.; municipalities may require the premises to close from 2:00 a.m. to 6:00 a.m., and certain county Sunday/holiday restrictions can apply. The Base case assumes ordinary afternoon/evening taproom hours and does not rely on late-night sales. See 37A O.S. §3-125.

For the model's roughly 960 annual barrels, federal excise liability is far below the $50,000 threshold. TTB's current bond guidance says qualifying small taxpayers can be exempt from the brewer's bond requirement if they meet the liability and payment conditions and obtain approval; therefore no surety premium or collateral is modeled. If the brewery does not qualify, the bond becomes a separate financial-assurance item – premium is an expense and any collateral is restricted cash, not operating runway.

Safety and environmental dependency: brewery CO₂ is a real workplace hazard. The Brewers Association estimates a 10-bbl average-strength fermentation can generate about 48 kg of CO₂ and recommends evaluating ventilation and monitoring. Wastewater strength, floor drains and stormwater exposure are also address-specific. Oklahoma DEQ has separate industrial wastewater and industrial stormwater programs; many breweries instead discharge to a municipal sewer under local pretreatment rules, so confirm the actual discharge path before design.

Operating economics

Taproom mix matters more than raw barrel count

The natural unit is a finished 31-gallon beer barrel. The Base case sells 80 bbl/month: 56 bbl direct to consumers in the taproom/to-go channel and 24 bbl through self-distribution. A three-market Oklahoma menu check found ordinary craft draft examples around $5.50 – $6.50 per pint-equivalent; the model uses $1,300 net operating revenue per direct-to-consumer barrel after pour loss, discounts and a lower-priced to-go mix, plus $540 per self-distributed wholesale barrel. Those wholesale economics are a planning assumption, not a published statewide average; obtain buyer-specific keg and package pricing before underwriting the Upside case.

Base revenue = (56 retail bbl × $1,300/bbl) + (24 wholesale bbl × $540/bbl) = $85,760/month
Revenue is net of customer discounts/refunds and excludes sales tax collected. Card fees are shown as variable operating costs. Beer excise tax is also an operating cost, not a reduction of customer revenue.
Operating scenarios – Oklahoma statewide model, Typical scope, stabilized month, 2026 USD
Metric Downside Base Upside
Finished beer volume 60 bbl 80 bbl 110 bbl
Direct-to-consumer share of volume 65% 70% 72%
Net operating revenue $58,680 $85,760 $123,376
Variable operating costs $25,538 $32,086 $42,726
Passive/economic contribution margin 56.5% 62.6% 65.4%
Fixed non-owner cash operating costs $35,000 $36,675 $49,000
Normalized passive-owner cash operating profit – $8,258 $10,599 $25,250
Working-owner pre-tax business cash benefit – $1,858 $16,999 $31,650
Working-owner cash after maintenance-capex reserve – $3,858 $14,499 $28,150
Monthly production vs. 125-bbl practical capacity – Oklahoma statewide model, Typical scope
Downside
60 bbl · 48%
Base
80 bbl · 64%
Upside
110 bbl · 88%
Takeaway: Upside stays inside the same physical capacity band, but the model steps fixed payroll, marketing and utility support up to $49,000/month rather than pretending 110 bbl costs the same to support as 80.

Taproom beer

Menu sales are modeled net of sales tax collected. The final state/local transaction-tax rate is address-specific, so the model excludes collected tax from revenue rather than treating it as income.

To-go beer

Included in the direct-to-consumer barrel realization. Verify packaging, labeling and transaction-tax treatment for the exact package and sales channel.

Self-distributed wholesale

Modeled at net wholesale revenue with resale documentation handled correctly. ABLE requires a small brewer to elect self-distribution or distribution through a distributor; it may not do both simultaneously.

The beer itself carries specific excise tax. Oklahoma law imposes $12.50 per 31-gallon barrel on beer manufactured for sale, use or distribution in the state, with an export exception. TTB's federal rate page lists $3.50 per barrel on the first 60,000 barrels for a qualifying domestic brewer producing no more than two million barrels. The Base model therefore carries $16.00/bbl of combined beer excise tax.

Cost structure

Labor, utilities and beer losses decide the margin

Payroll and brewery-grade building costs matter more than ingredients alone. Oklahoma's May 2023 wage data reported $12.34/hour mean pay for bartenders and $31.04 for food-service managers; the model treats those as older anchors, budgeting taproom staff at $16/hour and the owner's GM/sales replacement role at $32/hour before burden. The published minimum wage is $7.25 per hour. The 2026 new-employer unemployment rate is 1.5% on a $25,000 taxable wage base, and employers must carry workers' compensation insurance; the premium is quote-driven.

Base monthly operating costs – Oklahoma statewide model, 80 bbl/month, 2026 USD
Cost family Monthly Behavior / basis
Ingredients and process chemicals $9,600 Variable; $120 per finished bbl
Packaging and keg consumables $4,400 Variable; $55 per bbl weighted mix
Variable production + taproom labor, loaded $14,000 Variable/shift-driven; assistant brewing + hourly service
Card fees, beer excise and variable delivery $4,086 Variable; includes 2.8% card fee on direct sales
Fixed non-owner payroll $12,800 Head brewer + scheduled lead/admin coverage
Occupancy $4,875 6,000 sq. ft.; $4,125 base rent + $750 CAM/NNN allowance
Utilities $5,000 Modeled power, gas, water/sewer baseline; address quote required
Marketing, insurance, maintenance, lab, waste, software, admin, vehicle $14,000 Mostly fixed within Base capacity band
Fixed owner-replacement labor, loaded $6,400 Economic normalization for GM/sales/admin role
Total normalized passive-basis cash operating costs $75,161 Excludes D&A, debt service, maintenance capex and income tax

Passive-owner profit

$10,599/month in the stabilized Base case after fully loaded replacement labor for the owner's fixed GM/sales role. This is normalized cash operating profit before D&A, debt service, maintenance capex and income tax.

Imputed owner labor

$6,400/month. It is not a draw and not additional business profit. It is the market-value payroll expense avoided because the owner performs the management and sales work.

Working-owner benefit

$16,999/month = $10,599 residual passive-basis profit + $6,400 avoided replacement labor. After a $2,500/month maintenance-capex reserve, potential pre-tax owner cash is about $14,499.

No depreciation schedule is fabricated, so the article does not label the result EBIT. No debt is modeled, so scheduled principal and interest are $0 in the Base case. No owner income-tax reserve is modeled because the correct rate depends on entity elections and the owner's tax situation. That means the working-owner number is a pre-tax business cash benefit, not guaranteed take-home pay. At stabilization it annualizes to about $204,000 before maintenance capex and tax; in the modeled first operating year, the ramp compresses that figure to only about $62,000 before maintenance capex.

Two cost lines can break the plan quickly: first, brewery utility and wastewater charges can be materially higher than an ordinary warehouse, so $5,000/month is an allowance pending actual utility data. Second, the rent basket captures asking base rent, not a turnkey brewery: a cheaper shell with inadequate power, gas, floor drains or sewer capacity can be more expensive than a higher-rent second-generation space.

Unit economics + break-even

One finished barrel must carry about $671 of contribution

The Base weighted revenue is $1,072 per finished barrel. Costs that move with barrel volume – ingredients, packaging, direct hourly production/service labor, payment fees, beer excise and variable delivery – consume about $401.08/bbl. That leaves $670.92/bbl of passive/economic contribution, or 62.6%. Because the owner's role is fixed management and sales rather than direct unit-level brewing, no variable owner-replacement labor is placed in the barrel contribution; the full $6,400/month owner-replacement amount remains in the fixed-cost bridge.

Unit economics and break-even – Oklahoma statewide Base case, 2026 USD
Measure Base result Formula / decision basis
Weighted revenue per finished bbl $1,072.00 70% direct × $1,300 + 30% wholesale × $540
Variable operating cost per bbl $401.08 $32,086 ÷ 80 bbl
Passive/economic contribution per bbl $670.92 $1,072.00 – $401.08
Contribution margin 62.6% $670.92 ÷ $1,072.00
Cash-survival break-even $58,600 / 54.7 bbl $36,675 fixed non-owner cost ÷ matching CM
Sustainable working-owner break-even $68,825 / 64.2 bbl ($36,675 + $6,400 target owner compensation) ÷ matching CM
Passive-owner break-even $68,825 / 64.2 bbl Same threshold because owner replacement is entirely fixed in this configuration
Break-even volume against monthly capacity – Oklahoma statewide model, Base case
Cash-survival break-even
54.7 bbl
Sustainable owner / passive break-even
64.2 bbl
Base production
80 bbl
Takeaway: Base has roughly 15.8 bbl/month of volume cushion above the sustainable owner threshold, but a 20-bbl monthly shortfall pushes the business into the Downside loss case.
Capacity check: 64.2 bbl is only 51.4% of the modeled 125-bbl monthly ceiling, so break-even is physically achievable without adding tanks or shifts. The risk is commercial utilization, not theoretical production. The threshold is valid only inside this capacity band; if the brewery adds a production employee, second delivery route or longer taproom schedule, fixed costs step up and break-even must be solved again.

Liquidity + payback

Ramp cash is the real opening test

The Base opening ramp is deliberately slower than a straight-line annual forecast: 20, 28, 40, 52, 62, 70, 76 and 80 bbl in months 1 – 8, then 80 bbl/month. Fixed non-owner cash operating costs remain largely in place while volume is low. The model also reserves $2,500/month for maintenance capex and targets net working capital at 5% of monthly revenue as sales grow.

$65.6kMaximum cumulative ramp deficit
$91kOpening operating-cash reserve
$25kMinimum modeled cash floor
Month 53Working-owner unlevered project payback

The reserve equals the maximum cumulative ramp deficit plus a minimum closing-cash floor. The worst point is about – $65,600 around month 4; adding a $25,000 floor produces $90,600, rounded to $91,000. Year-one receipts are about $802,700 versus roughly $774,700 of cash operating disbursements, maintenance capex and added net working capital. Those flows are separate from the $683,000 pre-opening project cost; only the timing deficit is prefunded.

Working-owner project payback: month-0 capital basis $617,000 + monthly project cash flows through ramp → cumulative cash first turns nonnegative in month 53.
The $617,000 month-0 basis equals the $683,000 Typical project cost less the roughly $66,000 prefunded ramp-loss portion because those losses are included again as monthly negative project cash flows. The $25,000 minimum cash floor remains in the month-0 capital basis. This avoids counting the same ramp loss twice.

A passive launch is harder. Paying the replacement manager from month 1 increases the worst ramp deficit to about $95,400; preserving the same $25,000 minimum cash floor requires roughly $121,000 of opening operating cash, about $30,000 more than the owner-operated Typical case. Under the same unlevered, pre-tax project-cash convention, passive-owner project payback is approximately month 95. Neither payback is a simple “startup cost divided by annual profit” shortcut: both use monthly ramp cash, maintenance capex and net-working-capital changes. Debt would require a separate levered equity schedule after principal and interest.

Runway interpretation: the $91,000 reserve is sufficient for the modeled owner-operated ramp while retaining the $25,000 floor. It is not a promise of nine or twelve months of runway under any sales pattern. If permits delay opening after payroll and rent begin, or if launch volume sits below 52 bbl/month longer than modeled, the monthly cash schedule – not reserve ÷ average burn – should be rerun.

Oklahoma demand + sensitivity

State production supports the scale, not the address

A reliable statewide brewery-revenue amount is not publicly determinable from the available category data. The Brewers Association's 2025 profile reports 75 Oklahoma craft breweries producing 69,318 barrels, about 924 barrels per brewery as a simple derived proxy. Its $533 million figure is economic impact, not brewery revenue or TAM. The Base plan's 960 annual barrels is near that crude production proxy, but the final site must still prove local demand.

≈$13.4k20-bbl contribution swingAt about $671 contribution per bbl, 20 bbl moves monthly contribution by roughly $13,400 before any fixed-cost step; the scenario model then adjusts support costs.
$6,08010-point channel-mix revenueMoving 10% of Base volume from $540 wholesale realization to $1,300 direct realization adds about $6,080 revenue before extra service/card cost; rounded planning effect depends on labor.
$3,000+Utility / wastewater shockA $3,000 monthly overrun directly cuts Base passive profit from about $10,600 to $7,600 unless pricing, volume or efficiency offsets it.

The near-term industry backdrop deserves caution. The Brewers Association reported U.S. craft production down 4% in 2025, with microbrewery volume down 8.9%. That makes a “build it and capacity will fill” forecast especially weak. Early warning KPIs should be taproom revenue per open hour, direct-to-consumer share, barrels sold per month, gross beer loss, labor dollars per barrel, wholesale reorder rate, accounts-receivable days, utility cost per barrel and cash balance versus the $25,000 minimum floor.

Local variation and address checks

Local examples are used only to establish a statewide planning basket and show why address-level diligence cannot be skipped. They do not define the Base case.

Local variation and planning basket – Oklahoma observations checked August 2026
Check Observation Comparable basis How used / limitation
Industrial/flex rent – Oklahoma City $11.76/sq. ft./yr asking 5,000-sq.-ft. listing Large-market observation; asking rent, not executed lease
Industrial/flex rent – Tulsa $7.00/sq. ft./yr asking 5,480-sq.-ft. listing Second large-market observation; lease structure varies
Industrial/flex rent – Lawton $8.25/sq. ft./yr asking 5,092-sq.-ft. listing Smaller-market observation; asking rent only
State planning rent statistic $8.25/sq. ft./yr median Three observations above Base rent = 6,000 × $8.25 ÷ 12 = $4,125/month; plus $750 CAM/NNN allowance
On-premise craft draft pricing About $5.50 – $6.50 common examples Current menus in Oklahoma City, Tulsa and southwest Oklahoma Supports $6-range pint anchor; model uses barrel realization, not one menu price
Oklahoma City alcohol/local occupancy Certificate of Compliance $0; separate city alcohol license schedule City zoning/fire/safety/health compliance process Example only; exact city fees are not statewide
Tulsa and Lawton local approvals Both publish local alcohol/business approval pathways; exact fees differ or may require inquiry Local licensing / occupancy rules Confirms “varies by city/county”; final address must be checked directly

For example, Oklahoma City requires an alcohol Certificate of Compliance covering zoning, fire, safety and health and publishes a separate municipal alcoholic-beverage license schedule. Tulsa routes food/liquor licensing through its municipal licensing system and its certificate process checks local code compliance. Lawton explicitly lists alcohol/beer establishments among locally licensed businesses. Those examples prove variability; they are not a substitute for checking the final parcel, county and utility district.

Method + evidence

What is measured, what is modeled, and what still needs a quote

Research was reviewed August 28, 2026; dollars use a 2026 planning basis. Official fees and rules use published values where available, while older wage series retain their stated period. Rent, equipment and menu observations are market evidence, not government averages. Build-out, utilities, insurance, maintenance, ramp timing and wholesale realization remain model-dependent until the site and vendor package are known.

Sources and methodology register – Oklahoma brewery model, reviewed August 28, 2026
Source / publisher Geography / period Evidence type How used
Oklahoma ABLE – business licensing + employee training Oklahoma; current 2026 pages Official fee or rule Small Brewer and self-distribution authority/fees, employee licensing/training and required documents
Oklahoma business registration + Tax Commission Oklahoma; current / FY2024 rate table Official fee and tax rate LLC formation, sales-tax setup context and $12.50/bbl Oklahoma beer excise
TTB – permit processing + tax rates + bond guidance U.S.; June – August 2026 Official federal data/rule 43-day brewery median, $0 permit fee, $3.50/bbl rate and small-taxpayer bond treatment
FDA – Food Facility Registration U.S.; 2026 guidance Official federal rule Registration applicability gate and $0 registration fee
BLS Oklahoma OEWS + OESC + Oklahoma DOL Oklahoma; 2023 wage / 2026 UI Government data and rule Wage anchors, minimum wage context and 2026 new-employer UI rate
Brewers Association – Oklahoma stats + 2025 industry review Oklahoma / U.S.; 2025 Published industry benchmark 75 breweries, 69,318 bbl, derived 924 bbl/brewery proxy and current demand-risk context
Oklahoma City rent, Tulsa rent, Lawton rent; current draft-price and menu observations Multiple Oklahoma markets; Aug. 2026 Observed market quotes $8.25/sq.-ft./yr median asking-rent anchor and $5.50 – $6.50 craft-draft price context; neither is an executed statewide average
Blichmann + Glacier Tanks + BrewBids U.S. vendor/resale; 2026 observations Observed vendor quote Cross-checks equipment allowance and Lean used-equipment possibility; integration/rigging remain modeled
Oklahoma City + Tulsa + Lawton Local Oklahoma jurisdictions; current pages Official local rule Shows zoning/occupancy/alcohol approvals vary by city; exact final-address fees remain local
Oklahoma DEQ wastewater + stormwater Oklahoma; current Official conditional rule Environmental discharge/stormwater gates; no state permit fee modeled unless the selected site triggers coverage

The largest uncertainty is not the $160 state Small Brewer fee; it is the final premises. Before committing capital, obtain written zoning/use confirmation, brewery-specific utility and sewer capacity, contractor pricing for drains/electrical/gas/ventilation, insurance quotes, local alcohol and occupancy requirements, and buyer-specific wholesale pricing. Rebuild the model if the actual site changes floor area, available power, wastewater treatment, cold-storage needs, taproom seat count, operating days or practical monthly barrel capacity.

This is a planning model, not legal, tax, engineering or accounting advice. Rules and fees can change; confirm current requirements with the issuing federal, state and local authorities before filing or spending.