This note is the shrinking-asset typology section of the Public Asset Utilization Research Lab. For a typological comparison with defunct schools, see Structural Analysis of Abandoned School Small Concessions; for connections to the softening of public services, see The Softification Paradigm in Public Services.
Introduction
In 1994, Japan had 60,421 gas stations. That is the peak figure, confirmed by statistics from the Petroleum Association of Japan (石油連盟).
By 2024, the same statistics show 27,009 stations. Roughly 33,000 stations disappeared over thirty years.
The sites of closed gas stations are not simply vacant land. Underground hazardous material storage tanks — many made of fiberglass-reinforced plastic (FRP), roughly 2.4 meters in diameter and 5 to 6 meters long — frequently remain in place. Removal costs run into the millions of yen. When a closing operator cannot bear that cost, the alternative is "in-place filling" (充填残置): the tank is left in the ground and packed with sand or water.
This note classifies these 27,000 shrinking assets across two dimensions: the legal framework and actual conditions. The goal is to position defunct gas stations as one type of "shrinking asset" in Japan's urban landscape — alongside closed schools (1,951 currently unused) and the estimated ¥190 trillion in infrastructure maintenance costs over the next thirty years.
Thirty-Year Trend of Defunct Gas Stations
| End of Fiscal Year | Number of Stations | vs. Peak |
|---|---|---|
| 1994 (peak) | 60,421 stations | 100.0% |
| 2004 (10 years later) | approx. 49,000 stations | 81.1% |
| 2014 (20 years later) | approx. 33,000 stations | 54.6% |
| 2020 | approx. 29,000 stations | 48.0% |
| 2024 (latest) | 27,009 stations | 44.7% |
(The 2004, 2014, and 2020 figures are approximate values read from the trend chart in the same PAJ statistical series. The vs.-peak percentages are calculated relative to the 1994 figure.)
Fifty-five percent of gas stations have closed over thirty years. The pace of decline has slowed, but as government targets for EV adoption approach (100% electric new-vehicle sales by 2035), analysts suggest the rate may accelerate again.
In Tokyo alone, there were 967 stations at the end of fiscal 2020 and 898 stations at the end of fiscal 2023 — a reduction of roughly 30 to 40 stations per year.
Underground Tank Disposal: Three Options under the Fire Service Act
Gas stations are "hazardous materials facilities" (危険物施設) under the Fire Service Act, handling Class 4, Category 1 petroleum products (gasoline). Underground tank disposal at the time of closure is governed by Fire Service Act Article 12-6 and Fire Prevention Notice No. 78 (1991) (issued July 11, 1991, by the Director of the Hazardous Materials Regulation Division of the Fire and Disaster Management Agency). Note: the source used here is a secondary PDF published by the City of Utsunomiya; a primary public release by the Fire and Disaster Management Agency has not been independently confirmed. The notice number and its content can be verified through local fire department records.
Three disposal methods exist.
Option 1: Excavation and Removal
The tank is physically extracted from the ground. Environmental risk is minimized, but costs run in the millions of yen per tank (the practical market range is ¥1,000,000 to ¥3,000,000 per tank; multiple tanks raise the total further).
Option 2: In-Place Filling (Sand or Water)
The tank remains in the ground, and its interior is packed with sand or water. Fire Prevention Notice No. 78 stipulates: "When a decommissioned tank is unavoidably left buried, the interior of the tank must be completely filled with water or sand" (the word "completely" appears in the original text).
Option 3: Cleaned and Left in Place
The tank is cleaned with an emulsifying and neutralizing agent; the absence of flammable vapor is confirmed with a gas detector; and the tank is then left in place.
Fire Prevention Notice No. 78 explicitly states that removal is the principle and in-place filling is permissible only when unavoidable. In practice, however, the cost burden has made in-place filling the predominant choice (reliable national statistics on this breakdown are not publicly available).
Three Types of Shrinking Assets
The subsurface tank legacy falls into three types, classified along three axes: responsibility structure, cost structure, and legal status.
Type A: Operator Extant, Willing to Remove
The original operator still exists as a legal entity and can bear the removal cost. Disposal follows the "removal as principle" requirement of Fire Prevention Notice No. 78. These cases may qualify for removal subsidy programs run by the National Petroleum Association (全国石油協会) — specifically the "SS Network Maintenance and Reinforcement Support Program" and the "Program for Developing Petroleum Product Distribution Systems in Underpopulated Areas."
Type B: Operator Extant, Unwilling to Remove
The original operator still exists but faces removal costs at a scale that strains operations. After preliminary consultation with the fire department, the operator opts for in-place filling. This is legally compliant — recorded as "hazardous materials decommissioning complete" — but redevelopment of the surface (for housing or retail) becomes difficult.
Type C: Operator Gone, Ownership Unclear
The original operator has become unreachable — through bankruptcy or the advanced age of a sole proprietor — and land ownership is equally obscure due to inheritance waiver or untraceable heirs. The underground tank effectively becomes ownerless, and the local government may be compelled to take action. This type presents the greatest need for policy intervention.
A note on the typology's boundaries: The three types are structured around two primary axes — whether the operator is extant or gone, and whether land ownership is clear or unclear. In practice, however, a fourth scenario exists: the original operator is gone, but an heir retains clear ownership of the land and simply has no intention of removing the tank. This case fits neither Type B (operator extant but unwilling to remove) nor Type C (ownership unclear) in strict terms. For the purposes of this note, it is treated as a subvariant of Type B, but it may warrant separate treatment in any policy design. Accurate sizing of this sub-group would require cross-referencing municipal survey data with real estate registry records.
Compatibility with the Soil Contamination Countermeasures Act
Gas stations, as facilities that handle gasoline (which contains benzene, a designated hazardous substance), qualify as "Specified Facilities Using Hazardous Substances" (有害物質使用特定施設). When such a facility closes and a land alteration of 900 m² or more (excavation, land filling, etc.) is carried out, a notification obligation arises under Soil Contamination Countermeasures Act Article 4.
When a tank is left in place with filling and the land is maintained in its current state, no land alteration occurs and no notification obligation is triggered. However, the moment a land alteration arises — through sale, redevelopment, or construction work — a soil investigation obligation is triggered.
This structure severely constrains the liquidity of defunct gas station sites. Owners who want to sell face the immediate prospect of soil contamination investigation costs (¥800,000 to ¥3,000,000), and many defer the sale indefinitely. The result is land carrying underground tanks left idle for years.
Architectural Repurposing: The Transformation Approach of Lacaton & Vassal
Reframing 27,000 defunct gas stations as "shrinking assets" makes it possible to redefine them — not simply as liabilities, but as latent resources the city holds in reserve.
Lacaton & Vassal, the 2021 Pritzker Architecture Prize laureates, stated the following principle in their Harvard GSD lecture:
Never demolish. Always transform, with and for the inhabitants.
Their approach avoids demolishing existing structures and instead regenerates value through addition and conversion. Their realized projects in social housing, schools, and art institutions have received international recognition.
Applying this Transformation approach to defunct gas stations, the underground tank shifts from "hazardous structure awaiting urban disposal" to a potential physical foundation for cultural, observational, and public infrastructure. International precedents for adaptive architectural reuse — including TANK Shanghai, Gasholders London, and the Vienna Gasometers (for details, see International Comparison: Adaptive Reuse of Defunct Oil Terminals) — are all large-scale facilities. Whether a gas station, which is small in scale and dispersed across urban areas, can sustain the same approach remains a research question for the next phase.
Policy Implications
Implication 1: Policy Positioning of the 27,000-Station Scale
27,000 stations is approximately 14 times the number of defunct schools (1,951; see Structural Analysis of Abandoned School Small Concessions). Unlike defunct schools, however, defunct gas stations have no established policy framework for "public asset utilization." The Ministry of Land, Infrastructure, Transport and Tourism's Small Concession Platform targets public facilities — privately owned defunct gas stations are outside its scope. A policy blind spot.
Implication 2: Room to Rethink Subsidy Design
The National Petroleum Association's tank removal subsidy program operates as a mutual assistance scheme within the industry. It cannot readily address Type C cases (operator gone, ownership unclear). There is room to design a comprehensive public scheme — combining removal subsidies, soil investigation subsidies, and conversion support — that also accounts for compatibility with the Soil Contamination Countermeasures Act.
Implication 3: An Opportunity for Architectural Experimentation
Gas stations' characteristics — small footprint (500 to 1,000 m²), dispersed across urban areas (over 10,000 sites), existing subsurface infrastructure — make them well-suited to experimental architectural conversion projects. The risk of a single failure propagating to the whole is low, and multiple sites can test different approaches simultaneously.
Connection to the Quiet City Project
ISVD's Quiet City Project includes a proposal to use defunct gas stations as observation hubs (research stage; for details see The Quiet City Project: A Hypothesis Overview). Among the 27,000 dispersed urban sites, those located along arterial roads occupy positions well suited for noise observation. The underground tank can be redefined both as a space for installing monitoring equipment and as the physical materialization of the "five-layer meaning inversion" (see Five-Layer Meaning Inversion Methodology).
This is also an attempt to transform 27,000 shrinking assets from liabilities into urban observation infrastructure. Verifying feasibility requires multi-angle research incorporating compatibility with the legal framework — the Fire Service Act, the Soil Contamination Countermeasures Act, and the Building Standards Act. ISVD's role is to demonstrate, at minimum, that "the possibility exists" — quantitatively, from both the legal and factual sides.
Conclusion
33,000 stations closed in thirty years. That scale is 14 times the number of defunct schools and roughly 60 percent of Japan's total convenience store count (approximately 56,000 stores). Yet social awareness of this phenomenon is thin. People notice that gas stations are disappearing from neighborhoods; few stop to think that underground tanks may remain on those sites.
Making shrinking assets visible starts with counting them. The Petroleum Association of Japan's figure of 27,009 stations; the 900 m² land-alteration notification threshold set by Soil Contamination Countermeasures Act Article 4, alongside the ¥800,000-to-¥3,000,000 practical market cost of soil investigation (a market figure, not a statutory amount); Fire Prevention Notice No. 78's "removal as principle, in-place filling only when unavoidable." Arranging these numbers and provisions as research assets rather than liabilities is the task of the Public Asset Utilization Research Lab.
The next step is to attempt classification of the 27,000 stations into Types A, B, and C — and to produce a national estimate for Type C (operator gone, ownership unclear). No official statistics cover this territory, but a practical estimate appears achievable through the combination of municipal surveys, real estate registry data, and fire department inquiries.
Related guides: For institutional analysis methods in public asset utilization, see Introduction to EBPM; for comparison with the defunct school typology, see Structural Analysis of Abandoned School Small Concessions.
References
Gas Station (SS) Count Trends — Petroleum Association of Japan (石油連盟). Petroleum Association of Japan
Prefectural Gas Station Count Trends — National Federation of Petroleum Retail Merchants (全国石油商業組合連合会). National Federation of Petroleum Retail Merchants
Fire Prevention Notice No. 78 (Guidance on Safety Management for the Decommissioning of Underground Storage Tanks) — Fire and Disaster Management Agency, Hazardous Materials Regulation Division. Fire and Disaster Management Agency
Fire Service Act (Act No. 186 of 1948) — e-Gov Legal Search. Digital Agency of Japan
Soil Contamination Countermeasures Act (Act No. 53 of 2002) — e-Gov Legal Search. Digital Agency of Japan
Never demolish, always transform, with and for the inhabitants: Anne Lacaton on Urban Design and Architecture — Harvard Graduate School of Design. Harvard GSD
SS Network Maintenance and Reinforcement Support Program — Fuel Storage Tank Removal Program — National Petroleum Association (全国石油協会). National Petroleum Association