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									Land Development Code Critique
Citrus County, Florida

MAY 2006
duncan |associates
Table of Contents
Introduction ....................................................................................1
  Purpose of Critique.....................................................................................................1
  Project Goals .............................................................................................................1
  Basis of Recommendations ..........................................................................................1
  Next Steps .................................................................................................................2
  Plan Consistency ........................................................................................................2
Document Improvements................................................................3
  “How to Use this Code” Section...................................................................................3
  Graphics and Tables ..................................................................................................3
  “Plain English” Regulations..........................................................................................4
  Sample Page Layout ...................................................................................................4
  Table of Contents and Index........................................................................................4
  Ordinance on CD and Internet ....................................................................................4
Code Organization .........................................................................5
  Current and Proposed Structures..................................................................................5
Development Review Bodies and Procedures ................................6
  Clarify Development Review Procedures........................................................................6
  Streamline Development Review Process .......................................................................7
Zoning Districts ...............................................................................9
  District Nomenclature .................................................................................................9
  From Purely Performance Approach to Hybrid .............................................................10
  Alternatives to Cookie-Cutter Developments................................................................12
  Design Standards .....................................................................................................14
  Density Bonuses for Affordable Housing .....................................................................16
  Other Recommendations ..........................................................................................16
Use Regulations ............................................................................17
  Consolidated Use Table............................................................................................17
  Use Categories ........................................................................................................17
  Permitted, Limited and Conditional Uses.....................................................................18
  Standards for Principal, Accessory and Temporary Uses ...............................................18
General Development Standards .................................................23
  Off-Street Parking, Loading and Stacking....................................................................23
  Landscaping, Buffering and Screening ........................................................................24
  Sign Standards .........................................................................................................27
  Lighting Standards ....................................................................................................33
  Access and Circulation Standards ..............................................................................34
Resource Protection ......................................................................36
  Wetlands .................................................................................................................36

Citrus County                                                                                                    LDC Critique
May 2006                                                       i
  Listed Species...........................................................................................................37
  Groundwater, Spring and Wellhead Protection............................................................38
  Firewise Standards....................................................................................................38
  Commercial Use of Natural Resources .......................................................................38
Subdivision Regulations................................................................41
  Streets .....................................................................................................................41
  Sidewalks ................................................................................................................41
  Stormwater ..............................................................................................................41
  Large Lot Rural Subdivisions ......................................................................................41
  Concurrency ............................................................................................................42
  Transportation Corridor ............................................................................................45
  Related Financing Issues ...........................................................................................46
  Comprehensive Plan Provisions..................................................................................48
  Land Development Code ..........................................................................................48
Violations and Enforcement..........................................................50
  Violations ................................................................................................................50
  Enforcement ............................................................................................................50
  Add, Move and Remove Definitions as Needed ...........................................................51
  Review Authority Table ..............................................................................................52
  Table of Existing Uses ...............................................................................................54

Citrus County                                                                                                     LDC Critique
May 2006                                                       ii
Citrus County has retained Duncan Associates of Austin, Texas, and Muncie, Indiana, to work
with the County in the evaluation of its current Land Development Code (LDC) and,
eventually, in the preparation and implementation of new development regulations.

Purpose of Critique
This critique identifies opportunities for improving Citrus County’s development regulations.
This document will help the County and consultant reach agreement on regulatory changes
before actual ordinance drafting begins. Changing direction on a major issue in the middle
of the drafting process results in wasted time, wasted effort and overall frustration. On the
other hand, agreement on major issues early in the
project allows drafting to occur efficiently and results in a   Critique Elements
                                                                 • Document Improvements
better finished product.
                                                                •   Development Review
The County’s decision-makers should carefully consider          •   District & Use Standards
                                                                •   Development Standards
the policy suggestions offered in this report and provide       •   Resource Protection
direction to the consultant.                                    •   Subdivision Standards
                                                                •   Nonconformities,
                                                                    Enforcement, Definitions
Project Goals
Based on information presented in the County’s Request
for Proposals, the LDC should:
    •   Be a completely new document, not an edit of the existing code.
    •   Contain specific provisions to properly implement the goals, objectives and policies of
        the Plan.
    •   Be clear, concise and contain numerous graphics and charts to illustrate the intent of
        the code.
    •   Be internally consistent.
    •   Clearly describe permitted uses, conditional uses, dimensional requirements and other
        related information.
    •   Be user-friendly with a table of contents and index
These goals, along with policy direction from the Comprehensive Plan and input from local
stakeholders, serve as guiding principles for drafting new regulations for the County.

Basis of Recommendations
This technical analysis of Citrus County’s development regulations is based largely on:
    •   An independent analysis of the existing LDC
    •   A review of the Comprehensive Plan
    •   Stakeholder comments

Citrus County                                                                          LDC Critique
May 2006                                        1
    •   County Staff comments
    •   Public official comments
Independent analysis allows the consultant to recommend “best practices” to address
inadequacies in the County’s current regulations based on our experience elsewhere around
the country. These best practices represent solutions that may or may not necessarily be
acceptable in Citrus County but that, at minimum, provide a starting point for discussion in
addressing specific problems. The input from elected and appointed officials, staff and other
stakeholders offer a local perspective on existing regulatory deficiencies.
The approach used in preparing this critique is to read existing provisions very literally. In
short, the technical review focuses on what existing provisions actually “say,” not on how they
have been interpreted or applied over time by public officials and staff. While this approach
may result in occasional misinterpretations of regulatory intent, such miscues themselves
provide insight into provisions in need of reworking.
Some of the recommendations in this report can simply be implemented as part of the
revision process. Other recommendations will require discussion with County officials. Still
other issues will undoubtedly arise and be addressed, as more stakeholders become involved
in the process and as work on drafting and organization of the regulations uncovers
additional issues.
Finally, it is important to note that criticisms of existing regulations are in no way intended to
reflect poorly on the drafters of previous regulations, or upon public officials and staff
charged with administering them. Over time, amendments written by various people often
become stylistically inconsistent and conflicting in content.

Next Steps
This critique is the primary focus of Phase 1 in the process of writing Citrus County’s new
LDC. Phase 2 of the project will involve drafting of the new LDC. The following steps will
follow the submission of this critique to the County.
    •   Staff Meetings. Present and discuss draft critique with staff.
    •   Final Assessment Report. Following staff meetings, revise critique accordingly.
    •   Planning & Development Review Board Workshop. Key elements of critique presented
        at a workshop for the Planning & Development Review Board. Action should include a
        recommendation to the County Commission regarding direction for Phase 2.
    •   County Commission Workshop. Key elements of critique presented at a workshop for
        the County Commission. Action should include confirmation of the direction
        presented, and authorization to negotiate a Phase 2 contract including a work
        program, timetable, and public input mechanisms.

Plan Consistency
The appendix to this critique contains a separate Comprehensive Plan Consistency report.

Citrus County                                                                           LDC Critique
May 2006                                         2
Document Improvements
A new LDC should be written in plain, but defensible English and should have a logical flow.
The following suggestions offer ways to make the LDC easier to understand and navigate.

“How to Use this Code” Section
A “How to Use this Code” section would increase the ease-of-use of the document. This set
of instructions would be located just inside the front cover of the LDC and would provide
basic information to users on the organization of the regulations. This one-page preface
would set forth responses to a series of scenarios, such as:
    • If you want to know what zoning rules apply to your property
    • If you want to build a structure or establish a particular use
    • If you want to change your zoning (rezone)
    • If you want to vary from the standards that apply
    • If your property is located in an overlay district
    • If you want to subdivide your property
This section covers a substantial portion of the users of the LDC, giving them step-by-step
instructions on sections of the Code to which
they need to refer.

Graphics and Tables
The inclusion of tables is encouraged
wherever possible. The existing use tables
could be condensed (see Use Table
discussion below) and often older LDCs have
sets of standards that could be made much
more clear if they were in table format.                               User-friendly use table
Unlike many regulations, the existing LDC
contains graphics. Additional graphics will
be used in the new LDC to supplement,
explain and clarify the text. However, In
order to maintain legal defensibility,
graphics should not be used in place of

                                                            Graphics supplement the regulations

Citrus County                                                                              LDC Critique
May 2006                                        3
“Plain English” Regulations
To improve the ease of use of the LDC, it should be made less a collection of rules and more
of a reference tool for all potential users: developers, staff and decision-makers. Using plain
English drafting techniques rather than “legalese” makes the document readable, but still
allows it to contain the requirements necessary to make the new regulations enforceable.

Sample Page Layout
Modern word-processing software allows
communities to publish “in-house” documents
that look as professional as those once
laboriously typeset at the printer. Simple
techniques, such as the use of larger,
distinctive typefaces for titles and subtitles,
indented text to indicate the hierarchical level
of each paragraph, generous use of white
space, graphics and tables all help to improve
the visual presentation of an ordinance, and
ideally its ease-of-use. Many of these features
can be found in the sample page graphic to
the right.

Table of Contents and Index
All ordinances and regulatory documents
should contain a useful table of contents and
index. Citrus County’s existing LDC contains
well organized tables of contents for each
Chapter. Most subjects are grouped in a                         Typical page layout features
logical fashion. The new LDC will have a
consolidated table of contents and each Chapter could have its own, more specific table as
The current LDC contains an index in the form of a long table at the end of the document.
The new LDC should have a similar piece. A well-crafted index can be extremely useful to the
general public and to those who use the ordinance on a regular basis.

Ordinance on CD and Internet
When the new LDC is complete, the County should ensure that it can be distributed on CD-
ROM and continue to be posted on the Internet. The final file of the new regulations will be
delivered to the County and will consist of an MS-Word document, an Adobe Acrobat (PDF)
file of the entire new LDC and a PDF of each Article of the LDC. The PDFs may be posted on
the County’s website and are readable by most computer operating systems.

Citrus County                                                                       LDC Critique
May 2006                                           4
Code Organization
Current and Proposed Structures
One of the first steps in drafting is to reorganize the Citrus County’s existing LDC. The
following illustration shows that the proposed structure will be quite different from the
structure of the current Code.

Citrus County                                                                         LDC Critique
May 2006                                        5
Development Review Bodies and Procedures
The development review chapters of the new LDC should be clear and predictable. A
potential applicant should readily be able to understand the various review bodies, processes
and criteria that apply to a given procedure. The recommendations for improving the
development review process can be boiled down to two basic types of improvements:
clarification and streamlining.
Clarify Development Review Procedures                                              Submittal
Development Review Bodies
                                                                                   Sufficiency    Review
Section 2470 of the current regulations assigns final review authority to           Review
various administrative officials. The new LDC should clearly establish the
authority and duties for all development review bodies in one chapter. The
composition, terms of office, review authority (recommendation, final             Review &
decision or appeal) and other specifications for each body should be

Summary of Development Review Authority
The material on development review bodies should contain a table
summarizing each body’s review authority. A summary based on existing
review authority is included in the Appendix, based on a literal
reading of the existing LDC.                                      SIMPLIFIED

Application Contents and Forms                                                  MINOR

Section 2232.B consists of a list of materials required for        Planning                      MAJOR
preliminary plat submittal. The LDC should authorize the          Final Action
Director of Development Services to establish application
requirements for each type of approval. These requirements
                                                                               Final Action
should be collected in checklist form in an administrative manual or
separate application packets. This reduces the bulk of the LDC and allows
the specific application content requirements to be changed administratively                         Body
without going through the LDC text amendment process in front of the PDRB and                     Final Action
Board of County Commissioners.

Board of Adjustment to Hear Variances and Administrative Appeals
It is unclear from a literal reading of the current regulations if Citrus County has a Board of
Adjustment or not. The term shows up once in Section 3130; however, since that is the only
place its mentioned, it may be a scrivener’s error. Currently the Planning and Development
Review Board handle variances and appeals of administrative decisions. National best
practice is to have a separate Board of Adjustment/Appeals to deal with these two matters.

Citrus County                                                                          LDC Critique
May 2006                                        6
Boundary Surveys on Residential Permits
Over the years the County has wrestled with the idea of requiring boundary surveys along
with site plans for residential projects. Requiring such surveys could reduce the need for
variances or site plan modifications. In addition, accidental encroachments would not
happen so often. Since the consultant recommends that submittal requirements be moved
outside of the LDC and maintained administratively, the phrase “boundary survey” may not
appear in the finished LDC, whether it becomes a submittal requirement or not.

Public Notice and Hearing Requirements
Section 2600 of the existing LDC contains requirements for public notice and public hearings.
The counterpart section in the new LDC should retain much of the existing language and
contain tables (such as the one below) specifying which development review procedures
require what kind of public notice, and the review body holding the public hearing.

           Procedure                               Published   Posted       Mailed
           Amendment, Zoning Map (Rezoning)
           Amendment, Ordinance Text
             = Public notice required

In an effort for compliance with Policy 17.13.3 in the EAR-based amendments to the
Comprehensive Plan, a simple addition should be made to the LDC requiring public notice of
1,000 feet for rezonings to the EXT district.

Appeal Provisions
In addition to the recommendation above of having a Board of Adjustment hear appeals of
administrative decisions, it should be specified in the new code that appeals of a decision by
the Board of County Commissioners should be made to a “court of competent jurisdiction.”

Streamline Development Review Process
County staff has expressed concern over the numerous public hearing
and meeting required for certain review applications. One way to
decrease the number of meetings required for review would be to
collapse the Plat Review Team and the Technical Review Team into a
more general Development Review Team that would review or make
final decisions on site plans and plats.
Some of the problems are not obvious on the face of the code,
however. During the next step in the process, the consultant will work with the County to
diagram how multiple public hearings occur and to suggest additional remedies.

Citrus County                                                                        LDC Critique
May 2006                                       7
Preapplication Conferences
Section 2210 requires a preapplication conference prior to applying for a development
order. Many local governments use the preapplication meeting as a standard part of
development review because it provides an applicant with valuable input about what is
expected in the review process and informs staff of an applicant’s general development
intentions. The LDC should be more specific about which development review procedures
require a preapplication conference. The County should consider requiring a preapplication
conference for the following approvals:
    •   Site Plan Review
    •   Zoning Map Amendment (Rezoning)
    •   Conditional Use Permits
    •   Preliminary Plats
The intent is not to expand the current development review timeline, but to improve submittals
and reduce review time required.

Written Interpretations
Chapter 3 of the new LDC could have a section on Written Interpretations. An applicant
would file a request for an interpretation on a specific matter that is unclear in the LDC. The
Director of Development Services would then consult the LDC and staff (including legal staff).
Finally, the Director would render a written interpretation and make it available to the
applicant. All such interpretations would be kept on file and possibly online, available for
public inspection. This improves consistency in interpretations related to similar situations that
may occur at a later date. The LDC should be periodically amended to incorporate the
written interpretations that are on file.

Conditional Uses
The County has a surprisingly large number of conditional uses, each requiring a public
hearing and formal review process. It appears that many of these have been designated
conditional uses because of the lack of standards found in a more standard zoning ordinance
and the resulting concern about possible abuse of some of these uses.
To the extent that these have been designated “conditional” only in the LDC and not in the
comprehensive plan, many of these can be converted in the new LDC to uses allowed by right
but subject to specific development standards. Thus, a duplex, now allowed as a conditional
use in the LDR, could be allowed by right on lots meeting specific dimensional requirements.
Section 4450 of the current LDC already contains similar standards that apply to a few
specific uses, such as “Adult Living Facilities,” and Section 4650 contains site design
standards that are use-specific. Most of the concerns that arise with most of the uses now
listed as “conditional” can be addressed with similar, objective, standards and many of the
existing “conditional” uses can thus be moved to a similar category that involves only
administrative review.

Citrus County                                                                          LDC Critique
May 2006                                        8
Zoning Districts
The overriding theme for the zoning districts in the new LDC should be to allow flexibility in
design of new developments with a wide variety of housing choices and a mix of uses. The
following recommendations work toward these goals.

District Nomenclature
Citrus County does not seem to have a number of superfluous zoning districts. The following
table shows the existing hierarchy of districts on the left and the few proposed changes
(italicized and in red) on the right.

Residential Districts
Existing Hierarchy                                 Proposed Hierarchy
AGR        Agriculture                             AG       Agriculture
CL         Low Intensity Coastal and Lakes         CL       Low Intensity Coastal and Lakes
RUR        Rural Residential                       RUR      Rural Residential
CLR        Coastal and Lakes Residential           CLR      Coastal and Lakes Residential
CRR        Central Ridge Residential               CRR      Central Ridge Residential
LDR        Low Density Residential                 LDR       Low Density Residential
MDR        Medium Density Residential              MDR      Medium Density Residential
HDR        High Density Residential                HDR      High Density Residential
MHP        Mobile Home Park                        MHP      Mobile Home Park
Commercial Districts
New                                                NC         Neighborhood Commercial
PSO        Professional Service/Office             O          Office
CLC        Coastal and Lakes Commercial            CLC        Coastal and Lakes Commercial
GNC        General Commercial                      GNC        General Commercial
                                                   IL         Light Industrial
IND         Industrial
                                                   IH         Heavy Industrial
Special Purpose and Overlay Districts
EXT       Extractive                               EXT        Extractive
PSI       Public/Semi-Public, Institutional        PSI        Public/Semi-Public, Institutional
TCU       Transportation/Communication/Utilities   TCU        Transportation/Communication/Utilities
REC       Recreation                               REC        Recreation
CON       Conservation                             CON        Conservation
RVP       Recreational Vehicle Park/Campground     RVP        Recreational Vehicle Park/Campground
PDR       Planned Residential Development          PDR        Planned Residential Development
PDO       Planned Development Overlay              PDO        Planned Development Overlay
NA        Old Homosassa Special Overlay            OH         Old Homosassa Special Overlay
New                                                AIR        Airport Overlay

      •   The agricultural district is proposed to be shortened to “AG” simply to avoid confusion
          with the proposed AIR, Airport Overlay district.
      •   An NC, Neighborhood Commercial district is proposed to accommodate convenience
          uses in and around residential areas. It would have a maximum lot size (perhaps
          around 6,000 square feet) and permit uses to serve the immediate area.

Citrus County                                                                                 LDC Critique
May 2006                                            9
    •   The O, Office name change is proposed for simplification.
    •   Finally, the Economic Development Goal Setting Study conducted for Citrus County in
        2004 states that “Entirely new industries are being created during this period of
        technical change and invention. Future employers in the area will likely include these
        new technology companies, while some traditional industries might very well pass into
        the night.” The splitting of the IND, Industrial district into an IL, Light Industrial and IH,
        Heavy Industrial districts would help regulate such “cleaner” higher-tech industrial uses
        differently from traditional heavy industrial uses.

A Note on Planned Developments
The current LDC contains a “Planned Development Residential” district and a “Planned
Development Overlay” district, with additional references to Planned Commercial
Development and Planned Industrial Development. Nothing in the current LDC makes it
clear what the differences are. The status of planned developments – whether as free-
standing districts or as overlay districts – should be made clear in the new LDC, to avoid
future confusion and possible litigation over the issue.

From Purely Performance Approach to Hybrid
The residential zoning districts for Citrus County’s current LDC are based on maximum density
with planned development projects being granted more density than conventional, by-right
developments. The consultant believes that a mix of this performance approach along with
conventional lot requirements such as minimum lot area and width would be beneficial to the
new LDC. The table on the next page shows existing standards (shaded yellow) along with a
conversion for each district over to a minimum lot area and width standard (shaded green).

Citrus County                                                                             LDC Critique
May 2006                                         10
                                                                                                                        Min Lot
District/Category               Max Density                   Min Site Area           Min Lot Area*                  Width (ft)**
CL, CLRA by right               20.0 acres per unit           ---                     20 acres per unit                       800
CL in V zone                    40.0 acres per unit           40 acres                40 acres per unit                     1200
CL, CLRA planned                5.0 acres per unit            160 acres               5 acres per unit                        400
CLRA planned upland             10.0 acres per unit           20 acres                10 acres per unit                       600
AGR by right                    10.0 acres per unit           ---                     10 acres per unit                       600
RUR by right                    10.0 acres per unit           ---                     10 acres per unit                       600
LDR by right                    2.0 units per acre            ---                     15,000 SF                                70
LDR planned                     6.0 units per acre            ---                     5,000 SF                                 40
MDR by right                    6.0 units per acre            ---                     5,000 SF                                 40
MDR planned                     8.0 units per acre            ---                     4,000 SF                                 35
HDR by right                    12.0 units per acre           1.0 acre                2,600 SF per unit                       120
HDR planned                     20.0 units per acre           1.0acre                 1,500 SF per unit                       120
MHP by right                    6.0 units per acre            ---                     5,000 SF                                 40
MHP planned                     9.0 units per acre            ---                     3,500 SF                                 35

                                             Existing Standard
                                             Proposed Standard
* Minimum lot areas were derived by assuming 15% efficiency in the use of an acre after netting out sensitive and unbuildable land,
then reducing the buildable area of an acre by another 15% for street right-of-way and other exactions.
** Minimum lot widths were derived by taking the square root of 1/3 of the minimum lot area, thus producing a 1:3 lot

An advantage to moving away from basing districts solely on density is that developers from
outside Citrus County are likely to be more familiar with the dual approach recommended
above, as it is more common in other areas. At lest some of the nonresidential districts (such
as the proposed CN, Neighborhood Commercial district) should be assigned minimum lot
area requirements as well.

Citrus County                                                                                                     LDC Critique
May 2006                                                      11
Alternatives to Cookie-Cutter Developments
Policy 17.3.5 of the Comprehensive Plan states, “The County LDC shall
designate through suitable performance criteria, areas allowing single
family housing, cluster attached housing,…rural estates, and
agricultural residences.” In addition, Policy 17.5.3. states, “The LDC
shall contain incentives to encourage construction of Planned
Developments that feature innovative land use design, protection of
environmentally sensitive areas, and provide for a livable, attractive,
                                                                               LDR District (by right)
and functional mix of uses.” The following recommendations would             Conventional Subdivision
work toward implementing these policies by right, rather than the           Minimum Lot Size: 15,000 sf
negotiated Planned Development process, while discouraging land-                Density: 2units/acre
consuming, monotonous large lot development.
                                                                            Common Open Space: 0%
To integrate with other concepts in the Comprehensive Plan, the focus
should be on two general types of alternative residential developments:
    1. Higher density housing types in Planned Service Area (PSA); and
    2. Development patterns that conserve open space and
       agricultural areas outside the PSA.

Multiple Patterns of Subdivisions
To provide flexibility and certainty in base residential districts, the
County should consider explicitly allowing alternative residential
subdivision design types such as cluster and conservation development.
The current LDC encouraged in residential planned developments and            LDR District (by right)
                                                                               Cluster Subdivision
is mandatory in some instances in the CL district. The consultant             Density: 2 units/acre
recommends allowing cluster and conservation subdivisions by right           Common Open Space:
(within parameters) in most residential districts.                                    40%

Generally, in a conventional subdivision, only one housing type is
permitted. We recommend an approach that permits mixing of housing
types (see Zone for a Choice in Housing below). Where a conventional
subdivision might require open space only as needed to accommodate
stormwater management facilities on-site (5 to 10 percent of the site), a
cluster development would allow a mix of housing types and require 20
to 40 percent permanent open space and a conservation development
would require 60 percent open space. A cluster or conservation
subdivision could be permitted by-right in certain residential districts
that would allow reduced lot sizes and widths in trade for common
open space. This provision could be offered with increased density as          LDR District (by right)
an incentive if the County so desired (in much the same way that             Conservation Subdivision
                                                                               Density: 2 units/acre
Planned Developments are currently granted a density bonus).                  Common Open Space:

Citrus County                                                                    LDC Critique
May 2006                                      12
Zone for a Choice in Housing
In an effort to support affordable and workforce housing choice, we recommend allowing a
wider range of housing types in certain residential districts. A housing palette (such as the one
below) providing lot and bulk standards for varying dwelling unit types is an important
flexibility option that allows a developer to seize the optimum market opportunity at any point
in time without going through the rezoning process. Adding semi-attached, zero lot line, two-
family, townhouses, upper-story residential and other reduced cost housing types to existing
single-family districts ensures life-cycle housing for all. While some of these housing types are
not expressly prohibited in the LDC, they should be defined and standards put in place to
ensure citizens in the community are offered a choice in housing. In suburban areas,
perimeter buffers and increased open space standards can be used to alleviate concerns of
adjacent property owners where housing types change.

Life Cycle Housing
Citrus County has a tremendous retirement-age
population. It also has a sizeable population of young
families. Shouldn’t a person be able to stay in a beautiful
setting like Citrus County his or her entire life if they so
desire? Life cycle housing is defined as the opportunity to
provide a person’s housing needs for their entire lifetime
within a single neighborhood or area. The concept implies
that mixed neighborhoods, containing starter homes,
larger homes for families, apartments, condominiums or
townhouses for the retiree population, and assisted living
facilities for the elderly, should all be located in relatively
close proximity so that one’s entire lifetime could be spent
within a single neighborhood. Current housing patterns
move the population around in a way that historic patterns
of development never required. Use of the housing palette
(as shown to the right), along with careful thought about
permitted housing types in each district, will allow future
development of communities serving all of the segments of         Use of a housing palette, along with careful
                                                                  thought about permitted housing types in
our lifestyles.                                                   each district, will allow future development of
                                                                  communities serving all lifestyles segments.

Citrus County                                                                               LDC Critique
May 2006                                         13
Lot Averaging
Lot averaging permits modest flexibility in lot sizes without requiring   Lot #       Lot Area (sq ft)
the more complex standards typically associated with clustering.          1                5,010
Lot averaging is an effective technique where flexibility in lot size     2                4,800
may help preserve site resources.                                         3                5,500
                                                                          4                4,900
Lot averaging permits one or more lots in the subdivision to be           5                4,650
undersized, provided that the average lot size for all lots in the        6                5,005
development is no less than the minimum lot size for the zoning           7                4,950
district. Lot averaging is a technique that has been frequently           8                5,220
overlooked as communities adopt more sophisticated cluster or             9                4,620
                                                                          10               5,550
open space development regulations. Allowing lot sizes to be
                                                                          Avg              5,020
averaged over an entire site offers flexibility to adjust lot sizes   Example: Lot breakdown for a 10-lot
and still meet resource protection goals.                             subdivision   in   the   MDR      district
                                                                      (recommended minimum lot size = 5,000
                                                                      square feet, minimum lot size less 10% =
Planned Developments Generally                                        4,500 square feet)
The planned unit development standards in the current LDC
are relatively weak, imposing only a basic percentage open space requirement. Although the
resource protection standards overlay that and improve the effectiveness of the over-all
regulatory scheme, the new LDC should contain more standards to ensure that planned
developments actually enhance the quality of development and do not just change the lot
dimensions. Basic standards to ensure that some of the open space is useable for active
recreation, to require connection of open spaces to one another and to external greenways
and open space, and to include at least some amenities in planned developments are
relatively standard in modern development regulations.

Design Standards
The LDC contains “Additional Design Standards for Large Retail Projects” (Sec. 4660) and
“Design Standards for Small Nonresidential Development Projects” (Sec. 4661, which has
been in effect only since October 2005.
These sections contain many excellent standards designed to alleviate the monotony or long,
blank walls, huge parking lots and other characteristics of some modern development. There
is a good deal of redundancy between the two sections, however, and there is some
redundancy between these sections and the more general landscaping provisions for parking
lots contained in Section 4330. These sections should be consolidated in the new LDC, with
the standards applicable only to larger projects simply identified as such; issues addressed
adequately in other sections of the code should be dropped from this one.
Neither of these sections applies to large multi-family housing projects, which can raise many
of the same issues as large commercial development. The new LDC should apply these or
similar provisions to large multi-family housing projects, as well as to the nonresidential
projects now subject to these standards.

Citrus County                                                                               LDC Critique
May 2006                                        14
Chapter 5 of the current LDC contains a hodge-podge of “supplemental” standards. Some
of these appear to be very good, but they should be fully integrated with the more
comprehensive sets of standards set out elsewhere in the code.

Open Space and Amenities
Opens spaces, parks, plazas and playgrounds enhance
the community experience. They provide gathering spaces
and focal points for the community. Open space and
recreational areas can be used as a factor in determining
the appropriate level of density – with small lots, narrower
streets and higher densities conditioned on the provision
of the appropriate allocation of open space and
recreational areas. Alternative residential design types
such as cluster and conservation subdivisions as
                                                             Neighborhood amenities, such as natural
described above would be allowed with increased density, stormwater retention , that enhance the overall
provided that additional open space and recreational         quality of life for residents should be required in
                                                             new residential developments.
areas are also developed. Such space should be usable,
both in its size and design and its location within the
development, to serve as an amenity in perpetuity for the proposed development. The open
space should connect with existing or proposed open space in adjacent developments.
Other neighborhood amenities that enhance the overall quality of life for residents could be
required for developments looking for increased density options. Some possible amenities to
    •   Picnic areas                                        •   Swimming pools
    •   Paths and trails                                    •   Squares
    •   Play areas                                          •   Wider sidewalks with narrower streets
    •   Ball fields, basketball courts                      •   Street trees
    •   Health clubs                                        •   Natural stormwater retention
    •   Meeting/activity rooms                              •   Entrance features
The issue of open space and amenities is particularly important for higher density residential
developments. If multi-family units are developed in the context of a planned unit
development, then the open space requirements of Section 5431 apply; otherwise there do
not appear to be any basic standards for open space, recreational facilities or other
amenities, often required for multi-family complexes in other communities. Such on-site
facilities are particularly important in a relatively rural area, like Citrus County, where
apartment or condominium residents may be blocks or even miles from the nearest public
recreation facilities or similar amenities.
Open space and amenities are also important for the relatively new land-use concept of
Recreational Vehicle Parks.

Citrus County                                                                                  LDC Critique
May 2006                                            15
Density Bonuses for Affordable Housing
Policy 1.9.1 of the Comprehensive Plan states, “The County shall consider density bonuses
for affordable housing projects for possible inclusion in the LDC.” There are several options
and models to choose from when thinking of how to provide affordable housing density
bonuses. The consultant may provide affordable housing best practices at a later date;
however; the County should remember that the ability to do lot averaging and to mix housing
types is a great “non-controversial” way to allow for affordable housing since smaller lots are
made possible and more affordable housing types are permitted by right. In addition,
allowing accessory dwelling units by right (as described in the Use Regulations section below)
is the least complicated way for an LDC to facilitate inclusionary housing.
Density bonuses are not always adequate to encourage the development of affordable
housing by private developers. Sometimes a procedural incentive is even more effective,
following the old adage that “time is money.” The County may thus want to consider making
affordable housing subdivisions in the Planned Service Area subject only to Level 1 review,
while requiring Level 3 for market-rate projects in the same locations.

Other Recommendations
Create Airport Overlay
An airport overlay district should be incorporated into the new LDC for compliance with
Policy 14.4.1 of the Comprehensive Plan that states, “The County shall create an overlay
land use/zoning district which restricts height of structures and incompatible uses around the

Impervious Surface Ratio vs. Lot Coverage
Table 4-5 in the existing LDC contains impervious surface ratios (ISR) for each zoning district.
Stakeholder comments suggest switching from ISR to building coverage due to the obvious
difficulty of enforcing ISR in residential areas, where a person could lay a patio on the
weekend with no permit. If the County agrees to this switch, it can be done.

Street Setbacks
It appears that the setbacks for most buildings are established in Section 4245 of the LDC.
Minimum setbacks in the section are based on street type. This approach can be maintained
in the new LDC however the standards prohibit any pedestrian-oriented building orientation
that would mandate buildings to be placed close to the right-of-way line. This orientation
would be particularly appropriate in the proposed NC, Neighborhood Commercial district
and with some housing types described in Alternatives to Cookie Cutter Developments above.

Citrus County                                                                        LDC Critique
May 2006                                       16
  Use Regulations
  Consolidated Use Table
  A table containing all uses as rows, and all zoning districts as columns should be created. A
  sample use table from another community is provided below. See the Appendix for a use
  table showing Citrus County’s existing permitted uses. Aspects of the use table such as “use
  category” and “P/L/C” will be explained below.

                                                           RESIDENTIAL                     NONRESIDENTIAL







Use Category       Specific Use                                                                                            Standards


 Key: P = Permitted by Right         L = Limited Use      C = Conditional Use Permit Required          [blank] = Not       Permitted
               (Descriptions of Use Categories and Specific Uses are provided in Section 16.03 and Section 16.04)
Residential Uses
                   Single family, detached        P   P     P   P    P         P
                   Single family, attached            L     L   L    P    P    P                                            5.02.010
                   Two-Family                                        P    P    P
Household Living
                   Townhouse                                              P    P         P    P   P
                   Multifamily dwelling                                        P         P    P   P
                   Upper-story residential                                          L    L    L   L    L                   5.02.020
                   Home occupation                L   L     L   L    L    L    L    L    L    L   L    L                   5.03.020
Commercial Uses
                   Overnight accommodations,
Overnight                                                                                L    L   P         L               5.02.140
                   except as listed below
                   Bed and breakfast              C   C     C   C    C    L    L    P    P    P                             5.02.130

  Use Categories
  The NEW LDC should consolidate the permitted uses into use categories. Use categories
  should be based on similarities in uses, characteristics of the use and common accessory
  uses. They allow groups of similar uses to be permitted in a set of districts while certain
  specific uses from the category may be “singled out” and permitted in a different set of
  districts. Note in the use table above that in “Overnight Accommodations,” bed and
  breakfasts are singled out and allowed in three specific districts, while all other uses in that
  category are permitted elsewhere. In a sense, the existing LDC takes a step toward utilizing
  use categories by grouping some uses under “office,” “neighborhood commercial” etc.
  One of the requirements of broader use categories is a mechanism to define use. When
  broad use categories are employed, they commonly define characteristics of use, appropriate
  accessory uses, examples (names) of uses and excluded uses. The following sample table
  demonstrates this.

  Citrus County                                                                                                       LDC Critique
  May 2006                                                      17
Overnight Accommodations
Characteristics: Residential units arranged for short term stays of less than 30 days for rent or lease.
Examples                      Accessory Uses                               Uses not included
Hotel, motel, inn,            Ancillary indoor storage                     Campground, private, hunting/fishing camp, dude
  extended-stay               Associated office                              ranch, recreational vehicle (RV) park (see Outdoor
  facility, bed and           Bar or tavern (see 5.3.4.b and 5.3.4.m)        Recreation)
  breakfast home              Food preparation and dining facility         Convention center (see Indoor Recreation)
                              Laundry facility                             Patient Transient accommodations (see Medical
                              Meeting facility                               Facilities)
                              Off-street parking                           Short Term rental (see Household Living)
                              Restaurant (see 5.3.4.l)                     Transient lodging, shelter for the homeless (see
                              Swimming pool, other recreational              Social Service Institutions)

Permitted, Limited and Conditional Uses
The current use tables in the LDC provide a hierarchy of uses that might not be intuitively
clear. The following table shows the existing hierarch along with a proposed one that is more
in accord with other communities across the nation.
                      Existing Hierarchy                             Proposed Hierarchy
                      1 = Level 1 Review                             P = Permitted Use
                                                                     C = Conditional Use
                      2 = Level 2 - Conditional Use Review
                                                                     (requires BoCC approval)
                      D = Depends on use – subject to                L = Limited Use
                      specific criteria in LDC.                       (permitted subject to limitations)
                      S = Subject to Interpretation pursuant
                      to Section 1410. of LDC.

Article 5 should contain criteria for use interpretation that could apply to any potential use not
listed in the LDC. The phrase “other substantially similar uses” would therefore not have to be
included in the use table.

Standards for Principal, Accessory and Temporary Uses
Since the existing LDC is largely performance-based, it has many standards for specific uses
(Section 4650). Many of these standards should be carried over to the new LDC. The
following discussion provides some suggestions for better dealing with certain land uses.

Group Living
The current LDC and Future Land Use Map do not deal explicitly with the issue of residential
living facilities for small groups of individuals needing special care. Such facilities are often

Citrus County                                                                                                     LDC Critique
May 2006                                                       18
called “group homes,” or, in the Florida statutes, “community residential homes.”1 The
Florida statute establishes two categories of protected homes:
           Homes for 7 to 14 Residents. Under the statute, “’Community residential home’”
           means a dwelling unit licensed to serve clients of the Department of Children and
           Family Services, which provides a living environment for 7 to 14 unrelated residents
           who operate as the functional equivalent of a family, including such supervision and
           care by supportive staff as may be necessary to meet the physical, emotional, and
           social needs of the residents.”2 The statute establishes a site location review process
           for the siting of such facilities in multi-family residential districts. If the proposed
           facility is not located within 1,200 feet of another such facility or within 500 feet of a
           single-family home, the statute requires very specific findings by the local government
           to reject the proposed site. 3
           Homes for up to 6 Residents. Similar homes, with fewer than seven residents, are
           essentially allowed by right in single-family zoning districts, subject to a distance
           requirement between them. The statute provides, “Homes of six or fewer residents
           which otherwise meet the definition of a community residential home shall be deemed
           a single-family unit and a noncommercial, residential use for the purpose of local laws
           and ordinances. Homes of six or fewer residents which otherwise meet the definition of
           a community residential home shall be allowed in single-family or multifamily zoning
           without approval by the local government, provided that such homes shall not be
           located within a radius of 1,000 feet of another existing such home with six or fewer
Under current interpretations of the U.S. Fair Housing Act and the Americans with Disabilities
Act, group homes of similar sizes for persons with disabilities should be treated similarly to
those protected by the statutory scheme, regardless of whether the residents of the units are
“clients of the Department of Children and Family Services.” Therefore, the new LDC will
need to be adjusted accordingly.

Manufactured Homes
Section 4662 of the current LDC divides manufactured homes into two types: Residential
Design Manufactured Homes (RDMH) and Standard Design Manufactured Home (SDMH).
Homes that meet certain residential “look alike” standards such as roof pitch and skirting are
designated RDMH. However, it is not obvious in the LDC what advantage there is in having
this designation. This should be corrected in the new code by making it explicit that RDMH
homes are allowed in residential districts while SDMH homes are only permitted in rural or
agricultural districts and in manufactured home parks.

    See Fla. Stats. §419.001.
    Fla. Stats. §419.001(1)(a).
    Fla. Stats. §419.001(1)(a).
    Fla. Stats. §419.001(2).

Citrus County                                                                              LDC Critique
May 2006                                           19
Also, the only residential use explicitly permitted in the MHP district is “caretaker residence.”
The consolidated use table will explicitly show that manufactured home parks are allowed in
this district.

Industrial Uses
As described in District Nomenclature above, the set of
industrial uses regulated in the new LDC should be nuanced
to show where lighter, high tech industrial uses (such as
experimental laboratory) should be allowed versus where
more traditional industrial uses (such as feedlots) are more
In addition, a Policy 17.7.3 mandates that all new industrial
development shall be required to be served by central water Industrial use in Citrus County
and sewer facilities. This requirement will be part of specific
use standards for any industrial use listed in the proposed consolidated use table (see the
Appendix at the end of this critique).

Cell Towers
As part of this critique, the consultant has reviewed Section 4673, related to
telecommunications towers, with amendments proposed in a March 2, 2006, draft of an
ordinance containing multiple proposed amendments and updates to the LDC.
The basic philosophy that underlies the code is the one that we recommend:
     •   Allowing antennas on existing structures in nonresidential zones as a permitted use
         with relatively few restrictions (Section 4673.F.10);
     •   Requiring a reasonable level of proof from anyone proposing a new tower (Section
     •   Requiring that an applicant provide evidence of efforts to collocate a new antenna as
         an alternative to proposing a new tower (Section 4673.F.12).
The proposed deletion of Section 4673.L., requiring that an applicant provide certification
that a new facility will comply with federal regulations regarding interference is both
appropriate and necessary; under the Telecommunications Act of 1996, the Federal
Communications Commission has exclusive jurisdiction of this issue and has clearly
preempted the field.1
Section 4673.C.7., apparently intended to allow amateur radio antennas and receive-only
antennas, is broader than it needs to be. As written, it exempts all towers “under 70 feet in

    See, 47 U.S.C. § 332(c)(7)(A). which includes the following language:
         (iv) No State or local government or instrumentality thereof may regulate the
         placement, construction, and modification of personal wireless service facilities on the
         basis of the environmental effects of radio frequency emissions to the extent that such
         facilities comply with the Commission's regulations concerning such emissions.

Citrus County                                                                                       LDC Critique
May 2006                                                20
height.” The 70-foot height is a fairly common one used for amateur radio and receive-only
towers, but there are many commercial radio and other antennas that are 70 feet or less in
height. The County may wish to consider some modification to this language, either based
on the purpose (non-commercial, amateur radio or receive-only) or the number of such
towers on a lot (not more than one such tower on a lot without going through a use-by-review

Accessory and Temporary Uses
Several simple modifications to the existing accessory use
provisions could improve the LDC and satisfy some
stakeholder comments:
    •   Limit accessory structures to one-story
    •   Require that facade materials of accessory structures
        match principal structure
                                                                  Large garage in Citrus County
    •   Limit uses of accessory structures
    •   Prohibit buried gasoline tanks in residential areas or
        sensitive environmental areas
The new LDC could benefit from have specific standards for
certain temporary uses. Unlike many LDCs, subsection 2030.C
of the existing code provides general regulations for temporary
uses. Specific regulations for some temporary uses (such as
circuses, carnivals, fairs, tent sales or model homes/rows)
could be added as well.
                                                                  Temporary use in Citrus County
The Chamber of Commerce has raised questions about retail
sales as independent temporary uses; they have specifically suggested banning temporary
outdoor sales. That may not be the best solution, but the issue should be addressed. There
seems to be a significant difference to the County between an established business that
receives permission to use a portion of its parking lot for temporary sales of holiday
decorations and a transient merchant that seeks a permit to make temporary sales of flowers,
artwork or stuffed toys from a vacant lot. As this issue is considered, however, it will be
important to keep in mind such common temporary sales uses as fireworks stands, produce
stands, and holiday tree lots, some of which may be operated by local nonprofit

Accessory Dwelling Units and Duplexes
Unlike many development codes, Section 4451 of the Citrus County LDC allows accessory
dwelling units in relation to a residential structure. However, such units are required to be
located within the principal structure. The new code should allow them within or outside of
the principal structure. Accessory units often serve as an opportunity for owners of larger
homes to acquire income for upkeep of the principal structure. They also provide smaller,
affordable housing units for elderly residents and young adults. The existing standards for

Citrus County                                                                           LDC Critique
May 2006                                          21
accessory dwelling units appear to be good. Some additional standards to consider adopting
    •   Requiring owner-occupancy of one of the units
    •   Requiring an additional off-street parking space
    •   Making the minimum floor area for a detached unit around 25%
Detached units are often required to be a certain distance from the primary unit and must
meet all setback requirements. Accessory units should always be architecturally compatible
with the primary residence and on-site parking must be provided to serve additional
Because accessory dwelling units in separate structures are often used more intensively than
those in the primary residential structure, accessory dwelling units in separate structures
should be allowed only when the two dwelling units on the lot will conform with the density
limits for that district.
A separate, but conceptually related, provision of the current LDC allows duplexes in the LDR
(Low Density Residential) district as a conditional use (Level 2 Review). See Section 4624. In
contrast to the provisions for accessory dwelling units, there are no standards to guide the
approval of a duplex. There are many, older lots in the county that are very small and that
are inadequate to contain two dwelling units. Either this section should be revised to impose
a minimum lot size requirement for a duplex in the LDR or it should be merged with the
provisions for accessory dwelling units.

Citrus County                                                                       LDC Critique
May 2006                                      22
General Development Standards
Off-Street Parking, Loading and Stacking
The required parking schedule in Section 4234 of the current LDC should be modified to
integrate with the use categories concept described in the Use Regulations section above. Any
requirement based on number employees should be modified, as this number constantly
changes. Basing parking ratios on gross square footage or seating is more effective. In
addition, the County should decide if it wants to implement a maximum parking ratio. This
may be accomplished by requiring that no use may provide more than 110 percent of the
minimum required parking spaces.
The provisions for parking reduction are sensible and consistent with practice elsewhere; they
should be retained. In the revised LDC, these provisions will all be grouped in a section on
“alternate parking plans”.
In response to Section 4330, additional considerations should be made regarding the
landscaping in the interior of the parking area. As opposed to specifying a percentage
(currently 10 percent) of the parking area to be landscaped, the following ideas should be
    •   A required percentage of canopy
    •   A required distance to a canopy tree
        (in a specified planting area);
    •   A required landscape median per
        parking row; or
    •   A ratio of islands of a specified size
                                                         Possible Interior Landscaping Strategy
        per number of required/proposed
        parking spaces
The County should require a vegetative hedge, berm or low wall around the perimeter of all
parking areas. For better and more efficient collection, retention, conveyance and pollutant
filtering of storm water runoff, the use of a depressed planting median could be used in lieu
of a raised tree island. These requirements along with the maximum parking provision
described above, would make Citrus County’s parking lots more appealing.

Citrus County                                                                              LDC Critique
May 2006                                         23
Landscaping, Buffering and Screening
Citrus County’s landscape buffering standards appear to be quite good. However, a
stakeholder mentioned that something should be done to address transitions between
incompatible uses. The whole purpose for buffers to exist is to lessen the transition between
uses so perhaps some improvements in the existing language is necessary.
One problem with the current standards is that there are separate landscaping standards for
parking lots, and those do not mesh entirely with the more general landscaping standards.

Single-Family Home and Duplex Exemption
Section 4321 of the existing LDC exempts single-family homes and duplexes from the buffer
requirements. This exemption should not be in place. While such uses are relatively low
impact, there are instances, for example when duplexes are adjacent to a single family
development, where a minimal buffer could be required.

Plant Materials and Terminology
The types of trees required in buffers are currently labeled “small,” medium” and “large.” It is
not apparent in the LDC what the thresholds are for such sizes. These terms should be
changed to the more conventionally-accepted “canopy” and “understory” trees and the size
thresholds should be specified.
Many size standards for landscaping materials are specified with the traditional “diameter
breast high” phrase. Apparently local nurseries typically sell plant materials based on the size
of container. Staff has suggested changing the terminology in the code to match the
container sizes commonly offered locally. That is a good suggestion if the County has some
form of assurance that a 25-gallon container will ALWAYS contain a tree or shrub meeting
other dimensional requirements and that it will not simply be a large container with a small
The landscaping ordinance does not currently contain a list of approved plant materials or
any limitation on the use of noxious weeks or invasive exotic species in required landscaping.
At a minimum, the new LDC should prohibit the use of noxious weeds and invasive exotics.
In addition, it should clarify what the term “conifer” means where it is required in some buffer
districts. It may also be desirable to include a list of approved plant materials (Sec. 4330 –
Tree Protection – currently has such a list), with a procedure through which other materials
could be approved.
In addition to these relatively standard provisions for plant materials, it may be useful to
include in the new LDC a diversity requirement (maximum percentage of landscaping to be

Vacant Property
Section 4322.B allows a 50 percent reduction in buffer width where the adjacent parcel is
zoned nonresidential and is vacant. The current model assumes equal impacts by the uses on
either side of the property line. It would be more equitable to allow a reduction in proportion
to the impact of the use. For example, if an industrial use comes in next to a vacant parcel

Citrus County                                                                        LDC Critique
May 2006                                       24
that is zoned PSO, Personal Service and Office, a 40-foot buffer is required. The new
regulations could allow only a 20 percent reduction on the side of the industrial use. Then
when the office use develops, it would provide the remainder of the required buffer width.
Section 4322.D allows for smaller trees to be planted in the buffer where the adjacent parcel
is zoned residential and is vacant. The plants must reach the required size within three years
from the time of planting. This exemption should be removed from the code because
adjacent development could occur more swiftly than the growth of the plant material.

Eliminate Wooden Fences as a Buffering Component
Section 4324 allows a reduction in plant material when a
fence is used in the buffer. Wood fences have a limited life-
span before they begin to fall apart, while the associated
buildings have a longer lifetime. It is appropriate to provide
plant credit for more permanent structures, such as walls. The
new LDC should address this disparity by eliminating fence
credit in bufferyards and substituting walls instead. Fences
                                                                 Wood fences often do not stand the test
could be continued to allowed in buffers, they just would not    of time the way a wall would.
be deemed part of the required material in a buffer.

Citrus County                                                                          LDC Critique
May 2006                                      25
Average Buffer Depth
The new LDC should allow meandering
buffer depths provided that the average
depth of the buffer complies with the
minimum required depth.

Mechanical and Dumpster Screening
                                                Undulating buffer allows for creativity on constrained sites
The mechanical screening procedures in
Section 4661 that currently apply only to small
nonresidential developments should apply County-wide.
Similar to the mechanical screening provisions in the
existing LDC, the screening standards for dumpsters in
Section 4661 should be applied County-wide. In addition,
the minimum height of the dumpster screening should be
modified to not require specific minimum height, rather to
require that the enclosure be tall enough to screen the
dumpster entirely, regardless of height. The County could
also require spring action gates so that the enclosure would                Outdoor storage in Citrus County with
                                                                            inadequate screening height
not be rendered ineffective due to a user leaving the gate

Outdoor Display, Sales and Storage
The existing regulations do not very rigorously address
outdoor display, sales and storage. A simple table, such as
the one below, shows the districts in which each type is
allowed. Accompanying standards require various types of
placement of goods and screening.
                                                                            Outdoor display in another community
                                                                            impeding a walkway

            Category                       CN, CR             CG              CI             IL, IH
            Outdoor Retail Display
            Outdoor Sales
            Outdoor Storage
                       Table showing where each type of display/sales/storage is permitted

Citrus County                                                                                         LDC Critique
May 2006                                               26
Sign Standards
Sign regulations are included in Chapter 7 of the LDC. Although sign regulations are
typically integrated into zoning or development codes, we typically do not recommend
making major amendments to sign regulations at the same time that the general development
regulations are being updated. We also did not budget this project for a major update to
sign regulations.
The basic dimensional and numerical standards for signs, set out in Section 7239 –7400
appear to be sound and reasonable. What we recommend as part of the LDC update is that
we reorganize the sign regulations and eliminate some serious Constitutional problems. That
will provide the County with a workable framework for sign regulation. If the County wants to
address the issues of the numbers, sizes and heights of signs at a later date, the revised LDC
will provide a context in which that can happen.

Some Technical Modifications
The follow changes are largely technical in nature and seem unlikely to create controversy.
We can easily make these changes as part of recodifying the LDC:
      •   Section 7150, allowing for the substitution of ideological messages “for an advertising
          message on a permitted permanent sign.” This “substitution of message” language
          should be made broader to cover essentially any noncommercial message. It should
          not be limited in scope to “permitted permanent” signs but should also cover
          temporary signs and signs allowed without a permit (now “exempt” under the
      •   The long list of exemptions under §7220 could lead to the sign ordinance being found
          facially unconstitutional under Solantic, LLC v. City of Neptune Beach.1 The
          fundamental concern of the Eleventh Circuit in Solantic was the breadth of the
          apparent exemption, raising issues such as these:
                  The code does not, however, explain … why a moving or illuminated sign of
                  the permissible variety -- for example, a sign depicting a religious figure in
                  flashing lights, which would be permissible under § 27-580(17)'s exemption for
                  "religious displays" -- would be any less distracting or hazardous to motorists
                  than a moving or illuminated sign of the impermissible variety -- for example,
                  one depicting the President in flashing lights, which falls within no exemption
                  and is therefore categorically barred by § 27-581(5)'s prohibition on signs
                  containing "lights or illuminations that flash." Likewise, a homeowner could not
                  erect a yard sign emitting an audio message saying, "Support Our Troops,"
                  since § 27-581(9) generally bans signs that "emit any sound that is intended to
                  attract attention," but the government would be free to erect an equally

    410 F.3d 1250 (11th Cir. Fla. 2005).

Citrus County                                                                          LDC Critique
May 2006                                         27
                  distracting -- and presumably unsafe -- sign emitting the audio message,
                  "Support Your City Council," since governmental signs are completely exempt
                  from regulation under § 27-580(4).
The list of exemptions in the current Citrus County ordinance raises similar concerns. These
concerns can be addressed in part by moving many of these sign types to a “signs partially
exempt from ordinance” section that a) makes it clear that the signs do not require permits; b)
imposes size, location, height, and other design standards on these signs; and c) allows
deviations from those design standards only where the standard in the local ordinance is
clearly preempted by state or federal law or by a lawful court order.
Vague Descriptions. Some of the exemptions, however, are separately problematic,
including the following, which appear to be vague:
      •   Signs necessary to promote health, safety, and welfare and other regulatory, statutory,
          traffic control, or
      •   Directional signs erected on public property with permission as appropriate from the
          State of Florida, the United States, or Citrus County. Community directional signs are
          not exempt.
      •   Legal notices and official instruments.
      •   Holiday lights and decorations.
      •   Decorative flags and bunting for a celebration, convention, or commemoration when
          authorized by the County for a prescribed period of time.
Content-Based Exemptions Generally. The following exemptions are based on sign content
and are problematic for that reason, under a line of cases beginning with Metromedia, Inc. v.
City of San Diego.1 Although the courts have accepted some content-based distinctions
(commercial vs. noncommercial messages, provided that the noncommercial messages are
treated more favorably or at least as well as commercial ones; off-premise commercial
messages vs. on-premise commercial messages), using any other type of content-based
distinction will be subject to a “strict scrutiny” test in the courts, which essentially has the effect
of eliminating the typical “presumption of validity” available in zoning cases and shifting the
burden of proof to the local government defending a Constitutional challenge.2 Content-
based exemptions include:
      B. Public utility signs that identify the location of underground utility lines and facilities,
         high voltage lines and facilities, and other utility facilities and appurtenances.
      C. Decorative flags and bunting for a celebration, convention, or commemoration when
         authorized by the County for a prescribed period of time.

    453 U.S. 490, 494-95, 101 S. Ct. 2882, 69 L. Ed. 2d 800 (1981).
  See Metromedia, Inc., v. City of San Diego, 453 U.S. 490, 101 S. Ct. 2882, 69 L. Ed. 2d 800(1981); Ladue
v. Gilleo, 512 U.S. 43, 114 S. Ct. 2038, 129 L. Ed. 2d 36 (1994); Cafe Erotica of Fla., Inc. v. St. Johns
County, 360 F.3d 1274 (11th Cir. Fla.2004).

Citrus County                                                                                 LDC Critique
May 2006                                             28
      D. Memorial signs or tablets depicting historic events, names of buildings and dates when
         cut into any masonry surface or when constructed of bronze or other incombustible
         materials and attached to the surface of a building.
      E. Signs incorporated into machinery or equipment by a manufacturer or distributor
         which identify or advertise only the product or service dispensed by the machine or
         equipment, such as signs customarily affixed to vending machines, newspaper trucks,
         telephone booths, and gasoline pumps.
      G. Warning signs that do not exceed two square feet and are located within the property
         lines are exempt from permitting. Warning signs may include, but shall not be limited
         to: "No Trespassing," "Beware of Dog," "No Dumping," "No Loitering," and "No
         Parking". Such signs will be limited to one per residential lot of 150 feet or less of
         frontage. Signs intended for the purpose of meeting the definition of posted lands as
         defined in Chapter 810.011(5)(6), Florida Statutes, (F.S.), are not subject to
         separation requirements.
      H. Signs for occupant identification are subject to the following standards:
      J. Legal notices and official instruments.
      K. Holiday lights and decorations.
      S. Time, temperature, or date signs.
      T. Traditional barber poles.
      U. Residential name plates.
      V. Street address signs.
The 911 address signs are also content-based, but there is a clear public safety interest in
protecting those, so that language is probably defensible. Political, real estate and
directional signs – all also content-based distinctions -- are discussed separately, below.
Flags. The provisions regulating flags do not appear to be consistent with the Eleventh
Circuit’s holding in Dimmitt v. City of Clearwater,1 in which the Eleventh Circuit struck down
content-based restrictions on signs. This section can be salvaged, but the County will have to
choose between allowing commercial messages on flags and NOT allowing commercial
messages on flags; there appears to be no room under Dimmitt and related cases to allow
logos but not other commercial messages. Note that noncommercial
messages must also be allowed; the apparent difficulty in posting a
“Greenpeace” flag was one of the things that troubled the court in
Political Signs. The political sign provisions are drawn too narrowly,
because they provide for signs only for candidates for office. It is clear
that the First Amendment protects signs with messages such as “Save the
Manatees,” “Impeach the Mayor,” and “Stamp out Billboards.” This
                                                                               Political sign

    985 F.2d 1565 (11th Cir. 1993).

Citrus County                                                                            LDC Critique
May 2006                                           29
section can easily be re-crafted, using the current size standards.
      •   Signs for occupant identification are subject to the following standards:
                  One sign not to exceed one-square foot in area.
                  The sign designates the occupant or a lawful home occupation.
      •   Direction signs for a house of worship, academic school, public assembly facility, or
          hospital/emergency room located on a local street are subject to the following
                  The sign(s) shall not be located in the public right-of-way.
                  The sign(s) shall not exceed three square feet in areas.
                  One sign for each arterial or collector providing access; however, a total of no
                  more than three signs shall be allowed for each qualifying use.
      •   Onsite religious displays.
      •   Special events signs, to be removed within seven days after the event.
      •   For sale, rent or lease signs, or "Open House" signs by owner or agent are subject to
          the following standards:
                  One sign not to exceed six square feet per residential lot.
                  One sign not to exceed 32 square feet per nonresidential lot.
                  Sign shall be removed seven days after title transfer.
          •   Time, temperature, or date signs.
          •   Traditional barber poles.
          •   Residential name plates.
          •   Street address signs.
          •   Signs placed pursuant to Section 337.407, F.S., Signs and Lights in the Right-of-
          •   House numbers erected in accordance with E-911 Uniform Property Numbering
          •   Traffic control signs.
Real Estate Signs. Real estate signs are entitled to special protection
under Linmark Assocs., Inc. v. Township of Willingboro,1 in which the
Supreme Court held that the township could not prohibit “for sale” signs
in residential neighborhoods. The definition of a real estate sign,
however, is content-based, leading one federal judge in Florida to opine
that, at least as to real estate signs, “it is impossible to draft a sign

1                                                                                Real estate sign
    31 U.S. 85, 97 S. Ct. 1614, 52 L. Ed. 2d 155 (1977).

Citrus County                                                                              LDC Critique
May 2006                                              30
ordinance that is constitutional.”1 We recommend that communities deal with “for sale”
signs, yard sale signs and home occupation signs as commercial messages related to
commercial activities lawfully conducted on the premises, relying on the well-accepted
distinctions between commercial and noncommercial and on-premise and off-premise
commercial messages.
Directional Signs. In the first of the major contemporary cases striking
down sign ordinances because they contain too many content-based
distinctions, “directional” signs were one of the types of signs receiving
special treatment that troubled a federal court in Ohio.2 Similarly,
directional signs were one of the content-based sign types that troubled
the Eleventh Circuit in striking down the Neptune Beach ordinance.3 The
language in the Citrus County ordinance for “community directional signs
for master planned developments” is well-crafted; it might be possible to
build on that model and to extend it to religious institutions, schools and
others that are allowed “exempt” off-premise directional signs. It is an
area that should, however, be reviewed by the County Attorney before
                                                                                           Directional sign

Incidental Signs. Signs now considered “memorial” signs, “warning”
signs, “vehicular movement” signs and similar signs can easily be
handled under a category of small signs containing no commercial
messages, limited in size and lighting and simply allowed without a
Temporary Signs. Temporary signs should be separated into two
categories. Those in nonresidential districts should have no content-
based restrictions. As suggested above, those in residential              Incidental Sign

neighborhoods may Constitutionally be limited to noncommercial
messages and commercial messages advertising commercial activities lawfully conducted on
the premises, including the proposed sale or lease of the premises. Time limits should be
uniformly applied. Permission to erect a temporary sign can be tied to the lack of a
permanent sign on a commercial premises (as the present ordinance does), but the ordinance
should not limit the content. Signs promoting community fairs, carnivals and the United Way
will fall within the “noncommercial” message category, and any property owner will be free to
erect such signs, subject to size, number and duration limits applicable to the property.
Billboards. The billboard regulations appear to be defensible as written.

    Granite State Outdoor Adver., Inc. v. City of Clearwater, 213 F. Supp. 2d 1312, 1327 (M.D.Fla. 2002).
 North Olmsted Chamber of Commerce v. City of North Olmsted, 86 F. Supp. 2d 755, 765-66 (N.D.Ohio
    Solantic, LLC., v. City of Neptune Beach, 410 F.3d 1250 (11th Cir. Fla. 2005).

Citrus County                                                                                      LDC Critique
May 2006                                                31
Residential Development Identification Signs. Such
provisions are relatively common but still somewhat
troublesome because of their privileged status in the
right-of-way. The current Citrus County language is well-
crafted, with one exception. It would be preferable to
call these “neighborhood” identification signs, to
eliminate the suggestion that they are tied to the
commercial activity of development; “neighborhood”
should also be defined, to make it clear what type of       Residential development identification sign

area can have such a sign.
Model Home Signs. The model home sign provisions can be preserved by modifying them to
be clearly accessory to the lawful temporary use of operating a model home and sales office.
There seems to be little basis, however, for allowing flags at model homes that are any
different in size or scale from those allowed in residential neighborhoods generally.

Citrus County                                                                             LDC Critique
May 2006                                      32
Lighting Standards
The lighting provisions for Citrus County are not contained in one
specific location of the LDC, rather they are duplicated throughout
in sections requiring exterior lighting standards. These include
sections 4260- Interchange management areas, 4456- Additional
Standards for Bed and Breakfast Inn, 4660- Additional Design
Standards for Large Retail Projects, 4661- Design Standards for
Small Nonresidential Development Projects, 4680- “Old
Homosassa” Area Redevelopment Plan – Standards; Aesthetic                     Pedestrian-scaled outdoor lighting
Standards Mandatory for Nonresidential Projects Only. These                   in another community

provisions should be consolidated, the redundancies eliminated
and applied to the entire County.
The provisions seem to be adequate considering the
enforcement and compliance requirements that would result
from a more complex set of standards. However, a great
deal of good could result from requiring color corrected
lamps that provide the purest, whitest light possible. In
addition, full cut-off or shielded light fixtures do a
tremendous job protecting the night sky from unnecessary
glare that inefficiently spills upward from older types of
fixtures. If unshielded fixtures are to continue to be allowed, it
is a positive that the existing regulations already allow
shielded fixtures to be installed higher than unshielded             Height differential for parking lot and pedestrian
fixtures. Also, the maximum height for areas where                   lighting
concentrations of people are likely to walk should be lower
than the maximum allowed for the interiors of parking lots.

Citrus County                                                                                  LDC Critique
May 2006                                         33
Access and Circulation Standards
External and Internal Connectivity
Section 4221.H states, “The street layout in all new development shall be coordinated with
and interconnected to the street system of the surrounding area. Streets in proposed
subdivisions shall be connected to rights-of-way in adjacent areas to allow for property inter-
neighborhood traffic flow.” The existing LDC could do a better job explicitly requiring
residential subdivisions to have improved external connectivity (i.e., more than one entry and
exit) as a way to relieve vehicular backup resulting from low connectivity. The LDC should
contain requirements mandating the number of external entries and exits to a subdivision
based on a factor such as the number of dwelling units in the subdivision, rather than the
“softer” negotiable language quoted above.
The LDC should also include improved provisions for ensuring connectivity through collector
streets. The current code emphasizes the protection of thoroughfares, which are mapped for
the entire county. Although there are collector roads shown on current county transportation
plans, they do not appear to reflect a comprehensive system of collectors for the entire
county. In addition, in some cases developers have been allowed to block planned collector
roads with the gates for gated communities. This entire issue should be reexamined carefully
in the context of the new LDC>
Similarly, connectivity within a subdivision could be required in the LDC in order to facilitate
pedestrian activity and to lessen automobile traffic on certain streets by allowing it to disperse
throughout the street network. Internal connectivity is often defined by the ratio of links to
nodes in a subdivision. The number of street links divided by the number of nodes or end
links, including cul-de-sac heads yields a subdivision’s connectivity ratio. The example above
assumes a required minimum connectivity ratio of 1.4 links to nodes. In the alternative,
maximum block lengths could be established, creating a series of internal street connections.

Citrus County                                                                          LDC Critique
May 2006                                        34
                EXAMPLE 1: Does not meet ratio   EXAMPLE 2: Modified to meet ratio
                (13 links/11 nodes = 1.18)       (16 links/11 nodes = 1.45)

                Number = Link           = Node

Citrus County                                                                        LDC Critique
May 2006                                         35
Resource Protection
All of Chapter 3 of the Comprehensive Plan and portions of several other sections deal with
natural resource issues. Natural resource issues are similarly woven throughout the LDC.
The review of issues here is not comprehensive; it focuses on those aspects of resource
protection that appear to raise issues related to consistency between the Comprehensive Plan
and the LDC.
The current LDC contains some excellent provisions dealing with resource protection, but the
applicability of its provisions are not always clear. Although on their face, most of the
resource protection provisions appear to apply to most new development, there are specific
references to particular resource protection provisions for particular development types. The
new LDC should make these provisions broadly applicable to classes of developments, and
the only specific references to special rules for particular developments should occur where it
is the intent of the County to allow a particular development type some deviation from the
resource protection standards applicable to other developments.
Using the EAR amendments to the plan, the resource protection provisions of the code should
be rewritten to strengthen the role of resource protection in the regulation of development in
Citrus County. New provisions should require consideration of resource protection areas
from the beginning of the planning process for a parcel, rather than simply imposing
limitations on the development of particular parts of a project after the plan has been

Policy 3.8.4 of the Comprehensive Plan requires that:
        The County shall continue to enforce wetland protection regulations in the County
        Land Development Code (LDC) and revise them to reflect Ecosystem Management
        and Environmental Resource Protection (ERP)standards. Conservation Element 3-98
Objective 3.15 deals more broadly with wetlands policy, and Policy 3.15.2 of the
Comprehensive Plan includes more detailed provisions for regulatory protection of wetlands:
        Wetland protection standards and criteria shall be prepared, included within the
        County's LDC. The standards and regulations shall include at a minimum:
        •   Setbacks and buffers;
        •   Conservation easements;
        •   Compensatory mitigation, unless otherwise controlled by an ERP Permit;
        •   Performance standards;
        •   Evaluation-ranking scheme;
        •   Drainage criteria;

Citrus County                                                                        LDC Critique
May 2006                                      36
        •   Allowed and exempted uses;
        •   Wetland functions;
        •   Significant and insignificant effects of development on wetlands; and
        •   Recognition of Ecosystem Management principles. For those projects which receive
            exemptions from State or Regional wetland rules, the concepts and principles of
            Ecosystem Management will be implemented on a local level to achieve
            environmental benefit. Conservation Element 3-101
Section 4150 of the current LDC appears to be a thorough and practical approach to this
important issue. In initial interviews and the review of documents for this evaluation, no
issues regarding wetlands regulations arose. These provisions should largely be carried over
to the new code. It will be important to review it for consistency with new or changed
provisions for other natural resources that may affect wetlands.

Policy 17.1.1 of the Comprehensive Plan requires that the
development code include provisions for tree protection.
Section 4340 of the current LDC contains an exceptionally
comprehensive and well-considered program for preservation of
“regulated trees” and “specimen trees” as well as trees along
canopy corridors.
Initial interviews as part of this project and our review of
documents identified no issues needing further attention in
dealing with tree preservation. Our recommendation is to carry
                                                                     Gorgeous canopy corridor in Citrus County
these provisions over intact into the new code.

Listed Species
Objective 3.8 requires in part that “the County shall maintain
written criteria through Land Development Regulations for
protection of all listed species.”
Objective 20.7.1 separately requires that the County
“incorporate provisions into the LDC which provide for incentives
for mitigation of disturbed habitat resources where
redevelopment of coastal properties occur.”
Section 4170 of the current LDC contains basic provisions for
preservation of habitat and for mitigation where it cannot readily
be preserved.                                                        Manatee area in Citrus County

Initial interviews as part of this project and our review of documents identified no issues
needing further attention in dealing with tree preservation. Our recommendation is to carry
these provisions over intact into the new code. If the County has access to new studies with

Citrus County                                                                           LDC Critique
May 2006                                       37
specific recommendations for improved habitat protection, those recommendations can be
addressed as the new code is prepared.

Groundwater, Spring and Wellhead Protection
Objectives 3.3, 3.4 and 3.5 of the Comprehensive Plan all deal with the goal of protecting
the quality of groundwater. Objective 3.4 specifically requires that:
        The County shall maintain its interim wellhead protection regulations utilizing five-year
        time of travel zones to establish zones of contribution and develop a more
        comprehensive wellhead protection program within the planning period.
The Comprehensive Plan also includes this policy:
        Policy 17.1.2: “The County LDC shall contain performance standards which address
        buffering …potable water wellfields, and environmentally sensitive land.”
Section 4130 of the LDC addresses the issue of wellfield and wellhead protection thoroughly
and apparently effectively. In initial interviews regarding this project, no one identified
concerns about the effectiveness of the current regulations. Gail Easley has a separate
contract under which her firm is preparing a model springs protection ordinance, using Citrus
County and two or three other counties as demonstration sites. Their work on the springs
protection ordinance will be incorporated into the new code. Once the work on the springs
protection ordinance is complete, we will review it with staff to see if any of the standards or
other provisions from the springs protection ordinance should be added to the current
provisions of Section 4130 addressing wellfield and wellhead protection.
In short, it is our recommendation that the current provisions of Section 4130 be included in
the new code, subject to only minor modifications that may evolve from other work on the
code, including the separate springs protection ordinance.

Firewise Standards
Closely related to resource protection standards are firewise standards, which address a
different issue of relating new development to the natural environment. The current LDC does
not contain any firewise development standards. At least basic firewise standards should be
included in the new LDC.
The State Department of Community Affairs has provided suggested standards at .
Like the other resource-related standards, the firewise standards should be integrated with
other development standards. For example, a critical issue in firewise planning is ensuring
that there are at least two roadways out of any development; such a standard relates directly
to standards for road design in general and connectivity in particular.

Commercial Use of Natural Resources
Policy 3.12.3 of the plan requires:

Citrus County                                                                         LDC Critique
May 2006                                       38
        The County shall include in the land development and enforcement codes provisions
        for protection of natural resources and the environment associated with commercial
        activities which utilize resources in large measure.
Objective 17.13 deals more generally with mining uses. Policy 17.13.4 requires in part that:
        Using the data from [a required] inventory, the LDC shall be amended to:
        1.      Define buffer zones around the areas and resources identified above which
                cannot be restored and restrict mining activities to land outside of those
        2.      Require identification and protection of archaeological properties on sites
                proposed for mining;
        3.      Restrict the use of land that contains economically recoverable mineral deposits
                and lies outside environmentally sensitive areas that will not preclude later
                extraction of those minerals;
        4.      Require timely restoration of the ecosystem effected by the mining; and
        5.      Provide incentives for acquisition and preservation of environmentally
                significant regional resources that may be impacted by mining activities. These
                may include, but are not limited to, existing local, regional and state open
                space acquisition programs, conservation easements, impact fee credits,
                transfer of development rights, and tax incentives.
According to the Existing Land Use analysis in the Comprehensive Plan, some 1865 acres, or
about one-half of one percent of total land area, were used at that time for extractive
Section 4659 of the LDC requires that mineral extraction uses comply with the County’s
separate Mining Ordinance, codified as Section 66-1 of the Code of Ordinances. The
Mining Ordinance primarily addresses operations of a mine. The standards above are not
specifically carried into the Land Development Code but can be imposed as part of the
Comprehensive Plan consistency review as part of any proposed rezoning to the EXT
(Extractive) zoning district.
One participant in the review process has indicated that there are questions about the
possible preemption of the Mining Ordinance by state law, which addresses similar issues.
Although this contract does not include a revision of the mining ordinance, the revised LDC
should perhaps include some basic standards related to land development and mining, so
that those provisions can be enforced regardless of the ultimate fate of the current mining
One issue that clearly should be addressed in new standards is that of access. There
appears to be nothing in the code or the plan that specifically addresses access to an
extractive industry site. If the criteria from the plan – quoted above – are integrated into the
new code as criteria for rezoning to the EXT, Extractive district, it may be desirable to add a
provision expressly dealing with access routes to any new proposed mining site. Besides the
noise and vibrations of blasting and the generation of dust, truck traffic from mining sites is

Citrus County                                                                         LDC Critique
May 2006                                        39
one of the most significant impacts that may be felt by residential neighbors of a mining site.
The impacts of truck traffic are obviously minimized where the extractive site has direct access
onto a county thoroughfare, without using residential roads.

Citrus County                                                                        LDC Critique
May 2006                                       40
Subdivision Regulations
The streets section of the new LDC should have cross
section illustrations for each street type. These graphics
would show the width of each street right-of-way and
paved area and where the County expects sidewalks
and possibly utilities to be placed.
Note that some of this material currently resides in
Appendix A to the LDC. It is the consultant’s           Typical residential street cross section
understanding that staff will be updating Appendix A
concurrently with the update to the LDC. Obviously those two processes should be closely
The existing LDC apparently does not regulate block length. This may be important in some
parts of the county where a pedestrian orientation is desired. If the County does not want to
regulate block length, it could require a pedestrian access easement at the mid-point for any
block over, for example, 1,400 feet in length.
The County’s existing cul-de-sac standards are very good. One improvement to them,
however, would be to set a maximum length for the cul-de-sac.

In the current LDC sidewalks are required for large retail, small nonresidential, manufactured
home and RV parks, recreational resorts and nonresidential projects in Old Homosassa.
There should be a county-wide requirement for sidewalks depending on street type and
perhaps limited to the Planned Service Area. Large lot rural subdivisions and the Agricultural,
Conservation and Extractive districts should be exempt from sidewalk requirements.

Citrus County’s new stormwater regulations will be integrated into the new LDC. Also, in
order to have compliance with Policy 9.3.2 of the Comprehensive Plan, the new LDC will
contain minimum standards for recharge of stormwater in areas of high recharge, if such
provisions are not already in the new stormwater regulations.

Large Lot Rural Subdivisions
Section 2248 sets out criteria for a development to be deemed a large lot rural subdivision.
The Director of Development Services need only approve a boundary survey rather than a
final plat in order for the subdivision to be recorded. All subdivision standards in the LDC
must be met in order for the boundary survey to be approved. If this procedure is working
well for the County then it should continue. However, there are some standards from which it
would be reasonable to exempt large lot rural subdivisions. For example, vegetated swales

Citrus County                                                                           LDC Critique
May 2006                                        41
could be allowed for drainage rather than curb and gutter. As mentioned in the Sidewalks
section above, sidewalks should not be required in large lot rural subdivisions.

Adopted Level of Service Standards
There is perhaps no more major issue facing Citrus County than the implementation and
administration of its concurrency policies, as required by Fla. Stats. Section 163, and Chapter
9J-5 of the Florida Administrative Code. Under Florida law, local governments must have
plans and implementing regulations in place to ensure that adequate public facilities are
available to serve new development or that such facilities will be available concurrently with
the occupancy of the new development.
Policy 19.5.1 sets out the following Level of Service Standards to guide the concurrency

Recreation and Open Space
District Parks                                  5 acres per 1
Community Parks                                 1 acre per 1
Neighborhood Parks/Equipped Play Areas          1.5 acres per 1

Solid Waste
Class I Waste                                   3.50 pounds per capita per day
Class III Waste                                 2.69 pounds per capita per day

Sanitary Sewer
Average Flow                                    75 gallons per capita per day and 0.16 gallons per
                                                square foot of building per day (commercial and
Peak Flow                                       125 gallons per capital per day and 0.30 gallons per
                                                square foot of building per day (commercial and

Potable Water
Minimum Design Flow                             125 gallons per capita per day
Storage Capacity                                Minimum reserve of 24 hours water demand
Pressure                                        25 pounds per square inch to the user

Traffic Circulation
Level of Service “C” peak hour for all roadways, except: (1) four-laned sections of highways
on the Florida Intrastate Highway System, where level of service “B” peak hour shall be
maintained in rural areas, except as otherwise provided in Policy 10.3.5.

Citrus County                                                                              LDC Critique
May 2006                                      42
For roadways in small unincorporated urban areas, LOS "C" shall be maintained regardless
of the laneage; and (2) Level of Service “D” peak hour for minor arterials not in the Florida
Intrastate Highway System.

The Level of Service for drainage plans and facilities for all new subdivisions or planned
developments is as follows:
    •     For open basins - the retention of the first one-half inch up to one-and-a-half inches of
          runoff (water quality/pollution) and the 25-year, 24-hour storm event (water
    •     For closed basins - the retention of the first one-half inch up to one-and-a-half inches
          of runoff (water quality/pollution) and the 100-year, 24-hour storm event (water
If and when an interlocal agreement is enacted, the agreement will supersede this policy.

Materials                                           1.1 volumes per capita; 0.003 periodicals per capita
Library Facilities
Present to 1999                                     0.4 square feet per capita
2000-2005                                           0.5 square feet per capita

Planning Issues
As presently drafted, and, according to staff, as implemented, the Citrus County concurrency
system simply answers the question of whether there is capacity available in the system today
to absorb the additional demands that will result from a new development. That is not the
only relevant question.
The biggest issue is the fact that there is a great deal of demand to which the county has
made some form of commitment but which does not show up in current analyses of system
capacities. More than 20,000 lots in Citrus Spring and thousands of lots in other partially
built developments in the county represent hundreds of thousands of vehicular trips and
millions of gallons of potable water and wastewater every day that could be required to serve
new dwellings in the next several years but that are not represented in current analyses of the
systems. It is the consultant’s understanding that the County is working on a new traffic
model that will build in some of this potential demand. Such a model will help, but it will not
answer all of the questions. It is possible if not probable that such a model will show that
some roads in the northern part of the county are already significantly overloaded – by the
potential traffic from unbuilt lots in Citrus Springs.

Citrus County                                                                                  LDC Critique
May 2006                                         43
The effect of such a model may lead to denials of
proposed new developments that may better serve the
county’s purposes than completion of some parts of
Citrus Springs, where roads and utilities are not
complete. Alternatively, such an analysis may lead to
requiring a current developer to contribute to
expansion of a road that, based on traffic counts
today, has substantial additional capacity.
This issue has not proven critical because, until very
recent years, the pace of growth in Citrus County has
remained relatively modest. More recently, the             Citrus Springs is a large development with a few hundred
                                                           residents and the potential for more than 30,000 dwelling
county is issuing permits for thousands of units per       units. With the recent installation of utilities for some parts
year. Available capacities in some facilities are          of the development, people are building homes there
dwindling, and the robust market is likely to continue
to attract new development applications. There is
thus likely to be increased interest in the relationship
between demand related to approved but unbuilt
development and the potential demand from new
Citrus County has had some very large developments and
may have other relatively large-scale developments. In
general, local governments find that larger developments
often bring advantages to the community through the ability
to plan better on a larger parcel of ground and through a
long-term commitment to the community by a developer. If
a project is likely to be built over three or four or more years,
however, it is not realistic to expect that all facilities needed    There are many smaller subdivisions scattered
to serve the entire project are available. In concurrency and        around the county, many of which have
                                                                     significant numbers of vacant lots available.
adequate public facilities ordinances in other communities,
facilities included in a local or state rolling five year capital
improvements program are often considered as “available”
as of the dates on which they are scheduled for completion.
These issues are not simple. Part of the issue is simply one of accounting. Jurisdictions like
Montgomery County, Maryland, have long maintained reports on approved developments
that have not yet been fully built out; developing such a record, with at least rough
projections of demand from such projects, would be a good start. In one sense these are
planning issues that ought to be resolved in the context of an update to that section of the
comprehensive plan. Realistically, however, the new development code will not serve the
county as well as it should if these issues are not addressed in time to be addressed with
related substantive and procedural provisions in the new code.

Citrus County                                                                                   LDC Critique
May 2006                                        44
Procedural Issues
The current ordinance, codified as Section 4700 of the LDC, requires concurrency review as
part of the approval process, it does not address issues related to timing and phasing. Issues
that should be considered in an updated ordinance include:
      •   A pre-review process for concurrency, particularly for utilities and roads, to allow
          developers to conduct first-stage feasibility analyses;
      •   A reservation process to allow a developer to reserve a reasonable amount of capacity
          in road and/or utility systems for a proposed development before spending substantial
          sums on detailed site planning and preparation of application documents;
      •   An expiration policy for capacity reserved for a project that is not built or that is only
          partly built, with a clear statement of consequences of expiration. Clearly any such
          policy should be coordinated with the vested rights provisions of the code. Note that
          there is a related expiration provision for planned unit developments, but there does
          not appear to be any similar provision for other projects.
In addition, the new LDC should include clarify the standards and procedures that apply to
each type of final local development order issued by Citrus County.

Minimum Standards
Other than the concurrency standards of the comprehensive plan, the current LDC does not
specify a lot of minimum standards. Thus, someone building a private utility system that can
obtain state permits and that at least nominally meets concurrency requirements does not
have to install pipes and other facilities that meeting county standards. Some relatively large
developments can still be built without public sewer and water.
Although these are fundamentally planning issues that should be addressed in the
comprehensive plan, to the extent that there is general agreement among county officials on
establishing minimum standards on these issues, such standards can certainly be included in
the new LDC.

Transportation Corridor
As part of the critique, the consultant has reviewed a proposed new Section 4260,
“Transportation Corridor Management,” based on a March 2, 2006, draft of an ordinance
containing multiple proposed amendments and updates to the LDC.
The Florida Supreme Court has held that the “reservation” approach to transportation
corridors is not facially unconstitutional. See Palm Beach County v. Wright.1 In that case, the
Florida Supreme Court distinguished such a procedure from the decision in Joint Ventures,
Inc. v. Department of Transportation,2 in which the court struck down a reservation procedure
of the state because of procedural concerns; under the state law considered by the court in
Joint Ventures, the “reservation” was essentially self-implementing, and the property owner

    641 So. 2d 50, (Fla. 1994).
    563 So. 2d 622 (Fla. 1990).

Citrus County                                                                             LDC Critique
May 2006                                          45
could obtain relief only by filing an action in inverse condemnation. The court distinguished
the Palm Beach County system for these important differences:
          The thoroughfare map differs in several ways from the maps of reservation invalidated
          by Joint Ventures. The thoroughfare map only limits development to the extent
          necessary to ensure compatibility with future land use. The thoroughfare map is not
          recorded as were maps of reservation and may be amended twice a year. The road
          locations within the transportation corridors shown on the thoroughfare map have not
          been finally determined. Unlike the Department of Transportation which recorded the
          maps of reservation, Palm Beach County is a permitting authority which has the
          flexibility to ameliorate some of the hardships of a person owning land within the
          corridor. Section 337.241 precluded the issuance of all development permits for land
          within the recorded map. Moreover, the only purpose of that statute was to freeze
          property so as to depress land values in anticipation of eminent domain proceedings.
          While the Palm Beach County thoroughfare map can have the effect of adversely
          affecting land values of some property, it also serves as an invaluable tool for
          planning purposes. Thus, we hold that the adoption of the thoroughfare map is the
          proper subject of the county's police power which substantially advances a legitimate
          state interest. In fact, the county's ability to plan for future growth would be seriously
          impeded without the thoroughfare map.1
The proposed Citrus County system improves even more on the Palm Beach County system by
providing a potential form of compensation for the developer in the form of density transfers
and by providing an administrative appeal mechanism.
The proposed ordinance is well-crafted and should serve the County well. We have two
recommendations for consideration regarding this ordinance:
      •   The purpose of this ordinance is to facilitate right-of-way acquisition. Right-of-way
          costs are also a factor considered in the County’s impact fee schedule.2 To ensure
          that there is “rough proportionality” between the impacts of a proposed development
          and the costs imposed on the developer, there must be a provision for integrating this
          with or balancing it against the county’s impact fee ordinance.
      •   The decision on a proposed dedication waiver or compensation should be designated
          as a Level Two Quasi-Judicial Proceeding, to ensure that an aggrieved applicant has
          access to a clear administrative review, with the option for a Special Master under
          Section 2500.

Related Financing Issues
The issue of providing public services ultimately turns on money.

    641 So.2d 50, 53-54.
 See Citrus County 2003 Transportation Impact Fee Update Study, Tindale-Oliver & Associates, Inc., June
2004, p. 6; available on-line at (accessed March 2006).

Citrus County                                                                                  LDC Critique
May 2006                                            46
Citrus County has been creative in using utility assessments as a tool to help property owners
finance extensions of public services. Although facility financing policies are beyond the
scope of work on this project, to the extent that they exist, they should be reflected in and
referenced from the new LDC. Thus, for example, the County’s Administrative Regulation
11.10 that allows the owner of two residential lots to pay a reduced utility assessment if the
owner plans to use place only one residence on the two lots. The new LDC should include a
provision for the recording of a conservation easement or other device to surrender
additional development rights for the second (or any additional) lot in exchange for the
reduced assessment.

Citrus County                                                                       LDC Critique
May 2006                                      47
The existing LDC has extensive nonconforming development provisions. Structurally, the
language relating to variances should be moved to the Development Review Procedures
chapter of the new LDC.

Comprehensive Plan Provisions
Policy 17.2.12: The County shall include in the LDC requirements for nonconforming uses to
be buffered and meet performance criteria in accordance with a schedule which relates to
redevelopment of a specific time frame, or require the amortization or phasing out over a
specified period of time, nonconforming land uses. Where new development occurs making
another use incompatible, that new development will be required to buffer and meet
standards for development.
Policy 17.15.1: Nonconforming uses can only expand if clear and convincing evidence is
shown that the expansion is for the physical improvement of the structure and if all
performance standards can be met as specified in the LDC.
Policy 17.15.2: If performance standards cannot be or are not met prior to the expansion of
a nonconforming use, the use shall be amortized over a reasonable period of time (as
defined in the LDC).

Land Development Code
The current LDC is inconsistent with these plan provisions in several respects:
    •   Chapter 3, which deals with nonconforming development, contains no requirements
        for amortization of nonconforming uses; it does include a provision prohibiting the
        reestablishment of a nonconforming use if it is discontinued for 180 days (Section
    •   Chapter 3 also contains no provisions requiring the buffering of nonconforming uses.
    •   Section 3131 allows the replacement of a nonconforming mobile home with another
        nonconforming mobile home. Although it might be argued that the mobile home is a
        nonconforming “structure” rather than a nonconforming use, mobile home appears to
        be treated as a use in the classification of districts; if it is the intent of the County to
        maintain this liberal treatment of nonconforming mobile homes, the issue of whether
        the mobile home is a “use” or a “structure” should be reviewed by the County
        Attorney to determine whether this poses a serious inconsistency with the
        Comprehensive Plan.
There is an underlying philosophical inconsistency between Chapter 3 and the
Comprehensive Plan. The comprehensive plan sections quoted above indicate a strong
preference for eliminating nonconforming uses. Yet, the current LDC treats other
nonconforming situations – densities and structures in particular – very liberally. For

Citrus County                                                                           LDC Critique
May 2006                                         48
    •   a nonconforming use can be expanded to provide additional parking (Section
    •   a nonconforming mobile home may be expanded through the addition of attached
        carports, decks, patios and screen rooms (Section 3131.B); and
    •   nonconforming buildings or “structures” that are damaged or even destroyed can be
        “reconstructed…as it was before” if a building permit is pulled within 180 days
        (Section 3141).
The last provision is particularly troublesome, because the use of the term “structures” would
appear to extend to signs. Few communities allow a nonconforming sign that has been
destroyed or even substantially damaged to be replaced with another nonconforming sign;
this language is inconsistent with Section 7610.F., which would prohibit the replacement of
such a sign; the apparent contradiction should be resolved in the new code. However, the
new LDC should allow nonconforming structures to expand provided that the degree of the
nonconformity is not increased along with the expansion. For example, a structure that
encroaches over a setback lane should only be permitted to expand within the setback.
The buffering of nonconforming uses is an issue that must be addressed in a broader context
in the new code. There are a large number of nonconforming nonresidential uses scattered
around the county. Many are retail uses, but many also include services and even some light
industrial characteristics. Used auto sales, trailer sales, auto repair, auto salvage, mini-
warehouse, and contractor storage and operations are among the uses found in various
combinations in these scattered uses. Leaving all of them as nonconforming may be counter-
productive, because it makes it difficult for owners to obtain loans to improve the property. It
may make more sense to create a “rural business” district or something similar to
accommodate many of these uses and then to include phased-in standards for reducing the
degree of nonconformity. For example, the auto repair shops could be required to eliminate
outdoor storage of non-operating automobiles by a certain date, and screening of other
outdoor storage operations could be required by a specified date. This is an issue that
should be addressed initially as part of the process of creating new districts, and then,
secondarily, as an issue of nonconforming uses.

Citrus County                                                                        LDC Critique
May 2006                                       49
Violations and Enforcement
There should be a general “violations” section of the code that makes it clear that acting in
direct violation of the code, undertaking action requiring a permit without a permit,
undertaking action in violation of a permit, undertaking action in violation of a condition
imposed on a permit or approval and similar actions are violations of the LDC.

The new code should include a complete range of enforcement authority, consistent with
Florida law. The most effective forms of enforcement for zoning and similar violations often
involve administrative tools, such as denying or revoking permits. The new code should
contain clear authorization for the County to revoke permits and to stop work under permits
and for all decision-making bodies in the County to deny permits based on violations on the
property. Such provisions must also be supported by provisions for hearings and appeals.
There should also be clear provisions allowing the County to pursue multiple and alternative
remedies, such as denying permits while also seeking prosecution for an ordinance violation.

Citrus County                                                                       LDC Critique
May 2006                                      50
The existing definitions section in the LDC does a good job of avoiding one of the primary
problems that affect many development codes: standards do not seem to have crept into the
definitions over the years.

Add, Move and Remove Definitions as Needed
With any re-write of a development code comes the task of adding new definitions and
removing obsolete ones. In fact, Comprehensive Plan Policy 1.9.1 mandates a new definition
for "Affordable Housing" consistent with applicable State and Federal rules.
Several Sections of the LDC have their own sets of definitions. All of the definitions in the new
LDC (except for those for signs) will be consolidated at the end of the code.

Citrus County                                                                        LDC Critique
May 2006                                       51
Review Authority Table
We have made a simplified table of the review procedures included in the LDC in the table

                                                                   Dir. of Development
                                                                   Services/Com. Dev.

                                                                                                                                                    Plat Review Team
                                                                                                             Director of Public

                                                                                                                                                                       Technical Review
                                                                                                                                  County Engineer

                                                                                                                                                                                                            Board of County
                                                                                                                                                                                          Planning & Dev.
                                                                                         Building Official

D = Final Decision

                                                                                                                                                                                          Review Board
R = Review and Recommendation
<> = Public Hearing Required


Director of Development Services/Community
Development Action
Lot Reconfiguration and Lot Line Adjustment                              D                                                                                 R
Minor Subdivision                                                        D                                                                                 R
Large Lot Rural Subdivision                                              D
Certificate of Compliance                                                D
Tree Removal Permit (Dir. of Community Development)                      D
Temporary Use Permit                                                     D
Building Official Action
Building Permit                                                                            D
Certificate of Occupancy                                                                   D
Sign Permit                                                                                D
Director of Public Works Action
Potable Water Systems Permits                                                                                      D
Wastewater Treatment Systems Permit                                                                                D
County Engineer Action
Drainage Systems Permits                                                                                                              D
Transportation and Parking Systems Permit                                                                                             D
Street Light Permit                                                                                                                   D
Technical Review Team Action
Preliminary Subdivision Plat (no potential degradation of
                                                                                                                                                           R                D
service level)
Preliminary Site Plan (no potential degradation of service level
and no supplemental standards)
Subdivision Improvements Plan                                                                                                                              R                D
Final Site Plan                                                                                                                                                             D
Preliminary Subdivision Plat (additional density up to one unit
                                                                                                                                                           R                D
per acre and subject to supplemental standards)
Preliminary Site Plan (additional density up to one unit per
acre or additional intensity less than four acres in area and                                                                                                               D
subject to supplemental standards)

Citrus County                                                                                                                                                          LDC Critique
May 2006                                                  52
                                                                Dir. of Development
                                                                Services/Com. Dev.

                                                                                                                                                 Plat Review Team
                                                                                                          Director of Public

                                                                                                                                                                    Technical Review
                                                                                                                               County Engineer

                                                                                                                                                                                                         Board of County
                                                                                                                                                                                       Planning & Dev.
                                                                                      Building Official

D = Final Decision

                                                                                                                                                                                       Review Board
R = Review and Recommendation
<> = Public Hearing Required


Planning and Development Review Board Action
Preliminary Subdivision Plat for which a public hearing has
been requested following "notice of intent to approve" by the                                                                                                            R              <D>
Preliminary Site Plan for which a public hearing has been
                                                                                                                                                                         R              <D>
requested following "notice of intent to approve" by the TRT
Preliminary Plat or Plan that is proposed for increased
                                                                                                                                                                         R              <D>
residential density exceeding one unit per acre
Preliminary Plat or Plan for nonresidential development
proposed pursuant to supplemental standards of Chapter Five                                                                                                              R              <D>
of this LDC and exceeding four acres in land area
Preliminary Plan for nonresidential development proposed
pursuant to supplemental standards, as a conditional use, as
provided in Chapter Five of this LDC and subject to
                                                                                                                                                                         R              <D>
conditions not specified within this LDC to insure the
compatibility with adjacent properties and other property in
the district
Variance                                                                                                                                                                 R              <D>
Administrative Appeal                                                                                                                                                    R              <D>
Board of County Commissioners Action
Amendment to LDC                                                       R                                                                                                 R                                <D>
Amendment to Comprehensive Plan                                        R                                                                                                 R                                <D>
Vacation of Public R-O-W, Easements or Plats                           R                                                                                R                R                                <D>
Final Subdivision Plats                                                R                                                                                                 R                                <D>
Improvement Agreements                                                 R                                                                                                 R                                <D>
Developers Agreements                                                  R                                                                                                 R                                <D>
Final Development Plans for Planned Developments                       R                                                                                                 R                                <D>
Nonresidential Infill Areas Greater Than 400 Ft in Depth               R                                                                                                 R                                <D>
Platting Variance                                                      R                                                                                                 R                                <D>

Citrus County                                                                                                                                                       LDC Critique
May 2006                                               53
    Table of Existing Uses
                                                                                       RESIDENTIAL                                               NONRESIDENTIAL










USE CATEGORY                        SPECIFIC USE

                                                        Key P = Permitted Use (1 in existing code)           D=

                      Cropland/pasture                           P    P    P                                                                            P           P
                      Silviculture                               P    P    C            C                                                                                 P     P
                      Aquaculture                                P    C                                                                           P     P           P     P     P
Agriculture           Confinement feeding/feedlots               P    C    C                                                                      P
                      Plant nursery, wholesale                   P         C            C                                                               P
                      Sod farm                                   P         C            C                                                               P
                      High intensity agricultural use            C
Resource Extraction   Mining                                                                                                                            P
                      Single family                              P    P    P     P      P          P   P     P     MP          D           D                  D           D     P
                      Single family (associated with
                      commercial use)
                      Model home (no sales office)                    P    P     P      P          P   P     P     MP          P           P
                      Attached housing                           C         P     C      C          C   C           MP
                      Multifamily                                                C
                      Duplex                                                                       C   C
                      Multifamily                                                                                  MP
Household Living
                      Multifamily (up to 12.0 du/acre)                                                       P
                      Multifamily (12.1-20.0 du/acre)                                                        MP
                      Multifamily (up to 10.0 du/acre)                                                                         C
                      Multifamily (up to 6.0 du/acre)                                                                                      P
                      Multifamily (over 6.0 du/acre)                                                                                       C
                      Manufactured home                                                                            MP    ?
                      Manufactured home park                                                                       MP    ?
                      Caretaker residence                                                                                C                                                            C
Group Living          Assisted living facility                   C    C    C     C      C          C   C     P     MP    C     C     C     P                  P
                      Boarding house                             P                                     C     C     MP                P     P
                      Group home                                 C    C    C     C      C          C   C     P     MP          P     P     P                  P

    Citrus County                                                                                                                                                                     LDC Critique
    May 2006                                                                                  54
                                                                                 RESIDENTIAL                                               NONRESIDENTIAL










USE CATEGORY                     SPECIFIC USE

                   Nursing home                           C     C    C     C      C          C   C     C     MP          C     C     P                  P
                   Community center                                                              C     C           C     C     C     P
Community Service  Fraternal organization/lodge                                                  C     C           C     C     C     P      P                                   C
                   Library                                                                       C     C     MP          P     P     P                  P
Day Care           Day care center                        C     C    C     C      C          C   C     P     MP    C     P     P     P                  P
                   Educational facility (except public
Educational                                               C     C    C     C      C          C   C     C     MP          C     C     P      P
                   Educational facility                   C                                                                          P      P                             P     C
Government         Emergency service facility             P     P    P     P      P          P   P     P     P     P     P     P     P      P     P     P     P     P     P     P
Facilities         Government facility                    P     P    C     C      C          C   C     P     MP          P     P     P      C                 P           P
                   Clinic                                                                        C           MP          P     P     P
Medical Facilities Hospital/sanitarium                                                                                               P                  P
                   Medical/dental office                                                         C           MP          P     P     P                  P
                   Cemetery                                                                                                          P                              P
                      Cemetery (without funeral
                                                          C     C    C            C          C   C     C     MP          C     C                        P
Parks and Open
Areas                 Passive recreation                  P     P    P     P      P          P   P     P     MP    P                                                P     P     P

                      Playground                          P     C    C     C      C          C   C     C     MP    C     C     P     P                  P           P     P     P
                      Preserve/reserve                    P     C    C            C                                C                              P                 P     P     P
                      Airport/airfield                                                                                                      C           C     P
Passenger Terminals
                      Truck/bus terminals                                                                                            P      C
Places of Worship     House of worship                    C     C    C     C      C          C   C     C     MP          P     P     P                  P                       C
Social Service        Correctional facility                                                                                                             P
Institutions          Halfway house                       C     C    C     C      C      C       C     C     MP                      P                  P
                      Communications/transmission tower   D     D    D     D      D      D       D     D     D     D                 D      P     P     D     P     D     D     D
                      Maintenance facility                                                                         C                        P     P     P     P     P     P
Utilities             Power generation facility                                                                                             P                 P
                      Railroad rights of way (storage
                                                          C     C                                                                                 P
                      facilities or related structures)
                      Telephone/cable facilities                                                                   P                 P                  P     P

     Citrus County                                                                                                                                                              LDC Critique
     May 2006                                                                           55
                                                                                      RESIDENTIAL                                               NONRESIDENTIAL










USE CATEGORY                     SPECIFIC USE

                     Utility facility (water and wastewater)   P     P    P     P      P          P   P     P     MP    P                 P      P     P     P     P     P     P
                     Wellfields                                C     C    C     C      C          C   C     C     MP                C     C      C     C     C     C     C     C
                     Tavern, Bar, Lounge, Night Club,
                                                                                                                                          P      P
Indoor Recreation    Dance Hall
                     Theater/auditorium                                                                                                   P
                     Broadcasting station                                                                                                                    P     P
                     Dispatch/communication office                                                    C     C     MP                P     P                  P     P
                     Financial institution (without drive-
                                                                                                      C           MP          P     P     P
Office               up)
                     General office                                                                                                              P
                     Model home center                                                                C     C     MP          P     P     P
                     Professional business office                                                     C           MP                P     P
                     Ballfield/ball court                                                                         MP    C                 P                  P           P           P
                     Golf course                               P     C    C     C      C          C   C     C     MP    C                                                P           C
                     Hunting/fishing preserve                  P     C                 C                                C           P                                    P     P
                     Race track/outdoor arena                                                                                             C
Outdoor Recreation   Recreational resort                                                                          MP                      C                              C           C
                     Shooting range                                  C                 C                                                  C      C           P           C
                     Stable                                    P     C    C            C                          MP    C                                                P     P     P
                     Summer camp/retreat                             C                 C                                            P     P                  P           P     P     P
                     Swimming pool/bathing area                      C                                            MP    P                 P                  P           P     P     P
                     Bed and breakfast                               C    C                           C     C     MP          P     P     P                              C
                     Recreational vehicle park                                                                                                                           D
                     Truck stop                                                                                                           C      P
                     Parking facility                                                                                               P     P      P           P
                     Open air cafe                                                                    C     C     MP    C     P     P     P                                          C
Restaurants          Restaurant (no drive-up)                                                         C     C     MP    C     P     P     P                                          C
                     Restaurant (with drive-up)                                                                                           P

     Citrus County                                                                                                                                                                   LDC Critique
     May 2006                                                                                56
                                                                                   RESIDENTIAL                                             NONRESIDENTIAL










USE CATEGORY                    SPECIFIC USE

                    Art gallery/museum                                                           C     C     MP          P     P     P                  P           P     P
                    ATM                                                                                      MP
                    Barbershop/beauty parlor                                                     C     C     MP                P     P
                    Building/Trades Contractors (with
                                                                                                             MP                      P      P
                    outside storage)
                    Commercial/Trade Schools                                                                 MP                      P      P           P
                    Convenience store                                                            C     C     MP    C           C     P                                          C
                    Convenience store (without gas)                                                                      C

                    Dance/martial arts/instruction studio                                        C     C                 P     P     P

                    Distribution center                                                                      MP
                    Financial institution (with drive-up
                    Flea market                                                                                                      P      P
                    Funeral home/mortuary                                                        C     C                 C     C     P
Retail Sales and    Funeral home/mortuary (with
                                                                                                             MP                             P
Service             crematorium)
                    Golf driving range/miniature golf                                                        MP                C     P      P                       P
                    Grocery store/shopping center                                                                                           P
                    Grocery store/supermarket                                                                MP                      P

                    Health club/spa                                                              C     C                 C     C     P                              P

                    High intensity commercial use                                                                                    C
                    Hospital/sanitarium¹                                                                     MP
                    Hotel/motel                                                                              MP                      P      P
                    Kennels                                                                                  MP                      P
                    Laundry/dry cleaner                                                          C     C           C     P     P     P                                          C
                    Lawn care operations                                                                     MP                      P      P
                    Mini warehouses                                                                          MP                      P
                    Mobile home sales and service                                                            MP
                    Personal service business                                                    C     C     MP                P     P
                    Photography studio                                                           C     C     MP                P     P

    Citrus County                                                                                                                                                               LDC Critique
    May 2006                                                                              57
                                                                                        RESIDENTIAL                                             NONRESIDENTIAL










USE CATEGORY                       SPECIFIC USE

                       Plant nursery, retail                                                                                        C     P
                       Race track/outdoor arena                                                                   MP
                       Research lab                                                                               MP
                       Restaurants with drive-up facilities                                                       MP
                       Retail plan nurseries                                                                      MP
                       Retail sales                                                                                                       P
                       Retail sales (greater than 3,000 sq ft
                                                                                                                  MP                             P
                       per individual use)
                       Retail sales (less than 3,000 sq ft per
                                                                                                      C     C           C     P     P     P
                       individual use)
                       Sales, rental, service, repair –
                                                                                                                  MP                C                        P
                       motorized vehicles
                       Service business                                                               C     C           C     C     C     P                                          C
Retail Sales and       Shopping center                                                                            MP                      P      P
                       Specialty food store                                                           C     C           C     P     P     P                                          C
                       Strip center – multi-use (not greater
                                                                                                      C     C                 C     C     P
                       than 12,800 sq ft)
                       Tackle/bait shop                                                               C     C     MP    C     P     P     P                              P     P     C
                       Tavern, bar, lounge, night club,
                                                                                                                  MP                C
                       dance hall
                       Theater/auditorium                                                                         MP
                       Truck stops                                                                                MP
                       Vet/animal hospital/pet groomer (no
                                                                                                      C     C     MP          C     P     P                  P
                       outside kennels)
                       Vet/animal hospital/pet groomer
                                                                                                                                    C     P      P
                       (with outside kennels)
                       Veterinary office/animal hosp/pet
                       groom (with
Self-Service Storage   Mini warehouse                                                                                               C            P
                       Car wash facilities                                                                        MP                C     P                  P
                       Gasoline sales & service                                                                   MP                C     P                  P
Vehicle Sales and
Service                Mobile home sales and service                                                                                      P
                       Sales rental and repair of motorized
                                                                                                                                          P      P

    Citrus County                                                                                                                                                                    LDC Critique
    May 2006                                                                                   58
                                                                                RESIDENTIAL                                             NONRESIDENTIAL










USE CATEGORY                    SPECIFIC USE

                    Boat ramp                                                                                   C           C     P      C           P           P     P     C
Water-Oriented      Fishing dock/pier                          C          C                                     C           P     P                  P           P     P     P
                    Marina                                                                                                        C      P
Light Industrial
                    Light mechanical repair shop                                              C     C     MP          P     P     P

                    Distribution center                                                                   MP                      C      P

                    LP gas storage/distribution
Warehouse and       (exceeding 1,000 gals)
Freight Movement    LP gas storage/distribution (up to
                                                                                                                                  P      P           P     P
                    1,000 gals)
                    Storage                                                                               MP                             P     P
                    Warehousing                                                                                                          P
                    Commercial recycling center                                                           MP                      C      P
Waste-Related       Junkyard/salvage yard                                                                                                P
Service             Landfill                                                                                                             C     C
                    Solid waste hauler                                                                                            C      P
Wholesale Trade     Wholesaling                                                                           MP                             P
Heavy Industrial    Manufacturing                                                                         MP                             P
Other               Billboard                                                                                                     P      P

    Citrus County                                                                                                                                                            LDC Critique
    May 2006                                                                           59

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