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Ordinance 90-2684 ORDINANCE NO. 90-2684 AN ORDINANCE OF THE CITY COMMISSION OF THE CITY OF MIAMI BEACH, FLORIDA, MAKING FINDINGS; AMENDING MIAMI BEACH COMPREHENSIVE ZONING ORDINANCE NO. 89-2665, AMENDING SECTION 12, ENTITLED ',LIQUOR CONTROL REGULATIONS', BY ADDITION OF SUBSECTION 12-4, PROHIBITING TOTAL NUDITY OR SEXUAL CONDUCT IN ALCOHOLIC BEVERAGE ESTABLISHMENTS IN THE CITY OF MIAMI BEACH; PROHIBITING THE LOCATION OF ALCOHOLIC BEVERAGE ESTABLISHMENTS WHICH PERMIT PARTIAL NUDITY ON THE PREMISES WITHIN 300 FEET OF ANY DISTRICT DESIGNATED AS RS, RM, OR RPS ON THE CITY'S OFFICIAL ZONING DISTRICT MAP, OR WITHIN 300 FEET OF LAND UPON WHICH A HOUSE OF WORSHIP, SCHOOL, PUBLIC PARK OR PLAYGROUND IS LOCATED, OR WITHIN 1,000 FEET OF ANY OTHER ADULT ENTERTAINMENT ESTABLISHMENT; PROVIDING THAT HOTELS WITH A MINIMUM OF 300 HOTEL UNITS SHALL BE EXEMPT FROM THE DISTANCE SEPARATION REQUIREMENTS IN SECTION 12-4C; PROVIDING FOR MANDATORY REQUIREMENTS FOR ALCOHOLIC BEVERAGE ESTABLISHMENTS WHICH PERMIT PARTIAL NUDITY; PROVIDING THAT STATE---LICENSED ALCOHOLIC BEVERAGE ESTABLISHMENTS WHICH REGULARLY PERMITTED TOTAL NUDITY, PARTIAL NUDITY OR SEXUAL CONDUCT ON OR WITHIN ONE YEAR PRIOR TO DECEMBER 19, 1989,MAY CONTINUE TO PERMIT PARTIAL NUDITY, BUT THAT THEIR CONTINUED OPERATION SHALL BE GOVERNED BY SUBPARAGRAPH B OF SUBSECTION 13-3 AND SUBSECTION 13-4 ; PROVIDING FOR ENFORCEMENT AND PENALTIES FOR VIOLATIONS; AMENDING SECTION 7, ENTITLED ',PARKING REGULATIONS,' BY AMENDING SUBSECTION 7-2, ENTITLED ',OFF- STREET PARKING REQUIRED'', TO ESTABLISH A REQUIREMENT OF ONE PARKING SPACE PER THREE SEATS IN AN ALCOHOLIC BEVERAGE ESTABLISHMENT WHICH PERMITS PARTIAL NUDITY; AMENDING SUBSECTION 16-7 OF SECTION 16, ENTITLED ',BOARD OF ADJUSTMENT, BY PROVIDING FOR APPLICATIONS FOR VARIANCES OF THE DISTANCE REQUIREMENTS SET FORTH IN SUBSECTION 12-4; PROVIDING FOR SEVERABILITY; REPEALING ALL ORDINANCES IN CONFLICT THEREWITH; AND PROVIDING FOR AN EFFECTIVE DATE. BE IT ORDAINED BY THE CITY COMMISSION OF THE CITY OF MIAMI BEACH, FLORIDA: Section 1. FINDINGS That the City Commission of the City of Miami Beach, Florida makes the following findings: a) A number of alcoholic beverage establishments in the City of Miami Beach, Florida, permit or suffer Total or Partial Nudity or Sexual Conduct as defined herein within their establishments. b) A number of alcoholic beverage permittees have indicated an intention to create new establishments in Miami Beach, Florida, which will permit or suffer Total or Partial Nudity 1 or Sexual Conduct within such establishments. c) Some other local municipalities have recently prohibited Total or Partial Nudity and Sexual Conduct as defined herein, in establishments where alcoholic beverages, beer or wine are sold or offered for sale for consumption on the premises; the potential exists for some establishments which have been prohibited in those municipalities to relocate in Miami Beach. d) Studies conducted by other local governments and reports from police departments have indicated that there is a direct relationship between adult entertainment establishments, (especially those which sell alcoholic beverages for on premises consumption ) and such adverse secondary impacts upon the community as neighborhood deterioration, reduction in property values and increased crime, especially prostitution, rape, indecent exposure and child molestation; some of the most notable studies are the Minneapolis Report of the Attorney General's Working Group on the Regulation of Sexually Oriented Businesses conducted in 1989; the Saint Paul Minnesota Planning and Economic Development and the Minnesota Crime Control Planning Board's study, Effects on Surrounding Area of Adult Entertainment Businesses in Saint Paul, conducted in June of 1978; and the study conducted by the Phoenix Arizona Planning Department in 1979 entitled Relation of Criminal Activity and Adult Businesses. e) These studies have not indicated that there is any relationship between shows in large hotels which feature nude dancing and adverse secondary effects on the community. f) Reports from the City of Miami Beach Police Department indicate occurrences of the above-stated adverse secondary effects in connection with nude bars currently in operation in Miami Beach. 2 g) Due to the above-stated adverse secondary effects associated with alcoholic beverage establishments which permit Total nudity or sexual conduct as defined herein on their premises, such establishments constitute a nuisance in the community. Partial nudity constitutes a nuisance when located in close proximity to other such establishments, residential districts, houses of worship, schools, public parks or playgrounds. h) In City of Renton v. Playtime Theaters, Inc. , 106 5.ct. 925 (1986) , the United States Supreme Court held that cities have the authority to enact preventative legislation regarding adult entertainment to protect the quality of life within their communities. i) In International Food & Beverages System v. City of Fort Lauderdale, 664 F.Supp. 482 (S.D. Fla. 1987) , aff'd, 838 F. 2d 1220 (1988) , and Fillingim v. Boone, 835 F. 2d 1389 (11th Cir. 1988) , federal courts in Florida have recently held that municipalities in Florida may exercise the State's authority under the Twenty-first Amendment to the United States Constitution to prohibit nude and semi-nude entertainment in establishments which sell alcoholic beverages for consumption on the premises. j ) In order to preserve the public peace and good order and to safeguard the health, safety and welfare of the community and citizens of Miami Beach, Florida, it is necessary and advisable to prohibit total nudity and sexual conduct in alcoholic beverage establishments and to restrict the location of alcoholic beverage establishments permitting or suffering partial nudity. k) Notwithstanding the above-stated adverse secondary effects associated with alcoholic beverage establishments which permit 3 Total or Partial nudity or Sexual Conduct, the City Commission recognizes the fact that a total ban of such establishments may pose a hardship for existing businesses, and therefore is allowing the continued operation of Partial Nudity in establishments which were in operation on December 19 , 1989, or at any time in the year immediately preceding that date, under a valid license issued by the State of Florida Division of Alcoholic Beverages & Tobacco for sale of alcoholic beverages, beer or wine for consumption on the premises and which regularly provided entertainment including " Total Nudity" , "Partial Nudity" or "Sexual Conduct" as defined herein, provided that their continued operation shall be governed by Subparagraph B of Subsection 13-3 and Subsection 13-4 . Section 2 . ADDITION OF ZONING ORDINANCE SUBSECTION 12-4. That Section 12 , entitled "Liquor Control Regulations" of City of Miami Beach Comprehensive Zoning Ordinance No. 89-2665 is hereby amended by addition of Subsection 12-4 to read as follows: Section 12 LIQUOR CONTROL REGULATIONS 12-4 ALCOHOLIC BEVERAGE ESTABLISHMENTS PERMITTING TOTAL OR PARTIAL NUDITY OR SEXUAL CONDUCT A. For purposes of this Subsection, the following terms, phrases and words shall have the meanings given herein: 1. "Adult Bookstore" shall mean an establishment which sells, offers for sale or rents Adult Material for commercial gain. This definition includes establishments selling or renting adult videos when 4 applicable under the above-stated conditions. 2 . "Adult Booth" shall mean a small enclosed or partitioned area inside an establishment operated for commercial gain which is (1) designed or used for the viewing of Adult Material by one or more persons and (2) is accessible to any persons, regardless of whether a fee is charged for access. The term "Adult Booth" includes, but is not limited to, a "peep show" booth, or other booth used to view Adult Material. The term "Adult Booth" does not include a foyer through which any person can enter or exit the establishment, or a rest room. 3 . "Adult Entertainment Establishment" shall mean any Adult Bookstore, Adult Booth, Adult Motion Picture Theater, or establishment which permits Partial Nudity. 4 . "Adult Material" shall mean one or more of the following, regardless of whether it is new or used: 1) Books, magazines, periodicals or other printed matter; photographs, films, motion pictures, video cassettes, slides or other visual representations; recordings, other audio matter; and novelties or devices; which have as their primary or dominant theme subject matter depicting, exhibiting, illustrating, describing or relating to Specified Sexual Activities or Specified Anatomical Areas as defined herein; or; 2) Instruments, novelties, devices or paraphernalia which are designed for use in connection with Specified Sexual Activities as defined herein, except for birth control 5 devices or devices for disease prevention. 5. "Adult Motion Picture Theater" shall mean an enclosed Building used for presenting for observation by patrons motion pictures, films, or video media, distinguished or characterized by an emphasis on matter depicting, describing or relating to Specific Sexual Activities or Specified Anatomical Areas as hereafter defined. 6. "Nudity, Partial" means the exhibition by any female performer or employee of the establishment to any other Person of any portion of her breasts falling below the areola, or any simulation thereof (which definition shall include the entire lower portion of the human female breast, but shall not include any portion of the cleavage of the human female breast exhibited by a dress, blouse, shirt, leotard, bathing suit, or other wearing apparel, provided the areola is not so exposed) . 7 . "Nudity, Total" means the showing by any performer or employee of the establishment of all or any portion of the cleft of the human male or female buttocks with less than a full opaque covering; the showing by any performer or employee of the establishment of all or any portion of the female areola; the depiction by any performer or employee of the establishment of covered male genitals in a discernibly turgid state; the exhibition by any performer or employee of the establishment to any other Person, of his or her genitals, pubic area, vulva, anus, anal cleft or cleavage, or any portion of the foregoing specified anatomical areas, or any simulation thereof. 6 8 . "Parcel of Land" means any quantity of land capable of being described with such definiteness that its location and boundaries may be established, which is designated by its owner or developer as land to be used or developed as a unit, or which has been used or developed as a unit. 9 . "Sexual Conduct" means any sexual intercourse, masturbation, sodomy, bestiality, oral copulation, flagellation, any sexual act which is prohibited by law, erotic touching, caressing or fondling of the breasts, buttocks or any portion thereof, anus or genitals or the simulation thereof. 10. "Specified Anatomical Areas" as used in this Section above shall mean either of the following 1. Less than completely opaquely covered human genitals, pubic region, anal cleft, cleft of the buttocks, and; all or any part of the areola of the female breast; and 2 . Human male genitals in a discernibly turgid state, even if completely and opaquely covered. B. No Alcoholic Beverage Establishment shall permit Total Nudity or Sexual Conduct on any Parcel Of Land located in the City of Miami Beach. C. No Alcoholic Beverage Establishment permitting Partial Nudity is permitted on a Parcel Of Land located: 1. Within 300 feet of any district designated as RS, RM, or RPS on the City's Official Zoning District Map; or, 2 . Within 300 feet of any Parcel Of Land upon which a 7 house of worship, school, public park or playground is located; or 3 . Within 1, 000 feet of any Parcel Of Land upon which another Adult Entertainment Establishment is located. D. Mandatory Requirements 1. The minimum Building size of an Alcoholic Beverage Establishment which permits Partial Nudity shall be 8, 000 square feet. 2 . The Alcoholic Beverage Establishment which permits Partial Nudity shall have no less than 250 seats. 3 . The Alcoholic Beverage Establishment which permits Partial Nudity shall have a full service Restaurant and kitchen on-site, offering a complete menu during the operating hours of the establishment. 4 . Parking required for an Alcoholic Beverage Establishment which permits Partial Nudity shall be a minimum of one (1) space per three (3) seats, all of which shall be located on-site. 5. An Alcoholic Beverage Establishment which permits Partial Nudity shall have no Exterior signage describing or depicting the activities regulated by this Subsection taking place within the Premises. 6. Partial Nudity in Alcoholic Beverage Establishments shall occur only between the hours of 8 : 00 p.m. and 4 : 00 a.m. E. The minimum distance separation shall be measured by following a straight line from the main entrance or exit in which Partial Nudity associated with an Alcoholic Beverage Establishment occurs to the nearest point of the property designated as RS, RM, or RPS on the City's Official Zoning District Map or used for house of worship, school, or public park or playground. In cases 8 where a minimum distance is required between an Alcoholic Beverage Establishment permitting Partial Nudity and another Adult Entertainment Establishment, the distance separation shall be determined by measuring a straight line between the principle means of entrance of each Use. F. Exemption• 1. A Hotel with a minimum of three hundred (300) Hotel Units shall be exempt from Section 12-4 (C) (1, 2 , and 3) . G. An Alcoholic Beverage Establishment permits Total Nudity or Partial Nudity or Sexual Conduct under this Subsection if any Person maintaining, owning, managing or operating such Establishment knowingly or with reason to know, suffers or permits Total Nudity, or Partial Nudity or Sexual Conduct to occur on the Premises of such Establishment. H. Notwithstanding Subsection 12-4 , C (1, 2 , and 3) and I, Alcoholic Beverage Establishments which were in operation at a particular location on December 19, 1989 or at any time in the year immediately proceeding that date, under a valid license issued by the State of Florida Division of Alcoholic Beverages and Tobacco for sale of Alcoholic Beverages, Beer or Wine for consumption on the Premises, and which regularly provided entertainment including Total Nudity or Partial Nudity or Sexual Conduct as defined herein may continue to permit Partial Nudity after (the effective date of this Ordinance) 1990. However, whenever any such Non-conforming Use has been changed to a conforming Use, the former Non-conforming Use shall not be permitted at a later date. Such Establishments shall not be permitted to change to any Use other than are permitted in the Zoning District in 9 which the Use is located. Additionally, Subparagraph B of Subsection 13-3 and Subsection 13-4 of Zoning Ordinance 89-2665 shall apply to such Non-conforming Uses. I . VIOLATIONS AND PENALTIES Upon a finding by the appropriate administrative official or agency that a violation of this Section has occurred, the City shall initiate proceedings to revoke the Certificate of Use, Occupational License or Certificate of Occupancy, whichever are appropriate. Additionally, this Section may be enforced and violations may be punished as follows: 1. By enforcement procedures as set forth in Section 25 of the Miami Beach City Charter and penalties as provided in Section 1-8 of the Miami Beach City Code; or 2 . As provided in Subsection 21-2 of City of Miami Beach Zoning Ordinance 89-2665. Section 3 AMENDMENT OF SUBSECTION 7-2 BY ADDITION OF PARKING REQUIREMENT FOR ALCOHOLIC BEVERAGE ESTABLISHMENTS WHICH PERMIT PARTIAL NUDITY That Subsection 7-2 of City of Miami Beach Comprehensive Zoning Ordinance No. 89-2665, entitled "Off-street Parking Required" is hereby amended to read as follows: SECTION 7 PARKING REGULATIONS 7-2 Off-Street Parking Required Except as otherwise provided in this Ordinance, 10 when any Building or Structure is erected or altered,accessory Off-Street Parking Spaces shall be provided for the Building, Structure or additional Floor Area as follows: A. Parking District No. I 1. Adult Congregate Living Facility - 1 space per 2 beds. 2 Alcoholic Beverage Establishment which permits Partial Nudity - 1 on-site space per 3 seats. Section 4 AMENDMENT OF SUBSECTION 16-7 That Subsection 16-7 of Section 16, entitled "Board of Adjustment" of City of Miami Beach Comprehensive Zoning Ordinance No. 89-2665 is hereby amended to read as follows: Section 16 BOARD OF ADJUSTMENT 16-7 POWERS AND DUTIES A. The Board of Adjustment shall have the following powers and duties: 1. To hear and decide appeals when it is alleged that there is error in any order, requirement decision, or determination made by an administrative official in the enforcement of this Ordinance with the exception of appeals pursuant to Section 17-4H. In the event of an Administrative Appeal to the Board of Adjustment, the Planning and Zoning Director may 11 engage the services of an attorney for the purpose of representing the Administrative Officer who made the decision that is the subject of the appeal . In exercising this power, the Board of Adjustment, may upon appeal, reverse or affirm, wholly or partly, the order, requirement, decision, or determination, and to that end shall have all the powers of the officer from whom the appeal is taken. The concurring vote of four (4) members, of the Board shall be necessary to reverse any order, requirement, decision, or determination of any such administrative official or to decide in favor of the Applicant on any matter upon which the Board is required to pass under Ordinance. 2 . To authorize, upon application such Variance from the terms of this Ordinance as will not be contrary to the public interest when, owing to special conditions, a literal enforcement of a provision of this Ordinance would result in unnecessary and undue hardship. An application for a Variance shall be limited to the following development regulations: height, average and minimum unit sizes (but not the average unit size when used in determining the bonus for the Floor Area Ratio) , setback areas, size and location of Signs, Open Space Ratio, distance requirements of Subsection 12-4 , and off-Street parking and loading requirements (however, no Variance shall be given for off-Street parking for less than one space per Apartment Unit or Hotel Unit, or a request pertaining to the reduction of an impact fee, or for Lot Area when determining Floor Area Ratios) . In order to authorize any Variance from the terms 12 of this Ordinance, the Board of Adjustment shall find: Section 5. Severability. If any section, subsection, clause or provision of this Ordinance is held invalid, the remainder shall not be affected by such invalidity. Section 6. Repealer. All Ordinances or parts of Ordinances in conflict herewith be and the same are hereby repealed. Section 7 . Effective Date. This Ordinance shall take effect on the 3rd day of March 1990. PASSED and ADOPTED this 21st day of February 1990. VICE-MAYOR ATTEST: FORM APPROVED LEGAL DEPT. CITY CLERK 1st Reading 2/7/90 Date .2//y/io 2nd Reading 2/21/90 a: \nudeor3d 13 eat/ (4 ?Xim ' 'ea. ,, FLORIDA 3 3 1 3 9 ' *`•INCOAP��ORATEDj* `' V,4 C.4 TIONLANU U. S. A. OFFICE OF THE CITY MANAGER CITY HALL ROB W.PARKINS 1700 CONVENTION CENTER DRIVE CITY MANAGER TELEPHONE: 673-7010 COMMISSION MEMORANDUM NO. iI- '90 - DATE: FEB. 21, 1990 TO: Mayor Alex Dao . and Members of e City Commi io O FROM: Rob W. P. kins n �4 City Manager SUBJECT: AN ORDINANCE AMENDING ZONING ORDINANCE 89-2665 BY THE ADDITION OF REGULATIONS PERTAINING TO TOTAL NUDITY, SEXUAL CONDUCT, AND PARTIAL NUDITY IN ALCOHOLIC BEVERAGE ESTABLISHMENTS BACKGROUND On February 7 , 1990, the City Commission approved on first reading an amendment to the zoning ordinance. It permits partial nudity (pasties and G-strings) in alcoholic beverage establishments provided that certain distance separations and mandatory requirements are met. The ordinance also exempts hotels with a minimum of 300 rooms from the distance separation requirements. The amendment to the zoning ordinance follows the intent of a City Code Amendment (Ordinance 90-2678) , adopted on January 17 , 1990, which prohibits total nudity and sexual conduct in alcoholic beverage establishments but permits partial nudity. The zoning ordinance amendment further restricts the locations of these uses and provides additional site and operational requirements for such establishments. In December, 1989 and January, 1990, the City Commission was provided with copies of studies conducted by other local governments and from the City of Miami Beach Planning and Zoning Department. These reports shall be construed to be a part of the permanent record of the adoption proceedings regarding this Ordinance. These studies are: (1) the Minneapolis Report of the Attorney General ' s Working Group on the Regulation of Sexually Oriented Businesses, conducted in 1989 ; (2) the Saint Paul Minnesota Planning and Economic Development and the Minnesota Crime Control Planning Board' s study, Effects on Surrounding Area of Adult Entertainment Businesses in Saint Paul , conducted in June of 1978 ; (3) the study conducted by the Phoenix Arizona Planning Department in 1979 entitled Relation of Criminal Activity and Adult Businesses; and (4) The Regulation of Adult Entertainment Establishments in the City of Miami Beach: Analysis, Findings and Recommendations Pertaining to Nude Dancing in Alcoholic Beverage Establishments, prepared by the CMB Planning and Zoning Department in December, 1989 . CITY COMMISSION ACTION - FIRST READING On first reading (February 7 , 1990) , the City Commission approved an ordinance regulating partially nude bars. It followed the Planning Board ordinance with the following three amendments: 18 AGENDA _ - )_____ ITEM DATE 2 -21 - 9 o 1. The 300 foot required distance separation from a residential use (Planning Board) was changed to a 300 foot separation from a residential zoning district. 2 . The exemption from distance separation requirements for hotels was changed from a minimum of 250 hotel rooms (Planning Board ordinance) to 300 rooms. 3 . A new requirement was added which limits the hours that partial nudity may be exhibited from 8 : 00 pm to 4 : 00 am. PLANNING BOARD ACTIONS On January 15 and 16, 1990, the Planning Board held two public hearings and considered two separate Zoning Ordinance amendments - one Ordinance restricts the location of nude bars while the other Ordinance pertains to all other forms of adult entertainment (movies, bookstores, peep shows) . Prior to the public hearing, one of the members (James Silvers) determined he may have a conflict of interest and left the meeting. As such, six of - the seven members were present throughout the entire meeting. As set forth in the Zoning Ordinance, in order for a motion to receive an affirmative recommendation from the Planning Board, it is necessary that five votes be cast in favor of a motion. If a motion receives four of the six votes, it fails to pass. This is the same situation where the Board of Adjustment requires four of five votes in order to approve a variance. The attached Ordinance, which only received four votes in favor and two against, was not recommended by the Planning Board because it failed to receive five votes. The four votes in favor were cast by Norman Frank, Stephen Hertz, Keith Kovens, and Ralph Mizrahi. The two dissenting votes were cast by Joy Alschuler and Neisen Kasdin. The dissenters voted against the Ordinance because 1) it allowed partial nudity in alcoholic beverage establishments in the Redevelopment Area, and; 2) the Ordinance did not expand the 300 ft. to 400 ft. separation from a school , place of worship, park and playground from alcoholic beverage establishments that have partial nudity. The following motions also failed because they did not receive 5 votes. A motion to expand the separation between schools and nude bars from 300 ft. to 400 ft. failed four to two. Similarly, a motion to prohibit partial nudity in alcoholic beverage establishments in the Redevelopment Area failed on a vote of four votes in favor and 2 against. A motion to measure the distance separation from residential districts as opposed to residential uses failed 3-3 . As required in the Zoning Ordinance, the Planning Board' s recommendation, which is not to approve the attached Ordinance, (four to approve - two to deny) is hereby transmitted to the City Commission. SUMMARY OF THE ORDINANCE The basic concepts included in the proposed ordinance are as follows: 1. Allows partial nudity in alcoholic beverage establishments anywhere in the Redevelopment Area, provided that they meet the distance separation requirements. 2 . Distance separation will include a minimum distance of 300 ft. from residential zoning districts (RS, RM, or RPS) , house of worship, school, public park or playground; 1000 ft. distance separation from another adult entertainment establishment. 19 3 . Follows intent of the City Code Ordinance 90-2678 regarding partial and total nudity and sexual conduct. 4 . Prohibits all total nudity/sexual conduct in alcoholic beverage establishments. Allows performers to exhibit partial nudity with a G-string covering cleft of the buttocks and pubic area and pasties covering the areola if the establishments meet distance separation requirements as listed in item 2 above. 5. Grandfathers-in existing establishments for Partial Nudity - only. 6. Exempts hotels of a minimum size (300 units) from distance separation requirements. 7 . Provides for variances from Zoning Board of Adjustment for distance separation requirements. 8. Provides for penalties in City Code (fines, imprisonment) and in Zoning Ordinance (Code Enforcement Board fines) . 9 . Establishes the following mandatory requirements for alcoholic beverage establishments which have partial nudity. a. 'Minimum building size - 8 , 000 sq. ft. b. No less than 250 seats. c. On-site full service restaurant and kitchen offering a complete menu during the operating hours of the club. d. Parking requirement (1 space per 3 seats all of which shall be located on site) . e. No exterior signage describing or depicting the activities taking place within the premises. f. Hours in which partial nudity may be exhibited - 8 : 00 pm to 4 : 00 am. ANALYSIS OF THE PROPOSED ORDINANCE A. Distance Separations The distance separations set forth in the proposed ordinance strictly limit the number of potential locations for adult entertainment establishments in the City. On first reading, the City Commission amended one of the distance separation criteria to require a minimum of 300 feet from residential zoning districts as opposed to residential land uses. This change offers a simpler approach to administering the ordinance. It also makes the partially nude bar ordinance and the adult entertainment ordinance (motion picture theaters, bookstores, etc. ) consistent with one another, as they both now have identical distance separation requirements. The 1000 feet required between any two adult entertainment establishments reflects an accepted method of dispersing these businesses in order to limit any negative impacts which could be caused by a concentration of such uses. B. Mandatory Development Criteria The ordinance contains six mandatory development criteria which are intended to reduce the negative secondary impacts created by semi- nude bars. The criteria are also intended to ensure quality development in the entire City as well as in the Redevelopment Area. These criteria include setting forth minimum building sizes (8000 square feet and 250 seats) , reflecting a significant investment in the property, which would imply that a quality operation would be likely. Also required is a full service restaurant and kitchen offering a complete menu. Again, this would assist in ensuring quality development and operation. Also, the consumption of food by patrons tends to reduce the effects of alcohol in the bloodstream. The restaurant and kitchen, combined with the size of the facility, indicates that the partial nude aspects of the operation is of secondary importance in terms of land use. The ordinance also contains a stricter parking requirement (1 space per 3 seats, rather than 1 space per 4 seats) , which reflects the higher demand for parking generated by such establishments vs. - other establishments which do not provide semi-nude entertainment. Since the majority of patrons will be men arriving individually or in small groups, as opposed to couples, it is indeed likely that there will be a higher parking demand in a semi-nude bar. Additionally, the parking would be required to be provided on-site, further lessening the negative impact on surrounding properties and offering additional security from crime for the patrons and their automobiles. - The ordinance contains a clause stating that there shall be no exterior signage describing or depicting the activities taking place within the premises. Finally, the ordinance contains a limitation on the hours of operation as a partially nude bar (from 8 : 00 pm to 4 : 00 am) . This provision was added by the Commission during first reading of the ordinance. It would offer additional protection from any potential secondary impacts of the adult entertainment establishment by ensuring that adult activities would not be taking place during daytime hours when school children may be in the vicinity of the establishment. If partial nudity does not occur on the premises, then the bar would be allowed to operate under the same regulations as other bars in the City. C. Hotel Exemptions The ordinance provides for an exemption from the distance separation requirements for hotels containing 300 or more rooms. (The City Commission raised this figure from the Planning Board' s recommendation of 250 rooms. ) This will allow for Las Vegas type revues to be performed in the City' s larger hotels. A total of 11 hotels have 300 rooms or more (18 hotels have 250 rooms or more) . 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