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Special Liquor Licenses Approved for Orlando Main Street Small Restaurant Incentive Area

July 06, 2021

By: Tara Tedrow & Kyla Szubinski*

On June 29, 2021, Governor DeSantis signed HB 1647 allowing smaller restaurants to be eligible for Special Food Service (4COP SFS) liquor licenses. Owners with businesses and properties that fall within the Orlando Main Street Small Restaurant Incentive Area now have the opportunity to re-evaluate their licenses and possibly add sales for on premises consumption of liquor if they do not currently have it.

Florida Beverage Law limits the number of licenses that may be issued allowing a business to sell any alcoholic beverage that includes liquor and spirits. There are many exceptions to this quota license limitation; specifically, businesses may be issued a Special Food Service license allowing a business to serve any alcoholic beverage of any alcohol content.

The bill creates an exception to s. 561.20(1), F.S., by requiring the Department of Business and Professional Regulation (DBPR) to issue special alcoholic beverage licenses to bona fide restaurants in the Orlando Main Street Small Restaurant Incentive Area that:

  • Are licensed by the Division of Hotels and Restaurants,
  • Have at least 1,800 square feet of contiguous space (as opposed to a general rule of 2,500 square feet),
  • Are equipped to serve meals to at least 80 persons at one time (as opposed to the general rule of 150 customers), and
  • Derive at least 51 percent of their gross food and beverage revenue from the sale of food and nonalcoholic beverages during the first 60-day operating period after licensure, and each 12-month operating period thereafter.

The license will be revoked if the licensee fails to meet the 51 percent food and nonalcoholic beverages gross revenue requirement. If a licensee gets their license revoked, denied, or if the licensee does not qualify, the licensee may not have any interest in a subsequent license application for 120 days after the date of the denial or revocation.

Orlando Main Street small restaurants located within Orlando’s nine neighborhood commercial districts located throughout the city may be able to obtain less expensive liquor licenses, generate new revenue streams, and maintain their historic buildings. This is a great opportunity for restaurants to expand their alcoholic beverage service options and increase revenues from such sales without having to purchase a quota liquor license on the open market.

For questions on liquor licensing generally or the impact of these new regulations, contact shareholder Tara Tedrow at

*Kyla Szubinski, a summer law clerk, assisted with this article.

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Tara Tedrow is a shareholder in the firm’s Land Use, Zoning & Environmental Group and serves as chair of the Cannabis & Controlled Substances Group. She brings years of experience handling an array of complex legal matters for multi-billion dollar valued companies and entrepreneurs alike.
With a significant portion of her practice devoted to land use and development, Tara regularly advises clients on entitling projects for commercial, residential, industrial, office and mixed uses. She works with local governments and regulatory agencies to address the needs of her clients related to environmental permitting and compliance, zoning, comprehensive plans, concurrency, site plan approval, variance and waiver requests, due diligence and property rights.

Often sought out for high-profile and high-stakes land development projects, Tara has delivered positive outcomes for clients ranging from large multi-national and U.S.-based companies to high-net worth individuals seeking land use entitlements. With over 15 years of competitive debate experience, she is uniquely suited to handle complex and controversial projects and public hearings that present a myriad of political and legal challenges.

Tara has provided developers and clients with legal counsel and representation in Section 70.51 mediations. Her experience in land use and environmental dispute resolutions offers a unique benefit to clients navigating the alternative dispute resolution process following denial of a development order, zoning approval and other land use matters around the state.

Well-known for providing legal and lobbying representation for a wide range of cannabis clients, Tara and her team work with physicians, lenders, real estate developers, landlords, ancillary service providers, banks, licensed adult use and medical marijuana companies, cultivators, processors, retailers and license applicants, helping them to navigate the ever-changing regulatory landscape of marijuana and hemp regulations. She also assists clients in the national hemp industry in obtaining licensing and approvals for processing, retailing, cultivation and other forms of secondary byproduct monetization. Her deep knowledge of regulatory laws and understanding of operations and logistics for cannabis companies, along with her ability to make connections and build partnerships, bring strategic value to her clients. 

Tara is the only person in the state of Florida to be appointed by the Florida Department of Agriculture and Consumer Services to both the inaugural Industrial Hemp Advisory Council created under Senate Bill 1020 and to the state’s Hemp Advisory Committee, which she currently chairs. A prolific presenter and speaker at industry seminars and conferences, she has served as the keynote speaker on industry regulations at over 60 events in the past two years. In the fall of 2018, Tara became the first professor in the state of Florida to teach a law school course on marijuana law and policy at the University of Florida Levin College of Law, where she continues to teach today.

Prior to joining the firm, Tara worked as a legal extern for the University of Florida General Counsel and Office of the Vice President as well as for the Orlando Juvenile Public Defenders Office. For over a decade, she has also worked professionally as a private speech and debate coach and taught at multiple national debate institutes, including the National Debate Forum at Emerson University, the National Symposium for Debate at Grinnell College and Victory Briefs Institute at UCLA.

Tara is a contributing writer at the Orlando Sentinel and has spoken about various real estate topics on Fox News.

To view Tara's information specific to Land Use or Cannabis, click the corresponding links below. 

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