05/22/2026
At 9:32AM yesterday morning 5/21, I submitted my ✨31-page Opposition Memorandum ✨ for the Holder Industrial Park Project (HIP) Data Center Application Proposal for Citrus County, FL to every PDC, BOCC, Public comment director, State Representative, State Senator, and Regional Planning Council Member for our Districts here in Citrus County for public record in good faith utilizing publicly available information regarding this project. It is an astounding report, that is likely scratching some heads in high places right now...
This memorandum will become public record and available to all the public very soon.
It is extensive, researched, backed by Land Development Code, State Statues, and Florida Law. This took me weeks to put together, and as a citizen of the United States and our great State of Florida, it was my privilege to take part in this process. As soon as receipt that it is LIVE as a public record goes through, I will link it to a public SSH viewing folder where members of the public can view it without having to wait for it to show up on an agenda. But it was emailed with receipts, and as per public record procedure, upon emailing, it because a part of the public record for these applications. An excerpt of the memorandum is below.👇
I am sure this was a large load to drop. Like I said, it is EXTENSIVE, well cited and referenced, and includes very detailed information. When I say I have been collecting information on this particular project, I meant it.
This is no different than the detailed information gathering and reporting and oppositions I made during the State Parks vs Golf Course fiasco which helped, in part along with SIGNIFICANT PUBLIC SUPPORT AND LAND USE LAW EXPERTS, to change State law and stop development. ANYONE can do this, if they have the time and understanding of where to locate resources, and everyone that has been called to speak out should.
If you have any questions about this, please contact me at [email protected]. I will be rolling out more of the memorandum, how to fight this and what to say when speaking, and most importantly WHO you need to send them too, as well as what can help when drafting your own Oppositions to Public Servant staff, and much more about the insurmountable issues uncovered in the report in the following days and weeks. You can join Protect Nature Coast Florida - Citrus County, my personal group, to stay updated faster. Thank you! 🙏
✅ BELOW IS AN EXCEPT FROM THE OPPOSITION MEMORANDUM that was emailed to intended parties of the County and State (it goes into much more extensive detail than what is presented here):
EMAIL BODY:
Good afternoon,
My name is Jessica Ketner and I am a resident of Citrus County, FL (34434).
I am submitting the attached 31-page opposition memorandum regarding the proposed Holder Industrial Park (HIP) expansion located near US-41 and County Road 491, Lecanto in Citrus County Florida regarding the following planning and development applications:
CPA-2025-00012
CPA/AA-2025-00013 (CPA/AA/PUD2025-00013)
I respectfully ask that this 31-page attached memorandum be reviewed by all intended parties and considered as part of the public record and broader discussion surrounding the proposed expansion and the addition of “Information Processing and Data Center Utilities and Data Storage” uses within the HIP project area.
My concerns primarily relate to long-term land use compatibility, existing land use code enforcement, infrastructure impacts, water and environmental considerations, transportation expansion, emergency response impacts, [AVAILABLE INFORMATION WILL BE MADE PUBLIC LATER], and the potential regional impacts associated with large-scale industrial and data center development in our rural community.
NOTE TO RECORDS STAFF: Please accept the attached Opposition Memorandum regarding the Holder Industrial Park Expansion (HIP) applications CPA-2025-00012 and CPA-AA-2025-00013.
I, Jessica Ketner, a Citrus County resident and registered voter respectfully request that this memorandum and all attachments be:
Entered into the official public record for these applications;
Made available to the citrusclerk.portal.civicclerk as public record;
Distributed to all intended recipients listed in the Opposition Memorandum
Distributed to all County Planning & Development Commission members;
Distributed to all Board of County Commissioners members; and
Retained as part of the official record for all future hearings and proceedings related to these applications.
Please confirm receipt and inclusion into the record and distribution to all intended parties and CC via email when confirmation of receipt is available at [email protected]
Thank you.
🔴 OPPOSITION MEMORANDUM:
I, Jessica Ketner, a Citrus County resident and registered voter, am respectfully requesting this opposition memorandum to be submitted into the public record for the Citrus County Planning & Development Commission (PDC) and Board of County Commissioners (BOCC) regarding the proposed Holder Industrial Park (“HIP”) expansion applications submitted by Deltona Corporation and its representatives.
My relevant background to speak on matters involving these applications include Information Technology Management and Cybersecurity with an emphasis on Cloud Infrastructure Architecture as well as Machine Learning infrastructure (AI) with understanding server farms and their requirements for successful operation.
This opposition is not intended as a blanket opposition to all economic development or all industrial activity within Citrus County. Rather, this memorandum raises substantial planning, infrastructure, compatibility, utility, environmental, land use, procedural, and long-term policy concerns regarding the specific scale, structure, timing, and breadth of the proposed applications CPA-2025-00012 and CPA-AA-2025-00013.
The applications request extremely broad and long-lasting industrial entitlements while simultaneously leaving many of the most consequential operational details undefined. The public is being asked to approve a major industrial and utility framework that has not been seen or explored in Citrus County before the county, neighboring property owners, or residents have sufficient information regarding the true long-term operational intensity and infrastructure implications of the proposal. That is an unprecedented ask.
I have researched the publicly available applications, presentations, maps, planning analyses, and supporting materials provided by the applicant as well as county land use codes and comprehensive plans (which are referenced at the end of this document for ease of public inquiry). What I found through reviewing the applicant’s materials is that these proposals do not merely suggest a routine industrial park expansion request beginning in 2019 with prior approvals, but that the most recent amendments potentially bypass the serious issue relating to a major industry land use shift for the Holder Industrial Complex project (HIP). The amendments, along with the request to adopt “data centers” into industrial tiers (which have never been previously approved by the county), are asking the county to now approve broad industrial and utility entitlements for this project before the operational intensity, infrastructure demand, utility burden, and long-term impacts of these applications have been declared. As of now, the county’s LDC regarding Heavy Industrial Districts (IND)[i], only allows for manufacturing, processing, storage, warehousing, distribution, transportation, communication, and utility uses, but this industry type’s other classifications and unique infrastructure is not listed as allowable land use under IND designation.
…
[INFORMATION TO BE MADE PUBLIC AVAILABLE LATER]
…
However, any code change to our LDC would require the involvement of extensive procedures that must involve formal legislative processes backed by the Florida Growth Management Act, Florida Statutes Chapter 163[iii], Citrus County’s Comprehensive Plan[iv], and Citrus County’s LDC[v] through public hearings, staff review, and Board approval, and possible State review by Florida Commerce, FDOT, DEP, Water Management Districts, and other agencies involved[vi].
In addition, the HIP applications and associated amendments are specifically structured to establish a large-scale, infrastructure-served industrial platform capable of supporting data-center-compatible development and other high-intensity industrial users, including expanded utility systems, electrical substations, fiber expansion capability, wastewater infrastructure, and expressly permitted “Information Processing and Data Center Utilities and Data Storage” uses[vii]. This is a unique industry project type that has not been previously contemplated within Citrus County’s long term planning framework within the 2050 Comprehensive Plan[viii] for growth and development of the county.
The applicant even expressed this demonstrating a “Critical Gap Identified: Neither the LIND nor IND district use tables specifically lists ‘data centers,’ ‘information processing facilities,’ or ‘data storage’ as permitted uses.”[ix]
As per the current LDC, there exists no amendments that include district types specific to large-load customers/data centers (see Florida State’s own classification of data center industries in SB 484[x]) as part of the IND land use districts allowed.
This alone raises substantial concerns regarding consistency with the County’s current LDC framework. For this, I believe these applications should be denied.
But if that is not enough of a reason to support their denial, I would like to continue.
It is clear that this industry type has now come knocking on our rural county’s door, likely due to a “competitive arms race” for their installations around the nation, claiming benefits to the communities they target. However, what many communities are noticing now appears to be several adverse effects on resources, environment, and economic impact. The concern is that once land use approvals have been granted and established, and the data center has commenced operations, these hardships will become extremely hard to circumvent. Yet, we are seeing an industry boom unlike anything before in history where large load operators are typically targeting rural communities with available land, utility access, and less-developed regulatory frameworks, as well as availability to nearby water resources. We see this happening with these applications being close to the greater Lake Tsala Apopka area, an already drought-ridden area.
Much of the opposition for these applications coming from the residents of Citrus County and environmental experts hopefully will provide their own memorandums for environmental impact as well (that’s you Citrus County resident reading this!) since there are plentiful environmental reports of adverse impacts on communities that continue to surface that can be extensively referenced to back up the above claims (and can be found with a simple browser search).
However, this opposition memorandum does not focus entirely on these claims but instead focuses on opposition from a different approach - one grounded in Citrus County’s own adopted Comprehensive Plan, Land Development Code, compatibility standards, infrastructure policies, and long-term planning objectives.
Let’s dive in…
WHAT THE APPLICATIONS ARE ACTUALLY REQUESTING
The applications seek approval for multiple interrelated actions that collectively create a large-scale industrial entitlement framework:
· Expansion of Holder Industrial Park from approximately 557 acres to approximately 1,356 acres total along US-41, CR-491, N Tram Rd, near residential neighborhoods and Lake Tsala Apopka[xi].
· Future Land Use Map amendments converting additional land to Industrial Tier classifications for future land use to add “Information Processing” and “Data Center Utilities” and “Data Storage” as allowable uses within HIP Tier I and HIP Tier IIA and IIB[xii]
· Planned Service Area (PSA) expansion[xiii].
· Requesting amendments to convert additional parcels from AGR MH (Agricultural/Mobile Home), LDR MH (Low Density Residential/Mobile Home), RUR MH (Rural Residential/Mobile Home), TCU (Transportation/Communication/Utility), and some existing IND (Industrial) to multiple heavy industrial tiers[xiv].
· Amendments to the Holder Industrial Park Subarea Plan[xv].
· Revisions to the HIP framework to include “Information Processing,” “Data Center Utilities,” and “Data Storage” as allowable uses within the HIP framework[xvi].
· Allowance of clustered multifamily housing, workforce housing, and mixed-industrial support residential uses with densities up to 12 units per acre[xvii].
· Authorization of electrical substations throughout all industrial tiers[xviii].
· Utility expansion and infrastructure commitments[xix].
· Transportation corridor accommodations and future roadway widening accommodations[xx].
· Long-term entitlement certainty for future industrial recruitment[xxi].
The public-facing framing of the proposal as a general “industrial park expansion” significantly understates the practical implications of the requested amendments. The applications and presentations repeatedly reference future recruitment of[xxii]:
· Data Centers and Cloud Infrastructure
· Dedicated substations
· Massive power delivery infrastructure
· Transmission Upgrades
· High-tech industrial operations
· Technology infrastructure
· Utility-intensive uses
· Digitally oriented industrial operations.
· Need for reclaimed water/reuse systems for high demand uses.
· Large economic impact numbers
· Future Widening of US-41 and CR-491
· Roadway corridor dedication
· Multiple access points
NOTE: Reminder that “Information Processing,” “Data Center Utilities,” and “Data Storage” are not currently clearly identified as expressly allowable uses within the existing HIP Tier I and HIP Tier IIA/IIB framework. The applicant’s own analysis acknowledges that Citrus County’s current LIND and IND district use tables do not specifically list “data centers,” “information processing facilities,” or “data storage” as permitted uses either.[xxiii] The 2025–2026 applications therefore seek to amend the Holder Industrial Park Subarea Plan and associated policy language to specifically authorize these uses within the HIP framework.[xxiv] These proposed amendments substantially expand and alter the character, intensity, and long-term industrial scope of the previously approved industrial park beyond the general industrial framework presented during the earlier approvals.
I, Jessica Ketner, a Citrus County resident formally request that the Citrus County PDC and BOCC DO NOT approve CPA-2025-00012 and CPA-AA-2025-00013 as currently written, and that it be denied due to the following additional reasons:
(MEMORANDUM CONTINUES)
Written by Jessica Ketner
