That's actually an interesting question. Can a random property owner decide to make a public area clothing optional!
I always understood, probably incorrectly, the only reason Orient Beach is CO was because of the existence of Club Orient long prior to any of the later zoning rules or regs or societal issues regarding the nude usage. I remember our earliest trips and that beach was always accepted as CO but back then there was nothing there but sea grape and a wide open endless beach.
I've never quite understood how an individual or a business could make these decisions for either side of the island. Inquiring minds and all that.....