The article doesn't say if the Papas charged any fees for playing the course. If they do, I'd imagine they'd need to be zoned commercially in some way in order to run the course as a business. Even if they don't, the fact that they run a pro shop out of the garage might also require some sort of commercial zoning.
Beyond that, it's entirely up to the individual municipality to determine what zoning is required for particular land use. I know the owner of the course here has had different experiences in each town he's approached regarding building a pay-for-play disc golf business. In one town, he had to prove it was just like golf to get zoning approval. In another, he had to argue that it was nothing at all like golf because the zoning specifically disallowed a golf course (but not other recreational use like mini-golf or paintball or a ropes course).
There just isn't a catch-all answer to the question. It's up to the person looking to build the course to explore the local requirements and restrictions.
Maine Disc Golf
- the way disc golf should be