Dear City of Naples Property Owners,
As a follow-up to the community information notice distributed yesterday, this letter provides the nexus of our concerns [the Florida DEM as outlined below] and additional details on floodproofing requirements.
The City of Naples has experienced significant tropical weather events within the past two years, including Hurricanes Ian, Helene, and Milton. These hurricanes brought substantial water intrusion and damage, a vast difference from previous storms where wind damage was the most significant impact. As a result, understandably, property owners are looking for ways to mitigate flood damage to buildings. Many property owners are considering the use of flood panels to help prevent floodwaters from damaging buildings. Due to the recent interest in this topic, we are providing this position paper outlining the City’s stance regarding the use of flood panels.
The City of Naples is a voluntary participant in the National Flood Insurance Program (NFIP). Participation in this program allows for the purchase of federally backed flood insurance for buildings that may not otherwise qualify. Being voluntary members of the NFIP compels the City to follow certain regulations and procedures in construction and building code compliance enforcement.
Both Florida Building Code and NFIP regulations treat residential and non-residential buildings differently, particularly regarding their design in the Special Flood Hazard Area (SFHA). Currently, over 90 percent of the addresses within the city are within the SFHA. As a result, these buildings are subject to additional scrutiny related to the design and use of space below the FEMA-provided Base Flood Elevation (BFE). In general terms, a residential building is permitted to have a portion of the building built below the Design Flood Elevation (DFE) – defined as BFE plus one foot- provided the space is used only for parking, storage, and building access. Typically, this applies to residential garages. These enclosed spaces must also include flood vents, a mitigation measure known as ‘wet floodproofing’, which allows floodwaters to enter and exit without placing excessive pressure on the structure.
Non-residential buildings, however, are permitted to use a method known as ‘dry floodproofing’ to comply with flood code requirements. A non-residential space (enclosure) is permitted below the DFE, provided that a dry floodproofing system is properly designed and implemented. These systems are typically designed in accordance with ASCE 24-14 and FEMA P-936. An approved dry floodproofing system must demonstrate several key components, including:
- The building’s ability to withstand flood loads during a design storm while panels are in place.
- The inclusion of operational and maintenance plans.
- Sump pumps are planned for and added to mitigate the effects of seepage.
These requirements, among others, must be documented in a FEMA Dry Floodproofing Certificate, and submitted to the city before receiving a Certificate of Occupancy.
Recently, the Building Department was notified by the Florida Department of Emergency Management’s (FDEM) Floodplain Office of a residential property within the City of Naples that had examples of floodproofing installations FDEM deemed illegal. Additionally, City staff has observed that some property owners are purchasing and installing flood panels on existing residential buildings without obtaining building permits. In response, staff has begun discussions with stakeholders and is providing this communication to articulate the City’s position on this matter for the benefit of all.
First, any alterations or additions to an existing building, particularly within the SFHA, must be reviewed by the Building Department. Unpermitted work has led to heightened scrutiny from FEMA in other communities, particularly in Lee County, where some jurisdictions have faced potential removal from the NFIP. If the City of Naples were to be removed from the NFIP, the consequences to the housing market could be catastrophic.
Beyond the regulatory requirements for permits, the City has two major concerns regarding the retrofitting of existing residential buildings with flood panels. These concerns are central to the review process.
- Life Safety Hazards: In non-residential buildings, flood panels are an acceptable mitigation measure because these structures are generally unoccupied during storm events. A caretaker of the building can install the panels and evacuate, ensuring no one is trapped inside. However, in a residential setting, the deployment of flood panels raises serious concerns:
• Could occupants become trapped inside?
• If an emergency arises, how would first responders gain access to a dry floodproofed home?
• For these reasons, it is critical that any proposed installation of flood panels be reviewed in accordance with existing building and safety codes. - Structural Integrity: The ability of an existing building to withstand the loads imposed by floodwaters must be evaluated. When flood panels are deployed during flood conditions, multiple forces—including hydrodynamic and hydrostatic pressures—act upon the structure, forces that would not be present without the panels. Without professional engineering analysis, there is no way to determine whether the addition of flood panels creates a more dangerous condition during a flood event. ASCE 24-14 specifies the load calculations that must be performed when designing a dry floodproofing system, with a primary focus on ensuring the building’s stability under flood conditions.
The City of Naples is committed to supporting the community’s efforts to enhance resiliency. Staff has actively engaged with FEMA and the Florida Department of Emergency Management to advocate for additional flood mitigation measures that align with FEMA and Florida Building Code regulations. The City recognizes that many property owners view flood panels as an additional protective measure rather than a means to achieve code compliance. However, any alterations to a building, including installing flood panels, must be permitted and reviewed to ensure safety and suitability. Please review the guidance below or contact our office for permitting requirements.
The City understands the unprecedented nature of the storms we have experienced in recent years and the significant damage they have caused to properties. We recognize the need for property owners to seek solutions to protect their homes and investments. However, ensuring that these solutions are implemented safely and in compliance with regulations is critical to protecting lives, maintaining structural integrity, and preserving the City’s participation in the National Flood Insurance Program. The Building Department remains willing to issue permits for flood panels if the above conditions are met. Our priority is to ensure that floodproofing measures enhance—not compromise—the safety and integrity of residential structures.
Equally, we appreciate the community’s attention to this important matter and encourage property owners to work with licensed professionals and the City’s Building Department to ensure compliance with all applicable regulations.
Sincerely,
Stephen Beckman
City Building Official and Floodplain Administrator
City of Naples
City of Naples Building Department Website
Original Source: City of Naples email blast