Flood Mitigation Guidelines & Regulations for Property Owners

• BFE: Base Flood Elevation - BFE measures the height floodwaters are expected to reach during a base flood (a flood with a 1% chance of occurring—commonly referred to as the 100-year flood).
• CCCL: Coastal Construction Control Line - Construction Seaward of the CCCL. This program regulates structures and activities that can cause beach erosion, destabilize dunes, damage upland properties, or interfere with public access.
• FBC: Florida Building Code - Statewide code for construction and safety.
• FIRM: Flood Insurance Rate Map - A flood map is issued by FEMA for insurance and floodplain management purposes; it identifies Special Flood Hazard Areas (SFHAs) with an annual percentage risk of flooding.
• NFIP: National Flood Insurance Program - Administered by FEMA (Federal Emergency Management Agency), the NFIP provides federally-backed flood insurance to property owners or renters and works to reduce flood damage by enforcing floodplain management regulations.
• SFHA: Special Flood Hazard Area - Indicates an area where NFIP floodplain management regulations must be enforced.
• SI: Substantial improvement - any reconstruction, rehabilitation, addition, or other improvement to a structure, the total cost of which equals or exceeds 50 percent of the market value of the structure before the start of construction of the improvement.
• SD: Substantial damage - damage of any origin sustained by a structure whereby the cost of restoring the structure to its pre-damaged condition would equal or exceed 50 percent of the market value of the structure before the damage occurred.
  • FEMA uses these classifications to evaluate whether a building is permitted to be rebuilt after sustaining damage and/or make expensive improvements, and helps keep communities in good standing with the NFIP.. The FEMA Manual P-758 is the defining document for SI/SD designations.

While flood panels may seem like an effective mitigation tool, they present significant safety and structural risks in a residential setting.

1. Life Safety Hazards

• Unlike commercial buildings, residential homes are occupied during storms, raising serious risks:
• Entrapment Risks: Could residents become trapped inside with no safe exit?
• Emergency Access: How would first responders enter a dry floodproofed home during an emergency?
• For these reasons, it is critical that any proposed installation of flood panels be reviewed in accordance with existing building and safety codes.
   

2. Structural Integrity Risks

• When flood panels are deployed during flood conditions, multiple forces – including hydrodynamic and hydrostatic pressures – act upon the structure, forces that would not exist without the panels, and could compromise a structure’s stability.
• Without professional engineering analysis, flood panels may increase the risk of building failure.
  • Only a Florida Registered Design Professional (Structural Engineer or Architect) can determine if a building can support the floodproofing product.
• 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.

Please read the appropriate supporting document(s) included at the bottom of this page for more information on compliance regarding the voluntary installation of flood panels.

Residential Buildings (Single-Family, Multi-Family Homes) Compliance:

• Any floodproofing or flood mitigation product that attaches to a building requires a permit.
• Dry floodproofing is not permitted on structures located in V and Coastal A flood zones.
  • City of Naples Forerunner website indicating flood zones.
• Wet Floodproofing (Flood Vents) Required:
  • Spaces below the Design Flood Elevation (DFE) (Base Flood Elevation + 1 ft) may only be used for parking, storage, and building access.
  • Flood vents are required to allow floodwater to enter and exit, reducing structural pressure.

Non-Residential Buildings (Commercial, Mixed-Use) Compliance:

• Dry Floodproofing allowed if:
  • The building can withstand flood loads while panels are in place.
  • An operational and maintenance plan is documented.
  • Sump pumps are incorporated to manage seepage.
• Compliance must be documented via a FEMA Dry Floodproofing Certificate before issuance of a Certificate of Occupancy.

Permit Enforcement

• Any alterations or additions to an existing building, particularly within the Special Flood Hazard Area (SFHA), must be reviewed and permitted by the City’s Building Department.
  • The installation of voluntary flood panels that attach to an existing building fall into this category.
• Unpermitted installations of flood panels have already been flagged by the Florida Department of Emergency Management (FDEM) and could result in heightened FEMA scrutiny.
• Other Florida jurisdictions have faced potential NFIP removal due to non-compliant floodproofing measures, leading to severe consequences for property values and insurance eligibility.
   

Misleading Claims by Floodproofing/Flood Mitigation Companies 

Some companies claim that their floodproofing products do not require permits and that they can protect buildings from a 100-year flood (1% annual chance flood event). However:

• Most post-FIRM (built after 1974) buildings cannot use these products as proposed.
• Buildings constructed in compliance with the building codes and Flood Insurance Rate Map (FIRM) requirements at the time of construction cannot be altered in a way that makes them non-compliant with current codes or FIRM regulations. Any modifications must adhere to all applicable floodplain management and building codes.
• Flood barriers or panels may not block emergency exits or place unsafe loads on structures.
• In some cases, limited protection may be possible for specific areas (e.g., elevators or mechanical rooms), but not for the entire lower levels.

The following General Development Review Guide is the minimum requirements that should be submitted as applicable. Use of this guide does not guarantee that plans will be accepted on the first submittal but will aid in reducing the number of resubmittals required due to the lack of information or conflicting information being provided. 

This information is also listed in a helpful guide at the bottom of this page for your convenience.

Circumferential Wall Systems: 

Flood wall systems that wrap around a building will need to meet the criteria below to be approved for installation. Plans must show the following to have approval in CityView for the Fire Department's review:

• Marked egress routes from the building must continue utilizing door openings in the wall system. Each egress route must have a corresponding door through the wall system without changing directions.
• Vehicle access must be maintained for Fire-Rescue vehicles. Please show the FD access road that will be utilized with measurements that meet the criteria of NFPA 1 Section 18.2.
• Access to the FDCs must be maintained and meet the criteria of NFPA 14.
• Panel installations covering or blocking marked egress doors or routes will NOT be approved in multifamily buildings.  Any designated and constructed exit must be maintained as an exit at all times. It must remain unobstructed and accessible in accordance with safety regulations.

Individual Units

Panel installations covering openings in individual units will need to meet the criteria below to be approved for installation. 

• Dwelling unit door openings may have panels installed if a secondary means of escape is met. Please show all means of egress throughout the unit.
• Secondary means of escape must comply with NFPA 101:31.2 and NFPA 101:24.2
  • Each dwelling unit must have at least one secondary means of escape, which can be a door or window that meets the following criteria:
    • The opening must be at least a minimum width of 20 inches and a minimum height of 24 inches, with a total square footage of 5.7 sq ft
    • The opening must be at or below 44 in from the floor. 

**In addition, doors may meet the requirements for secondary means of escape if the door opens inward or is a slider, and the panel installed is less than 44 inches tall. 

Elevators

If panels are placed out in front of the elevator doors, then the elevators must be shut down and the power must be secured. 

Floodproofing of non-residential buildings will be reviewed and approved in accordance with NFPA 5000 Chapter 39 and ASCE Section 24. 

The City is actively working with FEMA and FDEM to advocate for additional flood mitigation measures that align with FEMA and the 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. Property owners are encouraged to:

• Consult with licensed professionals before making modifications.
  • Ensure a Structural Engineer evaluates your building for floodproofing feasibility to the level of protection desired. If the building cannot support the flood loads of the 100-year, 1% design flood, it could be possible to propose protection to a lesser degree the building structure will support.
• Work with the City’s Building Department to ensure compliance and safety.
• If considering the voluntary installation of flood panels, consider the sump pumps for seepage that will occur.
• A maintenance and operations plan should be established for any installed floodproofing system.

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.

Planning and Zoning:

• City of Naples Land Development regulations will apply to all permanently installed elements (i.e., fence/wall height and location, etc.).
• Permanent elements cannot be located within an easement.
• Please provide information related to where and how the panels will be stored when not in use. Note: shed and outdoor storage regulations will apply, and storage is not allowed in existing parking spaces.
• Please provide information related to the duration for which the flood proofing will be employed (how many days ahead of and after a storm) and an operating plan including details of installation/take-down. 
   

Natural Resources:

• No panels for fencing can be placed in the dune system.
• Depending on the design of the flood panels, it may require additional City Coastal Construction Setback Line (CCSL) permitting and state Coastal Construction Control Line (CCCL) permitting.
• For more information on CCCL permitting, visit the Natural Resources webpage: Construction Seaward of the CCCL

Stormwater:

• Flood Panels must comply with the City of Naples Stormwater Ordinance 2021-14654.
• Flood Panels, or floodproofing, are a separate element to a property's stormwater management system.
• A property’s stormwater management system must maintain its design function when implementing flood panels.