Comments:  There is confusion between “design flood elevation” (which is the water elevation) and the “elevation required in Sec. R322.3.2” which is where the minimum elevation of the lowest horizontal structural member relative to the water is specified.  FEMA deliberately changed to “required elevation” in the 2018 IRC (and Virginia picked up those changes in its 2018 edition).  FEMA previously comments to use phrasing that matches the IRC.   Citing “design flood” could mean a tank is lower than the dwelling it serves.  

REQUEST REVISION TO DELETE shown without underline for clarity. Remove the words “design flood” as shown with bold strike-through.

R322.3.10 Tanks. Underground tanks are prohibited in Coastal A Zones or Coastal High Hazard Areas. Aboveground tanks shall be installed at or above the design flood elevation required in Section R322.3.2. Where elevated on platforms, the platforms shall be cantilevered from or knee braced to the building or shall be supported on foundations that conform to the requirements of Section R322.3.