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.    

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

R322.3.6 Enclosed areas below required elevation. Enclosed areas lower than the design flood elevation required in Section R322.3.2 are prohibited in Coastal A Zones and Coastal High Hazard Areas.