St. Augustine Planning and Building staff and members of the Planning and Zoning Board spent a marathon special meeting on Feb. 19 discussing how to limit the use of fill in flood-prone areas, reduce neighborhood flood impacts and pursue flood insurance discounts under the Community Rating System.

The discussion centered on short-term, implementable steps staff called a “do no harm” approach — a two-track process that would give property owners clear, administratively approvable standards if they follow prescribed practices, while preserving an option for unique proposals to receive full public review by the board. "If you're not going to do exactly what CRS gives you points for in prohibiting fill, then you don't want to put this in the floodplain management ordinance," said Buddy Schallen, the city's building official and floodplain manager, urging caution about where new rules are placed because FDEM and FEMA review changes to the floodplain ordinance.

Why it matters: staff described multiple neighborhood-scale consequences when lots are heavily raised or enclosed with retaining walls — reduced on-site flood storage, redirected runoff to adjacent streets or properties, and higher finished-floor elevations that can push flood risk onto neighbors. Those physical changes also affect the city's standing in the federal Community Rating System (CRS), which reduces National Flood Insurance Program premiums for residents based on local activities. "FEMA is a big fan of no fill," Schallen said, noting the program assigns substantial points to prohibiting fill and to freeboard requirements.

Most important points and staff proposals

- Immediate priorities: staff proposed interim clarifications to existing code language and administrative standards to give applicants predictable options that minimize impacts to adjacent properties. The PZB asked staff to run focused stakeholder workshops and return with draft code language for review.

- Two-track approach: 1) standardized, administratively approvable designs and thresholds (faster approvals if applicants meet the criteria); 2) a public-hearing track for novel or exceptional proposals that require waivers or variances.

- High-impact regulatory options discussed included prohibiting fill in special flood hazard areas; banning certain building types (slab-on-grade, backfill stem walls) in vulnerable zones; increasing freeboard beyond the city’s 1-foot minimum; and applying coastal/"V-zone" construction standards where wave action is expected.

- Moderate and low-impact measures included limiting the amount of lot fill (for example, to 1–2 feet above existing grade), requiring "no-adverse-impact" certifications by a licensed engineer, and extending some flood protections into the 0.2% annual chance floodplain (Zone X) for new construction and substantial improvements.

CRS, insurance and federal programs

Staff briefed the board on the community rating system and flood-relief grant programs. St. Augustine currently reports 3,025 CRS points (class 5), producing about a 25% discount on NFIP flood insurance for structures that qualify. Some of the numbers staff cited:

- A 1-foot freeboard currently in the city gets CRS credit; raising freeboard could add substantial CRS points.
- Prohibiting fill in certain ways can add 100–280 CRS points depending on the scope and language used in ordinance.
- The state grant to prepare a watershed management plan is typically 75% state / 25% local match; the city plans to pursue that funding again.

On federally funded mitigation, Amy Skinner, director of the Planning and Building Department, updated the board on the Flood Mitigation Assistance (FMA) program. Properties from North and South Davis Shores were part of the FY2022 application cycle and remain under review by the state and FEMA; additional FY2023/FY2024 cycles were in process. "We're leveraging as much grant dollars as we can to help our efforts because these are really expensive," Skinner said.

Substantial damage rules and enforcement

Staff explained how substantial-damage and substantial-improvement rules work: when repair costs equal or exceed 50% of a structure's pre-damage market value, the owner must bring the structure into compliance with floodplain regulations (typically by elevating or demolishing and rebuilding). Buddy Schallen described the appeals options (elevation certificate, independent appraisal of pre-damage value, or contractor bids) and stressed that the building official is legally required to make substantial-damage determinations. The staff noted privacy constraints: lists of substantially damaged properties are protected under state privacy laws and cannot be released by permit staff.

Public comments and equity concerns

Several residents and contractors spoke during public comment. Points raised included: the practical challenges and odor/pests associated with elevating homes on pilings in tidal areas; the high cost of flood insurance and recent rate increases tied to FEMA's Risk Rating 2.0; the need to avoid policies that would force long-time residents to sell at depressed values; and a request for a moratorium or pause on rapid development until infrastructure and runoff impacts can be addressed.

Board direction and next steps

The Planning and Zoning Board and staff agreed on an expedited schedule: staff will hold stakeholder workshops (targeted for March) to gather contractor, resident and builder input, then present draft ordinance language to the board for discussion in April. The board expressed a goal to have final recommended language ready for a vote by May. "If we can have some draft amendment to our fill language to correct some of the looseness that we find is not quite specific enough... by May, we're voting on it," said a PZB member.

Staff reiterated that some measures (for example, prohibiting fill citywide in the floodplain) would need state review through FDEM and FEMA and therefore take longer to adopt; for that reason staff recommended interim, locally administered solutions where possible. Over the longer term, staff noted ongoing related studies: a city vulnerability assessment and adaptation plan, a resilient shoreline project (consultant-supported), and a comprehensive back-bay study with the U.S. Army Corps of Engineers.

What the meeting did not do

No new ordinance was adopted at the meeting and there were no recorded formal votes on regulatory changes. The board and staff instead agreed on a process: workshops, draft code clarifications for administratively approvable options, public input and a target to bring proposed code changes back for board action in the spring.

Ending

Planning staff said they will post materials online, schedule the community workshops and circulate draft language to stakeholders and the board prior to the April meeting. The board asked staff to prioritize clarity so that routine, lower-risk projects can be resolved administratively while proposals that could affect neighbors or shorelines receive full public review.