Prevent new fvwm windows from covering gnome panel

You can tell fvwm to put windows where they will cover as few existing pixels as possible with:
Style * MinOverlapPlacement

I like to use fvwm as my wm for gnome. To make the gnome panel act more like it does in gnome:
Style "*panel" NotTitle, !Borders, NoHandles, Icon, Sticky, WindowListSkip, CirculateSkip
(this may be overkill, but it works for me)

To prevent auto-placed windows from covering the gnome panel (or similar windows marked as Icon or with EWMH Struts enabled):
Style * MinOverlapPlacementPenalties 1 5 9999999 1 0.05 9999999
Note: the small values are based on the defaults, according to the man page. The large number was chosen to be larger than any (sane) resolution you might use (ie: 1600x1200=1920000 or 2*1280x1024=2621440). This obsene penalty for Icon or Struts windows ensures they won't be covered by new windows.