The Federal Emergency Management Agency included the prestigious girls’ summer camp in a “Special Flood Hazard Area” in its National Flood Insurance map for Kerr County in 2011, which means it was required to have flood insurance and faced tighter regulation on any future construction projects.

That designation means an area is likely to be inundated during a 100-year flood — one severe enough that it only has a 1% chance of happening in any given year.

Located in a low-lying area along the Guadalupe River in a region known as flash flood alley, Camp Mystic lost at least 27 campers and counselors and longtime owner Dick Eastland when historic floodwaters tore through its property before dawn on July 4.

The flood was far more severe than the 100-year event envisioned by FEMA, experts said, and moved so quickly in the middle of the night that it caught many off guard in a county that lacked a warning system.

But Syracuse University associate professor Sarah Pralle, who has extensively studied FEMA’s flood map determinations, said it was “particularly disturbing” that a camp in charge of the safety of so many young people would receive exemptions from basic flood regulation.

“It’s a mystery to me why they weren’t taking proactive steps to move structures away from the risk, let alone challenging what seems like a very reasonable map that shows these structures were in the 100-year flood zone,” she said.

Camp Mystic didn’t respond to emails seeking comment and calls to it rang unanswered. The camp has called the flood an “unimaginable tragedy” and added in a statement Thursday that it had restored power for the purpose of communicating with its supporters.

FEMA exempted buildings at old and new sites

In response to an appeal, FEMA in 2013 amended the county’s flood map to remove 15 of the camp’s buildings from the hazard area. Records show that those buildings were part of the 99-year-old Camp Mystic Guadalupe, which was devastated by last week’s flood.

After further appeals, FEMA removed 15 more Camp Mystic structures in 2019 and 2020 from the designation. Those buildings were located on nearby Camp Mystic Cypress Lake, a sister site that opened to campers in 2020 as part of a major expansion and suffered less damage in the flood.

Campers have said the cabins at Cypress Lake withstood significant damage, but those nicknamed “the flats” at the Guadalupe River camp were inundated.

Experts say Camp Mystic’s requests to amend the FEMA map could have been an attempt to avoid the requirement to carry flood insurance, to lower the camp’s insurance premiums or to pave the way for renovating or adding new structures under less costly regulations.

Pralle said the appeals were not surprising because communities and property owners have used them successfully to shield specific properties from regulation.

Analysis shows flood risks at both camp sites

Regardless of FEMA’s determinations, the risk was obvious.

At least 12 structures at Camp Mystic Guadalupe were fully within FEMA’s 100-year flood plain, and a few more were partially in that zone, according to an AP analysis of data provided by First Street, a data science company that specializes in modeling climate risk.

Jeremy Porter, the head of climate implications at First Street, said FEMA’s flood insurance map underestimates flood risks. That’s because it fails to take into account the effects of heavy precipitation on smaller waterways such as streams and creeks. First Street’s model puts nearly all of Camp Mystic Guadalupe at risk during a 100-year flood.

The buildings at the newer Cypress Lake site are farther from the south fork of the flood-prone river but adjacent to Cypress Creek. FEMA’s flood plain doesn’t consider the small waterway a risk.

However, First Street’s model, which takes into account heavy rain and runoff reaching the creek, shows that the majority of the Cypress Lake site lies within an area that is at risk during a 100-year flood.

In a statement, FEMA downplayed the significance of the flood map amendments.

“Flood maps are snapshots in time designed to show minimum standards for floodplain management and the highest risk areas for flood insurance,” the agency wrote. “They are not predictions of where it will flood, and they don’t show where it has flooded before.”

An ‘arduous’ appeal process can help property owners

Property owners challenging FEMA’s map designations hire engineers to conduct detailed studies to show where they believe the 100-year flood plain should actually be drawn. That is a “pretty arduous process” that can lead to more accurate maps while making it easier for future construction, said Chris Steubing, executive director of the Texas Floodplain Management Association, an industry group that represents floodplain managers.

Pralle, who reviewed the amendments for AP, noted that some of the exempted properties were within 2 feet (0.6 meters) of FEMA’s flood plain by the camp’s revised calculations, which she said left almost no margin for error. She said her research shows that FEMA approves about 90% of map amendment requests, and the process may favor the wealthy and well-connected.

A study she published in 2021 with researcher Devin Lea analyzed more than 20,000 buildings that had been removed from FEMA flood maps. It found that the amendments occurred more often in places where property values were higher, more white people lived and buildings were newer.

Camp expanded after ‘tremendous success’

FEMA had cautioned in its amendments that other parts of Camp Mystic remained on the flood map, and that “any future construction or substantial improvement” would be subject to flood plain management regulations.

County officials not only allowed the camp to keep operating, but to dramatically expand.

Considered Texas royalty after decades of taking care of the daughters of elite families, Camp Mystic owners Dick and Tweety Eastland cited the “tremendous success” of their original camp in explaining the need for a second site nearby.

The expansion included new cabins and a dining hall, chapel, archery range and more. The camp had 557 campers and more than 100 staffers between its two locations when a state licensing agency conducted an inspection on July 2, two days before the tragedy, records show.

FEMA referred questions about the expansion to local officials, who didn’t reply to messages seeking comment.

Steubing, a longtime municipal engineer in Texas, said the rain and flooding that hit Kerr County in a matter of hours were so much more intense than anything in its history that it’s hard to call the flood plain management a failure.

Local officials likely believed they were following existing regulations when they allowed the camp to keep growing, but “then Mother Nature set a new standard,” he said.

“You could have built things 2 feet (0.6 meters) higher, 3 feet (0.9 meters) higher, and they still might have gotten taken down,” he said.