Federal regulators repeatedly granted appeals to remove Camp Mystic’s buildings from their 100-year flood map, loosening oversight as the camp operated and expanded in a dangerous flood plain in the years before rushing waters swept away children and counselors, a review by The Associated Press found.

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.

This story was originally featured on Fortune.com

© Eli Hartman—AP Photo

Texas inspectors signed off on Camp Mystic’s emergency planning just two days before catastrophic flooding killed more than two dozen people at the all-girls Christian summer camp, most of them children.

The Department of State Health Services released records Tuesday showing the camp complied with a host of state regulations regarding “procedures to be implemented in case of a disaster.” Among them: instructing campers what to do if they need to evacuate and assigning specific duties to each staff member and counselor.

Five years of inspection reports released to The Associated Press do not offer any details of those plans at Mystic, raising new questions about the camp’s preparedness ahead of the torrential July 4 rainfall in flood-prone Texas Hill Country.

The National Weather Service had issued a flood watch for the area July 3 at 1:18 p.m. That danger prompted at least one of the roughly 18 camps along the Guadalupe River to move dozens of campers to higher ground.

The uncertainty about what happened at Mystic comes as local officials have repeatedly dodged questions about who was monitoring the weather and what measures were taken ahead of the flooding.

Tragedy falls on the historic camp

Camp Mystic, established in 1926, did not evacuate and was especially hit hard when the river rose from 14 feet (4.2 meters) to 29.5 feet (9 meters) within 60 minutes in the early morning hours. Flooding on that stretch of the Guadalupe starts at about 10 feet (3 meters).

A wall of water overwhelmed people in cabins, tents and trailers along the river’s edge. Some survivors were found clinging to trees.

At least 27 campers and counselors died during the floods, and officials said Tuesday that five campers and one counselor have still not been found. Among the dead was Richard “Dick” Eastland, the camp’s beloved director described by campers as a father figure.

Charlotte Lauten, 19, spent nine summers at Camp Mystic, mostly recently in 2023. She said she didn’t recall ever receiving instructions as a camper on what do in the case of a weather emergency.

“I do know that the counselors go through orientation training for a week before camp starts,” she said. “They do brief them on all those types of things.”

One thing that likely hindered the girls’ ability to escape was how dark it would have been, Lauten said. Campers don’t have access to their phones while at camp, she said, adding they wouldn’t have cell service anyway because of the remote location.

“This is the middle of nowhere and they didn’t have power,” she said. “It would have been pitch black, like could not see 5 feet in front of you type of darkness. I’ve never seen stars like there because there’s just no light.”

Inspections found no issues

The state inspected Camp Mystic on July 2, the same day the Texas Division of Emergency Management activated emergency response resources ahead of the anticipated flooding.

The inspection found no deficiencies or violations at the camp in a long list of health and safety criteria. The camp had 557 campers and more than 100 staffers at the time between its Guadalupe and Cypress Lake locations.

The disaster plans are required to be posted in all camp buildings but aren’t filed with the state, said Lara Anton, a spokesperson for the Texas Department of State Health Services.

“We do not have them,” Anton said in an email. “You’d have to get it from the camp.”

Camp Mystic did not respond to requests for comment on its emergency plan. In a statement on its website, the camp said it has been “in communication with local and state authorities who are tirelessly deploying extensive resources to search for our missing girls.”

Camps are responsible for developing their own emergency plan. Inspectors evaluate the plans to ensure they meet several state requirements, including procedures for evacuation.

“The inspector checked that they had plans posted for those elements in every building,” Anton said, “and that they had trained staff and volunteers on what to do.”

Camp Mystic is licensed by the state and a member of the Camping Association for Mutual Progress, which says its goal is to “raise health and safety standards” for summer camps. Leaders of that association didn’t return messages.

The American Camp Association said Tuesday that Camp Mystic is not accredited with that organization, whose standards focus on safety and risk management. Spokesperson Lauren McMillin declined to say whether the camp previously had been accredited with the association, which describes itself as “the only nationwide accrediting organization for all year-round and summer camps.”

Authorities review rain and river gauges

One rain gauge about a mile (1.6 kilometers) from Camp Mystic recorded 9.5 inches (24 centimeters) of precipitation July 4, according to Guadalupe-Blanco River Authority data. Another of the agency’s gauges — further south and to the west — recorded 12.2 inches (31 centimeters) of precipitation. The authority told the AP that a review of its equipment found both were functioning during the flood event.

However, at least four United States Geological Survey gauges along the Guadalupe River experienced some level of failure July 4.

The gauges, located near Hunt and Kerrville, stopped collecting both river levels and the flow rate of water in the early morning hours of July 4.

One gauge, about 5 miles (8 kilometers) northeast of Camp Mystic, recorded a level of 29.5 feet (9 meters) at 4:35 a.m., according to National Oceanic and Atmospheric Administration data. It was the last recorded river level from the instrumentation until a USGS hydrologist installed a temporary gauge. At the time, the hydrologist measured the high water mark at 37.52 feet (11.44 meters).

At that location, a river level of 32 feet (9.75 meters) could lead to “disastrous life-threatening flooding,” which could cover the roads of the lowest camps and resorts, according to NOAA.

This story was originally featured on Fortune.com

© Julio Cortez—AP