INNOWAVE STUDIO · DATA AS OF OCTOBER 2026
The July 4, 2025 flood on the Guadalupe River, which killed at least 135 people, has become a siting rule. Texas now makes NFPA 1194, 2021 Edition binding on private campgrounds and RV parks and requires written plans for floods, evacuation orders and tornadoes. Lawmakers in North Carolina and Pennsylvania have moved related bills, and insurers and lenders now ask flood and wildfire questions before they quote.
Hazard screening has therefore moved to the front of the deal. Creekside or brushy land can still work. But sleeping units must stay out of the floodplain, guests need two ways out, and the insurance cost must come from a real quote.
This is a planning guide, not legal advice. Confirm each point with the authority having jurisdiction (AHJ), the floodplain administrator and counsel.
What Texas’s Camp Safety Act requires of RV parks
The statute
SB 1, the “Heaven’s 27 Camp Safety Act,” passed the House 120–4 on September 3, 2025 in the 89th Legislature’s second special session. It took effect when signed on September 5, 2025 and created Health and Safety Code Chapter 762. A “campground” there means a commercial property providing cabins to transient overnight guests, or an RV park as defined in Water Code §13.087.
The “floodplain” is FEMA’s 100-year floodplain, even where a letter of map amendment (LOMA) or fill-based revision removed the land. The core duties in Chapter 762 are:
Ladders (§762.002(a)(1)): a roof-access emergency ladder in each floodplain cabin.
Three plans (§762.002(a)(2)): evacuate floodplain areas on a flash flood or flood warning; evacuate on a county or city order for wildfire, hurricane or other disaster; shelter in place on a tornado warning or shelter order.
Fixed triggers (§762.002(b)): the flood plan runs when the National Weather Service (NWS) issues a warning for any area of the campground.
Filing (§762.002(c)–(d)): copies go to county emergency management, and to the city’s when the park is inside city limits; filed plans are confidential.
Fire standard (§762.003): private campgrounds must meet NFPA 1194, 2021 Edition, except Sections 1.1.1 and 5.1.1.1. Local fire, electrical, LP-gas, sanitation and environmental health rules may not be stricter.
Who approves the plan
The statute requires filing, not approval. The enrolled bill analysis names no approver for private campground plans, while youth camps submit plans to the Department of State Health Services (DSHS) for annual approval. At an October 2025 webinar, the Texas Association of Campground Owners (TACO) said the approving authority was still undefined. It urged parks to write plans anyway but to wait on ladders.
DSHS rules due by January 1, 2026 target youth camps. NFPA’s 2026 edition adds EV-charging provisions, but the statute names the 2021 edition. The preemption list in §762.003(c) does not mention zoning or floodplain permits, so local flood rules still apply. Youth camps face more: DSHS may not license one with a floodplain cabin unless, among limited exceptions, each cabin is at least 1,000 feet from a floodway.
Sirens, and bills elsewhere
SB 3 created a siren grant program, and SB 5 funded it with $50 million for a 30-county area, with backup power required. When the Hill Country flooded again in July 2026, Gov. Greg Abbott said he was told the sirens along the Guadalupe had worked, though one sounded after a brief delay.
Other states have proposals, not law:
North Carolina: S945, filed April 29, 2026, would require campgrounds with cabins or RV sites to install floodplain-cabin ladders and file emergency plans locally.
Pennsylvania: HB 2398 passed the House in fall 2026; it covers organized camps within 500 feet of a special flood hazard area.
Flood screening: maps, the 180-day rule and the 500-year line
Read the map, then read past it
FEMA’s special flood hazard area (SFHA) has a 1% annual chance of flooding and appears as zones A, AE and VE. Shaded X lies between the 1% and 0.2% (500-year) floods. Start at FEMA’s Map Service Center, then ask the floodplain administrator about preliminary maps and stricter local rules.
| Zone | Meaning | Cabins, park models, buildings | RV sites |
|---|---|---|---|
| Floodway | Main flood channel | Avoid; fill or buildings need a no-rise study | Avoid |
| VE | Coastal high hazard | Avoid | Under 180 days, highway-ready, or elevated to V-zone standards |
| A / AE | 1% annual chance | Elevate and anchor; Texas ladder and plan duties | Under 180 days, highway-ready, or elevated |
| Shaded X | Between 1% and 0.2% annual chance | 2027 IBC may require 500-year elevation | Generally allowed |
| Unshaded X | Above the 0.2% flood | Preferred | Preferred for annual sites |
The 180-day rule
Under 44 CFR 60.3(c)(14), an RV in zones A1-30, AH or AE has three options. It must stay fewer than 180 consecutive days, be fully licensed and ready for highway use, or meet manufactured-home elevation and anchoring rules. Section 60.3(e)(9) mirrors this for V zones. “Ready for highway use” means on wheels or jacks, with quick-disconnect utilities and no permanently attached additions. FEMA defines an RV as a single-chassis unit of 400 square feet or less.
This collides with the long-stay model. An attached deck, hard-piped utilities or a park model set on piers can void the exemption. Put annual sites and park models outside the SFHA.
Floodways
Section 60.3(d)(3) bars fill, new construction and other development in the regulatory floodway unless hydraulic analysis shows no rise in base flood levels.
The 500-year line in the 2027 codes
The 2027 IBC “expands flood hazard areas, including the 500-year floodplain,” and ties elevation to risk category. Its flood standard, ASCE 24-24, applies the mapped 500-year floodplain to Flood Design Classes 2 through 4. Only Class 1, the lowest-risk tier, stays at the 100-year line. The change survived 2026 balloting over homebuilder opposition. It binds only after local adoption, but a clubhouse designed now may be permitted under it.
Flash-flood terrain
On July 4, 2025, the Guadalupe at Hunt rose about 26 feet in 45 minutes. In the July 2026 flood, much of the damage came from tributary creeks. NWS warns that 12 inches of rushing water can carry away most cars, and over half of flood drownings involve driving into floodwater. Screen upstream drainage, every creek crossing on the access road, and warning lead time.
Using flood-fringe land
Where local rules allow, fringe land can hold open space, trails, dog parks, overflow parking, detention and short-stay RV sites. Keep sleeping units, bathhouses and electrical gear above the design flood elevation. Federal flood policies exclude septic systems, pools, fencing and plantings, so fringe damage is mostly self-insured.
Wildfire and the WUI: maps, moratoria, access and water
Codes and hazard maps
For wildland-urban interface (WUI) sites, the ICC’s International Wildland-Urban Interface Code (IWUIC) has a 2027 edition scheduled for September 2026 publication. NFPA 1140, Standard for Wildland Fire Protection, covers rural, suburban and WUI areas. Neither applies until adopted.
State maps set the trigger. California’s Fire Hazard Severity Zones rate land Moderate, High or Very High. State-responsibility maps took effect April 1, 2024, and local maps followed in early 2025. They measure hazard, not risk, so mitigation does not change the zone. California requires 100 feet of defensible space under Public Resources Code 4291, and CAL FIRE calls the 0–5-foot zone the most important. In a campground, that clearance has to be planned around each cabin, bathhouse and pad.
Colorado’s SB23-166, signed May 12, 2023, created a Wildfire Resiliency Code Board and requires local governments with WUI areas to adopt codes meeting its minimums. The 2025 state code was established on July 1, 2025. In Texas, Chapter 762 already requires a wildfire evacuation plan, and brokers report wildfire concern even outside high-risk areas.
Moratoria
Lake County, Colorado adopted Resolution 2026-06 on February 17, 2026. It paused new applications for RV parks, campgrounds, lodges and event sites for six months while staff rewrite old code and hazard standards. The Willow fire started June 28, 2026 and forced evacuations west of Leadville. On July 20, 2026, the county extended the pause by 60 days, citing a declared disaster emergency.
Access, egress and water
Egress is the hardest flaw to fix after purchase. In the 2020 Creek Fire, the California National Guard airlifted about 264 people from the Mammoth Pool area in six flights. Design points:
Two exits: two access points onto different roads, ideally leading in different directions. A gated, emergency-only second exit is a common compromise; confirm the fire marshal accepts it.
Apparatus roads: summaries of NFPA 1194 cite 20-foot fire lanes and turnarounds on dead ends over 150 feet (state site-plan matrix). Confirm against the adopted text.
Water: carriers ask whether hydrants are within 1,000 feet and a fire station within five miles. Rural sites need storage tanks or draft points sized with the fire marshal.
Fuel management: a mowed or irrigated perimeter, noncombustible ground cover around cabins, and red-flag rules for campfires.
Designing the evacuation plan
Warnings: phones are not enough
Texas ties the flood plan to any NWS flash flood or flood warning, but phones may stay silent. NWS sends Wireless Emergency Alerts for flash flood warnings only when the damage threat is “considerable” or “catastrophic”; tornado warnings carry no such condition. On July 3–4, 2025, the first flash flood warning came at 11:41 p.m. The first alert-triggering “considerable” warning followed at 1:14 a.m., and a flash flood emergency for Hunt and Ingram at 4:03 a.m.
Layer the system:
Weather radio: NOAA Weather Radio broadcasts warnings 24 hours a day from more than 1,000 transmitters. Put alarmed receivers in the office and staff housing.
Direct feeds: route NWS alerts for the park’s location to staff phones and guest text lists.
Outdoor voice: a siren or public address (PA) system with backup power. Texas youth camps need a PA that works without internet, plus redundant broadband, a useful benchmark for parks.
Public sirens: in 2025, Comfort, which had NWS-linked sirens, reported no casualties.
Triggers and actions
| Trigger | Action | Texas status |
|---|---|---|
| Flash flood watch or red flag warning | Alert guests, put staff on standby, stage vehicles | Best practice |
| NWS flash flood or flood warning for park area | Evacuate floodplain sites | Required, §762.002(b) |
| County or city evacuation order | Evacuate the park | Plan required, §762.002(a)(2) |
| Tornado warning | Shelter in place | Required, §762.002(b) |
Routes, rally points and signage
Routes should climb away from water and avoid low-water crossings. Rally points belong above the 500-year line, with room to stage vehicles and take a head count. Assume many guests cannot hitch a trailer in time; move people first and leave rigs if needed. Youth camps must post routes in each cabin and light them at night, and park cabins and bathhouses should do the same. Use large, reflective site numbers, and include the numbered site map in the county filing.
Training, guests and records
Staff: train each season and log it; youth camps must provide annual training and keep written records. Run at least one drill after dark.
Check-in: hand out a one-page plan summary, disclose floodplain sites, enroll guests in text alerts, and record party size, pets, mobility needs and guests without vehicles.
Records: keep the date each plan went to county emergency management, plus annual updates, drill logs, ladder checks and alert logs. TACO notes that NFPA 1194 also expects a written plan submitted to the local authority for review.
Insurance, lending and a pre-acquisition checklist
A softer market that skips campgrounds
The CIAB Q1 2026 survey found average commercial premiums down 1.2%, the first decline since Q3 2017, with property down 5.8%. Small accounts still rose 1.1%. Campground specialists are more cautious: North Star Brokerage expects the hard market to persist in wildfire-prone areas. Leavitt cites wildfire, wind, hail and flood in Texas and Louisiana, priced across whole regions.
The flood insurance gap
The National Flood Insurance Program (NFIP) caps nonresidential policies at $500,000 for the building and $500,000 for contents. It excludes anything outside the insured structure, vehicles and lost business income. Most RV park value sits in roads, utilities and pads, and guests’ rigs are not insured as buildings. Private flood and business-interruption cover cost extra. After Hurricane Helene, all 38 Blue Ridge member parks of a Carolinas association were damaged and 16 closed.
Lenders must require flood insurance on federally backed loans in the SFHA, and NFIP authority currently runs only to December 11, 2026. A lapse would halt new policies and could delay closings.
Lender diligence
Banks typically lend 65% to 75% of value at 1.25x debt service coverage. Newmark’s insurance line of 2.7% of revenue predates the hard market, and MMCG Invest now puts a bindable quote and a stressed insurance line in every study. Expect these questions:
How many sites and buildings sit in the SFHA, the floodway and the 500-year floodplain?
Does the access road cross a creek, is there a second exit, and is the park in a mapped wildfire zone?
Has the evacuation plan been filed, and when?
What are the bindable property, liability and flood quotes?
Pre-acquisition siting checklist
Order a flood zone determination; check the floodway, preliminary maps and past map revisions.
Walk every drainage on and above the site, and drive the access road after heavy rain.
Plot the 500-year line; put buildings above it and annual sites and park models outside the SFHA.
Check state wildfire maps and the local WUI code, then confirm two exits, access and water with the fire marshal.
Check for moratoria and pending code rewrites.
Draft the evacuation plan at concept stage and review it with county emergency management.
Get bindable quotes before earnest money goes hard, then stress net operating income with a higher insurance line.
For state-by-state site-plan rules, see this 50-state regulatory matrix. In InnoWave Studio’s planning work, hazard lines go on the base map before the first site is drawn. The cheapest fix is the one made before closing.
Sources
Bill Analysis, S.B. 1, 89th Legislature, 2nd Called Session (Enrolled)
DSHS: Updates on Implementation of New Youth Camp Legislation, October 10, 2025
Texas Tribune: Texas camp safety legislation (September 3, 2025)
Woodall’s: Texas Is 1st State to Adopt NFPA 1194 as State Building Std.
Woodall’s: TACO Webinar Focuses on Impact of New NFPA 1194 Law
Woodall’s: Q&A: TACO on Emergency Planning, Passing NFPA 1194
NFPA 1194: Standard for Recreational Vehicle Parks and Campgrounds, 2026 Edition
Texas Water Development Board: SB 3 Outdoor Warning Siren Program briefing
Lower Bucks Source: Davis Bill to Keep Organized Campers Safe From Flood Risks Passes House
eCFR: 44 CFR 60.3, Flood plain management criteria for flood-prone areas
ASFPM: ASCE 24-24 to be Included in the 2027 Edition of the International Building Codes
Blue Collar Commercial Group: Buying an RV Park in the Texas Hill Country (2026 Guide)
CAL FIRE Office of the State Fire Marshal: Fire Hazard Severity Zones
Colorado General Assembly: SB23-166, Wildfire Resiliency Code Board
Citizen Portal: Lake County extends temporary moratorium for 60 days
North Star Brokerage: RV park and campground insurance guide (July 2025)
Leavitt Recreation & Hospitality: The Real Reason Your RV Park Premiums Keep Going Up
National Association of Realtors: FAQ, National Flood Insurance Program Expires December 11, 2026