# Wildfire Risk By Market: The County Average Is a Lie | Part 1 - August 7th, 2026 ## What is left Fire season is here. The National Preparedness Level is at 5, the highest possible. Ninety-two large fires are burning across the country. And the federal government’s own tract-level risk data says the places where people are building carry wildfire loss rates that exceed those of the worst hurricane markets in America. This two-part series, written by Principal Architect [Patrick Chopson](https://cove.inc/executive-bios-patrick-chopson/), AIA, uses FEMA’s National Risk Index to examine wildfire exposure across five counties in three states. The finding that anchors the series: wildfire risk hides inside county averages. Los Angeles County’s wildfire rate looks negligible at $91 per million dollars of building value. The worst tract in the county carries a rate of $7,373, more than double New Orleans’ hurricane rate. The ratio between the two is 81 to 1. **Part 1** establishes the data, the insurance crisis, and the code gap. [Part 2](https://cove.inc/blog/wildfire-resilient-design-by-market-part-2) goes market by market and ranks the design responses. --- ### What is left The first thing I noticed in Pacific Palisades was the road. There were shallow depressions in the asphalt, dozens of them, one after another along the curb line. That is where the cars were. Hundreds of them burned in place, and each one melted a bowl into the street. The houses were gone, but the road remembered the cars. Then the foundations. Slabs swept to bare concrete. On the few walls still standing, the outlines of furniture were scorched into the plaster like photographic negatives. A sofa. A dresser. Somebody’s bookshelf, rendered as a shadow. And then the things that made no sense at all. A basketball hoop over a driveway with nothing behind it, backboard intact, net gone. A native oak in a front yard, scorched and alive, in the middle of a block of nothing. A rose bush. A wood fence, unburned, running along a lot where every single structure had been erased. Those survivors are not miracles. They are data. Here is the part that should change how architects work: the houses I looked at did not burn from the outside in. They burned from the inside out. Embers found openings. Windows left open on an unseasonably warm January afternoon, or glass that failed under radiant load and then admitted embers into a bedroom. Open eaves with exposed rafter tails that funneled hot gas and firebrands straight into the attic. And clay and concrete tile roofs. Most people assume they are fireproof. They are noncombustible, which is a different thing entirely. The tile does not burn. The gaps beneath it at the eave and the rake are ember highways to the underlayment, the battens, and the sheathing. Without bird stops or mortar closures, and without a fire-rated underlayment, a barrel tile roof is a beautiful colander. The fire did not defeat those houses. The details did. Every one of those details is a line item somebody decided not to spend money on, or, more often, never got asked about. ### The second fire There is a second fire that follows the first one, and nobody photographs it, because it is made of permits. The Palisades Fire destroyed over 6,800 structures. Twelve people died in the Palisades Fire itself. Across both the Palisades and Eaton fires, the official death count was 31. An excess-mortality study [published in JAMA](https://jamanetwork.com/journals/jama/fullarticle/2837351) in August 2025 attributed as many as 440 deaths to the January 2025 fires in the four weeks following ignition, roughly 14 times the official toll. [Redfin estimated](https://www.redfin.com/news/press-releases/redfin-reports-over-50-billion-worth-of-los-angeles-homes-were-impacted-by-the-january-wildfires/) $51.7 billion worth of residential property was impacted. Eighteen months later, in mid-July 2026, here is where the rebuild stood: [1,628 building permits submitted. 1,088 issued. 905 homes under construction. Twenty-seven homes with certificates of occupancy.](https://palipost.com/interactive-pali-rebuild-map-shows-27-new-homes-completed/) Twenty-seven out of over 6,800. Four-tenths of one percent. Now hold that next to the number that actually governs whether a community survives: most homeowners policies cap Additional Living Expenses at 24 months. That is the money that pays your rent while your house does not exist. So at month 18, with 0.4 percent of the neighborhood habitable, the clock on temporary housing for everybody has six months left. The insurance settlements were not going to close that gap either. [PaliBuilds](https://labusinessjournal.com/featured/tool-identifies-insurance-payout-estimate-gaps/) studied 37 Palisades claims against actual contractor budgets. Every single one fell short. The median gap was $1.4 million, about $559 per square foot. Carrier estimates averaged roughly $462 per square foot, which nets out to $350 to $400 of actual hard construction cost, against local builder budgets running as high as $1,065. Meanwhile the land under those lots lost 35 to 40 percent of its value, and construction pricing went up, because 800 houses trying to hire the same framing crew in the same ZIP code is a demand shock. So run the arithmetic a family actually runs. Construction cost up. Land value down. A million-dollar coverage gap. A 24-month housing allowance against a four-year rebuild. Sixteen separate agency clearances on a hillside lot, by one contractor’s count. You sell. [Redfin found](https://www.redfin.com/news/los-angeles-wildfires-anniversary/) investors bought 40.3 percent of lot sales in 90272 in the third quarter of 2025 alone. Later reporting put developer acquisition of fire-damaged property across the Palisades and Altadena near 45 percent. Or you hold, because you were underinsured or uninsured, and you pay taxes on a vacant lot you cannot afford to build on and will not sell at a 40 percent discount. Or you rebuild, and you spend four years inside the permitting system to do it. There is also a fourth case nobody plans for. You were one of the lucky ones. Your house survived. Some blocks have exactly one standing home on them, and that homeowner is enduring machinery essentially around the clock. Los Angeles County is currently running a public survey on extended construction hours, which tells you everything about who the recovery is optimized for. And here is how a community actually dies, slowly and on paper. A family signs a twelve-month lease in Santa Monica, then renews it. The kid starts at a new school and makes friends there. The commute from the rental is better. The dog learns a different park. At month 30, when the permit finally clears, the family that fully intended to rebuild does not. Of the more than 22,500 homes destroyed in five of California’s most destructive fires between 2017 and 2020, [fewer than 40 percent had been rebuilt](https://calmatters.org/housing/2026/01/la-fires-rebuild-permitting/) by 2025. What comes back is not what left. Seventy-four apartment buildings containing 870 units were demolished across the two January fires, roughly 70 percent of those units in the Palisades. Most had fewer than ten units. Most were built in the 1950s. Most were rent-controlled. That housing type is simply gone, because nobody is building a 1953 eight-unit walkup on a $1.6 million lot in 2026. The single-family fabric goes the same way, just more politely. Los Angeles is running a Standard Plan Pilot to accelerate permitting, and I understand exactly why: right now speed is mercy. But the end state of a few pre-approved plan sets stamped across a coastal canyon community is a subdivision. The stucco box in the Palisades and the stucco box in Chatsworth become the same building with a different view. Ocean and mountains on one side, tract-home massing on the other. A wildfire takes the buildings. The rebuild takes the place. This is why I will not treat fire-resilient design as a sustainability line item or a nice-to-have upgrade, and it has nothing to do with sentiment. The most powerful heritage preservation tools available to an architect in a wildfire market are a properly closed Class A roof assembly, a listed ember-resistant vent, a hardened first five feet, and 30 feet of separation between structures. A building that survives is a neighbor who stays. A neighbor who stays is a block that still has a culture in 2032. ### The county average is a lie We pulled tract-level data from [FEMA’s National Risk Index](https://www.fema.gov/about/openfema/data-sets/national-risk-index-data) (v1.20, released December 2025) for five counties across three states: Los Angeles County and San Diego County in California, El Paso County (Colorado Springs) and Boulder County in Colorado, and Jackson County (Medford and Ashland) in Oregon. That is 3,528 census tracts. Sorted by county-level wildfire expected annual loss rate, San Diego leads. Jackson County, Oregon, a market of 223,000 people that almost never appears in national wildfire coverage, is second. El Paso County, where Colorado Springs is expanding straight into the wildland-urban interface, is third. *Source: FEMA National Risk Index v1.20 (December 2025)* And Los Angeles County is dead last. Ninety-one dollars per million dollars of building value. Two percent of total expected annual loss. By the county average, LA barely registers as a wildfire market. That number is a lie, and it is a specific, mechanical kind of lie worth understanding, because the same lie is embedded in most of the risk screens that lenders, insurers, and developers actually use. Los Angeles County has 2,492 census tracts with more than $10 million in building value. Of those, 1,782, or 72 percent, have zero wildfire expected annual loss. Downtown, the Westside flats, the South Bay: concrete, asphalt, and distance from vegetated fuel. No measurable exposure at all. Average that against the canyons and you get $91. But the roughly 3 percent of tracts where wildfire actually concentrates carry loss rates that make the worst hurricane markets in America look tame. The worst wildfire tract in LA County runs an expected annual loss rate of $7,373 per million dollars of building value. For reference, New Orleans’ county-wide hurricane loss rate, the highest number in our entire [hurricane resilience series](https://cove.inc/blog/hurricane-risk-by-market-fema-data-2026/), is $3,416. The worst tract in LA is more than double that. San Diego’s worst tract is $16,667 per million. Nearly five times the New Orleans rate. In LA County, the worst tract carries 81 times the county average. That single ratio is the whole story of wildfire in a major metro. The risk does not exist for most of the county, and it is catastrophic where it does. Any analysis that stops at the county line is wrong in the direction that gets buildings built badly. *Source: FEMA National Risk Index v1.20 (December 2025). Tracts with >$10M building value.* ### The tracts that burned were already on the list This is the part that should be uncomfortable for the profession. The tracts that burned in the January 2025 Palisades Fire were already rated Very High wildfire risk in this dataset, with loss rates among the highest in Los Angeles County. The NRI’s wildfire model runs on the USDA Forest Service’s FSim burn probability system, computed from landscape and fuel conditions that existed before the fire. Nothing about that outcome required hindsight. The same model identifies every other high-risk tract in these five markets today. Right now. For free. And the ignition itself was not an act of God. The current understanding is that a fire started on New Year’s Day, was believed extinguished, and rekindled under wind on January 7. A holdover in a Very High Fire Hazard Severity Zone during a Santa Ana event is not a surprise. It is a Tuesday. So the only real question left is whether the next building on one of those tracts gets designed to match what the federal government already published about the site. ### Wildfire is never the only hazard In our hurricane series, wind and surge dominated everything: 73 percent of total expected annual loss in New Orleans, 68 percent in [Savannah](https://cove.inc/blog/savannah-hurricane-building-code/). Wildfire does not behave that way, even in wildfire country. Inland flooding is the top hazard in four of these five counties. Earthquake dominates LA County at 60 percent of total EAL. Wildfire is the second-largest hazard in San Diego and El Paso. In Boulder it essentially ties with avalanche for second. In LA it is about 2 percent of the county total. That is not an argument for deprioritizing wildfire. It is an argument against single-hazard design, which is most of what gets built. A noncombustible wall assembly that is not seismically detailed fails in the earthquake. A hardened envelope on a slab that floods is a hardened envelope on a slab that floods. The building has to perform against everything the site carries, including the hazards that never made the news. *Source: FEMA National Risk Index v1.20 (December 2025)* But wildfire is where the design response is most underspecified by code, where insurance is repricing fastest, and where the gap between what the federal data shows and what the building code requires is widest. Which brings me to the two institutions that are supposed to close that gap, and what each of them is currently doing about it. ### The insurance market moved. It is not waiting for us. Carriers are done waiting for code. They are underwriting at the parcel and the assembly, with their own models, right now. The [California FAIR Plan](https://www.insurance.ca.gov/0400-news/0100-press-releases/2025/release015-2025.cfm), designed as a temporary backstop, grew 44 percent between fall 2024 and the end of 2025, past 668,600 policies, with roughly $645 billion in residential exposure and commercial exposure up 82 percent. After the Palisades and Eaton fires it levied a $1 billion special assessment on member insurers, its first since 1994. It then filed for a 35.8 percent rate increase and was approved for 29.1 percent, and that filing was the first in FAIR Plan history to price using forward-looking wildfire catastrophe models and the net cost of reinsurance. [State Farm non-renewed more than 1,600 policies](https://www.cbsnews.com/news/fires-california-palisades-fire-homeowners-insurance-state-farm-fair-losses/) in Pacific Palisades before January 2025, after more than a year of trimming exposure in high-risk ZIP codes. But those aggregate numbers mask the gap at the individual level, which is where the PaliBuilds claims data landed. Here is the part architects need to actually internalize. Under California’s Safer from Wildfires regulation, every admitted insurer that uses wildfire risk in pricing is required to offer credits for documented mitigation. The FAIR Plan now stacks up to twelve separate hardening credits. Class A roofing. Listed ember-resistant vents. Defensible space to PRC 4291. Noncombustible ground surface in the first five feet. And I want to be honest about the size of that carrot, because the industry oversells it: those credits apply only to the wildfire portion of the premium, so the actual dollars are modest. Anyone selling you home hardening on the strength of the discount is selling it wrong. The discount is a rounding error. The asset is being in the insurable pool at all. In hurricane markets the question was whether a carrier would cover you. In wildfire markets that question was answered “no” years ago across whole ZIP codes. The live question is what it takes to get back in, and that is an architectural question with an architectural answer. [Commissioner Lara’s own framing](https://calmatters.org/economy/2026/03/california-insurance-commissioner-job/) is that a structurally healthy California market is a three-to-five-year project and that the state is not out of the woods. Believe him. ### The code did not move. Say it out loud. Now the other institution. **2020:** [AB 3074](https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201920200AB3074) directs California’s Board of Forestry to write an ember-resistant Zone 0 rule for the first five feet around structures. **2024:** [SB 504](https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202320240SB504) strengthens the Board’s authority to make it enforceable. **February 2025, one month after the Palisades burned:** Executive Order N-18-25 directs the Board to adopt final Zone 0 regulations by December 31, 2025. **December 31, 2025:** not adopted. **April 2026:** a subcommittee releases another draft, publicly framed as prioritizing education and outreach rather than penalties. Still not before the full Board. Six years. The first five feet. The single cheapest and best-documented mitigation in all of wildfire science, and California cannot get it into the code. Meanwhile the [City of San Diego wrote its own Zone 0](https://www.sandiego.gov/fire/community-risk-reduction/wildfire-prevention) into its municipal WUI code, effective for new structures on February 28, 2026, and for existing structures a year later. A city did in months what the state has not managed in six years. In the Palisades, the Governor suspended the 2025/2026 California Building Standards Code for fire rebuilds so homeowners can design to the 2022 code. I understand the reasoning and I even agree with parts of it, because predictability has real value when thousands of people are permitting at once. But say the sentence out loud: after the most destructive fire in Los Angeles history, we made the rebuild code the older code. And the fast lane has a tell. Stay within 110 percent of your original footprint and you get the expedited path plus an exemption from Los Angeles’ all-electric ordinance. Exceed it and you lose both. So the incentive structure gently steers a fire rebuild toward gas appliances, in 2026, inside a Very High Fire Hazard Severity Zone. Nobody designed that outcome. It is just what happens when you bolt emergency exemptions onto a code without asking what they add up to. Colorado adopted the [Colorado Wildfire Resiliency Code](https://dfpc.colorado.gov/sections/wildfire-resiliency-code-board) on July 1, 2025, three years after the Marshall Fire destroyed more than a thousand homes in a suburb, and after [FEMA denied the state $101 million](https://www.propublica.org/article/colorado-law-to-require-more-wildfire-resistant-homes) in resilient infrastructure grants partly because it lacked a statewide building standard. Full enforcement began July 1, 2026. The code applies only to new construction in WUI areas, which means the existing building stock that carried the Marshall Fire losses is unaffected. [Seventeen of the twenty largest wildfires](https://dfpc.colorado.gov/sections/wildfire-information-center/historical-wildfire-information) in Colorado history have happened since 2012. And stakeholders involved in drafting the code have described the requirements as modest: a statewide floor, not a statewide standard. Colorado went from no code to a code, but the question is whether the code it wrote matches what the FEMA data says the state actually needs. The code is a floor. In wildfire markets, the floor is on the wrong story of the building. Which is exactly why this lands on the architect. Nobody is going to require the thing that saves the building. You have to specify it, and you have to be able to defend it to a client whose insurance settlement is $1.4 million short. ### What Part 2 does [Part 2](https://cove.inc/blog/wildfire-resilient-design-by-market-part-2) goes market by market. LA County’s worst tracts are not the worst in this dataset. San Diego’s are. Colorado Springs has 97 percent wildfire penetration across the county. Boulder’s Marshall Fire proved what happens when a grass fire hits a suburb. And Jackson County, Oregon, lost more than 2,400 structures in a single afternoon. Each market has a different wildfire problem, and each one demands a different design response.