HOMEOWNER'S POLICIES - On September 16, State Farm General filed new underwriting guidelines with the California Department of Insurance that would allow it to consider new policies for homes with qualifying Wildfire Prepared Home designations from the Insurance Institute for Business & Home Safety (IBHS).
According to State Farm and reporting by the San Francisco Chronicle, homes meeting the lower IBHS standard could be considered for new policies in areas State Farm classifies as low to moderate wildfire risk. High and very high fire risk properties meeting the higher standard could be considered, provided they also satisfy State Farm's normal underwriting requirements.
Don't confuse State Farm's wildfire-risk classifications with California's Fire Hazard Severity Zones, though. They aren't the same thing. CAL FIRE maps wildfire hazard. Insurance companies evaluate risk. But it is what State Farm proposes to require of existing homes that deserves a closer look.
IBHS has two levels of Wildfire Prepared Home designations. The lower level, called Base or Essential, is described by IBHS as appropriate for most existing homes and typically achieved through retrofits. The higher level, called Plus or Enhanced, is different. IBHS says it’s Plus or Enhanced designation is commonly used for new construction. Yet that is the standard State Farm proposes to use as its requirement for policies for older homes with a high risk of burning.
In the Base or Essential designation for the low to moderate fire risk properties with minimal danger of burning, the first five feet around the house must be free of anything that could burn. No grass. No flowers. No shrubs – No privacy hedge. No succulents or cacti. No trees. No wood mulch. No wood or vinyl fencing. No artificial turf or real grass. No wood furniture or furniture cushions. You get the idea, right?
For the next 5 to 30 feet from the house, detached garages, sheds, ADUs and other structures must be at least 10 feet from the house and at least 10 feet from one another. Each of those structures must also have its own five-foot nothing-can-burn zone, and those zones cannot overlap. For the higher-risk houses, the rules change dramatically. Detached garages, sheds and ADUs cannot be located anywhere within 30 feet of the house.
There is a reason IBHS cares so much about distance. When wildfire enters a densely built neighborhood, the fire stops behaving as a wildfire and becomes an urban conflagration. Burning buildings or structures become fuel for other buildings or structures. IBHS describes a "domino effect" in which wind-driven fire spreads from structure to structure and that maintaining appropriate separation between structures is important to interrupting the domino effect. In its recommendations for rebuilding Los Angeles after the 2025 fires, IBHS went further, calling on the City to “use setbacks to maximize the spacing between structures to the greatest extent possible.”
The National Institute of Standards and Technology (NIST) independently describes the same problem: tightly spaced properties in high-density communities allow fire to spread more easily, while sheds, fences, decks, vehicles and other parcel-level fuels can form pathways that carry fire through the neighborhood. After the 2025 Los Angeles fires, IBHS reported that greater structure spacing improved the chances that homes would escape damage during conflagration conditions.
So, the spacing requirements aren't arbitrary. The problem is applying them to existing Los Angeles neighborhoods where the houses, garages, property lines and streets were laid out decades ago— while the City continues approving new development that reduces the very structure separation IBHS says matters.
Let's start with a perfectly ordinary Los Angeles house.
You bought a house built in 1955 on a 5,700 sq ft lot. There is a detached garage 15 feet behind it. The garage may have been there for 70 years. Under the low or moderate fire risk designation, the requirements are already substantial.
The first five feet around the house must have nothing that can burn. Then there is the garage. It’s 15 feet from the house, so it meets the at least 10-feet from the house rule. You’re clear. Phew! But the detached garage has to also be at least 10 feet from any other structures – gazebo, shed, greenhouse, pergola, playset, covered patio, carport -- that are also within 5 to 30 feet from the house. Each of those structures that IBHS lists must be at least 10 feet apart and have their own five-foot nothing-can-burn zone, and those zones cannot overlap.
Take out a tape measure. Do you have 10 feet between your house and garage? Do you have 10 feet between your house and your shed? Do you have trees, shrubs or grass next to any of these structures? This is the standard State Farm proposes to use for its low-to-moderate-risk policies.
Now let's look at the requirement for high-risk properties. The garage cannot remain 15 feet away. It has to be at least 30 feet from the house. But it isn't just the garage. Detached ADUs, sheds, greenhouses, pergolas, carports, gazebos, playsets and other accessory structures of 15 square feet or more must be at least 30 feet from the house, too.
You also have to meet all of the low to moderate property fire risk requirements. Then you have to add the higher-level requirements: upgraded windows and doors, noncombustible siding, additional protection for eaves, soffits, gutters, skylights and decks. For a substantial cost, you can replace windows, siding and doors, rebuild a deck, and remove trees. You can replace vents, remove hedges and other plants. But you cannot manufacture another 30 feet of land.
Suppose there is enough room to move the garage farther from your house by moving it toward the property line. What's on the other side of that property line? Your neighbor's house or your neighbor’s ADU. If a garage less than 10 or 30 feet from the house creates a wildfire exposure, moving that garage 10 or 30 feet from your house doesn't make the exposure disappear. You may have reduced your risk by shifting it to your neighbor.
Now replace that old garage with something California has spent years encouraging homeowners to build: an ADU. Same small lot. Same distance from the house. Same wildfire exposure. But now state housing policy wants another housing unit there. The fire doesn't care whether the building holds a car or a family. And neither does IBHS. Its higher standard specifically includes detached ADUs among the structures that cannot be within 30 feet of the home.
California isn't merely asking homeowners to cope with density that was built decades ago. Its housing policies can add density today while its wildfire policies impose costs on the homeowners living with the resulting conditions. That's where an insurance standard collides with the physical reality of an existing city.
Again: where does that old garage or new ADU go? That isn't an abstract question in Los Angeles. On a small urban lot, there may simply be nowhere to put it. And California's own fire regulations also tell us that this lack of space matters.
The State Minimum Fire Safe Regulations begin with a 30-foot setback for buildings from property lines and roads. The purpose is important: when that separation can't be achieved, the regulations require an alternative method intended to reduce structure-to-structure ignition. The regulations also expressly recognize why 30 feet may sometimes be impossible. Among the reasons listed are parcel dimensions, topography, site constraints and "development density requirements."
Read that again: 30 feet may sometimes be impossible. Among the reasons listed are parcel dimensions, topography, site constraints and "development density requirements."
California's own fire regulations recognize that housing density can make its preferred physical separation impossible. Government's answer has been to permit reduced setbacks in appropriate circumstances when alternative methods are used to reduce the structure-to-structure ignition risk. Those methods can include noncombustible walls, hardscape, noncombustible areas and additional structure hardening.
Those measures may help improve fire safety. But they don't create space. And an insurance company is not required to reach the same conclusion about the remaining risk that a government agency reached when it approved the development.
I don't blame State Farm for that.
State Farm didn't determine California's housing allocations. It didn't write the state's ADU laws. It doesn't decide how much housing density Los Angeles should accommodate in its fire-prone neighborhoods. State Farm has a different job. It decides which risks it is willing to insure.
And that's why this filing raises a much bigger question about California housing policy. We have spent years talking about the insurance crisis as though insurability is primarily an individual homeowner problem. Harden your house. Replace your vents. Change your windows. Remove your landscape plants. Create Zone 0. Those things don't make the lot bigger. They don't move the garage. And they don't move the house next door.
That's particularly important because IBHS itself doesn't describe its standards for high and very high risk properties as the ordinary retrofit standard for existing homes. It says most existing homes can achieve the lower designation through retrofits, while the higher designation is commonly pursued during new construction or major exterior renovations. Nevertheless, State Farm proposes to use that higher standard as a pathway to new insurance.
Consider what that could mean for someone who has owned the same house for decades. The homeowner didn't determine the size of the lot. The homeowner didn't decide where the house was built. The homeowner didn't determine the setback of the detached garage. The homeowner certainly didn't decide how close the neighbor's house would be. The homeowner can spend thousands of dollars hardening the structure and still be unable to change those facts.
A colleague offered an unsettling phrase when I showed him the requirements: "constructive eviction." He wasn't offering a legal conclusion. He was describing a potential practical consequence. What happens when access to ordinary private insurance increasingly depends on physical conditions an existing homeowner cannot afford to or cannot feasibly change?
That question becomes even more important when government is simultaneously encouraging greater housing density. This isn't an argument against building more housing. California can add housing without assuming that every location presents the same wildfire conditions or that every lot can accommodate the same structural density. It is an argument for confronting a contradiction.
Housing policy asks how we can fit more housing onto the land. Fire policy recognizes that physical separation between structures matters, but allows alternative methods when that separation can't be achieved. And now State Farm is telling us that physical separation or density matters to insurability.
State Farm isn't saying that home hardening and vegetation management can substitute for structure separation. Under the IBHS standards it wants to use, homeowners have to do all three. Meanwhile, California is pursuing two policies that pull in opposite directions. It is making it easier to add housing and structures to fire-prone neighborhoods. At the same time, it is imposing increasingly costly wildfire-mitigation requirements on the people who already live there.
Think about what that means for an existing homeowner.
I can screen my vents. I can replace my windows and siding. I can remove vegetation. I can create defensible space. I might even be able to tear down or relocate my own garage. But I can't move my neighbor's house. And I can't control how many additional structures government allows to be built around me.
If structure separation matters enough to IBHS that it remains a requirement even after a home has been hardened and vegetation has been managed, California policymakers have some explaining to do.
Why are they approving greater structural density in fire-prone communities while simultaneously making existing homeowners spend more and more money mitigating wildfire risk?
And if those land-use decisions ultimately make our homes more expensive to insure—or harder to insure at all—why are we the ones left holding the bag?
(Diana Nicole is plant scientist and ecological land care specialist in Los Angeles. She writes about fire policy and evidence-based fire safety at dianaznicole.com. Previous columns are available at the citywatchla archives.)
