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Wildfire risk-score appeals

Carriers increasingly use wildfire risk models. A few states require disclosure and formal appeal clocks; others offer disclosure-on-request or only company-specific paths.

California — strongest formal regime

Under 10 CCR § 2644.9, when a Wildfire Risk Model or rating factor segments, differentials, or surcharges wildfire risk, the insurer must provide the score/classification in writing on application, renewal, nonrenewal, and post-mitigation timelines, plus the range, relative position, rate impact, property-feature explanation, mitigation measures that lower the score, and premium reduction for each measure under the then-effective rating plan.

Appeals may be oral or written (agents must forward promptly). Acknowledgments and written decisions run on the regulation’s 10/30-day-style clocks; denials must point to CDI complaint rights. See CDI Safer from Wildfires materials at insurance.ca.gov.

Colorado — HB 25-1182 clocks

HB 25-1182 requires disclosure of score/classification, range, explanation, and mitigation discounts for insurers using wildfire/catastrophe models or scores, with consumer appeal — acknowledge within 10 calendar days and decide within 30 calendar days (confirm implementing regulation effective dates on doi.colorado.gov). Regulation 5-1-29 filing requirements are effective January 1, 2027.

Oregon & Montana — disclosure-forward

  • Oregon — ORS 742.277 / SB 82 require property-specific explanation when wildfire risk drives cancel, nonrenew, or material rate change, including plain-language methodology when scores are used (dfr.oregon.gov).
  • Montana — MCA 33-16-117: admitted insurers using a wildfire risk score must, on request within 30 days, provide score, range, scoring entity, date, and adverse factors (statute text). Disclosure ≠ CA-style appeal hearing.

Practical appeal kit

  • Dated photos of roof, vents, Zone 0, decks, and outbuilding distances.
  • Invoices and contractor scopes for Class-A roof, ember mesh, enclosure work.
  • CAL FIRE / local fire-department / IBHS Wildfire Prepared Home inspection reports where accepted.
  • Firewise or Fire Risk Reduction Community documentation.
  • A short cover letter mapping each mitigation to the factors the carrier listed.

Mitigation improves the risk story; it is not a voucher for renewal or a specific premium.

Official sources cited

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