Wildfire insurance non-renewal: what the vegetation side actually requires

What's actually happening in 2026

Non-renewals in the Bay Area hills aren't a moratorium situation; they're a pricing-and-risk-score situation. The state's Sustainable Insurance Strategy let carriers use catastrophe models and pass reinsurance costs through to rates starting December 2024, and in exchange a dozen insurer groups have committed to write more policies in high-risk ZIP codes. Farmers joined that list in May 2026 with a pledge to market to at least 300,000 policyholders in distressed areas; Mercury, CSAA, USAA, Travelers, and others are on the CDI's list as committed or pending.

What that means for a homeowner in Mill Valley, the Oakland hills, or Woodside: the carriers coming back are the ones pricing by model, and the models reward documented mitigation. The FAIR Plan grew to roughly 697,000 policies by mid-2026 but its growth has slowed as carriers return. Your leverage is the mitigation file.

The vegetation items insurers are required to credit

Since October 2022, 10 CCR §2644.9 has required every insurer that rates on wildfire risk to give a discount for each of these "immediate surroundings" items. These are the regulation's words, lightly condensed:

1. Vegetation and debris cleared from under decks.
2. Vegetation, debris, mulch, and stored or movable combustibles cleared within 5 feet of the building.
3. Only noncombustible fences and gates within 5 feet of the building.
4. No combustible sheds or outbuildings within 30 feet of the building (or as far as the insured controls).
5. Compliance with Public Resources Code §4291 and any local defensible-space ordinance.

Plus the structure items — Class A roof, enclosed eaves, ember-resistant vents, multi-pane windows, 6 inches of noncombustible clearance at the base of walls — and two community items (a Firewise USA site in good standing, or a Board of Forestry–listed Fire Risk Reduction Community). Each item must carry its own discount. The CDI's March 2026 briefing put total discounts at 4%–40%, largest for the highest-risk homes.

What inspectors look for beyond the regulation

The regulation is the floor. Carrier inspections and the forms they use go further on trees. CSAA's California Wildfire Mitigation Verification Form tracks the regulation item by item and must be signed by a qualified inspection professional, not the homeowner. Industry practice on top of that, consistent across brokers and inspection vendors even where carriers don't publish a list:

• No branches within 10 feet of the roofline or chimney outlet
• Roughly 10 feet of crown separation between trees in the 5–30 ft zone, more on slopes
• No ladder fuels — shrubs or low limbs that carry fire from the ground into the canopy
• Dead trees and dead limbs removed
• Photos at underwriting and at renewal; some carriers re-verify annually

The state's Zone 0 regulation — adopted by the Board of Forestry on August 19, 2026, then withdrawn from the Office of Administrative Law on September 8 and not yet refiled — would codify much of this for Very High Fire Hazard Severity Zones: no live branches within 10 feet of a chimney, nothing under the eaves, limbs raised 6 feet, branches 5 feet above the roof, and a phased timeline for existing homes. It is not law today. But the draft is the standard insurers are reading, and the vegetation items in it are what a carrier inspector means by "defensible space." See the Zone 0 guide for the actual text and status.

The protected-tree problem

This is the part that gets Bay Area homeowners stuck. The carrier wants the coast live oak over the roof gone or cut back 10 feet. The city protects the oak and requires a permit, an arborist report, and sometimes replacement trees. Both are right. The way through is usually pruning to clearance under the city's standard (which often doesn't need a removal permit, though some cities permit major pruning too), documented by an arborist so the insurer sees a professional judgment rather than a refusal. Where removal is justified on fire-hazard grounds, the arborist report is what the city needs to approve it. The permits guide covers this city by city.

What to do after a non-renewal notice, in order

1. Read the notice for the date and the reason. Count back 75 days from expiration. If the notice is short, the policy continues for 75 days from receipt.
2. Check for a moratorium. CDI posts a bulletin per declared fire with the covered ZIP codes. None cover Bay Area counties as of October 2026, but check — a covered ZIP means the insurer must offer to rescind the non-renewal.
3. Request your risk score and the itemized discounts in writing. You're entitled to both under §2644.9(k). This tells you exactly which items the carrier thinks you're missing.
4. Do the vegetation items and document them. Dated before-and-after photos of each item, invoices, and a professional statement. If trees are involved, get the arborist's letter before the work so the permit and the insurer file line up.
5. Appeal. Written request with the file. Acknowledgment in 10 days, decision in 30. Parallel-shop with an independent broker using the CDI Home Insurance Finder, filtered to insurers writing in higher-risk areas.
6. If nothing binds in time, FAIR Plan plus a DIC policy. Bind before expiration to avoid force-placed coverage from your lender. The FAIR Plan covers fire and a few named perils; the Difference in Conditions policy from a standard carrier adds liability, water, theft, and loss of use. Apply for the FAIR Plan mitigation discounts through the broker's attestation form.
7. Complain if the timelines slip. CDI Consumer Hotline 800-927-4357.

Where a consulting arborist fits

We don't sell insurance, inspect for IBHS, or do the tree work. What we do is produce the vegetation half of the file: an arborist letter on letterhead stating conditions by zone and the work scoped or completed, a dated and labeled photo record, a checklist mapped to the §2644.9 items and the carrier's own form, and — where a protected tree is the sticking point — the arborist report the city needs. That's the Insurance Documentation Package, $650, with a $250 re-inspection letter once the work is done. If you just want someone to read the carrier's letter and your photos first, a desk review is $250.

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