After the Marshall Fire: How to Document Your Mitigation and Appeal Your Wildfire Risk Score in Colorado

On December 30, 2021, a grass fire driven by wind gusts near 115 mph swept out of Boulder County and into the towns of Superior and Louisville. By the time snow finally stopped it, the Marshall Fire had destroyed 1,084 homes — the most destructive wildfire in Colorado history, and it didn't happen in a remote mountain forest. It happened in subdivisions, on ordinary streets, in neighborhoods most people would never have called "high risk."

That's the part that reshaped Colorado's insurance market. After the Marshall Fire, insurers leaned harder on wildfire risk models to decide who they'll cover and what they'll charge — and a lot of homeowners found themselves non-renewed or surcharged based on a "wildfire risk score" they never saw and couldn't question.

A new state law changes that. And if you've done mitigation work on your property, it gives you a concrete way to push back.

What HB25-1182 actually does

House Bill 25-1182, "Risk Model Use in Property Insurance Policies," was signed into law on May 28, 2025 and takes effect July 1, 2026. It targets how insurers use wildfire risk models, catastrophe models, and scoring methods to underwrite and price homeowners policies.

Three parts matter most if you own a home in a wildfire-prone area:

1. You get to see your score. An insurer that uses a wildfire risk score to underwrite, non-renew, price, or surcharge your policy must disclose that score (and any risk classification) to you, along with the main property features driving it.
2. Your mitigation has to count. Insurers must either build property-specific and community-level mitigation into their models, or — if they don't — offer discounts to homeowners who can demonstrate that mitigation work was done.
3. You can appeal. The law specifically authorizes you to appeal your wildfire risk score or classification directly to your insurer, and requires insurers to publish their appeal process on their website.

In plain terms: the work you do to harden your home and clear defensible space is no longer supposed to be invisible to your insurer. But there's a catch built into the word "demonstrate."

The catch: the credit is only as good as your proof

Here's where most homeowners get stuck. The law gives you the right to have your mitigation counted — but it puts the burden of proof on you. If you call your insurer and say "I cleared my defensible space, lower my score," that's not evidence. Insurers process claims and appeals on documentation, not descriptions.

And this is exactly the gap the generic "HB25-1182 explainer" articles from law firms and agencies tend to skip. They'll tell you the law exists. They won't tell you what a carrier-ready proof package actually looks like. That's the difference between an appeal that gets approved and one that gets filed away.

So let's be specific.

What "verifiable proof" of mitigation looks like

When you appeal a score or ask for a mitigation discount, you're essentially building a small case file. The stronger and more standardized it looks, the easier it is for an underwriter to say yes. A solid package includes:

• Before-and-after photos, taken from multiple angles, that clearly show the same area. A pile of brush gone, a tree limbed up, a deck cleared underneath.
• Dated receipts and invoices for every piece of mitigation work — defensible space clearing, tree removal, gutter guards, vent upgrades, roof or siding work.
• A simple property map showing your home, the cleared zones around it, defensible-space distances, and which trees you kept or removed.
• Inspection or assessment reports, ideally from a certified arborist or a fire-mitigation specialist, or from a local wildfire program.
• Permits, if any work required them.
• Timestamps and location data on your photos, which quietly answer the underwriter's unspoken question: when was this done, and was it done here?

The throughline is credibility. Anyone can take a phone photo. What moves an underwriter is documentation that's organized, dated, located, and tied to a recognized standard.

Tie your work to a recognized standard

You don't get to invent what "mitigated" means — and you don't have to. There are established standards underwriters already respect. The most relevant for individual homes is the Insurance Institute for Business & Home Safety (IBHS) Wildfire Prepared Home program, which has two designation levels:

• Base (being renamed Essential) focuses on the leading cause of home ignition — wind-blown embers. It centers on a noncombustible 0–5 foot zone right around the house, roughly 30 feet of defensible space, and upgrades to vulnerable features like vents and gutters.
• Plus (being renamed Enhanced) builds on all the Base requirements and adds protection against flames and radiant heat.

You don't necessarily need a formal designation to appeal — but framing your work in the language of these standards (the 0–5 foot zone, defensible-space distances, ember-resistant vents) signals to an underwriter that you know what actually reduces risk. Colorado's defensible-space guidance from the state Division of Fire Prevention and Control lines up with the same zone-based thinking.

What to do next

If you've been non-renewed, surcharged, or simply want to qualify for a mitigation discount, here's a practical sequence:

1. Request your wildfire risk score in writing from your insurer, along with the property features driving it. After July 1, 2026, they're required to provide it.
2. Read the score's reasoning. It tells you exactly which factors to address — and which to document.
3. Document what you've already done. Gather receipts, take before/after photos (or re-shoot current conditions from clear angles), and map your defensible-space zones.
4. Close the gaps. If the score flags something you haven't addressed — say, combustibles in the 0–5 foot zone — do that work and document it too.
5. File the appeal directly with your insurer, following the appeal process they're now required to publish. Attach your proof package.
6. Escalate if needed. If your insurer's decision isn't satisfactory, you can raise it with the Colorado Division of Insurance, which oversees the new requirements.

The homeowners who'll benefit most from HB25-1182 aren't necessarily the ones who've done the most work — they're the ones who can prove the work they've done.

Emberly helps Colorado homeowners and contractors turn mitigation work into organized, standards-aligned, insurance-ready proof — the kind of documentation an underwriter can actually accept. If you want to be ready before the law takes effect, join the waitlist at emberly.tech.

This article is general information, not legal or insurance advice. For your specific policy, confirm details with your insurer and the Colorado Division of Insurance.