COLORADO WILDFIRE RESILIENCY CODE

Important Revisions Needed

PROBLEM

The Wildfire Resiliency Code Board (created pursuant to SB23-166 and SB25-142) recently adopted “minimum codes and
standards,” which mandate certain wildfire resiliency building requirements to be adopted by local governments by
April 1, 2026.

These new standards, while focused on the important objective of reducing wildfire spread, fall short of the legislation’s
intent. They disallow certain products that are equally as fire resilient as some still allowed – this will create a building
materials supply shortage and significantly increase building costs, with no increased safety.

There are also other unintended consequences, such as inconsistencies with the International Wildland-Urban Interface
Code (IWUI); and, some banned products having greater mold, pest and hail impact resistance, which creates an entirely
new problem for local governments and home owners.

Stakeholders who were aware of the legislation and the process were engaged through the development of the new
“minimum codes and standards” and attempted throughout to bring important concerns and data to the conversation –
key concerns were not considered nor addressed. The Board adopted the final product only one day after taking final
public comments – comments were not addressed in any manner – how the Board incorporated or why they did not.

However, a number of stakeholders were unaware of the legislation or the Wildfire Resiliency Code Board work and
only became aware after being alerted about the adoption of the “minimum codes and standards.” These stakeholders
and others have formed a coalition seeking to make modifications to the final “minimum codes and standards” and
provide local governments additional time to work through adoption.

SUPPLY CHAIN CHALLENGES & INCREASED BUILDING COSTS

The limitation of CWRC-compliant products will create a supply chain challenge for homeowners and builders. This will
increase building costs and exacerbate the current affordable housing challenges in Colorado. This is concerning,
especially when some products no longer allowed under this Code are equally as fire resistant as some that are allowed.

The Home Innovation Research Labs conducted an analysis of the Cost Impact Of Building A House In Compliance With
IWUIC*. This report, focusing on compliance with the International Wildland-Urban Interface Code (IWUIC), indicates
that construction costs will increase. Given that housing prices have risen since the study and Colorado’s code is more
restrictive than the IWUIC, it is clear that the cost impacts in Colorado will be even higher. Note, this report does not
even touch on the cost of retrofitting a home if it meets the 25% replacement threshold the legislation requires, which is
more expensive than a new-build.

The cost increases associated with this specific policy cannot be viewed in a vacuum. There have been a number of
other mandates going into effect that will also increase the cost of building homes – new energy codes, new dredge and
fill requirements (anticipated to increase costs beyond $25k per home). The compounding cost increases from these
policies will hamper our state’s ability to provide affordable housing at a time when this is a critical need.

SOLUTION

• Provide an immediate mechanism to revisit the policy, rather than waiting for the 3-year review.
• Ensure policy is a balanced approach that thoroughly weighs benefits and costs.
• Provide a mechanism for appeal – for products and other interested parties.
• Delay the local government implementation deadline, to allow for the needed continued refinement of the
  Code – ensure alignment with IWUIC and address unintended consequences.
• The significance of this policy change warrants reporting to the Legislature on progress during the annual
  SMART Act hearings.

BACKGROUND MATERIALS

• Enacting Legislation
  • SB23-166 (Cutter, Exum, Froelich, Velasco) – creates the board and charges them to “adopt model codes,
    requiring governing bodies with jurisdiction in an area within the wildland-urban interface to adopt codes
    that meet or exceed the standards set forth in the model codes.”
  • SB25-142 (Baisley, Cutter, Velasco) – “extends the time frame within which a governing body of a city,
    town, or city and county with jurisdiction in an area within the wildland-urban interface is required to
    adopt wildfire codes and standards.”
• Letters of Concern
  • Industry/Building Trades Coalition: 11/24/25 Letter – identifying unintended consequences, asking for a
    delay, seeking to work collaboratively toward a resolution
  • Colorado Municipal League
    • 12/5/25 Letter – asking for implementation extension, identifying process did not comply with
      Administrative Procedures Act.
    • 7/20/24 to Governor – provisions of 24-4- 103 (2.7), C.R.S., prohibit the creation of state rules
      creating an unfunded mandate on local governments unless accompanied by state funding.
  • American Wood Council: 12/22/25 Letter – does not (1) improve wildfire safety through
    performance-based standards, nor (2) prevent unnecessary increases in housing costs; respectfully
    requests for wildfire resiliency code reconsideration.

Questions or More Information

Kachina Weaver – kachina@weaverstrategies.com (303) 883-7076
Heidi Morgan – heidi@wagnermorganstrategies.com (303) 229-3149

Home Innovation Research Labs report: Cost Impact Of Building A House In Compliance With IWUIC –
Cost Impact Of Building A House In Compliance With IWUIC (PDF)