FIELD NOTE · SUPPLEMENTAL SET
Class A on a bare lot: a roofing market measured in years
ISSUEDJULY 11, 2026DRAWN BY THE NIGHTLY SWEEP
The 2025 edition of Title 24 took effect on January 1, 2026, a year into the Palisades and Eaton rebuild, and it moved the Class A roofing requirement out of one book and into another. Chapter 7A of the Building Code is a pointer now, and the wildland urban interface provisions live in a standalone Part 7. Eighteen months in, with lots still bare and the codebook under them already one edition newer, this is not a season of roofing work but a decade of it.
The work in it arrives address by address across years, on clocks held by insurers and plan check queues, and the roofing volume in it outlasts any bidding season a contractor can plan around.
The requirement is narrower than the burn scars, and reading it as a burn scar rule is the first mistake available here. Class A under the new Part 7 attaches to the wildland urban interface areas and fire hazard severity zones mapped by the state, not to the fire. LAist reported that more than 7,800 buildings inside the area burned by the Eaton Fire fall outside those zones even after the 2025 map expansion, and that the 2026 addition of a High local responsibility area category brings in roughly a thousand more. A contractor working these addresses is reading two maps at once, the burn footprint for where the work is and the hazard zones for what the assembly has to be.
Eighteen months on, the paper moves and the buildings do not. The county's most recent count, an economic update published with the LAEDC on June 8, 2026, puts 26.7 percent of destroyed structures as permitted and 0.47 percent as approved for occupancy, and reports an average of 79 days from rebuild permit application to issuance. A fast plan check now sits in front of a completion column that has barely moved.
In Pacific Palisades, figures from the Department of Building and Safety reported on July 7, 2026 put rebuilding permits on 1,419 properties and certificates of occupancy on 28 addresses. The first fully rebuilt home in West Altadena took its certificate on December 5, 2025, eleven months after the Eaton Fire, and the supervisor's release announcing it carried no cumulative count.
16,251 STRUCTURES DESTROYED ACROSS THE EATON AND PALISADES FIRES, COUNTY OF LOS ANGELES 26.7% OF DESTROYED STRUCTURES PERMITTED TO REBUILD, JUNE 8, 2026 0.47% APPROVED FOR OCCUPANCY ON THAT DATE
The working consequence for the trade sits in the first of those two percentages. At 26.7 percent permitted, nearly three quarters of the roofs owed on this loss have not yet reached a permit, which puts the bulk of the work in front of the companies bidding now rather than behind them.
Six months in, the same four jurisdictions were reporting the same two numbers. The Los Angeles Times counted 352 applications in unincorporated Los Angeles County with about 15 percent issued, 389 in the City of Los Angeles with nearly 25 percent issued, 77 in Malibu with none issued, and 20 in Pasadena with 2 issued. Average time to issue was 55 days in the City and about 60 days in the County.
Twenty applications, in Pasadena, six months after the fire.
Plans could go in while a lot was still being cleared, but nothing could be issued until the ground under it was clean, so the debris phase ran on a clock of its own underneath every one of those counts.
The permit record answers when, roughly, and for which address, and it does not answer whether the owner still intends to. The distance between those two columns is decided by money, by insurance, and by a plan check queue, arriving at thousands of addresses on thousands of separate schedules, and very little of it is a roofing capacity question at eighteen months.
As of May 26, 2026, seven and a half years after the fire, the ledger reads 3,891 applications, 3,647 permits issued and 3,191 certificates of occupancy, with 244 applications still in review and 456 houses still in construction.
Paradise is in its eighth year.
Single family rebuild in Paradise, California, against years elapsed since the Camp Fire of November 8, 2018. Source: Town of Paradise rebuilding statistics as of 5/26/26; the 2022 and 2024 points from the town's weekly recovery updates dated 1-19-22 and 5-15-2024, as republished on makeitparadise.org.
The ceiling on all of it is lower than the permit counts suggest. Across five California wildfires that each destroyed a thousand or more residential structures, Tubbs in 2017, Carr, Camp and Woolsey in 2018, and the North Complex in 2020, the Los Angeles Times counted 22,438 residential structures burned and about 8,420 rebuilt, measured five to about seven and a half years out.
The count came from the CAL FIRE damage inspection database, local building department records and state housing data. About 75 percent of what burned was single family. The rest had not been rebuilt when the count was taken.
A rebuild of this size stops being an emergency long before it stops being work, and year eight in Paradise is an ordinary book of residential jobs, still filing, still framing, and still owing a Class A assembly on a house whose neighbors moved back years earlier.
Class A there means an assembly tested to ASTM E108 or UL 790, the requirement the 2025 cycle lifted out of Chapter 7A and printed at CWUIC 504.2, as reproduced by UpCodes. A job scoped at just under half the covering and a job scoped at just over it are therefore priced against different sections of the same code, on the same house, in the same twelve months.
That threshold does not run on the 16,251 that burned. It runs on existing structures inside the zones designated by CAL FIRE and the Office of the State Fire Marshal, including those of the 2,047 damaged and left standing that sit inside one. Those zones reach a long way past both burn scars, into Southern California streets that never saw flame.
The fire chose the lots. The map chose the requirement. Inside the zones, the structural scope a fire zone rebuild picks up shows up on the same drawings as the roof assembly.
Two clocks run inside that claim file and they are not the same coverage: the dwelling clock, the one Section 2051.5 governs, gives an insured at least 36 months to collect full replacement cost. The coverage that pays for somewhere to live in the meantime carries its own limit, and Los Angeles County reported on June 8, 2026 that approximately 38 percent of survivors have already exhausted or will soon exhaust displacement assistance. A household past that limit is paying its own housing costs while it waits, and deciding whether to build now, smaller, or later.
That decision sits upstream of every roof on the list, and it is made in a claim file rather than at a bid table, which is why the useful unit of work in a rebuild this long is the individual filing and its date. Reading the burn areas and the cities around them as a single permit record scored for roofing puts the address in front of a contractor in the week it clears, whether it is a cleared lot in Altadena or a street in Pasadena that never burned.
The 36 months are a floor and they run from the date of that first payment rather than from the fire or the permit, so the deadline on the roof, the one no insurer may set closer than 36 months to that payment, was fixed inside a claim file before any roofing contractor knew the address existed. Paradise, seven and a half years out, still has 456 houses in construction.
The work in it arrives address by address across years, on clocks held by insurers and plan check queues, and the roofing volume in it outlasts any bidding season a contractor can plan around.
The requirement is narrower than the burn scars, and reading it as a burn scar rule is the first mistake available here. Class A under the new Part 7 attaches to the wildland urban interface areas and fire hazard severity zones mapped by the state, not to the fire. LAist reported that more than 7,800 buildings inside the area burned by the Eaton Fire fall outside those zones even after the 2025 map expansion, and that the 2026 addition of a High local responsibility area category brings in roughly a thousand more. A contractor working these addresses is reading two maps at once, the burn footprint for where the work is and the hazard zones for what the assembly has to be.
Bare lots at eighteen months
The County of Los Angeles counts 16,251 structures destroyed across the two fires, 9,414 in the Eaton and 6,837 in the Palisades, with a further 2,047 damaged and left standing. Both fires started on January 7, 2025, hours apart, both were contained on January 31, and reporting at the one year mark put the residential share of that loss at nearly 13,000 homes.Eighteen months on, the paper moves and the buildings do not. The county's most recent count, an economic update published with the LAEDC on June 8, 2026, puts 26.7 percent of destroyed structures as permitted and 0.47 percent as approved for occupancy, and reports an average of 79 days from rebuild permit application to issuance. A fast plan check now sits in front of a completion column that has barely moved.
In Pacific Palisades, figures from the Department of Building and Safety reported on July 7, 2026 put rebuilding permits on 1,419 properties and certificates of occupancy on 28 addresses. The first fully rebuilt home in West Altadena took its certificate on December 5, 2025, eleven months after the Eaton Fire, and the supervisor's release announcing it carried no cumulative count.
16,251 STRUCTURES DESTROYED ACROSS THE EATON AND PALISADES FIRES, COUNTY OF LOS ANGELES 26.7% OF DESTROYED STRUCTURES PERMITTED TO REBUILD, JUNE 8, 2026 0.47% APPROVED FOR OCCUPANCY ON THAT DATE
The working consequence for the trade sits in the first of those two percentages. At 26.7 percent permitted, nearly three quarters of the roofs owed on this loss have not yet reached a permit, which puts the bulk of the work in front of the companies bidding now rather than behind them.
Six months in, the same four jurisdictions were reporting the same two numbers. The Los Angeles Times counted 352 applications in unincorporated Los Angeles County with about 15 percent issued, 389 in the City of Los Angeles with nearly 25 percent issued, 77 in Malibu with none issued, and 20 in Pasadena with 2 issued. Average time to issue was 55 days in the City and about 60 days in the County.
Twenty applications, in Pasadena, six months after the fire.
Plans could go in while a lot was still being cleared, but nothing could be issued until the ground under it was clean, so the debris phase ran on a clock of its own underneath every one of those counts.
The permit record answers when, roughly, and for which address, and it does not answer whether the owner still intends to. The distance between those two columns is decided by money, by insurance, and by a plan check queue, arriving at thousands of addresses on thousands of separate schedules, and very little of it is a roofing capacity question at eighteen months.
Roofs still going on in Paradise's eighth year
The Camp Fire burned Paradise on November 8, 2018, and the town has published its own rebuilding ledger ever since, which makes it the best documented of the comparable American rebuilds, the one that prints a record you can read year by year. At three years and two months, on January 19, 2022, the town had taken 2,101 single family applications, issued 1,914 permits and signed off 1,196 certificates of occupancy. At five and a half years, on May 15, 2024, those figures were 3,207 applications, 2,993 permits and 2,370 certificates.As of May 26, 2026, seven and a half years after the fire, the ledger reads 3,891 applications, 3,647 permits issued and 3,191 certificates of occupancy, with 244 applications still in review and 456 houses still in construction.
Paradise is in its eighth year.
Single family rebuild in Paradise, California, against years elapsed since the Camp Fire of November 8, 2018. Source: Town of Paradise rebuilding statistics as of 5/26/26; the 2022 and 2024 points from the town's weekly recovery updates dated 1-19-22 and 5-15-2024, as republished on makeitparadise.org.
The ceiling on all of it is lower than the permit counts suggest. Across five California wildfires that each destroyed a thousand or more residential structures, Tubbs in 2017, Carr, Camp and Woolsey in 2018, and the North Complex in 2020, the Los Angeles Times counted 22,438 residential structures burned and about 8,420 rebuilt, measured five to about seven and a half years out.
The count came from the CAL FIRE damage inspection database, local building department records and state housing data. About 75 percent of what burned was single family. The rest had not been rebuilt when the count was taken.
A rebuild of this size stops being an emergency long before it stops being work, and year eight in Paradise is an ordinary book of residential jobs, still filing, still framing, and still owing a Class A assembly on a house whose neighbors moved back years earlier.
A roof covering, half replaced in twelve months
The burned lots are not the whole of this market, and CWUIC 507.1 carries two sentences that a roofing contractor prices separately. Any portion of a roof covering applied during an addition, alteration or repair to an existing structure must meet at least a Class A fire classification. Where the covering is replaced in full, or where 50 percent or more of it is replaced in a 12 month period, the roof goes instead to Sections 504.2 and 504.2.1, which is the new construction standard rather than a patch held to the old one.Class A there means an assembly tested to ASTM E108 or UL 790, the requirement the 2025 cycle lifted out of Chapter 7A and printed at CWUIC 504.2, as reproduced by UpCodes. A job scoped at just under half the covering and a job scoped at just over it are therefore priced against different sections of the same code, on the same house, in the same twelve months.
That threshold does not run on the 16,251 that burned. It runs on existing structures inside the zones designated by CAL FIRE and the Office of the State Fire Marshal, including those of the 2,047 damaged and left standing that sit inside one. Those zones reach a long way past both burn scars, into Southern California streets that never saw flame.
The fire chose the lots. The map chose the requirement. Inside the zones, the structural scope a fire zone rebuild picks up shows up on the same drawings as the roof assembly.
Class A ordered against a 36 month clock
Insurance Code 2051.5 has barred any time limit shorter than 36 months from the date of the first actual cash value payment since 2018, for an insured collecting full replacement cost after a declared state of emergency, and SB 495 amended the section again effective January 1, 2026. The statute then adds one or more extensions of six months for good cause, where the delay is beyond the insured's control, including permit delays, material shortages and a lack of available contractors. The statute names the constraint plainly. A lack of available contractors is written into California law as a legitimate reason a claim runs long.Two clocks run inside that claim file and they are not the same coverage: the dwelling clock, the one Section 2051.5 governs, gives an insured at least 36 months to collect full replacement cost. The coverage that pays for somewhere to live in the meantime carries its own limit, and Los Angeles County reported on June 8, 2026 that approximately 38 percent of survivors have already exhausted or will soon exhaust displacement assistance. A household past that limit is paying its own housing costs while it waits, and deciding whether to build now, smaller, or later.
That decision sits upstream of every roof on the list, and it is made in a claim file rather than at a bid table, which is why the useful unit of work in a rebuild this long is the individual filing and its date. Reading the burn areas and the cities around them as a single permit record scored for roofing puts the address in front of a contractor in the week it clears, whether it is a cleared lot in Altadena or a street in Pasadena that never burned.
The 36 months are a floor and they run from the date of that first payment rather than from the fire or the permit, so the deadline on the roof, the one no insurer may set closer than 36 months to that payment, was fixed inside a claim file before any roofing contractor knew the address existed. Paradise, seven and a half years out, still has 456 houses in construction.