Select Committee on Agriculture Sixth Report


APPENDIX 39

Memorandum submitted by the Association of British Insurers (F64)

  I refer to your letter of 12 June and my interim reply of 22 June.

  Enclosed, please find 20 copies of the memorandum that you requested. This deals with a number of the issues you raise and puts into perspective the insurance market and its activities in relation to the flood risk as well as details of our co-operation with the Environment Agency. However, to supplement the memorandum I would emphasise a number of specific points.

  Insurers have become very concerned about development in flood plain areas, both coastal and riverine regions. Insurers believe that the controls exercised in England and Wales are no longer adequate. A major problem is that individual planning authorities effectively have autonomy in terms of planning approvals. The system introduced into Scotland by the Scottish Office (NPPG7) could serve as a very useful model for adaptation, development and implementation in England and Wales. This would ensure that insurers became more involved in planning decisions nationally. In Scotland, there have already been situations where the input of insurers has successfully influenced decision making.

  In relation to the raising of insurance premiums as a financial instrument, you will see from the memorandum that this is already implicit. Indeed, a number of insurers do already increase premiums to reflect the flood risk. So, to some extent, there is already a general pattern developing and acceptance that premiums reflect risk. The principle is applied elsewhere in relation to subsidence and crime risks and this is already well known to consumers. However, premiums to reflect the true potentially developing risk could well be unsustainable by those consumers most exposed to the risk. In the worst case scenarios, this could lead to insurance affordability, even availability, issues. This is in no-ones interest and financial instruments could not offer a practical solution to the problem for those worst affected.

  You will also appreciate from the memorandum that the insurance market is highly complex and competitive. It is not just a question of generating appropriate levels of premium but more about the total potential exposure and whether the insurer has adequate financial capacity in a catastrophe situation. There is also the point that insurers in the UK operate in an entirely free and competitive market place. It would be difficult, therefore, to regularise the approach to flood risk cover and premium.

  On the political side there are also some fundamental issues. For example, individual policyholders would feel that they were paying through increased insurance premiums for inadequate flood defences which, traditionally, have been funded from the public purse. To do this retrospectively could well cause major PR problems for the Government, the various agencies as well as insurers, particularly where consumers have not previously been aware that a significant risk exists.

  Our view, therefore, is that the most acceptable practical approach is to better manage defence strategy. Firstly, flood plain development should be controlled sensibly. Secondly, the Environment Agency and its various regions should operate in a much more co-ordinated way against a sea and riverine defence strategy with target standards of service (in line with current MAFF policy guidelines) for each flood area taking into account sound economic considerations, insurance aspects and risk assessment techniques. Naturally, the outcome would be expected to address most significant areas of need; hence the desirability of an over-arching flood strategy.

  If this approach were to be developed in liasion with insurers and other interested parties, there is every chance that the Government can achieve a sustainable flood defence strategy underpinned by insurance cover at affordable premiums.

  We do hope that the information contained in this letter and the attached memorandum will be helpful to the Agricultural Committee in reaching positive decisions. If you require any further information or clarification of any points, please let me know.

THE INSURANCE MARKET AND FLOOD RISK

1.  INTRODUCTION

  1.1  This paper sets out the particular concerns of insurers in relation to flood risk and describes the action taken to date, puts this into operational context and also analyses future prospects for flood cover.

  1.2  This paper is in four main parts:

    Part 2: How the Research is Helping Insurers

    Part 3: The Outlook for Insurance Cover

    Part 4: Action Needed.

2.  BACKGROUND

  2.1  The Association of British Insurers' (ABI) is the trade association for insurance companies. It has around 450 members which between them account for over 95 per cent of the UK insurance business. ABIs key objectives are to help insurance companies by representing their interests to Government, particularly on public policy issues; providing them with technical services, in particular in respect of industry statistics, market and regulatory information and reducing the incidence of claims; and promoting insurance and insurance companies generally. ABI helps its members at the pre-competitive stage, to improve their chance of success in achieving a balanced underwriting account.

  2.2  For many years, insurance companies and the "reinsurers", who insure insurance companies, have been concerned about the size of their exposure to natural perils.

  2.3  For this reason, ABI looked at some of the ways in which management of natural perils exposures could be improved. Two areas were identified for urgent attention. These were windstorm and flood risk.

  2.4  Flood risk primarily in coastal (and estuarine) areas has, over the last few years, become the priority because of the potential catastrophe exposure.

  2.5  The low lying coastal zone of England and Wales represents a relatively small area, approximately3 per cent of the total land area. However, the value of the insurable assets within the coastal zone and major estuarine areas that are at risk from flooding due to storm surges and waves is enormous.

  2.6  While MAFF and EA have sought to implement Government policy by:

    —  encouraging sensible defence measures and;

    —  encouraging flood warning systems,

a serious potential risk is still posed if defences are inadequate by design or condition or if storm conditions exceed their defence design criteria.

  2.7  With riverine flooding, the problems for insurers have to date been perceived as less significant. As a general rule, the impact is more isolated so that exposures are limited and can be managed by individual insurers. An important exception is the Thames Upstream of the Barrier. The consequences of catastrophic flooding in the City and West End in particular in terms of buildings and infrastructure are extreme. The recent flooding from riverine sources over Central England at Easter and other more isolated incidents do, however, indicate that insurers should be more concerned about the potentially catastrophic risks now apparently presented by riverine flooding. The need to address this and how is dealt with later in the paper.

  2.8  In the light of the potential coastal flood risk exposures, insurers could have decided unilaterally to withdraw cover. This would then have made the UK consistent with other European countries where flood cover is not traditionally provided and can only be bought on a limited basis. However, this would have contradicted openly previous undertakings, probably could not be justified in the absence of conclusive research evidence, and poses both moral and political problems.

  2.9  For these reasons, and with the support of Lloyd's and the London Insurance and Reinsurance Market Association (LIRMA), ABI decided to commission a series of projects with consulting engineers, Sir William Halcrow and Partners Limited (Halcrow). The aim would be:

    —  to identify levels of risk and exposure;

    —  where appropriate, to co-ordinate with and influence flood defence work and strategy through liaison and co-operation with the Environment Agency and Ministry of Agriculture Fisheries and Food;

    —  to help insurers to continue providing cover.

PART ONE

3.  OUTLINE AND RESULTS OF INSURERS' FLOOD RESEARCH

The Original Study—Risk Assessment

  3.1  In 1994 Halcrow were commissioned to undertake a coastal flood risk assessment for the whole of England and Wales, including the major estuaries. The orginal study was based on data from the Sea Defence Survey (SDS). This was undertaken by the NRA in 1990. It was essentially a "condition" survey. The condition of defences is an important consideration for insurers because it provides a basis for assessing levels of risk. In addition to this, water level, wave, beach profile, bathymetric and topographic data inter alia was taken into account. The study provided flood risk areas for insurance purposes defined in one kilometre squares within risk bands one, two and three for return periods of 50, 100 and 200 years respectively. Postcodes falling within each of the risk bands were identified. The results were launched to members at a seminar in November 1994. They were subsequently circulated in report form.

Update Study—Risk Assessment

  3.2  The SDS was updated in 1995 to take into account new work which had been carried out on sea defences and changes in relevant beach levels. Halcrow were, therefore, commissioned to revise the original output against the updated SDS data. The results showed a decrease in band one flood risks of around 7 per cent. The revised output was circulated to members in 1995.

Thames Upstream of and Including the Barrier

  3.3  The original study did not provide risk banding information for areas along the Thames upstream of the Barrier. This was based on the assumption that the Barrier itself provided London with protection against an event with up to a 1,000 year return period. Despite this there remained concerns within the insurance community about the possibility of combined freshwater and fluvial flow causing flooding upstream of the Barrier. Some reassurance was also needed regarding the design criteria for the Thames Barrier itself.

  3.4  Further research was commissioned with Halcrow to establish water levels at specific locations along the River Thames and assess the integrity of its flood defences in relation to these levels. As part of this, the design criteria for the Barrier was taken into account, together with the rules governing its closure. This study was also based on the latest SDS data.

  3.5  The study concludes that the Barrier adquately fulfils its design criteria. However, the study also indicates a possibility that extreme water levels in the higher reaches of the river could give rise to potential flood risk. Significantly, there is no apparent risk of flooding in or around the City and West End areas. In addition, the results do not take into account the most recent remedial flood defence work. Neither do they take account of any inaccuracy in the Environment Agency's stored SDS data. Therefore, it is possible that defences identified as potentially at risk do not present any danger.

  3.6  ABI has reviewed the position recently with the Environment Agency's Thames Region in the light of concerns that the Barrier needed to be Year 2000 compliant. ABI has been reassured by the response which indicates that the necessary actions are being taken and that the Barrier can, if necessary, be operated through effective manual overrides.

Single Storm Event

  3.7  The original and update studies had only identified the risk posed by extreme conditions at each coastal and estuarine location. The results provided an indication of flood risk potential for each separate flood area but not the collective risk and maximum exposure to single storm events. The latter would be necessary for insurers to make a realistic assessment of their maximum exposure to potential worst case storm scenarios.

  3.8  ABI commissioned Halcrow, in conjunction with the UK Meteorological Office, to establish the potential at risk flood areas.

  3.9  The study has identified the two worst storms for the East, South and West Coasts together with two storms which could affect more than one coast. The study included possible but hypothetical variations to these storms so as to be confident of identifying worst case scenarios. The study analyses the impact of these eight storms, maps their potential impact by flood area and lists affected postcodes.

  3.10  The worst case scenario of Exposure  Average Damage has been assessed in the light of the Single Event study. It is now represented by a combined East and South coast flood. The latest information should reassure insurers and reinsurers that there is sufficient capacity in the market to cope with this.

"Weak Links" Study

  3.11  An ancillary benefit of the original, update, and Thames studies was that they gave Halcrow the ability to identify critical links within a defence structure which gave rise to the different levels of flood risk area banding. It was soon recognised that a study to identify the "Weak Links" in the defences would help potentially in the targeting of defence work.

  3.12  Following specific and more general liasion with the Environment Agency a joint study was commissioned with Halcrow to identify relevant defences and validate the findings. This created a strong platform from which to develop co-operation between insurers and the Agency and Ministry.

  3.13  This jointly funded study has identified the potential "Weak Links" in defences, the primary failure mechanism (or data deficiency) and the implications in terms of flood risk damage. This work took into account the information on which the earlier update study was based.

  3.14  In relation to the coastal and estuarine studies, the results show that 1,232 defence structures could be at risk in the band one and two categories. 66 per cent because of a potentially inadequate structure and 34 per cent because of inadequate defence or foreshore data.

Riverine Flooding

  3.15  To date ABI has not undertaken any specific research into riverine flooding. As explained earlier, it has not been seen as presenting the same catastrophe threat as coastal flooding. However, in the light of the Easter flooding and other more isolated but significant events, the industry will be reviewing whether specific research would be valuable. Whether or not a positive decision is taken, the ABI, nonetheless, will be working on a much wider basis with the Environment Agency to help ensure that riverine defences are adequate. Further details of the way this co-operation should develop and other ways to help alleviate the existing threats, both coastal and riverine, are set out in Part Four.

4.  DIALOGUE WITH ENVIRONMENT AGENCY (EA) AND MINISTRY OF AGRICULTURE, FISHERIES AND FOOD (MAFF)

  4.1  Working together on the "weak links" study demonstrates the way in which ABI, EA and MAFF have worked together to improve knowledge about the threats posed by coastal flooding.

  4.2  This positive approach should help to ensure that adequate strategies are employed to protect consumers and property taking into account the criteria against which defence measures are considered.

  4.3  Insurers recognise that protection against flooding can never be absolute but want to ensure that the risks are kept to a reasonable minimum. This is a common objective with EA and MAFF. EA and MAFF have themselves recognised the value of this co-operation. The research is being analysed by EA to identify where the defences are inadequate by design or condition and this will help them to prioritise defence work.

  4.4  Insurers and EA are committed to working together in this way to ensure, as far as possible, that lives and property are adequately protected within the relevant economic constraints.

PART TWO

5.  HOW THE RESEARCH IS HELPING INSURERS

  5.1  To put the application of output of data into context, it is necessary to understand the commercial and regulatory factors which affect insurers operationally. Like other businesses, insurers must perform to the satisfaction of shareholders so must aim to produce returns on investment which are "equivalent" to those other businesses. However, the volatility of claims and the need for insurers to be "secure" has led to insurers being tightly regulated. Because of this, the amount of business an insurer can write is determined by their capital base and the ratio of premiums to capital is rather confusingly called the "Solvency Margin"—though solvency ratio would be more correct. The Department of Trade and Industry makes an assessment of each insurer's solvency margin against set criteria and judgement all applied on a "prudential" basis.

  5.2  Individual insurers try to obtain sufficient premium to cover their potential exposure and to do this they need to understand the underlying risk. Put simply, the output of the Halcrow research can be applied to this end by analysing the areas at risk against the locations and post codes of insured properties to establish aggregate portfolio exposure. Insurers can then determine the premium income they need and the level of premium for different risk locations.

  5.3  Insurers usually have to operate with the support of reinsurers to give them added capacity or to reduce the financial consequences of a catastrophic loss. These reinsurers need to be satisfied that the insurers they are backing are not themselves overexposed and also require the technical evidence the research provides in order to take on these risks.

  5.4  The data analyses from the original study were, therefore, able to assist the insurers to:

    —  determine the correct premium rates to charge; and

    —  provide information to reinsurers to gain their "capacity" and "catastrophe" support.

  5.5  Only a few years ago, insurers could buy ample reinsurance protection for major storm or flood damage at a relatively low cost. Things are very different now. Due partly to the storms of 1990, which cost insurers £2,400 million, reinsurance premiums for the biggest UK insurers increased fourfold, while the amount of protection reduced significantly. Insurers recovered 60 per cent of their losses from the 1990 storms from reinsurers, now they would recover only 20 per cent. With concerns over the potential impacts of climate change, insurers and reinsurers are now much more aware of the need to manage accumulations of exposure.

  5.7  This has been a major driving force behind the desire of insurers to harness new technology such as geographic information systems (GIS) and to use flood and storm etc data in increasingly advanced catastrophe models.

Macro: Modelling and Estimated Maximum Loss

  5.8  In the past, historic claims experience was a good measure for predicting future risk. Nowadays insurers recognise that the world is changing too rapidly for them to be able to rely solely on this method. Insurers need to be more precise, and one way to do this is to analyse the concept of risk by looking separately at its component parts: hazard, vulnerability and exposure. Insurers can then build predictive models and compare them with historic results.

Hazard

  5.9  The hazard is a combination of frequency and severity. In the case of flood, the probability of flood and the depth of flood are important, but other factors have to be considered; how much warning can be given, the velocity of the water, whether it is freshwater or salt water, the extent of contamination, and the duration of inundation. All of these have an effect on the amount of damage. The hazard is largely outside the control of insurers, and is changing all the time, not just due to climate change, coastal erosion, sea level rise and tectonic tilt, but other factors, such as deforestation, loss of flood plains and urbanisation which all tend to increase the hazard or move it to new areas. In such circumstances, insurers are very interested in the standards of sea and river defences and how much protection they provide, hence the ABI's commissioning of the Halcrow studies. While hazard is hard to manage, the other sides of the triangle are perhaps more controllable; there is an analogy here with the water industry in the South East of England; they are currently facing up to the problems of projected reductions in precipitation and possible water shortages, by looking at ways to manage demand through metering and consumer awareness. Insurers may have to look at ways to manage this demand side for situations where there is too much water ie floods.

Vulnerability

  5.10  Vulnerability could be seen as a potential candidate for such "demand management". Modern building materials such as chipboard and plasterboard are very vulnerable to flood damage. The same applies to the typical contents of a home, office or factory, for example the increasing use of high value and easily damaged electronic equipment.

  5.11  In propoerties in very high risk situations, flood damage can be reduced by designing the building to be less vulnerable to flood damage and by keeping vulnerable contents on upper floors. A good example of this is General Accident's new building in York, which was designed from the outset to be flood proof.

Exposure

  5.12  The location of a property is clearly crucial, and insurers welcome the efforts of the Environment Agency to discourage new developments in flood plains. In Scotland, GA and ABI were consulted by the Scottish Office when they were drawing up the Planning Policy Guidelines for flood (NPPG 7) and we were pleased to see them adopt our suggestions that the insurance industry be more involved in planning decisions in Scotland.

  5.13  Insurers and reinsurers are increasingly aware of the potential accumulations of exposure from properties in high hazard areas, and new technology like GIS is making it easier for their assessments to become more precise. Exposure management is the easiest way to control the risk to an insurer of suffering catastrophic losses following a major flood, and insurers are already monitoring their exposure to ensure that the market shares the risks equally.

  5.14  Another way insurers could reduce exposure is by applying an excess to flood claims. This has the added attraction of giving an incentive to the household to take precautions when a flood warning is given, for example by moving property upstairs, or putting sandbags in front of the door. In many of our scenarios, however, the depth of flood is so great that the average claims cost would not be significantly reduced by applying an excess, and it could be seen as being unfair to those unable through age or infirmity to be able to move their possessions in time.

Reinsurance Issues

  5.15  A major insurer will typically buy reinsurance protection from over a hundred reinsurance companies all round the world, so that the risk of a major event is literally spread throughout the global economy. This is a very efficient way to reduce the burden on the UK economy from a major storm or flood, but it does mean an annual cost of many millions of pounds of premium flowing out of the UK. To minimise this, while at the same time ensuring there is enough protection against a disaster, requires sophisticated mathematical calculations and modelling. A key part of such modelling is something insurers call "Mean Loss Ratios".

Mean Loss Ratios

  5.16  Many insurers have developed sophisticated mathematical models for assessing the likely costs of different flood scenarios. This is essential work to enable insurers to assess just how much a major flood might cost and, from this, how much reinsurance they need to purchase to protect themselves. A major insurer could spend as much as £25 million a year on catastrophe reinsurance, depending on its size and the amount of risk it retains, so the accuracy of these flood models is very important, not just to the insurance industry, but to the UK economy; if insurers buy too much reinsurance, that means too much money is leaving the country. If insurers buy too little, and there is a major flood, that means the UK economy is bearing too much of the cost.

  5.17  A central part of any such flood model is the relationship between the depth of flood and amount of damage sustained. This is what insurers call the "Mean Loss Ratio". The Flood Hazard Research Centre at Middlesex University has carried out very thorough and detailed work for MAFF to determine this relationship in terms of the cost to UK plc for various flood scenarios. Unfortunately, its figures, whilst indicative, are not easily applied to insurance modelling without extensive calibration to take account of other factors, in particular, "new for old" claims settlements and other different forms of indemnity which the insurer may use. In other words, the amount which insurers actually pay in claims is likely to be considerably more than the "Middlesex figures" would suggets. Therefore, so that UK insurers can better assess how much reinsurance to purchase, General Accident and the Alexander Howden Group are sponsoring research projects at Dundee University which are designed to produce a set of flood damage tables based on what floods actually cost the insurance industry. The "Dundee Mean Loss Ratios" will be made freely available to UK insurers and to reinsurance companies, and hopefully will become the industry standard for flood modelling.

Micro: Underwriting Individual Risks

  5.18  At the micro, or individual risk level, it is possible to address two sides of the risk triangle:

    (i)  Vulnerability—insurance surveyors can advise commercial enterprises to store easily damaged goods on racks or upper floors, or take other precautions, including local flood defences. In some cases, insurers may call for a hydrologist's report for a specific site, and make more detailed recommendations;

    (ii)  Exposure—the main thrust of insurers' efforts will be on the exposure aspects.

  5.19  Exposure management will increasingly become very important as insurers become more precise in their analyses of possible flood scenarios and hazardous areas. Managing that exposure will not be done overnight; no major insurer would want to cancel all its policies in such areas without very good reasons. However, where it considers it has more than its share of policies in a high risk area, it may increasingly be looking to manage its exposure in such areas by seeking a higher premium.

  5.20  Not so long ago, household insurance was rated at postcode area level. Now it is typically at postcode sector level and increasingly at full postcode unit level. Many insurers aim to rate at individual address level, and indeed some already do so in high hazard areas.

  5.21  From a rating point of view, the Halcrow research was intended primarily to assist with insurers' rating of commercial risks; these tend to be individually underwritten, and underwriters are looking not just at premium, but also recommendations on specific precautions to be taken.

  5.22  However, the research has been of great interest to household insurers, and many of them have been looking at additional sources of good quality, high resolution data which can enable them to gain competitive advantage by identifying degrees of hazard within the high hazard areas identified in the Halcrow reports. The best source of data of course is from actual flood events, but it is not always easy to gather. Aerial photography might be one solution, but for some reason floods are often accompanied by low cloud cover and stormy conditions, which makes this solution difficult and dangerous. We are interested in the potential for using synthetic aperture radar satellite data, especially as the number of such satellites and therefore the availability of such data is growing rapidly. Insurers would hope that ultimately it might be possible to track floods in real time, so as to be able to monitor the development of the flood and improve the warnings to those likely to be affected. Not only do warnings reduce the amount of loss to property, they could potentially save lives.

PART THREE

6.  THE OUTLOOK FOR INSURANCE COVER

  6.1  As explained in Part Two, the information from the existing and any future research will be applied by the insurance industry in two basic ways, managing overall portfolio exposure and in underwriting individual property risks.

  6.2  Balancing of exposures is likely to continue for a number of years, and insurers will increasingly be using GIS data together with local knowledge to become more precise in their underwriting.

  6.3  To date insurers have been very responsible in the use of the output from the research. Rates have and may continue to increase in selected locations because of risks being assessed for flood cover on a geograpic basis. Some insurers may also decide they are overexposed in certain areas and either not accept new business or, possibly, not renew. However, as rates stabilise at realistic levels there should not be significant problems in finding cover. The approach being taken by insurers is entirely consistent with higher theft insurance rates being charged in high crime areas or higher rates for areas with a demonstrably worse subsidence risk. It also recognises the conflicting demands of consumers many of who want to pay only the premium that is commensurate with the risk they bring. The skill will be to contain increases by the continued development of sensible flood defence strategy and strict control of development in flood prone areas and to uphold a balanced approach to risk pricing.

  6.4  Some potential weaknesses have, of course, been identified regarding defences in general. However, the way in which the research has helped insurers more accurately to quantify the real risk of coastal flooding and the positive action being taken by EA should allay any significant fears that coastal and estuarine or Thames flooding represents an uninsurable risk.

  6.5  The single event study shows that the exposure to storm scenarios, although substantial, is less than originally feared, so capacity problems with flood risks in the market overall should be avoided.

  6.6  This generally positive outlook should continue provided flood defence strategy and development controls are developed effectively. Insurers recognise the invaluable work, finance and co-ordination already employed by EA and MAFF. However, more needs to be done if insurers are to continue in the longer term to provide cover with any confidence that shareholders' interests are adequately protected. Consumers and businesses also need confidence that their own "investment" in potentially affected local communities is protected adequately. Otherwise, there is the possibility of "blight" developing significantly in defended coastal areas.

  6.7  Inevitably, the research which has been carried out gives rise to the question of availability and affordability of insurance. While these are not issues at present, we need to be aware that they could become problems in the future. This is particularly the case for:

    —  properties in areas where the residents have refused to have flood defence work carried out for aesthetic or other reasons;

    —  properties purchased cheaply because of a history of regular flooding.

  6.8  This then poses the question whether insurers should provide cover in such cases, at the expense of their other customers? Arguably, the unrealistic continued provision of cover could seriously compound the problem. It would be far better to control development now and increase general public awareness of the threat and difficult realities before a withdrawal of cover presents serious and less manageable economic consequences in the longer term.

  6.9  So far insurers are extremely encouraged by the discussion and co-operation with EA and MAFF in relation to coastal flood research. There has also been some dialogue with the Scottish Office and the Scottish Environment Protection Agency. This demonstrates that the commercial and political problems can be overcome to the benefit of all. It is a process that the insurance industry is committed to, so that the risk of coastal flooding is reduced to an acceptable level.

PART FOUR

7.  ACTION NEEDED

  7.1  It would be wrong to assume that in an insurance context all is now well in relation to coastal flood defence. The progress made is very encouraging but "too little too late" is a saying that must be avoided in future.

  7.2  From an insurers' point of view there must be even more liaison and co-operation between interested parties. This should not be limited to national organisations: liaison with local communities and their elected representatives and insurer involvement in local Flood Defence Committees should also be considered, so that they understand the issues facing insurers. The more informed we are the better placed we will be to make sensible decisions on flood defence.

  7.3  The issue in March 1997 of the Environment Agency policy document "Policy and Practice for the Protection of Flood Plains" is an extremely positive development. It focuses attention on the important issues of river and coastal flood plain development. Although it does not represent a change in flood defence policy, the consolidation of existing custom and practice is a valuable intitiative. Insurers also welcome the recent legislation in Scotland which requires local authorities to review the flood risks in their areas and in particular to ensure that culverts and storm drains are adequately maintained.

  7.4  Insurers recognise the interests which flood defence strategy has to balance. The policy statement should be used as the catalyst in improving planning controls and implementation of remedial schemes.

  7.5  There appears also to be considerable scope for achieving consistency and improving the co-ordination between the mainly autonomous Environment Agency regions. To establish a sensible overarching national strategy and make it effective demands very close liaison and discussion between regions albeit within target standards for the defences which are their responsibility.

  7.6  Consideration should also be given to the commerical constraints of the insurance industry and their duties to their shareholders. Insurers should not be expected automatically to provide cover where regular flooding occurs, where remedial schemes have been refused at local level or where development has taken place without due regard to adequate defence provision and hence insurance implications. If effective planning controls were to be introduced, the likelihood is that problems over insurance availability and affordability would be reduced to a minimum.

  7.7  The launch of the new EA warning system is a positive development which has the wholehearted support of insurers.

8.  CONCLUSION

  8.1  The insurance industry will continue working with EA, MAFF and others but it will be essential in future not to rely exclusively on insurers to continue providing cover. Rather, efforts should be made to reduce exposures to a manageable level leaving insurers as a sensible long-stop which helps to make flood defence manageable in economic terms.

26 June 1998


 
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