Can the Florida Insurance Market Withstand a US$100 Billion Repeat of Hurricane Andrew?
Hurricane Andrew’s landfall in Florida in 1992 changed the face of property catastrophe insurance and kick-started many new initiatives, including the development of hurricane risk modeling. However, with significant exposure growth, the impact of social inflation, and climate change complications, the insurance market could struggle to respond to a repeat of Andrew. The wide-ranging impact of Hurricane Andrew on the Florida insurance market is a familiar story within the risk management world. However, 30 years on from August 24, 1992, when Andrew made landfall in Dade County, Florida, memories appear to be getting shorter, as the insurance industry once more seems to be in danger of underestimating its exposure to a Category 5 storm hitting the state. Image from the GOES-7 satellite shows Hurricane Andrew at its peak intensity on August 23, 1992, before making landfall near Homestead, Florida. Image source: NOAAWhen Hurricane Andrew came ashore as the first named tropical storm of the 1992 North Atlantic hurricane season, it followed a seven-year hiatus in major hurricane activity in Florida. Industry predictions at the time were that it would cost insurers around US$4 billion to US$5 billion, but Andrew ended up costing the insurance industry US$15 billion (in 1992 values) for Florida claims, and it caused the deaths of 44 people in the state. Following Hurricane Andrew, more than 650,000 claims were filed, leaving eight insurers becoming insolvent and a further three driven into insolvency the following year. Fast forward to today, and RMS® predictions for a repeat of Andrew would see the insured loss for wind and surge in the range of US$80 billion (GR) and US$90 billion (GU), in which other non-modeled losses and social inflation could lead to a US$100 billion event. Aftermath of Andrew The losses from Hurricane Andrew vindicated the need for catastrophe modeling solutions including the use of multiple simulated storms beyond those previously experienced in history. Catastrophe models enabled the new Bermuda reinsurance market: eight new reinsurers were established without the need for their own historical experience. In time, catastrophe models would enable the creation of insurance-linked securities such as catastrophe bonds, to tap into capital markets for alternatives to reinsurance. Without Hurricane Andrew, it might have taken much longer for this revolution to happen. The crisis caused by Andrew certainly precipitated some rapid and innovative changes to help manage a much larger hurricane risk cost than previously recognized, allowing the market to prepare for the hyperactive Florida hurricane seasons of 2004 and 2005. However, the following years were unusually quiet for intense storms landfalling in Florida, encouraging actions that further raised insurers’ hurricane risk costs. Among these was the 25 percent roof replacement rule in 2007, which mandated that if 25 percent or more of a roof is ‘repaired, replaced or recovered’ in any 12-month period, then the entire roofing system or roof section must be brought up to the latest building code. “Until the hurricanes returned with a vengeance in 2017,” says Peter Datin, senior director of modeling at RMS, “the significant additional cost imposed on insurers due to this code update was not clear.” Development of Hurricane Modeling Before Hurricane Andrew, exposure mapping by the insurance industry involved tracking premiums at a fairly coarse ‘Cresta Zone’ resolution. Post-Andrew, as modelers provided insurers with the ability to model exposures at a finer scale, insurers recognized how higher resolution data could provide a more accurate assessment of risk. RMS released its first hurricane model in 1993. Since then, there have been many updates and innovations, from basin-wide stochastic tracks, coupled ocean-atmosphere storm surge modeling, and significant enhancements in damage assessment modeling. After Hurricane Katrina in 2005, Robert Muir-Wood, chief research officer at RMS, coined the term ‘post-event loss amplification’ (PLA) to cover all processes that can raise losses after a major catastrophe, such as demand surge and claims inflation. Auguste Boissonnade, vice president of model development at RMS, who designed the first RMS hurricane model, worked on how to quantify these different factors in generating the overall insurance loss after cat events. Hurricane Katrina floodingFor the most extreme catastrophes, when damage requires the long-term evacuation of large parts of a city, the definition of a “super catastrophe” (or “super-cat”) event applies, where secondary consequences can be a significant component of the original damage. The flooding of New Orleans after Hurricane Katrina was such a super-cat. “With the hurricane catastrophes of 2004 and 2005 came the realization that cat loss models needed to allow for undervaluation of insured exposures as well as the secondary impact of economic, social, and political factors that could amplify the losses,” Boissonnade says. After major hurricanes, RMS vulnerability modelers review lessons that can be learned from the events and the resulting claims data. “Through claims analyses, it has been possible to quantify the degree to which changes in wind design codes have reduced damage and losses to buildings and incorporate those learnings into cat models,” added Datin. Current Market Dynamics The average cost of an annual homeowner’s policy in Florida is expected to soar to US$4,231 this year, almost three times the U.S. annual average, according to the Insurance Information Institute. Five Florida market insurers have already gone insolvent so far in 2022, faced with rising claims costs and increased costs for reinsurance. Meanwhile, the number of policies written by Citizens, a post-Andrew creation, has risen to over a million, as insurers have either gone insolvent, withdrawn capacity from the market, or had their ratings downgraded, making it harder for insureds to secure coverage that will meet their mortgage lenders’ approval. In July 2022, rating agency Demotech wrote to 17 insurers warning them they could be downgraded from A (exceptional) to S (substantial) or M (moderate), potentially impacting millions of policyholders whose mortgage providers demand home insurance from the strongest-rated carriers. Florida legislators then looked to circumvent the use of Demotech ratings with a new stopgap measure, where Citizens take on a reinsurance role to pay claims for insolvent insurers. At the same time, insurers are struggling to secure reinsurance capacity, and Citizens only managed to get a third of its desired reinsurance cover, making it harder for carriers to deploy sufficient capacity to meet the demand for hurricane coverage. There has also been a huge increase in the volume of catastrophe claims in recent years, driven by social inflation and undervaluation of exposures. Likely Impact of Andrew Now “Our prediction that a repeat of Andrew today could cause as much as US$100 billion in insured losses is based in large part on changes in exposure and population since 1992, coupled with updated predictions of the impact of wind and storm surge, with significant anticipated post-event loss amplification. Together these components reveal a more complete picture of potential economic and insured losses,” says Mohsen Rahnama, chief risk modeling officer at RMS. Combined wind and surge losses for a repeat of Hurricane Andrew are estimated at US$87 billion. Post-event loss amplification, whether it is from a slow recovery, supply chain issues from COVID-19, or current inflationary trends, could take the ultimate loss closer to US$100 billion. The impact of storm surge, particularly with the climate change-related rise in sea levels, is also more pronounced now compared to estimates at the time of Andrew. South Florida property developmentAdded to this is the significant demographic shift in Florida. As of this year, the population of Florida is estimated at over 22 million – a 61 percent increase from the number of people in 1992. Building counts in Andrew’s wind and surge footprints have increased by 40 percent to 1.9 million and by 32 percent to 55,000 respectively. Economic exposure has also increased by 77 percent in the wind footprint and 67 percent in the surge footprint. And in Miami-Dade County, the number of high-rise buildings that are over 15 stories has tripled since 1992, many of which are now potentially in Andrew’s surge footprint. “While the wind was the main driver of loss in 1992, the number of new, high-valued buildings near the coast suggests that storm surge losses may play an increasing role in a repeat of this event,” says Rahnama. In constant-dollar terms, economic exposure has grown substantially within both Andrew’s wind and surge footprints, based on an analysis of the total built floor area (see Figure 1). On top of this, cost inflation since 1992 has been substantial, with replacement costs in Florida estimated to have increased between two times and 2.5 times since 1992, based on historical construction cost indices. Figure 1: Exposure growth in Hurricane Andrew’s footprint (in constant dollars). Source: RMSOne key uncertainty in estimating the losses from a repeat of Hurricane Andrew concerns the impact of claims litigation. “Irma in 2017 was the first significant hurricane to make landfall since the 25 percent roof replacement rule was expanded in 2017 to all buildings across Florida, and it contributed to a significant increase in claims frequency and severity, as roof damage sustained during the storm attracted many roofing contractors, who handed over their exaggerated claims to be pursued by attorneys,” recalls Datin. An estimated US$15 billion has been paid to claimants by insurers in Florida since 2013, driven by assignment of benefits (AOB) cases, where litigation has capitalized on the 25 percent roof replacement rule, with a significant portion of the cost being driven by attorney’s fees on both sides. However, a new law passed by the Florida legislature in May 2022 changed the 25 percent roof replacement rule to exempt roofs “built, repaired, or replaced in compliance with the 2007 Florida Building Code, or any subsequent editions of the Florida Building Code.” “This means that only the damaged portion of the roof on newly built or upgraded roofs needs to be repaired after a damaging wind event instead of the entire roof or roofing system. Most importantly for insurers, the right of the contractor or assignee to obtain compensation for attorney fees – that drives up the cost of claims even further – has been removed,” adds Datin. Muir-Wood adds: “There is further hope for insurers following a recent appeal court ruling in Florida which could provide the blueprint for insurers to successfully argue against contractors in such lawsuits. Here we have at least one factor that is now being brought under control, which has significantly raised the insurance costs of hurricane losses. However, insurers will be watching closely to see if there is any reduction in social inflation because of recent legislative measures.” Can the US$100 Billion Repeat of Andrew be Prevented? Should another Category 5 hurricane make landfall in southeast Florida today, not only will the insured loss be more considerable, but the insurance industry will face major challenges that could severely impact its ability to withstand the event. What can the risk management industry do to mitigate losses? Risk modeling has advanced dramatically. “Insurers need to collect detailed data on their exposures and values and then employ high-resolution modeling alongside all those factors that can affect the ultimate loss, whether from post-event loss amplification or from more resilient construction standards,” says Muir-Wood. The spirit of the industry working together with regulators, similar to post-Andrew, needs to be resurrected. “To help insurance carriers to remain competitive, regulators and legislators have been working with the industry to prevent claims litigation from getting out of control and potentially threatening the viability of hurricane insurance in Florida,” adds Boissonnade. “And legislators also need to keep a close eye on how claims respond to the changes to the 25 percent roof replacement rule, and in measures that reduce the need for litigation, so as to reduce vexatious claims,” he adds. Datin acknowledges the role that risk modelers can play, “The catastrophe modeling community has already helped drive positive change in Florida by demonstrating the impacts of building codes and the effects of AOB-driven claims inflation on modeled risk.” In addition, says Rahnama: “It’s crucial that modeling for hurricane risk takes greater account of the effects of climate change on global warming and sea level rise, and the impact those will ultimately on wind and storm surge in the event of another hurricane like Andrew. Let’s not sleepwalk into another Andrew-type scenario. The insights are there, and the warning signs have flashed – we just need to learn from history.”
Deconstructing Social Inflation
After the loss creep associated with Hurricane Irma in 2017, (re)insurers are keen to quantify how social inflation could exacerbate claims costs in the future. The challenge lies in eliminating the more persistent, longer-term trends, allowing these factors to be explicitly modeled and reducing the “surprise factor” the next time a major storm blows through. A few days after Hurricane Irma passed over Marco Island, Florida, on September 10, 2017, RMS® deployed a reconnaissance team to offer some initial feedback on the damage that was sustained. Most properties on the island had clay tile roofs and while the team noted some dislodged or broken tiles, damage did not appear to be severe. A year later, when Peter Datin, senior director of modeling at RMS, decided to revisit the area, he was shocked by what he saw. “There were so many roofing contractors still on the island, and almost every house seemed to be getting a full roof replacement. We found out that US$900 million worth of roofing permits for repairs had been filed in Marco Island alone.” Trying to find the exact shape and color for tile replacements was a challenge, forcing contractors to replace the entire roof for aesthetic reasons. Then there is Florida's “25 percent rule,” which previously applied to High-Velocity Hurricane Zones in South Florida (Miami-Dade and Broward Counties) before expanding statewide under the 2017 Florida Building Code. Under the rule, if a loss assessor or contractor determines that a quarter or more of the roof has been damaged in the last 12 months, it cannot simply be repaired, and 100 percent must be replaced. This begins to explain why, in the aftermath of Hurricane Irma and to a lesser extent Hurricane Michael in 2018, claims severity and loss creep were such an issue. “We looked at some modeling aspects in terms of the physical meaning of this,” says Datin. “If we were to directly implement an engineering or physics-based approach, what does that mean? How does it impact the vulnerability curve? "We went through this exercise last summer and found that if you hit that threshold of the 25 percent roof damage ratio, particularly for low wind speeds, that's a fourfold increase on your claims. At certain wind speeds, it can therefore have a very material increase on the losses being paid. It’s not quite that straightforward to implement on the vulnerability curve, but it is very significant.” But issues such as the 25 percent rule do not tell the whole story, and in a highly litigious market such as Florida, determining whether a roof needs a complete replacement is not just down to physics. Increasingly, the confluence of additional factors that fall under the broad description of “social inflation” are also having a meaningful impact on the total cost of claims. What Is Social Inflation? Broadly, social inflation refers to all the ways in which insurers’ claims costs rise over and above general economic inflation (i.e., growth in wages and prices), which will influence the cost of repairs and/or replacing damaged property. It therefore captures the growth in costs connected to the following: unanticipated emerging perils associated with, for example, new materials or technologies, shifts in the legal environment, evolving social attitudes and preferences towards equitable risk absorption, and demographic and political developments. (Source: Geneva Association) Florida's “David and Goliath” Law A major driver is the assertive strategies of the plaintiffs' bar, compounded by the three-year window in which to file a claim and the use and potential abuse of practices such as assignment of benefits (AOB). The use of public adjusters and broader societal attitudes towards insurance claiming also need to be taken into consideration. Meanwhile, the expansion of coverage terms and conditions in the loss-free years between 2005 and 2017 and generous policy interpretations play their part in driving up claims frequency and severity. What Is Assignment of Benefits (AOB)? An assignment of benefits, or AOB, is a document signed by a policyholder that allows a third party, such as a water extraction company, a roofer or a plumber to '”stand in the shoes” of the insured and seek payment directly from the policyholder's insurance company for the cost of repairs. AOBs have long been part of Florida’s insurance marketplace. (Source: Florida Office of Insurance Regulation) More recently, the effects of COVID-19 has impacted the cost of repairs, in turn increasing insurers' loss ratios. (Re)insurers naturally want to better understand how social inflation is likely to impact their cost of claims. But determining the impact of social inflation on the “claims signal” is far from simple. From a modeling perspective, the first step is deselecting the different elements that contribute toward social inflation and understanding which trends are longer term in nature. The recently released Version 21 of the RMS North Atlantic Hurricane Models incorporates an alternative view of vulnerability for clients and reflects the changing market conditions applicable to Florida residential lines, including the 25 percent roof replacement rule. However, the effects of social inflation are still largely considered non-modeled. They are removed from available data where possible, during the model development process. Any residual impacts are implicitly represented in the model. “Quantifying the impacts of social inflation is a complex task, partly because of the uncertainty in how long these factors will persist,” says Jeff Waters, senior product manager at RMS. “The question is, going forward, how much of an issue is social inflation really going to be for the next three, five or 10 years? Should we start thinking more about ways in which to explicitly account for these social inflation factors or give model users the ability to manually fold in these different factors? “One issue is that social inflation really ramped up over the last few years,” he continues. “It's especially true in Florida following events like Hurricanes Irma and Michael. At RMS, we have been working hard trying to determine which of these signals are caused by social inflation and which are caused by other things happening in Florida. Certainly, the view of vulnerability in Version 21 starts to reflect these elevated risk factors.” AOB had a clear impact on claims from Irma and Michael. Florida's “David and Goliath” law was intended to level the playing field between policyholders and economically powerful insurers, notes the Insurance Information Institute's Jeff Dunsavage. Instead, the law offered an incentive for attorneys to file thousands of AOB-related suits. The ease with which unscrupulous contractors can “find” damage and make claims within three years of a catastrophe loss has further exacerbated the problem. Waters points out that in 2006 there were only around 400 AOB lawsuits in the market. By 2018, that number had risen to over 135,000. In a decade that had seen very few storms, it was difficult to predict how significant an impact AOB would have on hurricane-related claims, until Irma struck. Of the Irma and Michael claims investigated by RMS, roughly 20 percent were impacted by AOB. “From a claims severity standpoint, the cost of those claims increased up to threefold on average compared to claims that were not affected by AOB," says Waters. Insurers on the Brink The problem is not just limited to recent hurricane events. Due to the Sunshine State's increased litigation, insurers are continuing to face a barrage of AOB non-catastrophe claims, including losses relating to water and roof damage. Reforms introduced in 2019 initially helped rein in the more opportunistic claims, but notifications dialed back up again after attorneys were able to find and exploit loopholes. Amid pressures on the court system due to COVID-19, reform efforts are continuing. In April 2021, the Florida Legislature passed a new law intended to curb market abuse of litigation and roofing contractor practices, among other reforms. Governor Ron DeSantis said the law had been a reaction to “mounting insurance costs” for homeowners. As loss ratios rose, carriers have been passing some of the additional costs back onto the policyholders in the form of additional premiums (around US$680 per family on average). Meanwhile, some carriers have begun to offer policies with limited AOB rights, or none at all, in an effort to get more control over the spiraling situation. “There are some pushes in the legislature to try to curb some of the more litigious behavior on the part of the trial lawyers,” says Matthew Nielsen, senior director, regulatory affairs at RMS. Nielsen thinks the 2021 hurricane season could be telling in terms of separating out some of the more permanent changes in the market where social inflation is concerned. The National Oceanic and Atmospheric Administration (NOAA) still predicts another above-average season in the North Atlantic, but currently does not anticipate the historic level of storm activity seen in 2020. “What's going to happen when the next hurricane makes landfall, and which of these elements are actually going to still be here?” asks Nielsen. “What nobody wants to see again is the kind of chaos that came after 2004 and 2005, when there were questions about the health of the insurance market and what the roles of the Florida Hurricane Catastrophe Fund (FHCF) and Florida Citizens Property Insurance Corporation were going to be.” “Ultimately, we're trying to figure out which of these social inflation signals are going to stick around, and the difficulty is separating the long-term signals from the short-term ones,” he continues. “The 25 percent roof replacement rule is written into legislation, and so that is going to be the new reality going forward. On the other hand, we don't want to include something that is a temporary blip on the radar.”
The Data Driving Wildfire Exposure Reduction
Recent research by RMS® in collaboration with the CIPR and IBHS is helping move the dial on wildfire risk assessment, providing a benefit-cost analysis of science-based mitigation strategies The significant increase in the impact of wildfire activity in North America in the last four years has sparked an evolving insurance problem. Across California, for example, 235,250 homeowners’ insurance policies faced non-renewal in 2019, an increase of 31 percent over the previous year. In addition, areas of moderate to very-high risk saw a 61 percent increase – narrow that to the top 10 counties and the non-renewal rate exceeded 200 percent. A consequence of this insurance availability and affordability emergency is that many residents have sought refuge in the California FAIR (Fair Access to Insurance Requirements) Plan, a statewide insurance pool that provides wildfire cover for dwellings and commercial properties. In recent years, the surge in wildfire events has driven a huge rise in people purchasing cover via the plan, with numbers more than doubling in highly exposed areas. In November 2020, in an effort to temporarily help the private insurance market and alleviate pressure on the FAIR Plan, California Insurance Commissioner Ricardo Lara took the extraordinary step of introducing a mandatory one-year moratorium on insurance companies non-renewing or canceling residential property insurance policies. The move was designed to help the 18 percent of California’s residential insurance market affected by the record 2020 wildfire season. The Challenge of Finding an Exit “The FAIR Plan was only ever designed as a temporary landing spot for those struggling to find fire-related insurance cover, with homeowners ultimately expected to shift back into the private market after a period of time,” explains Jeff Czajkowski, director of the Center for Insurance Policy and Research (CIPR) at the National Association of Insurance Commissioners. “The challenge that they have now, however, is that the lack of affordable cover means for many of those who enter the plan there is potentially no real exit strategy.” The FAIR Plan was only ever designed as a temporary landing spot for those struggling to find fire-related insurance cover, with homeowners ultimately expected to shift back into the private market after a period of time. The challenge that they have now, however, is that the lack of affordable cover means for many of those who enter the plan there is potentially no real exit strategy. Jeff Czajkowski, director of the Center for Insurance Policy and Research (CIPR) at the National Association of Insurance Commissioners These concerns are echoed by Matt Nielsen, senior director of global governmental and regulatory affairs at RMS. “Eventually you run into similar problems to those experienced in Florida when they sought to address the issue of hurricane cover. You simply end up with so many policies within the plan that you have to reassess the risk transfer mechanism itself and look at who is actually paying for it.” The most expedient way to develop an exit strategy is to reduce wildfire exposure levels, which in turn will stimulate activity in the private insurance market and lead to the improved availability and affordability of cover in exposed regions. Yet therein lies the challenge. There is a fundamental stumbling block to this endeavor unique to California’s insurance market and enshrined in regulation. California Code of Regulations, Article 4 – Determination of Reasonable Rates, §2644.5 – Catastrophe Adjustment: “In those insurance lines and coverages where catastrophes occur, the catastrophic losses of any one accident year in the recorded period are replaced by a loading based on a multi-year, long-term average of catastrophe claims. The number of years over which the average shall be calculated shall be at least 20 years for homeowners’ multiple peril fire. …” In effect, this regulation prevents the use of predictive modeling, the mainstay of exposure assessment and accurate insurance pricing, and limits the scope of applicable data to the last 20 years. That might be acceptable if wildfire constituted a relatively stable exposure and if all aspects of the risk could be effectively captured in a period of two decades – but as the last few years have demonstrated, that is clearly not the case. As Roy Wright, president and CEO of the Insurance Institute for Business & Home Safety (IBHS), states: “Simply looking back might be interesting, but is it relevant? I don’t mean that the data gathered over the last 20 years is irrelevant, but on its own it is insufficient to understand and get ahead of wildfire risk, particularly when you apply the last four years to the 20-year retrospective, which have significantly skewed the market. That is when catastrophe models provide the analytical means to rationalize such deviations and to anticipate how this threat might evolve.” Simply looking back might be interesting, but is it relevant? I don’t mean that the data gathered over the last 20 years is irrelevant, but on its own it is insufficient to understand and get ahead of wildfire risk, particularly when you apply the last four years to the 20-year retrospective, which have significantly skewed the market. Roy Wright, president and CEO, Insurance Institute for Business & Home Safety (IBHS) The insurance industry has long viewed wildfire as an attritional risk, but such a perspective is no longer valid, believes Michael Young, senior director of product management at RMS. “It is only in the last five years that we are starting to see wildfire damaging thousands of buildings in a single event,” he says. “We are reaching the level where the technology associated with cat modeling has become critical because without that analysis you can’t predict future trends. The significant increase in related losses means that it has the potential to be a solvency-impacting peril as well as a rate-impacting one.” Addressing the Insurance Equation “Wildfire by its nature is a hyper-localized peril, which makes accurate assessment very data dependent,” Young continues. “Yet historically, insurers have relied upon wildfire risk scores to guide renewal decisions or to write new business in the wildland-urban interface (WUI). Such approaches often rely on zip-code-level data, which does not factor in environmental, community or structure-level mitigation measures. That lack of ground-level data to inform underwriting decisions means, often, non-renewal is the only feasible approach in highly exposed areas for insurers.” California is unique as it is the only U.S. state to stipulate that predictive modeling cannot be applied to insurance rate adjustments. However, this limitation is currently coming under significant scrutiny from all angles. In recent months, the California Department of Insurance has convened two separate investigatory hearings to address areas including: Insurance availability and affordability Need for consistent home-hardening standards and insurance incentives for mitigation Lack of transparency from insurers on wildfire risk scores and rate justification In support of efforts to demonstrate the need for a more data-driven, model-based approach to stimulating a healthy private insurance market, the CIPR, in conjunction with IBHS and RMS, has worked to facilitate greater collaboration between regulators, the scientific community and risk modelers in an effort to raise awareness of the value that catastrophe models can bring. “The Department of Insurance and all other stakeholders recognize that until we can create a well-functioning insurance market for wildfire risk, there will be no winners,” says Czajkowski. “That is why we are working as a conduit to bring all parties to the table to facilitate productive dialogue. A key part of this process is raising awareness on the part of the regulator both around the methodology and depth of science and data that underpins the cat model outputs.” In November 2020, as part of this process, CIPR, RMS and IBHS co-produced a report entitled “Application of Wildfire Mitigation to Insured Property Exposure.” “The aim of the report is to demonstrate the ability of cat models to reflect structure-specific and community-level mitigation measures,” Czajkowski continues, “based on the mitigation recommendations of IBHS and the National Fire Protection Association’s Firewise USA recognition program. It details the model outputs showing the benefits of these mitigation activities for multiple locations across California, Oregon and Colorado. Based on that data, we also produced a basic benefit-cost analysis of these measures to illustrate the potential economic viability of home-hardening measures.” Applying the Hard Science The study aims to demonstrate that learnings from building science research can be reflected in a catastrophe model framework and proactively inform decision-making around the reduction of wildfire risk for residential homeowners in wildfire zones. As Wright explains, the hard science that IBHS has developed around wildfire is critical to any model-based mitigation drive. “For any model to be successful, it needs to be based on the physical science. In the case of wildfire, for example, our research has shown that flame-driven ignitions account for approximately only a small portion of losses, while the vast majority are ember-driven. “Our facilities at IBHS enable us to conduct full-scale testing using single- and multi-story buildings, assessing components that influence exposure such as roofing materials, vents, decks and fences, so we can generate hard data on the various impacts of flame, ember, smoke and radiant heat. We can provide the physical science that is needed to analyze secondary and tertiary modifiers—factors that drive so much of the output generated by the models.” Our facilities at IBHS enable us to conduct full-scale testing using single- and multi-story buildings, assessing components that influence exposure such as roofing materials, vents, decks and fences, so we can generate hard data on the various impacts of flame, ember, smoke and radiant heat. Roy Wright, president and CEO, Insurance Institute for Business & Home Safety (IBHS) To quantify the benefits of various mitigation features, the report used the RMS® U.S. Wildfire HD Model to quantify hypothetical loss reduction benefits in nine communities across California, Colorado and Oregon. The simulated reductions in losses were compared to the costs associated with the mitigation measures, while a benefit-cost methodology was applied to assess the economic effectiveness of the two overall mitigation strategies modeled: structural mitigation and vegetation management. The multitude of factors that influence the survivability of a structure exposed to wildfire, including the site hazard parameters and structural characteristics of the property, were assessed in the model for 1,161 locations across the communities, three in each state. Each structure was assigned a set of primary characteristics based on a series of assumptions. For each property, RMS performed five separate mitigation case runs of the model, adjusting the vulnerability curves based on specific site hazard and secondary modifier model selections. This produced a neutral setting with all secondary modifiers set to zero—no penalty or credit applied—plus two structural mitigation scenarios and two vegetation management scenarios combined with the structural mitigation. The Direct Value of Mitigation Given the scale of the report, although relatively small in terms of the overall scope of wildfire losses, it is only possible to provide a snapshot of some of the key findings. The full report is available to download. Focusing on the three communities in California—Upper Deerwood (high risk), Berry Creek (high risk) and Oroville (medium risk)—the neutral setting produced an average annual loss (AAL) per structure of $3,169, $637 and $35, respectively. Figure 1: Financial impact of adjusting the secondary modifiers to produce both a structural (STR) credit and penaltyFigure 1 shows the impact of adjusting the secondary modifiers to produce a structural (STR) maximum credit (i.e., a well-built, wildfire-resistant structure) and a structural maximum penalty (i.e., a poorly built structure with limited resistance). In the case of Upper Deerwood, the applied credit saw an average reduction of $899 (i.e., wildfire-avoided losses) compared to the neutral setting, while conversely the penalty increased the AAL on average $2,409. For Berry Creek, the figures were a reduction of $222 and an increase of $633. And for Oroville, which had a relatively low neutral setting, the average reduction was $26. Figure 2: Financial analysis of the mean AAL difference for structural (STR) and vegetation (VEG) credit and penalty scenariosIn Figure 2 above, analyzing the mean AAL difference for structural and vegetation (VEG) credit and penalty scenarios revealed a reduction of $2,018 in Upper Deerwood and an increase of $2,511. The data, therefore, showed that moving from a poorly built to well-built structure on average reduced wildfire expected losses by $4,529. For Berry Creek, this shift resulted in an average savings of $1,092, while for Oroville there was no meaningful difference. The authors then applied three cost scenarios based on a range of wildfire mitigation costs: low ($20,000 structural, $25,000 structural and vegetation); medium ($40,000 structural, $50,000 structural and vegetation); and high ($60,000 structural, $75,000 structural and vegetation). Focusing again on the findings for California, the model outputs showed that in the low-cost scenario (and 1 percent discount rate) for 10-, 25- and 50-year time horizons, both structural only as well as structural and vegetation wildfire mitigation were economically efficient on average in the Upper Deerwood, California, community. For Berry Creek, California, economic efficiency for structural mitigation was achieved on average in the 50-year time horizon and in the 25- and 50-year time horizons for structural and vegetation mitigation. Moving the Needle Forward As Young recognizes, the scope of the report is insufficient to provide the depth of data necessary to drive a market shift, but it is valuable in the context of ongoing dialogue. “This report is essentially a teaser to show that based on modeled data, the potential exists to reduce wildfire risk by adopting mitigation strategies in a way that is economically viable for all parties,” he says. “The key aspect about introducing mitigation appropriately in the context of insurance is to allow the right differential of rate. It is to give the right signals without allowing that differential to restrict the availability of insurance by pricing people out of the market.” That ability to differentiate at the localized level will be critical to ending what he describes as the “peanut butter” approach—spreading the risk—and reducing the need to adopt a non-renewal strategy for highly exposed areas. “You have to be able to operate at a much more granular level,” he explains, “both spatially and in terms of the attributes of the structure, given the hyperlocalized nature of the wildfire peril. Risk-based pricing at the individual location level will see a shift away from the peanut-butter approach and reduce the need for widespread non-renewals. You need to be able to factor in not only the physical attributes, but also the actions by the homeowner to reduce their risk. Risk-based pricing at the individual location level will see a shift away from the peanut-butter approach and reduce the need for widespread non-renewals. You need to be able to factor in not only the physical attributes, but also the actions by the homeowner to reduce their risk. Michael Young, senior director of product management at RMS “It is imperative we create an environment in which mitigation measures are acknowledged, that the right incentives are applied and that credit is given for steps taken by the property owner and the community. But to reach that point, you must start with the modeled output. Without that analysis based on detailed, scientific data to guide the decision-making process, it will be incredibly difficult for the market to move forward.” As Czajkowski concludes: “There is no doubt that more research is absolutely needed at a more granular level across a wider playing field to fully demonstrate the value of these risk mitigation measures. However, what this report does is provide a solid foundation upon which to stimulate further dialogue and provide the momentum for the continuation of the critical data-driven work that is required to help reduce exposure to wildfire.”
Like Moths to the Flame
Why is it that, in many different situations and perils, people appear to want to relocate toward the risk? What is the role of the private insurance and reinsurance industry in curbing their clients’ risk tropism? Florida showed rapid percentage growth in terms of exposure and number of policyholders If the Great Miami Hurricane of 1926 were to occur again today it would result in insurance losses approaching US$200 billion. Even adjusted for inflation, that is hundreds of times more than the US$100 million damage toll in 1926. Over the past 100 years, the Florida coast has developed exponentially, with wealthy individuals drawn to buying lavish coastal properties — and the accompanying wind and storm-surge risks. Since 2000, the number of people living in coastal areas of Florida increased by 4.2 million, or 27 percent, to 19.8 million in 2015, according to the U.S. Census Bureau. This is an example of unintended “risk tropism,” explains Robert Muir-Wood, chief research officer at RMS. Just as the sunflower is a ‘heliotrope’, turning toward the sun, research has shown how humans have an innate drive to live near water, on a river or at the beach, often at increased risk of flood hazards. “There is a very strong human desire to find the perfect primal location for your house. It is something that is built deeply into the human psyche,” Muir-Wood explains. “People want to live with the sound of the sea, or in the forest ‘close to nature,’ and they are drawn to these locations thinking about all the positives and amenity values, but not really understanding or evaluating the accompanying risk factors. “People will pay a lot to live right next to the ocean,” he adds. “It’s an incredibly powerful force and they will invest in doing that, so the price of land goes up by a factor of two or three times when you get close to the beach.” Even when beachfront properties are wiped out in hurricane catastrophes, far from driving individuals away from a high-risk zone, research shows they simply “build back bigger,” says Muir-Wood. “The disaster can provide the opportunity to start again, and wealthier people move in and take the opportunity to rebuild grander houses. At least the new houses are more likely to be built to code, so maybe the reduction in vulnerability partly offsets the increased exposure at risk.” Risk tropism can also be found with the encroachment of high-value properties into the wildlands of California, leading to a big increase in wildfire insurance losses. Living close to trees can be good for mental health until those same trees bring a conflagration. Insurance losses due to wildfire exceeded US$10 billion in 2017 and have already breached US$12 billion for last year’s Camp, Hill and Woolsey Fires, according to the California Department of Insurance. It is not the number of fires that have increased, but the number of houses consumed by the fires. “Insurance tends to stop working when you have levels of risk above one percent […] People are unprepared to pay for it” Robert Muir-Wood RMS Muir-Wood notes that the footprint of the 2017 Tubbs Fire, with claims reaching to nearly US$10 billion, was very similar to the area burned during the Hanley Fire of 1964. The principal difference in outcome is driven by how much housing has been developed in the path of the fire. “If a fire like that arrives twice in one hundred years to destroy your house, then the amount you are going to have to pay in insurance premium is going to be more than 2 percent of the value per year,” he says. “People will think that’s unjustified and will resist it, but actually insurance tends to stop working when you have levels of risk cost above 1 percent of the property value, meaning, quite simply, that people are unprepared to pay for it.” Risk tropism can also be found in the business sector, in the way that technology companies have clustered in Silicon Valley: a tectonic rift within a fast-moving tectonic plate boundary. The tectonics have created the San Francisco Bay and modulate the climate to bring natural air-conditioning. “Why is it that, around the world, the technology sector has picked locations — including Silicon Valley, Seattle, Japan and Taiwan — that are on plate boundaries and are earthquake prone?” asks Muir-Wood. “There seems to be some ideal mix of mountains and water. The Bay Area is a very attractive environment, which has brought the best students to the universities and has helped companies attract some of the smartest people to come and live and work in Silicon Valley,” he continues. “But one day there will be a magnitude 7+ earthquake in the Bay Area that will bring incredible disruption, that will affect the technology firms themselves.” Insurance and reinsurance companies have an important role to play in informing and dissuading organizations and high net worth individuals from being drawn toward highly exposed locations; they can help by pricing the risk correctly and maintaining underwriting discipline. The difficulty comes when politics and insurance collide. The growth of Fair Access to Insurance Requirements (FAIR) plans and beach plans, offering more affordable insurance in parts of the U.S. that are highly exposed to wind and quake perils, is one example of how this function is undermined. At its peak, the size of the residual market in hurricane-exposed states was US$885 billion, according to the Insurance Information Institute (III). It has steadily been reduced, partly as a result of the influx of non-traditional capacity from the ILS market and competitive pricing in the general reinsurance market. However, in many cases the markets-of-last-resort remain some of the largest property insurers in coastal states. Between 2005 and 2009 (following Hurricanes Charley, Frances, Ivan and Jeanne in 2004), the plans in Mississippi, Texas and Florida showed rapid percentage growth in terms of exposure and number of policyholders. A factor fueling this growth, according to the III, was the rise in coastal properties. As long as state-backed insurers are willing to subsidize the cost of cover for those choosing to locate in the riskiest locations, private (re)insurance will fail as an effective check on risk tropism, thinks Muir-Wood. “In California there are quite a few properties that have not been able to get standard fire insurance,” he observes. “But there are state or government-backed schemes available, and they are being used by people whose wildfire risk is considered to be too high.”
A Climate Model Challenge
Insurance-linked securities (ILS) investors want to know more about how climate change impacts investment decisions, according to Paul Wilson, head of non-life analytics at Securis Investment Partners, an ILS asset manager We make investments that are typically annual to two-to-three years in duration, so we need to understand the implications of climate change on those timescales,” explains Paul Wilson, head of non-life analytics at Securis Investment Partners. “We reevaluate investments as part of any renewal process, and it’s right to ask if any opportunity is still attractive given what we know about how our climate is changing. “The fundamental question that we’re trying to address is, ‘Have I priced the risk of this investment correctly for the next year?’” he continues. “And therefore, we need to know if the catastrophe models we are using accurately account for the impact climate change may be having. Or are they overly reliant on historical data and, as such, are not actually representing the true current risk levels for today’s climate?” Expertise in climate change is a requirement for how Securis is thinking about risk. “We have investors who are asking questions about climate change, and we have a responsibility to be able to demonstrate to them that we are taking the implications into consideration in our investment decisions.” “We have investors who are asking questions about climate change, and we have a responsibility to demonstrate to them that we are taking the implications into consideration in our investment decisions Paul Wilson Securis Investment Partners The rate at which a changing climate may influence natural catastrophes will present both a challenge and opportunity to the wider industry as well as to catastrophe modeling companies, thinks Wilson. The results coming out of climate change attribution studies are going to have to start informing the decisions around risk. For example, according to attribution studies, climate change tripled the chances of Hurricane Harvey’s record rainfall. “Climate change is a big challenge for the catastrophe modeling community,” he says. “It’s going to put a greater burden on catastrophe modelers to ensure that their models are up to date. The frequency and nature of model updates will have to change. Models we are using today may become out of date in just a few years’ time. That’s interesting when you think about the number of perils and regions where climate change could have a significant impact. “All of those climate-related models could be impacted by climate change, so we have to question the impact that is having today,” he adds. “If the model you are using to price the risk has been calibrated to the last 50 years, but you believe the last 10 or last 20 years are more representative because of the implication of climate change, then how do you adjust your model according to that? That’s the question we should all be looking to address.”
ILS: A Responsible Investment Approach
As environmental, social and governance principles become more prominent in guiding investment strategies, the ILS market must respond In recent years, there has been a sharper focus by the investment community on responsible investment. One indicator of this has been the increased adoption of the Principles for Responsible Investment (PRI), as environmental, social and governance (ESG) concerns become a more prominent influencer of investment strategies. Investment houses are also seeking closer alignment between their ESG practices and the United Nations’ Sustainable Development Goals (SDGs). The 17 interconnected SDGs, set in 2015, are a call to action to end poverty, achieve peace and prosperity for all, and create a sustainable society by 2030. As investors target more demonstrable outcomes from their investment practices, is there a possible opportunity for the insurance-linked securities (ILS) market to grow, given the potential societal capital that insurance can generate? “Insurance certainly has all of the hallmarks of an ESG-compatible investment opportunity,” believes Charlotte Acton, director of capital and resilience solutions at RMS. “It has the potential to promote resilience through enabling broader access and uptake of appropriate affordable financial protection and reducing the protection gap; supporting faster and more efficient responses to disasters; and incentivizing mitigation and resilient building practices pre- and post-event.” RMS has been collaborating on numerous initiatives designed to further the role of insurance and insurance technologies in disaster and climate-change resilience. These include exploring ways to monetize the dividends of resilience to incentivize resilient building, using catastrophe models to quantify the benefits of resilience investments such as flood defenses, and earthquake retrofit programs for housing. The work has also involved designing innovative parametric structures to provide rapid post-disaster liquidity. “Investors will want a clear understanding of the exposure or assets that are being protected and whether they are ESG-friendly” Charlotte Acton RMS “ILS offers a clear route for investors to engage with insurance,” explains Acton, “broadening the capital pool that supports insurance is critical as it facilitates the expansion of insurance to new regions and allows the industry to absorb increasingly large losses from growing threats such as climate change.” Viewed as a force for social good, it can certainly be argued that insurance-linked securities supports a number of the U.N.’s SDGs, including reducing the human impact of disasters and creating more sustainable cities, increasing overall resilience levels and increasing access to financial services that enhance sustainable growth potential. While there is opportunity for ILS to play a large part in ESG, the specific role of ILS within PRI is still being determined. According to LGT Capital Partners ESG Report 2019, managers in the ILS space have, in general, yet to start “actively integrating ESG into their investment strategies,” adding that across the ILS asset class “there is still little agreement on how ESG considerations should be applied. However, there is movement in this area. For example, the Bermuda Stock Exchange, a primary exchange for ILS issuers, recently launched an ESG initiative in line with the World Federation of Exchanges’ Sustainability Principles, stating that ESG was a priority in 2019 “with the aim to empower sustainable and responsible growth for its member companies, listings and the wider community.” For ILS to become a key investment option for ESG-focused investors, it must be able to demonstrate its sustainability credentials clearly. “Investors will want a clear understanding of the exposure or assets that are being protected,” Acton explains, “and whether they are ESG-friendly. They will want to know whether the protection offered provides significant societal benefits. If the ILS market can factor ESG considerations into its approach more effectively, then there is no reason why it should not attract greater attention from responsible investors.”
Today's Stress Test for Tomorrow's Climate
Why the PRA’s stress test has pushed climate change to the top of (re)insurance company agendas As part of its 2019 biennial insurance stress test, the U.K. insurance industry regulator — for the first time — asked insurers and reinsurers to conduct an exploratory exercise in relation to climate change. Using predictions published by the United Nations’ Intergovernmental Panel on Climate Change (IPCC) and in other academic literature, the Bank of England’s Prudential Regulation Authority (PRA) came up with a series of future climate change scenarios, which it asked (re)insurers to use as a basis for stress-testing the impact on their assets and liabilities. The PRA stress test came at a time when pressure is building for commercial and financial services businesses around the world to assess the likely impact of climate change on their business, through initiatives such as the Task Force for Climate-Related Financial Disclosures (TCFD). The submission deadline for the stress-tested scenarios ended on October 31, 2019, following which the PRA will publish a summary of overall results. From a property catastrophe (re)insurance industry perspective, the importance of assessing the potential impact, both in the near and long term, is clear. Companies must ensure their underwriting strategies and solvency levels are adequate so as to be able to account for additional losses from rising sea levels, more climate extremes, and potentially more frequent and/or intense natural catastrophes. Then there’s the more strategic considerations in the long term — how much coverages change and what will consumers demand in a changing climate? The PRA stress test, explains Callum Higgins, product manager of global climate at RMS, is the regulator’s attempt to test the waters. The hypothetical narratives are designed to help companies think about how different plausible futures could impact their business models, according to the PRA. “The climate change scenarios are not designed to assess current financial resilience but rather to provide additional impetus in this area, with results comparable across firms to better understand the different approaches companies are using.” “There was pressure on clients to respond to this because those that don’t participate will probably come under greater scrutiny” Callum Higgins RMS RMS was particularly well placed to support (re)insurers in responding to the “Assumptions to Assess the Impact on an Insurer’s Liabilities” section of the climate change scenarios, with catastrophe models the perfect tools to evaluate such physical climate change risk to liabilities. This portion of the stress test examined how changes in both U.S. hurricane and U.K. weather risk under the different climate change scenarios may affect losses. The assumptions around U.K. weather included shifts in U.K. inland and coastal flood hazard, looking at the potential loss changes from increased surface runoff and sea level rise. While in the U.S., the assumptions included a 10 percent and 20 percent increase in the frequency of major hurricanes by 2050 and 2100, respectively. “While the assumptions and scenarios are hypothetical, it is important (re)insurers use this work to develop their capabilities to understand physical climate change risk,” says Higgins. “At the moment, it is exploratory work, but results will be used to guide future exercises that may put (re)insurers under pressure to provide more sophisticated responses.” Given the short timescales involved, RMS promptly modified the necessary models in time for clients to benefit for their submissions. “To help clients start thinking about how to respond to the PRA request, we provided them with industrywide factors, which allowed for the approximation of losses under the PRA assumptions but will likely not accurately reflect the impact on their portfolios. For this reason, we could also run (re)insurers’ own exposures through the adjusted models, via RMS Analytical Services, better satisfying the PRA’s requirements for those who choose this approach. “To reasonably represent these assumptions and scenarios, we think it does need help from vendor companies like RMS to adjust the model data appropriately, which is possibly out of scope for many businesses,” he adds. Detailed results based on the outcome of the stress-test exercise can be applied to use cases beyond the regulatory submission for the PRA. These or other similar scenarios can be used to sensitivity test possible answers to questions such as how will technical pricing of U.K. flood be affected by climate change, how should U.S. underwriting strategy shift in response to sea level rise or how will capital adequacy requirements change as a result of climate change — and inform strategic decisions accordingly.