Insurance and property finance
5.1
This chapter examines evidence received about the market for insuring
and financing buildings and infrastructure, particularly for insurance products
relating to residential properties. In doing so, it is noted that several
recent and ongoing inquiries relating to natural disasters have examined issues
regarding the pricing, availability and the terms and conditions of insurance,
including the following:
-
the 2009 Victorian Bushfires Royal Commission (2009–2010);
- the Queensland Floods Commission of Inquiry (2011–2012);
-
the Australian Government's Natural Disaster Insurance Review
(2011);
-
the inquiry conducted by the House of Representatives Standing
Committee on Social Policy and Legal Affairs into the operation of the
insurance industry during disaster events (2012);
-
the Productivity Commission's inquiry into the funding of natural
disasters in Australia (2014);
-
the Joint Select Committee on Northern Australia's inquiry into
the development of Northern Australia (2014);
- the Australian Government's Northern Australia Insurance Premiums
Taskforce (2015); and
-
the current inquiry being conducted by the Australian Competition
and Consumer Commission (ACCC) into the supply of residential building,
contents and strata insurance in Northern Australia.
5.2
Although it did not explicitly address matters relating to climate
change, the Senate Economics References Committee also completed an inquiry
into matters relating to the insurance industry in 2017. Among other matters,
that inquiry considered recent increases in the cost of insurance and the state
of competition and transparency in the marketplace.
5.3
Following the 2010–11 Queensland floods, the insurance arrangements for
state and territory government-owned assets were also reviewed.[1]
5.4
Many of the issues relating to climate change that have implications for
the insurance market also are relevant to property finance. Both insurers and
lenders need to manage risk and prudential requirements successfully. A key
point of difference is that property finance is long-term (such as 30-year
mortgages) whereas regular property insurance contracts are for 12 months.
Therefore, developments in short-term insurance contracts could influence
long-term property lending. In particular, rising insurance premiums in areas
considered at risk due to climate change will likely affect property values,
with consequences for the approach taken by financial institutions to lending
in those regions.
5.5
This chapter principally focuses on insurance as this received the most
attention in submissions and during the committee's public hearings.
Pricing of insurance products
5.6
Before examining the evidence relating to climate change, it is
instructive to consider how insurance products for buildings are developed and priced.
5.7
IAG explained that, fundamentally, insurance 'is a purchase for
consumers to transfer certain risks to an insurer'. In offering insurance
products to a customer, insurers 'identify and manage the costs of those risks
to ensure there are sufficient funds to meet the cost of future claims as they
arise'. In doing this, the likelihood of an event occurring that would result
in the customer making a claim, and the cost of that claim, are estimated.[2]
5.8
IAG argued that risk-based pricing through insurance premiums 'provides
an important signal to individuals and the communities of the level of exposure
to risks'. IAG also advised that this is widely recognised, with risk-based
price signals 'considered one of the most important roles that insurers play to
assist society to respond to natural perils'. IAG advised that the Geneva
Association's Risk Statement and the United Nation's Principles for Sustainable
Insurance 'both call for insurers to adopt this approach internationally'.[3]
5.9
IAG provided the following information about how it assesses risks
relating to climate change:
At IAG we have an internal team monitoring changes to the
climate and we price our policies year on year for the expected risks of the
following year. The long-term risks of climate change are difficult for us to
model as there are no certain data. However, our internal team works to
understand future climate scenarios so this information can help inform our
future strategy. As weather becomes more extreme with climate change, the year
on year risk will continue to increase.[4]
5.10
The use of risk-based pricing for determining premiums assists insurers
to ensure their businesses are sustainable. Policyholders are also protected
through prudential standards and supervision: the Insurance Council of
Australia noted that insurers are also required to 'maintain regulated amounts
of capital in order to pay claims'. The Insurance Council noted there is a
tension between risk and the required amount of capital holdings; that is, the 'higher the risk of claims being lodged,
the higher insurance premiums can be expected to be and the larger the capital
holdings held by the insurer'.[5]
Relationship between insurance and climate change risks
5.11
The implications of climate change are particularly relevant for insuring
buildings and the contents within them. For example, rising sea levels, flooding,
bushfires and storm surges could damage or destroy properties. Water-related
damage, including from sewage, soil, and mud, could leave buildings
contaminated and deemed uninhabitable.[6]
5.12
Damage from extreme events already results in high costs. For example:
-
the insurance losses from Cyclone Debbie are estimated to be
greater than $1.6 billion;[7] and
-
the Black Saturday bushfires resulted in an estimated $1.2
billion in claims (including claims relating to property, contents and motor
vehicles).[8]
5.13
Overall, the insurance industry advised that around $9 billion is paid
each year in Australia in response to insurance claims linked to extreme
weather events. Without climate change scenarios being taken into account (that
is, based only on factors such as changes in population size and distribution,
and changes in building costs), this figure is expected to increase to $39
billion by 2050.[9] The Insurance Council noted that the 'increasing migration and expansion of
Australian communities, along with their insured assets, into locations with
significant exposures to extreme weather has already contributed to growth in
disaster losses'.[10]
5.14
There is also evidence indicating that climate change is worsening the
insurance losses associated with extreme natural hazards. For example, Lloyd's
of London has estimated that, when all other factors are held constant, the
20-centimetre rise in sea level recorded at lower Manhattan since the 1950s
resulted in insured losses in New York City from Superstorm Sandy being 30 per
cent higher.[11]
5.15
As insurance is a product designed to manage exposure to particular
risks, it follows that expected changes in risks, such as those caused by
climate change, will affect insurance markets. As the Governor of the Bank of
England recognised in a speech given in 2015, the insurance industry has been
at the forefront of planning for climate change. Mr Carney observed:
While there is always room for scientific disagreement about
climate change (as there is with any scientific issue) I have found that
insurers are amongst the most determined advocates for tackling it sooner
rather than later. And little wonder. While others have been debating the
theory, you have been dealing with the reality...[12]
5.16
For property owners, the key issue with climate change for insurance is
how the price of insurance premiums will be affected. The remaining sections of
this chapter address this issue. Other issues that have previously caused
concerns following extreme events, such as the meaning of terms relied on in
insurance contracts, were not considered during this inquiry.
Recent developments affecting insurance affordability
5.17
In recent years, insurance premiums have increased significantly in
parts of northern Australia. A taskforce established by the Australian
Government concluded that the increased premiums follow insurers aligning
premiums more closely with the risk of damage to individual properties, and
that the increases in northern Australia are intended to 'more accurately
reflect the high risk of damage due to cyclones'.[13]
5.18
The taskforce found that the change in the setting of insurance premiums
'is not the result of any change in the behaviour of households, but has
been driven by the growth in technology and competition in insurance markets
and reassessments of the risk of cyclone damage'. Developments cited in support
of this conclusion were:
- that more complete datasets regarding risk, greater computing
power and improvements in models for estimating risks have enabled insurers to
'increasingly set premiums on properties in northern Australia in line with the
risk that the individual property brings to the pool';
-
losses experienced from events such as Cyclone Yasi; and
- reassessment of catastrophe reinsurance informed by advances in
catastrophe modelling—that is, insurers have reallocated a greater share of the
overall cost of reinsurance to premiums in northern Australia to account for the
'higher frequency of cyclones in northern Australia than, say, earthquakes in
capital cities'.[14]
5.19
In commenting on the role of the insurance market in relation to regions
that have a history of natural hazards, or are otherwise considered to be at an
elevated risk of experiencing such hazards, the insurance sector highlighted
how a well-functioning insurance market has assisted communities to recover
from such events. For example, the Insurance Council submitted that:
Without a sustainable insurance market, events like Cyclone
Debbie would leave communities, businesses and individuals with little or no
ability to recover from these frequent natural disasters. Without insurance
being available, national, local and individual economies must absorb these
substantial shocks and losses from within their own resources, or suffer the
loss without recovery, ultimately restricting growth and development.[15]
5.20
IAG noted that insurance 'plays an important role in keeping the general
costs of post disaster recovery down'. Without a well-functioning insurance
market or if insurance was to become unaffordable, IAG argued that 'the
Government may be called on to cover more of the costs to rebuild communities
following an extreme weather event'.[16]
Implications for the future affordability and availability of insurance and
property finance
5.21
As noted above, it is expected that the total amount paid in response to
insurance claims each year is expected to increase from $9 billion in 2018 to
$39 billion by 2050 based on factors such as changes in population size
and distribution, and changes in building costs.[17] Climate change is also expected to result in the increased frequency or
intensity of extreme weather events. Accordingly, the Insurance Council observed
that:
...any potential changes to the severity and frequency of
extreme weather events, brought on by climate change, will occur in an
environment where extreme weather has already become more devastating and
expensive for many Australian communities.[18]
5.22
These developments are expected to have implications for the
affordability of insurance. At present, the Insurance Council advised that
nowhere in Australia is uninsurable, however, 'there are plenty of locations
where it's costing a lot of money to insure your property compared to safer
locations'.[19]
5.23
The National Insurance Brokers Association of Australia (NIBA) argued
that if 'the experience of insurance losses over the past 10 years continues,
property insurance in Australia will start to become unaffordable'. NIBA added
that many property owners in northern Queensland already face this situation.[20] Lake Macquarie City Council similarly observed that the insurance premiums of
at-risk properties are expected to rise due to climate change, 'potentially
making insurance unaffordable for some'.[21] Likewise, the National Climate Change Adaptation Research Facility (NCCARF)
commented that in areas where 'risk is known and high', property owners are
often underinsured or uninsured due to insurance either not being available or
prohibitively expensive.[22]
5.24
Evidence of significant amounts of uninsured properties and underinsured
properties (that is, where the sum insured does not cover the rebuilding cost)
have also been revealed in the aftermath of disasters. Following the 2009 Black
Saturday bushfires, it was estimated that around '13 per cent of destroyed
residential properties might have been without insurance cover'. In addition,
there was 'ample evidence of under-insurance'.[23] Evidence given by the Insurance Council indicated that the extent of
underinsurance is clearest following bushfire events, as it is rare that other
events cause a customer to reach the maximum limit of the sum insured.[24]
5.25
An additional consideration is that some of the areas with a heightened
risk of climate change are also areas where the cost of claims has been
increasing due to higher construction and repair costs. As Mr Karl Sullivan
from the Insurance Council explained, this places further upwards pressure on
insurance premiums:
We recently completed a little piece of work looking at the
cost of rebuilding around Australia. If you take a model home in Frankston in
Victoria and say, 'This is the home that we're going to build all around
Australia,' that same home will cost you 42 per cent more to build in the city
of Darwin. That's because the building codes are more extensive up there to
deal with the cyclone threat. But, put in very simple terms, the cost of a
carpenter, a bricklayer and a roofer is much higher. The cost of all your
building supplies is much higher. Their costs in terms of electricity and fuel
and all the other inputs are much, much higher. If you go to Cairns it's about
30 per cent higher. If you go over to Broome, it's around 38 or
39 per cent higher. So, just taken on a like-for-like basis, a premium would be
42 per cent higher in Darwin, all things being equal—not even considering
that there might be a higher frequency of cyclones.[25]
5.26
Furthermore, IAG noted that existing risk issues evident in some regions
could spread to other areas that are considered low-risk at present, due to
changes and increases in natural peril risks linked to climate change.[26]
5.27
As insurance premiums cover a short period, insurance customers might
not appreciate the future consequences of climate change-related risks in a
timely manner. Lake Macquarie City Council advised that it has 'received clear
advice from the insurance industry that it does not consider future climate in
determining insurance premiums as insurance policies are typically for a
12-month period, and therefore consider only the risks associated with current
climate hazards'.[27]
5.28
In explaining this approach, the Insurance Council noted that, although insurers
have access to long-term risk analysis such as projected flood mapping for
2100, the sector has to balance the costs associated with insuring the next 12
months and longer-term affordability. Mr Karl Sullivan from the Insurance
Council explained:
You can imagine the outcry from the community if insurers
started insuring as if those scenarios were here today. We have to strike a
balancing act between what we're insuring in the next 12 months—and what those
costs might be and how we might drive those down—and this longer term view
about: what policies can be changed and tweaked now in a very real practical
sense on the ground through development control plans and the National
Construction Code to make sure that what these guys are underwriting in 80
years' time is still affordable to underwrite.[28]
5.29
It was also noted that insurance policies often do not cover repairs
that improve resilience, such as raising flood-affected floor levels in houses
that are damaged during an extreme event.[29]
5.30
The management of climate risks through appropriate urban planning,
defensive infrastructure and building regulations also has implications for the
scale of possible damage and the size of insurance claims. For example, it was
noted that a 2014 study undertaken by CSIRO concluded that at least half of the
direct damage to residential housing from coastal inundation, extreme winds,
bushfire and inland flooding could be avoided through proactive intervention
applying well-known measures. CSIRO advised that, in present value terms, the
cost of intervention is generally one-tenth of the damages avoided or less.[30]
5.31
The committee also received evidence suggesting that lenders are
declining to provide finance for buildings in at-risk areas. Regional
Development Australia – South West (RDA South West) argued that, like insurance
companies, lenders are similarly using climate simulation models to calculate
their exposure to risk.[31]
5.32
It is noteworthy that extreme weather events have resulted in insurance
and lending becoming unavailable in other countries. Although such outcomes are
considered rare, the Governor of the Bank of England referred to examples in
the Caribbean where storm patterns meant householders could not get insurance
cover. This prompted 'mortgage lending to dry up, values to collapse and
neighbourhoods to become abandoned'.[32]
5.33
In the United Kingdom, issues with insurance affordability in high flood
risk areas resulted in the establishment of a flood re-insurance scheme known
as Flood Re. Under this scheme, additional insurance costs associated with a
high risk of flooding are funded by a levy on the insurance industry.[33]
Responses and future directions
5.34
The Insurance Council of Australia commented that the industry is
undertaking activities to assist policy makers and communities to address the
implications of climate change. These activities include:
- maintaining strong prudential foundations to ensure that the
industry continues to be able to respond to large extreme weather events when
they occur;
- ensuring that insurance products deliver competitive price
signals through risk‑based pricing that assist communities and decision-makers
to recognise and adapt to current and emerging extreme weather risks; and
- assisting to increase community resilience to extreme weather
over time by sharing industry expertise to help policy decision-makers and the
community.[34]
5.35
In the final report of the Northern Australia Insurance Premiums
Taskforce, it was suggested that governments could provide additional
funding for research to 'improve mitigation options particularly for roof
strengthening and water ingress'.
The Taskforce also recommended that mitigation could be enhanced through
education campaigns encouraging property owners to improve the resilience of
their properties, as well as through public works. The Taskforce further
suggested that governments could subsidise the cost of mitigation works for low-income
households.[35]
5.36
In its response to the Northern Australia Insurance Premiums Taskforce,
the Australian Government indicated that it would not intervene directly in the
insurance market and would instead proceed with reforms intended to 'place
downward pressure on insurance premiums through increased accountability and
transparency within the industry, as well as proposals to increase consumer
understanding of insurance'. Specifically, the Government:
- urged the Insurance Council of Australia to expedite work on
reforming the General Insurance Code of Practice;
- will introduce legislation to extend the unfair contract term
provision in the Australian Consumer Law to insurance contracts; and
- will require the Australian Securities and Investments Commission
and Treasury to undertake work that will assist consumers to understand their
insurance needs, and to enhance transparency and disclosure practices in the
insurance sector.[36]
5.37
Despite the concerns about rising premiums, the insurance sector
maintained that risk-based pricing provides a useful signal for promoting and
guiding adaptation. The Insurance Council submitted that:
The insurance industry can assist governments and the
community to adapt to today's residual risk and how those risks may grow into
the future. The price signals offered by the market must be heeded rather
than supressed, and used to motivate targeted mitigation and building design
choices.[37]
5.38
The ability for price signals to provide suitable incentives for individuals
to manage their risk was recognised by non-industry submitters; for example, RDA South
West stated that 'to some extent these market forces will manage consumer
decisions better than government regulation'.[38]
5.39
Nevertheless, insurance industry participants are also aware that a
potential outcome of risk-based pricing is that insurance products could become
unaffordable for some property owners. IAG submitted that it is 'aware that
responding to risk through pricing alone may affect our relationship with our
customers, governments and the broader community'. To address long-term issues
facing the insurance market, IAG argued there is a need for 'government and the
insurance industry to align thinking and work with the community to reduce,
manage and adapt to the risks they face'.[39]
5.40
Similarly, the Insurance Council of Australia argued that a 'new
partnership between governments and the general insurance industry on climate
change adaptation would assist the community'. The Insurance Council added that
tools and programs it has developed could assist local governments and the
community to understand how risks might increase. In particular, it referred to
its Hazard DataGlobe, the Building Resilience Rating Tool, and the Property
Resilience and Exposure Program. The Insurance Council explained that the
latter program 'has been designed to assist local governments to identify risk
hotspots in their community and to examine the cost benefits of mitigation
options to reduce those risks'.[40]
5.41
Another potential approach was noted by Professor Lesley Hughes, who
reasoned that there might be a role for government in future to regulate
insurance companies as to where 'they have a right not to insure or what they
compulsorily must insure'.[41]
5.42
It was argued that there is a need for greater coordination between
different levels of government on these issues, including by governments
agreeing to a 'clear and consistent strategy to mitigate the nature and extent
of losses that can and do arise from major weather events that regularly occur
across Australia'.[42]
5.43
The need for information about climate and exposure risk was also
recognised. From the perspective of individuals dealing with lenders, RDA South
West argued that there 'should be complete transparency for home buyers on disaster
risk profiles so consumers can make more informed decisions'.[43] For the insurance industry, it was emphasised that accurate information about
risk is necessary to avoid a 'contagion' effect. Sustainable Business Australia
explained:
While only a small proportion of Australian housing might be
ultimately at risk of falling value due to climate change, it should be
remembered that a "contagion" effect has been observed in other
markets where sudden repricing of risk occurred, particularly where there is
limited information available about the extent of risk throughout the market.
Relatively low levels of outright losses on subprime mortgages precipitated the
financial crisis. Climate change has terrible implications for both insurers,
as specialists in risk, and their customers—and by extension, for society at
large. In a worst-case scenario, an insurer collapsing due to unforeseen
natural disaster losses would obviously result in devastating social costs, in
addition to the obvious financial ones.[44]
5.44
In the United Kingdom, the Governor of the Bank of England has urged
insurers to be 'unrelenting' in pursuing improvements in risk modelling.[45]
5.45
To address climate change risks, the Insurance Council argued that
appropriate revisions to land-use planning schemes (discussed in Chapter 4) and
building codes (discussed in Chapter 6) are required. In addition, it argued
that 'localised defensive infrastructure' would help ensure communities are
able to be maintained and insured in the future.[46]
5.46
Similarly, IAG recommended that infrastructure, planning and zoning
requirements be reviewed, as well as research undertaken into building codes to
ensure they are adequate to meet the risks of future extreme weather events. It
also argued for the continued creation of open data sets on current risks and
weather patterns, and that community efforts to adapt and improve resilience
should be encouraged and rewarded.[47]
5.47
The Northern Territory Government also commented on these issues.
It submitted that:
It may be possible in some circumstances to mitigate the
impact of climate change through engineering solutions such as the construction
of flood basins or diversion barriers to limit the impact of flood waters on
valuable assets, thereby reducing risks, and presumably insurance premiums.
It may be beneficial to improve information, mapping and data
to improve forecasts of the impact of extreme events. Reviewing or upgrading
engineering and building standards, and more rigorous compliance against these
may be other options. Anything that can be done to reduce the uncertainty of
whether infrastructure and assets will be affected, and how they will perform
when they are, is likely to minimise the upward pressure on insurance premiums.[48]
5.48
Since the committee's evidence on insurance matters was received, there
has been a development regarding the Australian Government's approach to
improving the resilience of communities to natural disasters. In April 2018,
the Minister for Law Enforcement and Cyber Security announced the creation of a
Natural Resilience Taskforce to 'lead nation-wide reforms to reduce the impact
and financial burden of disasters on our communities and economy'. The Minister
explained that the taskforce, in consultation with the state and territory
governments and the finance and insurance sectors, would 'develop a five-year
national disaster mitigation framework to reduce the impact of disasters'.[49]
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