Dr. Swenja Surminski:

Regarding transparency, there are certain elements, for example, when one starts with a flood insurance policy or the policy documentation. This has been one of my concerns and the same applies to the UK. There is just no indication of someone's risk level on policy documentation. A person renews his or her policy, receives the policy document and pays a premium but it does not really tell him or her anything about the specific risk. There is no reason why insurers could not do that. The next step involves explaining what options would exist, for example, if an insurance company assessed the risk and the consumer did not agree. It creates that first step and there then needs to be a process. The latter exists in some countries. For example, there is a mechanism in Australia where there are certain forms policyholders can complete if they disagree with that assessment and they can then launch that appeal to Insurance Australia and start a dialogue. This is just an example but one needs to start somewhere with transparency. When it comes to pricing, clearly, that is a commercial decision on the part of insurers. Transparency is more difficult in this area because one is not pricing just for floods but for the entire package. Again, however, it could be argued that there could be greater transparency regarding how the rates might be affected by flood risk. That works in other countries as well, so these are two examples.

In a situation where there is evidence of a flood defence scheme being put in place, being tested and working, there is no reason why that should not feature in the flood risk models insurers use. Having said that, there are lots of other potential reasons which might count against an insurer underwriting in that particular region and which might have nothing to do with flood risk. Again, this comes back to the point about transparency. There could be a mechanism whereby there is a degree of disclosure regarding the decision about not granting cover. There needs to be an explanation attached to such a decision. From experience, I know it is quite difficult to then pinpoint where the efforts are exhausted because the question arises as to what one expects from a shop owner, for example. How many efforts does a shop owner need to make before he or she comes to the conclusion that there is no insurance cover available? This is something that needs to be looked into to because if someone has called ten insurers or five brokers, does that mean that the person is uninsurable? There is probably a mechanism - possibly with Insurance Ireland - that could be simplified and some sort of signposting - such as a dedicated service for people who are struggling to access insurance - put in place. These are things that have been tried and explored in other countries, so there is scope to do that.