Independent TD Carol Nolan says she has been contacted by a number of constituents who have been informed by their insurance providers that they are facing premium increases of up to 400% on the basis that their residential properties are listed on the OPW’s National Indicative Fluvial Mapping (NIFM).
This comes despite confirmation the TD has received from the Minister of State for the OPW Kevin Boxer Moran that the NIFM only provide an indication of areas that may be liable to flooding and are not suitable to assess the flood risk associated with individual properties or point locations, or to replace a detailed site-specific flood risk assessment.
The OPW has also confirmed to Deputy Nolan that while the OPW has no plans at this time to update these indicative flood maps, the Disclaimer and Conditions for Use of OPW flood maps includes a provision that users of the website must not use the flood maps, or any other content of the website for commercial purposes.
As such, Deputy Nolan said, the Disclaimer prevents insurance companies from using the flood maps generated by the OPW:
“This is a profoundly distressing issue for the Offaly homeowners who have contacted me. Some of them have been told that their residential premiums will now rise from €600 to over €3000 and all on the basis of OPW maps that the insurance companies are prohibited from using in this way and despite the fact that the homes in question have never flooded at any point over the last 50 or 100 years,” said Deputy Nolan.
“Insurance Ireland has apparently highlighted to the OPW that it does not use the OPW flood maps to inform its flood modelling and the decision on whether to offer insurance, the level of premiums charged, and the policy terms applied are matters for individual insurers.”
“But that rule is clearly being flouted and people are being fleeced because of it.”
“When my constituents challenged their insurance providers on the 400% increase, they were specifically told that this was because they had classified the property as high risk solely based on the OPW’s flood maps.”
“I am calling for an urgent investigation into this matter so we can establish how widespread this problem is. If it is happening in Offaly, it is almost certainly happening elsewhere and not just for residential properties either.”
“I will be raising the issue directly with the Department of Finance who have policy responsibility for flood insurance reform and engagement with the sector. Government must intervene and demand accountability from individual providers.
“Insurance companies cannot and should not treat the OPW flood maps as if they were some kind of treasure map that can be weaponised and used to source and extract exorbitant and unjustifiable premiums from struggling homeowners,” said Deputy Nolan.
Minister Boxer Moran previously told the Dáil in April that “the Department of Finance engages with the insurance industry on all aspects of insurance reform, including flood cover issues. These matters are a priority for the Government and efforts continue to be made to encourage a responsive approach to the provision of flood insurance from the insurance industry. The Minister of State at the Department of Finance with special responsibility for Financial Services, Credit Unions and Insurance Robert Troy recently met with the CEOs of the major insurers where he strongly emphasised to industry the need to take a reasonable approach to the provision of cover where properties are proven to be in low risk areas, including after investment in flood defences.”
“The OPW has a role to assist insurance companies to take into account the protection provided by completed flood defence schemes. In this regard, the OPW has a Memorandum of Understanding (MoU) with Insurance Ireland, the representative body of the insurance industry. The MoU sets out principles of how the two organisations work together to ensure that appropriate and relevant information on these completed schemes is provided to insurers to facilitate, to the greatest extent possible, the availability to the public of insurance against the risk of flooding.”
“While the MoU does not guarantee the availability of insurance, Insurance Ireland members have committed to take into account all information provided by the OPW when assessing exposure to flood risk within these protected areas.”
A Working Group operates under the MOU for the purpose of sharing data with the insurance industry. The data provided by the OPW is based on the detailed design of completed flood relief schemes. The OPW and Insurance Ireland have completed a review of the MoU that is in place since 2014. The MoU has been circulated by Insurance Ireland to its members for their consideration and formal sign off of the MoU is expected shortly. The current MoU continues in operation pending the sign-off of the new MoU,” he said.
“The OPW, through the Catchment Flood Risk Assessment and Management (CFRAM) Programme, carried out the largest ever flood risk study in Ireland to date, which assessed 80% of properties at risk from Ireland’s main causes of flooding. The OPW Flood Maps, that show the flood risk for 300 communities, are a key output of the study together with 29 Flood Risk Management Plans, with the proposed flood relief measures to address the flood risk in each community,” he added.
“The Flood Maps are available to the public at www.floodinfo.ie however, it is important to note that they are community based maps. The maps were not designed to designate individual properties at risk. Therefore they do not show individual properties and they do not identify if a property close to an extent is, or is not, within an area at risk of flooding. The maps show the probable extent of flooding based on future projections.”
The Disclaimer and Conditions for Use of OPW Flood Maps on www.floodinfo.ie includes a provision that users of the website must not use the Flood Maps, or any other content of the website for commercial purposes. As such, the Disclaimer prevents insurance companies from using the flood maps generated by the OPW,” the Minister said.
“The insurance industry has its own flood modelling tools for assessing the level of risk that it is willing to underwrite in relation to individual properties. It has highlighted to the OPW that it does not use the OPW Flood Maps to inform its flood modelling. The decision on whether to offer insurance, the level of premiums charged and the policy terms applied are matters for individual insurers. Insurance companies make commercial decisions on the provision of insurance cover based on their assessment of the risks they would be accepting on a case-by-case basis. Neither the Minister for Finance or the Central Bank of Ireland can direct the provision or pricing of insurance products, in accordance with the EU framework for insurance (Solvency II Directive).”