BIBA response to Defra proposals for consultation on a national flood emergency framework

BIBA response to Defra proposals for consultation on a national flood emergency framework
The British Insurance Brokers’ Association (BIBA) is the UK’s leading general insurance intermediary organisation. We represent the interests of insurance brokers, intermediaries and their customers.

BIBA represents 2,300 insurance intermediaries including 98 of the UK’s top 100 insurance intermediaries. Our members handle about half the value of all UK home, contents, motor, travel, commercial and industrial insurance policies. Independent insurance intermediaries distribute nearly two-thirds of all UK non-marine general insurance, of which BIBA members account for more than 80%. They also introduce an estimated £20 billion of premium income into London’s insurance market each year.

BIBA is pleased to have the opportunity to respond to the Defra proposals for consultation on a national flood emergency framework.

Our responses to the 16 questions set out are as follows:

1. Do you agree that the approach outlined above (resulting in more bespoke, local advice on possible and actual flooding) would help emergency responders and planners to make good decisions on when to activate emergency plans, and escalate or de-escalate their response?

Yes we agree with the approach outlined in the consultation document for more bespoke local advice on possible and actual flooding. The environment agency 4 stage flood warning service, (Flood watch, Flood warning, Severe flood warning, All clear), is a user friendly system that we in the insurance broking sector are happy to help promote and include on our website and in press communications. The new forecasting centre and direct advice should help emergency responders.

We are concerned that currently there is still no single body responsible for surface water.

It is important that the advice filters down to all appropriate stakeholders (Local resilience forums responsible for householders and business) in the region and that the system is tested regularly.

Communicating the 4 stage flood warning service should be made in a variety of ways eg. on the websites of the local Parish and town council. LRF’s awareness of the service could be raised if the local council includes detail with their literature eg. Council tax bills. Utility companies could also do this with your water bill. (flagged appropriately) Special consideration should be made for disabled people and the elderly. Neighborhood watch schemes should also be liaised with.

2. What are the risks or potential issues for you or your organisation?

There are risks of false alarm, meaning some premises are vulnerable to crime if evacuated unnecessarily. But this is low level. Continued promotion of business continually planning for the SME sector is vital and insurance brokers can help with this. There is the potential that flood insurance will be harder to obtain and will become expensive if the government fail to implement Sir Michael Pitts recommendation.

3. How might the Environment Agency improve the effectiveness of public information on flood warnings leading up to an incident?

They could include the insurance sector in the communications, this would help our sector to respond faster and minimise loss to the property and the resultant suffering of people and business. The ‘flood line warning direct’ could be more heavily promoted.

4. Do you agree that the division of responsibilities outlined in the Annex is the right one to ensure that planning for and responding to flood emergencies is effective and comprehensive?

Yes, this seems a suitable division. We would like to comment that this is a complicated web of different bodies. (DEFRA, EA, HPA, PCT, DWA, STAC, COBR, NCC, CLG, LRF’s, GO’s RRT’s, COI, SCG, FRSNCC, MET OFFICE, HIGHWAYS, RRF’s, RCCC’s and MILITARY) and therefore it is vital that UK central government or national lead body keeps all the communication and co-operation functioning during times of pressure. Would the NCC be the appropriate body for the responding to flood emergencies, and DEFRA for planning? The combined result of the division of responsibility must be easily and clearly available to all participants, similar to a well constructed business continuity plan.

5. Are there things missing, or bigger gaps which need to be filled?

There is no mention in the consultation document of insurance. Insurance brokers however, are a key facilitator in co-coordinating recovery from flood. The insurance industry plays a key role in advising on flood protection of properties and businesses, and total engagement in the event of a flood disaster. We organise temporary re-housing, repairs and all other work to ensure that properties can be re-occupied safely and, if possible, improved to be more resilient to further flooding in the future. We also play a key role in maintaining the availability of flood insurance in the future and at an affordable cost. BIBA also has a special scheme for properties at risk of flood that can offer cover that is not normally available.

6. If so, who should fill those gaps and how?

BIBA is the trade body that most closely represents the insurance interests of consumers and businesses through insurance brokers. We are attempting to help those people who do not have insurance at present but do need protection from flooding. The ABI and CILA should also be involved.

7. Do you agree that the new and planned arrangements referred to above will provide what emergency responders, and those whose health and/or social care may be affected by flooding, actually need?

The emergency responders need to have very clear guidance. The framework does not mention specific support for those who are vulnerable (the elderly and infirm) and how their health needs and or social care may be affected.

8. How valuable is the preliminary flood planning guidance and how might it be improved?

It is vital as it minimises risk to health/life and could mitigate property damage and financial loss. BIBA would like to offer their support in this guidance process. We believe the guidance needs to reach all businesses and consumers and we call on the government to support a national campaign to raise awareness of the guidance.

9. What further guidance or assistance do LRFs need to complete work on updating and improving their flood plans?

Please see our response to question 4.

10. Do you agree that there is a need for more formal guidance and advice on emergency planning for flood events that extend beyond the local level?

Yes, flood waters do not respect administrative boundaries and formal guidance on a regional basis would be beneficial. There is a need for more formal guidance with a master template for each region to incorporate neighboring regions that may be similarly affected and in need of support. However, it is important that each region is funded sufficiently and doesn’t rely on assistance from other regions.

11. From your perspective, what are the key factors for effective planning for the consequences of dam breach/ reservoir inundation?

Scenario planning including evacuation plans, and early warning systems. It is essential that local water authorities are closely involved and liaise with the local council, deliberate acts of terrorism issue should also be included.

12. Will the newly developed guidance for local authorities lead to increased and improved mutual aid arrangements between local authorities?

We believe it should do.

13. If not, what is needed to make this happen?

The Government need to give it sufficient support so it can be prioritised.

14. What role should LRFs and RRFs play in developing and calling upon mutual aid arrangements in the event of a flooding emergency in their area?

They should have a pre agreed plan in place of how to help their neighbouring areas. But they must not be relied upon by their neighbours in case they are inundated themselves.

15. What sort of mutual aid arrangements do we need to ensure the deployment of suitable equipment and trained people from multiple agencies in the event of an urgent need to rescue people from flood waters?

Local water board professionals should be able to offer support eg. Diver/Canoe clubs offering services on top of the agencies main plans. a list of available contacts should be updated and easily available. There must be a wider system of support eg available boats and who can pilot them in an emergency.

16. Do you agree that we should invest in developing and maintaining a new electronic, aggregated, accessible and easily updatable compendium of information, advice and guidance owned and maintained collectively by central departments and agencies?

Yes, BIBA would like to be involved in contributing to this compendium.

BIBA believes these issues are of great importance to the insurance industry. BIBA will, on behalf of its members, continue to promote the availability of flood insurance through its expert members who have a wealth of knowledge and experience. However we believe it is important not to underestimate the impact of climate change, the government must continue to action the recommendations from the Pitt report to ensure the continual availability of affordable flood cover in the UK.

BIBA would request that they be included on any further Defra consultation papers or communications in respect of this subject going forwards.

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