I am conscious of the difficulties that the absence or withdrawal of flood insurance cover can cause to homeowners and businesses, and that is one of the reasons the Government has been prioritising investment in flood defences over the last number of years.
However, you should be aware that provision of insurance is a commercial matter for insurance companies, which is based on a proper assessment of the risks they are willing to accept. This assessment will in many cases include insurers own presumptions based on their private modelling and research. Consequently, neither I as Minister for Finance nor the Central Bank of Ireland can interfere in the provision or pricing of insurance products or have the power to direct insurance companies to provide flood cover to specific individuals or businesses. This position is reinforced by the EU framework for insurance (Solvency II Directive) which expressly prohibits Member States from doing so.
In May last year, the OPW completed the most extensive and comprehensive study on flood risk through the National Catchment-based Flood Risk Assessment and Management (CFRAM) Programme which identified the flooding risk to 300 communities. The Flood Risk Management Plans prepared under the CFRAM Programme identify 118 flood relief schemes in addition to the 35 flood relief projects that are already in design and development under the existing capital programme.
Current government policy in relation to increasing flood insurance coverage is focused on the development of a sustainable, planned and risk-based approach to managing flooding problems. This it believes should in turn lead to the increased availability of flood insurance. To achieve this aim there is a focus on:
- prioritising spending on flood relief measures by the Office of Public Works (OPW) and relevant local authorities,
- implementation of flood relief management plans by the OPW to implement flood relief schemes, and
- maintaining channels of communication between the OPW and the insurance industry, in order to reach a better understanding about the provision of flood cover in marginal areas.
This commitment is underpinned by a significant capital works investment programme to be delivered by the OPW and Local Authorities, and complemented by a Memorandum of Understanding between the OPW and Insurance Ireland, which provides for the exchange of data in relation to completed flood defence schemes.
The nature of this arrangement is that, overall, there has been an increase in the provision of flood insurance cover observed in areas protected by these schemes over the period 2015 to 2019, according to Insurance Ireland Flood Survey Results.
I have not discussed the issue of flooding in Dublin 3 directly with Insurance Ireland. However, my officials are in regular contact with both Insurance Ireland and the OPW regarding proposed and completed flood defence schemes around the country and how the levels of insurance cover might be improved in areas where flood defence works have been completed.
You should also note that I have been advised by the OPW that in relation to the schemes located in Dublin 3 (The Tolka - East Wall Scheme, the Tolka - Hawthorne Terrace Scheme, and elements of the Tolka - Richmond Road Scheme) that all have been built to the 1/100 year standard, and that information in relation to these schemes has been shared with Insurance Ireland under the Memorandum of Understanding.
Finally, you should be aware that a consumer can make a complaint to the Financial Services and Pensions Ombudsman in relation to any dealings with a Financial Services or Insurance provider during which they feel they have been unfairly treated. In addition, individuals who are experiencing difficulty in obtaining flood insurance or believe that they are being treated unfairly may contact Insurance Ireland which operates a free Insurance Information Service for those who have queries, complaints or difficulties in relation to insurance ((01 676 1914 or email@example.com).