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Monroe County’s Mitigating F f Wi d D Factors for Wind Damage Prepared by the Grassroots Organization FIRM Fair Insurance Rates in Monroe November 10, 2009

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Page 1: Monroe County’s Mitigating F f Wi d DFactors for Wind Damage · 2010. 11. 23. · Metal Roofs (continued) There are more metal roofs in Monroe County than anyThere are more metal

Monroe County’s Mitigating F f Wi d DFactors for Wind Damage

Prepared by the Grassroots Organization FIRMFair Insurance Rates in Monroe November 10, 2009

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ArgumentArgument

Monroe County’s windstorm insurance rate increase should be ydenied. Actual experience indicates that claims paid in Monroe County are less than claims paid in other areas of the state. This is due to a variety of factors relating to:

Construction Geography Meteorology

The proposed increase from Citizens Property Insurance Corporation should be denied because CPIC has not presented an actuarially sound rate that adequately addresses these verifiable factors Monroe Co nt has a histor of b ilding strong str ct resfactors. Monroe County has a history of building strong structures – a practiced being encouraged throughout the state – and this should be reflected in our windstorm insurance rates.

November 13, 2009Slide 2

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Wind Rating ModelsWind Rating ModelsComputer models are used to predict wind risk. Models predict highest windstorm damage in Monroe

County. Actual hurricane wind experience does not support p pp

these high rates.Models inaccurately predict wind risk for Monroe County risk because: Do not reflect Monroe County construction standards Do not accurately model roof cover and sheathing Overstate strike probabilities compared to other Overstate strike probabilities compared to other

coastal areas Do not accurately allocate damage from wind versus

water (storm surge)November 13, 2009Slide 3

water (storm surge)

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Wind Rating Models(continued)

Models are only as good as the data that is input into them. FIRM believes that data related to the issues in this presentation currently is not provided for Monroe County.

November 13, 2009Slide 4

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Wind Rating Models –G G OGarbage In, Garbage Out

Because the data for Monroe County is inaccurate, the resulting rate indications are inaccurate. Yet OIR has no authority t h ll th f d t l d lto challenge the fundamental model assumptions or verify input data. Garbage in, garbage out – and OIR has no way to clean it upno way to clean it up.

November 13, 2009Slide 5

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CONSTRUCTION CONVENTIONS SAND VULNERABILITIES

Modeling conventions Building codes Historic structures Roofs

Roof coveringsRoof coveringsRoof-to-wall connections

Site-built homes Site-built homes Garages Building height

November 13, 2009Slide 6

Building height

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AssertionAssertion

Structural factors that reduce damage in Monroe are not properly modeled and thus not accounted for in our rates:our rates: Stronger building codes for a longer period of time Sturdy historic structures in Key Westy y Superior sheathing and metal roof construction Superior construction due to site-built homes Lack of attached garages Lower building height

November 13, 2009Slide 7

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Modeling ConventionsModeling Conventions

Computer models assign structures a strength classification based on a

Strength Classification

Garage Door

Sheathing Nailing

Roof to Wall Connections

Roof Shape

Opening Protection

Computer models assign structures a strength classification based on a set of assumptions regarding the building stock in the modeled areas.

g p

Weak Weak(30 psf)

6d (55 psf)

Toe nails Gable or Hip

None or Plywood

Medium Weak 6d Clips Gable or None orMedium Weak(30 psf)

6d(80 psf)

Clips Gable or Hip

None or Plywood

Strong Strong(52 psf)

8d130 psf)

Straps Gable or Hip

None or Plywood(5 ps )

These assumptions do not take into account the realities of construction in Monroe County that create structures which e ceed these parameters

November 13, 2009Slide 8

exceed these parameters.

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Modeling Conventions(continued)

Mitigation is the process of adding features to a home that canMitigation is the process of adding features to a home that can help it better withstand damage from wind. The models assume all homes start “weak” and may or may not be mitigated to additional wind resistance standards FIRM believes that:additional wind resistance standards. FIRM believes that:

• Monroe County homes start out as “medium” or “strong”• Many mitigation features (such as shutters and hurricane

straps) are required in Monroe Countystraps) are required in Monroe County.• Because it is not in the insurance company’s financial

interest to calculate and apply mitigation credits and thus reduce premiums and because modelers acquire datareduce premiums, and because modelers acquire data primarily from insurers, homes hardened through mitigation may be underreported in the models.

November 13, 2009Slide 9

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Building CodesBuilding Codes

Monroe County has had the strictest building code for all construction (residential, commercial residential and commercial) in thecommercial-residential, and commercial) in the state for the longest period of time. As of 1982, the Standard Building CodeAs of 1982, the Standard Building Code

required Monroe County to have the state’s highest windspeed rating for a 3-second gust.

Since 2002, Monroe County structures have been constructed and renovated to withstand 150 MPH gusts

November 13, 2009Slide 10

150 MPH gusts.

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Building Codes (continued)Building Codes (continued)11.2% 5.3%

5.2%%

Protective CoveringsShutters are the norm in the Keys not the

17.9%4.9% Shutters are the norm in the Keys, not the

exception, and have been required for all new construction in Monroe since 1990.

59% of residents in a recent survey reported

37.8%

2.3%

15.4%

y phaving shutters or impact-resistant windows; another 18% have some other (non-plywood) protective covering.Wh th t d k di t

Class A ShuttersClass B ShuttersClass C ShuttersImpact Resistant Doors/WindowsPlywood

Whether rated weak, medium or strong, models presume all structures have either no protective opening coverings or plywood alone, giving no additionalPlywood

Other Protective CoveringsNoneUnknown

plywood alone, giving no additional value to other proven techniques such as shutters.

November 13, 2009Slide 11

SOURCE: FIRM online survey, September 2009

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Historic StructuresHistoric Structures

Key West is the most densely populated region of Monroe County. Key West has the largest collection of historic wood-frame homes

(2,350) in the country. These homes have withstood storms for well over 100 years due to

ifi t ti ti i l dispecific construction conventions, including: Pin and dowel joinery Metal roofs

Sh i t i ll Sheer interior walls Relatively low height Heavy beams

Further, at least half of these homes have been substantially reinforced during renovation with the addition of features such as hurricane clips, creating a much younger effective age than “age of home” (determined by original construction date) would suggest

November 13, 2009Slide 12

home (determined by original construction date) would suggest.

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Historic Structures (continued)Historic Structures (continued)

The Key West Hurricane of 1919 had winds around 110 yMPH.

There are 252 homes in Key West standing today that i d th H i f 1919survived the Hurricane of 1919.

These homes also survived Hurricane Georges in 1998, again with 110MPH winds.again with 110MPH winds.

These historic frame homes have demonstrated that they exceed the FCHLPM definition of “weak” buildings b th h i d t l t t 110MPHbecause they have survived at least two 110MPH storms.

November 13, 2009Slide 13

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RoofsRoofsMonroe County Roof

Installation Date 83% of roofs in the KeysInstallation Date 83% of roofs in the Keys are younger than 20 years old.

1998 - 200973%

1992 -

83% of roofs were installed when the Monroe County b ildi d ll d f1992

199810%

Older than 1992

building code called for roofs to withstand 150 MPH 3-second gusts.1992

17%3 seco d gusts

SOURCE: FIRM online survey September 2009

November 13, 2009Slide 14

SOURCE: FIRM online survey, September 2009

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Roofs: Roof Coverings -Metal Roofs Metal roofs have been proven to be Metal roofs have been proven to be

more wind-worthy than shingle or asphalt roofs which are standard in the Florida Building Codethe Florida Building Code. Keys construction conventions require

plywood rather than manufactured d t th h thi t i lproducts as the sheathing material.

Metal roofs are more impervious to UV degradation than other materials.

V-crimp metal roofs do not produce wind-borne debris to the extent that shingle or tile roofs do.

November 13, 2009Slide 15

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Roof Coverings –Metal Roofs (continued)

There are more metal roofs in Monroe County than any There are more metal roofs in Monroe County than any other roof type.

To date in 2009, only one asphalt shingle roof was installed in the City of Key West. y y Between 2002 and 2006, 95% of roofs replaced in Key West

were V-crimp metal roofs compliant with the FBC’s 150MPH gust standards.

Nearly one-third of all Key West roofs are under 10 years old.

Roof Permits Issued in City of Key West: V-Crimp vs. AsphaltType 1998 1999 2000 2001 2002 2003 2004 2005 2006 Total %Type 1998 1999 2000 2001 2002 2003 2004 2005 2006 Total %

V-crimp 392 559 285 307 312 230 210 458 528 3281 83.3%

Asphalt 205 252 70 38 19 21 23 10 21 659 16.7%

November 13, 2009Slide 16

Total 597 811 355 345 331 251 233 468 549 3940 100.0%

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Roof Coverings (continued)Roof Coverings (continued)

The Public Model, and perhaps Hurricane Loss Projection Methodologies, require that roof covering be assumed to be on a weak sheathing consideredbe assumed to be on a weak sheathing considered to resist -55 psf when calculating roof covering mitigation.g Therefore, superior metal roofs inappropriately

receive no credit versus asphalt shingles. In the Keys metal roof sheathing is typically installed toKeys, metal roof sheathing is typically installed to resist up to -183psf.

November 13, 2009Slide 17

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Roof Coverings (continued)Roof Coverings (continued)

5 9%4.6%

50 1%

8.1%

6.2%

5.9%Roof Coverings

61% of roofs county-wide t l d50.1% are metal or poured

concrete. The majority of roofs25.1%

Metal PanelsMetal ShinglesPoured Concrete

The majority of roofs surveyed would be classified as very, very Poured Concrete

Clay or Barrel TileFlat Asphalt/TarUnknown

resistant to wind.

SOURCE: FIRM online survey September 2009

November 13, 2009Slide 18

SOURCE: FIRM online survey, September 2009

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Roof Coverings (continued)Roof Coverings (continued)

According to the FIRM survey According to the FIRM survey, 51% of roofs have FBC equivalent, reinforced

concrete or ½” plywood or greater roof p y gdecks*

36% have secondary water resistance All models assume our pre-1970 homes

are weak structures (similar to those in northern Florida) rather than “medium ”northern Florida) rather than “medium.”

*45% of respondents could not answer this question.SOURCE: FIRM online survey, September 2009

November 13, 2009Slide 19

y, p

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Roof-to-Wall ConnectionsRoof to Wall Connections

Hurricane clips and straps have been the norm on new and renovated frame and CBS construction since at least the 1950ssince at least the 1950s. Monroe Code as early as 1986 required roof to wall

straps and wall to foundation connections/sill to pile p pconnections and sheer walls.

Code requires reinforced masonry walls, corners, headers and vertical bars at windows and doorsheaders, and vertical bars at windows and doors.

Code requires that new homes are designed by licensed Professional Engineers or Architects.

November 13, 2009Slide 20

g

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Roof-to-Wall Connections (continued)

8% Hurricane Clips Many homeowners don’t k h h i f8%

6%

13%p

Single Wraps

know how their roofs are connected to their walls. According to informed homeowners, however:

22%

Double Wraps

StructurallyConnected

homeowners, however: Just 6% of roofs are

toe-nailed to the walls 43% of roofs have

h i li t

43%

ToeNails/Screws

Unknown

hurricane clips or straps Models assume that all

homes are weak and have roofs that are toe-have roofs that are toenailed. That is not the case in Monroe County.

SO C S

November 13, 2009Slide 21

SOURCE: FIRM online survey, September 2009

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Roofs (continued)Roofs (continued)

Keys superior roof systems and wind resistant design create a medium to stronghome which should be modeled. With nailing of 1x6 at 2.5” on center and 8” on center when transitioning to plywood FBC requires all sheathing to be re-nailed

during a re-roofing, so older homes in time will all be strong.

November 13, 2009Slide 22

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Site-Built HomesSite Built Homes

Tight controls on development (due to our status as an Area of Critical State Concern) have constrained the way homes are constructed.the way homes are constructed.

There are no significant, mass-produced residential “developments” in the Keys.All h d i d b li d P f i l All new homes are designed by licensed Professional Engineers or Architects, per County code.

The majority of new homes are built on site. Manufactured homes must meet the strictest

standards for wind-resistance.

November 13, 2009Slide 23

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GaragesGarages

Garages are a known weakness above 35 MPH winds.G d t ti l l bilit i Garage doors create a particular vulnerability in hurricanes, as wind often enters through a garage door, creating uplift on the attached roof structure.door, creating uplift on the attached roof structure.

The Public Model assumes all weak, medium, and strong homes have attached garages rated g g gto withstand 30psf, 30psf, and 52 psf respectively.

November 13, 2009Slide 24

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Garages (continued)Garages (continued)

Keys homes have few “attached” garages Keys homes have few attached garages. Fewer than 18% of homes in Monroe County have “attached garages”. 18% includes lower levels below the stilt home; not an attached garage. Many attachments are car ports not under the home roof Many attachments are car ports, not under the home roof.

Prevalence of Garages in the Florida KeysSOURCE: Monroe County Property Appraiser DataSOURCE: Monroe County Property Appraiser Data

Classification # of

Properties Attached Garages*

% of Homes

Detached Garages

% of Homes

single familysingle family residence 31,726 5,721 18.00% 254 0.80%

duplex 1,822 141 7.70% 11 0.60%

November 13, 2009Slide 25

*The ‘attached garage’ data includes all types of attachments including built-in lower level and true ground level attached garages.

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Garages (continued)Garages (continued)

2.9%5.9% Additional Structures

Of h d th t11.2%

2 5%

1.7%

Of homes surveyed, the great majority have no additional structures.

Only 7% of survey respondents

7.1%68.7%

2.5% Only 7% of survey respondents report having attached garages.

Models assume that all structures start out “weak”

Attached GarageDetached GarageScreened Porches

and that an attached garage is part of what makes a home weak. Whether using survey data or data from the PropertyScreened Porches

ShedPool or GuesthouseOther StructureNo Other Structure

data or data from the Property Appraiser, it is clear that homes in Monroe County do not have attached garages.

November 13, 2009Slide 26

SOURCE: FIRM online survey, September 2009 (see appendix)

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Building HeightBuilding Height

Monroe County’s Comprehensive Plan places a 35 foot Monroe County s Comprehensive Plan places a 35-foot limit on building height in the Keys. The only exceptions to this regulation are equipment towers and certain equipment on the roofs of commercial structures.

According to a FIRM survey, 79% of homes are two stories or fewerstories or fewer.

Most residential structures in Key West, the most densely populated area of the Keys, are under 25 feet tall.

Wind speeds are measured at 10 meters, and intensify with increasing height.

November 13, 2009Slide 27

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Construction ConundrumConstruction Conundrum

High Cost to Harden Home

High Replacement CostHigh Cost Factor in Rate + = High Premium

because

Hardened Home Lower PML

It costs us more to build sturdy homes. Insurance companies Insurance companies

Build high cost factors into the base rate Charge high replacement costs

Do not reduce PML based on the lower risk from a hardened home Do not reduce PML based on the lower risk from a hardened home Why bother building a sturdy structure?

November 13, 2009Slide 28

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SummarySummary

Structural factors that reduce damage in Monroe are not properly modeled and thus not accounted for in our rates: Stronger building codes for a longer period of time Sturdy historic structures in Key West

S i h thi d t l f t ti Superior sheathing and metal roof construction Lack of attached garages Superior site-built construction Superior site built construction Lower building height

No insurance incentive to harden home

November 13, 2009Slide 29

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GEOGRAPHYGEOGRAPHY

P l i D i d Di ib i Population Density and Distribution Linear Geography Threat Zone Threat Zone Proximity to Cuba

November 13, 2009Slide 30

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AssertionAssertion

Geographic factors are ignored or inaccurately applied when factoring PML for the Florida Keys. Low population density Low population density Lack of structures on largest land area in the County Linear geography minimizes risk that any storm strike

ill i t ti Fl id Kwill impact entire Florida Keys Threat zones drawn without consideration of Keys

linear structure Storms that cross Cuba tend to weaken before

striking the Keys

November 13, 2009Slide 31

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Population Density and Distribution

Population in Monroe continues to decrease Density in Monroe is extremely lowy y Monroe - 80 per sq mile Collier - 124 per sq milep q Miami-Dade - 1158 per sq mile Broward – 1374 per sq mile Broward 1374 per sq mile

PML in Keys should be decreasing

November 13, 2009Slide 32

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Population Density and Distribution (continued)

f f C The bulk of the land of Monroe County is the unpopulated Everglades on the mainland. Storms that come within 62 statute miles of this area of thethat come within 62 statute miles of this area of the County could be over 200 miles from the populated area of the Keys. This should be taken into account when calculating proximity of land-falling hurricanes.

Pale pink area represents Monroe County. Mainland area is in the Everglades.

November 13, 2009Slide 33

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Linear GeographyLinear Geography

Due to the linear geography of the populated Keys, it is likely that a storm could impact one area of the chain and not impact another at all. PML calculations should take this into

taccount.

November 13, 2009Slide 34

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Threat ZonesThreat Zones

The Threat Zone circles on the Public Model for zip codes is rather large for Monroe.

Hurricanes entering a circle on the mainland are likely to hit land and cause damage.

Hurricanes entering the circle in the western Keys are much less likely to hit land and cause damage, and certainly not to the entire county or even adjacent zip code.

November 13, 2009Slide 35

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Threat Zones (continued)Threat Zones (continued)

xxxxxxxxxxx

The Florida Keys (inhabited, developed

xxxx

xx

developed Monroe County)

xxxx

xxxx

11/11/13

November 13, 2009Slide 36

x

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Proximity to CubaProximity to Cuba

The mountains of Cuba are 90 miles away from the The mountains of Cuba are 90 miles away from the Florida Keys. Mountainous regions create frictionand generally reduce the intensity of storms that g y ypass over them, and this has frequently been the case in the Keys. Ninety miles is too short a di t t f t t t b ilddistance over open water for most storms to re-build in intensity.

Florida KeysFlorida Keys

Cuba

November 13, 2009Slide 37

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SummarySummary

Geographic factors are ignored or inaccurately applied when factoring PML for the Florida Keys. Low population density Low population density Lack of structures on largest land area in the County Linear geography minimizes risk that any storm strike

ill i t ti Fl id Kwill impact entire Florida Keys Threat zones drawn without consideration of Keys

linear structure Storms that cross Cuba tend to weaken before

striking the Keys

November 13, 2009Slide 38

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METEOROLOGYMETEOROLOGY

Strike Probabilities Wind versus Flood (storm surge)( g )

November 13, 2009Slide 39

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AssertionAssertion

Meteorological factors that would indicate wind damage are misapplied when calculating PML f th Fl id Kfor the Florida Keys. Monroe County does not have the highest

i k i th St trisk in the State. Models used to estimate losses do not

adequately distinguish between damage fromadequately distinguish between damage from wind versus water.

November 13, 2009Slide 40

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Strike ProbabilitiesStrike Probabilities

Strike Probabilities vary Strike Probabilities vary based on data sets, time frames and other criteria used by statisticians.used by statisticians.

While Monroe County may be more vulnerable to tropical activity than othertropical activity than other areas, the magnitude of the difference in vulnerability is not as great y gas models and windstorm insurance rates would suggest.

SOURCE: www.floridahurricane.net

November 13, 2009Slide 41 November 13, 2009Slide 41

SOURCE: www.floridahurricane.net

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Strike Probabilities: Return Frequency by Category in Key Coastal Areas per FSUCategory in Key Coastal Areas per FSU

According to an historical study by Florida State University, low intensity storms occur in the Keys about as frequently as in panhandle counties andstorms occur in the Keys about as frequently as in panhandle counties, and higher intensity storms occur more frequently in other southeast Florida counties than in Monroe.

N t th t di t thi t d C t 5 t d h th th M H i A dNote that according to this study, no Category 5 storms occurred anywhere other than Monroe. Hurricane Andrew was a Cat 5 storm that hit Miami-Dade in 1992. Data used in modeling should be fully vetted for accuracy.

All Tropical Storms

Cat 1 & Higher

Cat 2 & Higher

Cat 3 & Higher

Cat 4 & Higher

Cat 5 & Higher

Monroe 4 9 14 20 78 156

Bay/Gulf/Franklin 4 9 22 78 0 0

Miami-Dade/ 6 12 16 20 26 0Broward/Palm Beach 6 12 16 20 26 0

Collier/Lee 7 22 31 39 156 0

Martin to Brevard 12 14 20 52 156 0

November 13, 2009Slide 42Slide 42

SOURCE: Data extrapolated from maps of storms by frequency at FSU study online at http://gis.coaps.fsu.edu/httpdocs/Rtrn.php

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Strike Probabilities: Return Frequency by Category in South Florida per CSUCategory in South Florida per CSU

Data from a Colorado State University study of storms between 1900 and 2006 paints a different picture for strike probabilities in the Keys However2006 paints a different picture for strike probabilities in the Keys. However, this study includes the large, unpopulated and uninsured portion of Monroe County that is on the mainland.

Region orCounty

Probability of 1 or More Named Storms Making Landfall in the Region

Probability of 1 or More Hurricanes Making

Landfall in the Region

Probability of 1 or More Intense Hurricanes Making

Landfall in the Region

Region 6 50.4 39.4 20.5

Monroe 32.0 24.1 11.8

Miami-Dade 12.0 8.8 4.1

Broward 5.6 4.1 1.9

SOURCE: United States Landfall Probability Webpage By Philip Klotzbach and William Gray, Colorado State University, With Assistance

Palm Beach 8.9 6.4 3.0

Martin 3.4 2.5 1.1

November 13, 2009Slide 43Slide 43

SOURCE: United States Landfall Probability Webpage By Philip Klotzbach and William Gray, Colorado State University, With Assistance From Uma Shama, Larry Harman, and Daniel Fitch, GeoGraphics Laboratory, Bridgewater State College,http://www.e-transit.org/hurricane/Full%20Data%20Table.xls

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Wind vs. Flood S S(Storm Surge) The Keys are a low lying chain of islands with the highest elevation The Keys are a low-lying chain of islands, with the highest elevation

at 14 feet. (1) According to meteorologists at the National Weather Service, the

greatest threat to the Keys from Category 3 and higher hurricanesgreatest threat to the Keys from Category 3 and higher hurricanes predicted by SLOSH models is from storm surge, not wind. Any wind damage that would occur would be washed away by the surge.(2) Thus, flood insurance would pay first and most for thesurge.(2) Thus, flood insurance would pay first and most for the greatest portion of damage occurring from a significant hurricane.

Wilma, a storm many consider to be the “100-year storm,” demonstrated this.demonstrated this.

(1) NOAA Satellite and Information Service, http://lwf.ncdc.noaa.gov/oa/reports/georges/georges.html

(2) Matt Strahan Meteorologist in Charge National Weather Service Key West

November 13, 2009Slide 44 November 13, 2009Slide 44

(2) Matt Strahan, Meteorologist in Charge, National Weather Service, Key West

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Wind vs. Flood: Claims Paid Cin Monroe County

Aft H i Wil I Milli After Hurricane Wilma, flood insurance paid 14 times more in claims than wind insurance did $322$250

$300$350

In Millions

wind insurance did. Flood claims for Hurricane

Wilma alone exceeded all wind claims paid in 2005 $23

$322$92

$100

$150$200

$250

wind claims paid in 2005 for four named storms (Dennis, Katrina, Rita, Wilma).

$23

$0

$50

Claims Paida)

Wilma Wind Claims (1)Wilma Flood Claims (2)Total 2005 Wind Claims (3)

(1) Citizens Property Insurance as of February 28, 2006

(2) National Flood Insurance Program as of 6/30/09

(3) Citizens Property Insurance as of July 2008

November 13, 2009Slide 45

Total 2005 Wind Claims (3)(3) Citizens Property Insurance as of July 2008

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Wind vs. Storm Surge Losses: I d i b H i S hInundation by Hurricane Strength

Most of the FloridaMost of the Florida Keys would flood in a storm of Category 2 or greater. A Category 3 or higher storm would cause significant floodcause significant flood damage.

November 13, 2009Slide 46 November 13, 2009Slide 46

SOURCE: Monroe County Emergency Management

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Wind vs. Storm Surge Losses: SLOSH Model Storm surge predictions are generally based on the SLOSH Model. Prior g p g y

SLOSH models do not necessarily work in the Keys. The SLOSH model covers inland areas. The Keys have none. The SLOSH model does not take into account the wave action that we experience

i th K d t l l tiin the Keys due to our low elevation. Experience in direct-hit storms bears this out:

Storm SLOSH Predicted Surge Actual Experienced Surge

Not Named 1919 8 feet 14 feet

Not Named 1935 9 feet 20 to 24 feet

Hurricane Donna 8 feet 12 to 14 feet

Models predicting surge based on the older SLOSH model may under-predict flooding in the Keys, thus leading to over-prediction of wind damage.

SO C S C S

November 13, 2009Slide 47

SOURCE: Matt Strahan, Meteorologist in Charge, National Weather Service, Key West

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Wind vs. Flood CDamage by Category

CatWind (mph)

Damage Extent

Surge (feet) Damage DescriptionCat (mph) Extent (feet) Damage Description

1 74-95 Minimal 4-5 No real damage to building structures. Damage primarily to unanchored mobile homes, shrubbery, and trees. Also, some coastal road flooding and minor pier damage.

2 96-110 Moderate 6-8Some roofing material, door, and window damage to buildings. Considerable damage to vegetation, mobile homes and piers. Coastal and low-lying escape routes flood 2-4 hours 2 96 110 Moderate 6 8 vegetation, mobile homes and piers. Coastal and low lying escape routes flood 2 4 hours before arrival of center. Small craft in unprotected anchorages break mooring.

3 111-130 Extensive 9-12

Some structural damage to small residences and utility buildings with a minor amount of curtainwall failures. Mobile homes are destroyed. Flooding near the coast destroys smaller structures with larger structures damaged by floating debris. Terrain

ti l l th 5 f t ASL b fl d d i l d 8 il continuously lower than 5 feet ASL may be flooded inland 8 miles or more.

4 131-155 Extreme 13-18

More extensive curtainwall failures with some complete roof structure failure on small residences. Major erosion of beach. Major damage to lower floors of structures near the shore. Terrain continuously lower than 10 feet ASL may be flooded requiring massive evacuation of residential areas inland as far as 6 miles.massive evacuation of residential areas inland as far as 6 miles.

5 >155 Catastrophic >19

Complete roof failure on many residences and industrial buildings. Some complete building failures with small utility buildings blown over or away. Major damage to lower floors of all structures located less than 15 feet ASL and within 500 yards of the shoreline. Massive evacuation of residential areas on low ground within 5 to 10 miles of the

h li b i d

November 13, 2009Slide 48

shoreline may be required.

Source: *The COMET® Program, part of the University Corporation for Atmospheric Research’s(UCAR’s) Office of Programs (UOP).

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Estimate of Wind vs. Surge D b S S hDamage by Storm Strength

K W t A St Tid **Key West Average Storm Tide** Vs. Storm Category for Average 1000 SF home

A A AFL Public

M d l

Hurricane

AverageStormTide in

feet

AverageGroundfloor in

feet

AverageFlood inHome in

feet

Model Wind

DamageRatio*

% WaterDamage*

Estimated Cost of Wind Damage***

Estimated Cost of Flood

Damage***

$35,000 to $177,500 to Cat 5 10.4 5.5 4.9 14-37% 71 - 97% $92,500 $242,500

Cat 4 9.1 5.5 3.6 5-14% 59% $35,000 $147,500

Cat 3 7.5 5.5 2 3-5% 49% $1,250 $122,500

*Source: FL Public Model presentation June, 2009, extrapolated estimate by FIRM Engineer based on Masonry Structure Vulnerability slide No. 81**15mph forward speed, tide 2 ft NGVD1929, Calculated by SLOSH Model*** Based on FL Public Model presentation June 2009, slide 98.

November 13, 2009Slide 49

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Estimate of Wind vs. Surge D b S S hDamage by Storm StrengthThis chart combines data from http://www comet ucar edu/nsflab/web/index htm (COMET)This chart combines data from http://www.comet.ucar.edu/nsflab/web/index.htm (COMET) and the FPHM model and is a representation estimating storm surge versus wind damage. If, for example, construction experts state that a home is considered totaled at 25% damage loss, that would occur from flooding due to 135 mph wind, whereas wind-only damage from 135 mph wind would only be 15% This would indicate that FEMA

Storm Characteristics FIRM Estimate of Damage Ratio %Wind Speed Surge

only damage from 135 mph wind would only be 15%. This would indicate that FEMA would pay those claims for damage above 130 mph winds.

CATEGORYp

(mph)g

Depth (ft) Surge * Wind * *1 74-95 4-5 5% 0%2 96-110 6-8 30% 1%3 110-130 9-12 60% 5%4 131-155 13-18 80% 15%5 >155 >19 90% 18%

November 13, 2009Slide 50

SOURCE: http://www.comet.ucar.edu/nsflab/web/index.htm and the FPHM model; Extrapolated estimate prepared by FIRM retired engineer Al Sachs

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Wind/Flood Damage Probable Maximum Loss (PML) Argument

The Florida Keys in Monroe County are a low lying area with The Florida Keys in Monroe County are a low lying area with elevations from 5 feet or less to a high in Islamorada of about 11 feet. A small section of Key West rises to no greater than 18 feet.

Because of this most residents carry both flood and wind insurance ybut depending on conditions either one or the other will pay for the damage. For example, Wilma was a Category 3 storm, but FEMA paid for the widespread flood damage while wind damage claims were minimalwere minimal.

We believe that, since not all claims will be paid by the wind insurer, this fact should be reflected in our wind rates.

The new SLOSH model from the National Weather Service may The new SLOSH model from the National Weather Service may provide a vehicle for more accurately predicting damage due to wind versus water.

November 13, 2009Slide 51

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Storm Surge and Wind Combination Model

Prepared byMatt Strahan

Meteorologist in Charge NWS Key WestMeteorologist in Charge, NWS Key WestMay 26, 2009

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Storm Surge Defined

STORM SURGE is an abnormal rise of water generated by a storm over and above thegenerated by a storm, over and above the predicted astronomical tide.

STORM TIDE is the total water level during a storm (i.e astronomical tide + storm surge)

53

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The Effects of Low Pressure

• Lower central pressure associated with the• Lower central pressure associated with the storm causes the ocean to rise/bulge up

• However the contribution of pressure to total• However, the contribution of pressure to total storm surge is small compared to wind

54

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What about Waves?

• Breaking waves also contribute to the total gwater level through wave runup/setup

• Wave runup is the time-varying fluctuation f l l l i h h liof water-level elevation at the shoreline

due to wave breaking• Wave setup the time averaged water level• Wave setup the time-averaged water level

rise due to wave breaking. • The magnitude of both runup and setup e ag tude o bot u up a d setup

are related to offshore wave period, wave height, and shelf slope

55

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NHC Storm Surge Products

• Maximum Envelope of• Maximum Envelope of Water (MEOW)

• Maximum of MEOWMaximum of MEOW (MOM)

• Probabilistic Storm SurgeProbabilistic Storm Surge Heights

• Deterministic/Operational pSLOSH Runs

• Public Advisory Statement

56

y

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Deterministic SLOSH run shows limited surge threat to gPensacola area

Rmax=25 mi(forecast)

57

(forecast)

Surge Based on NHC -12 hr. Advisory

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Probabilistic product shows considerable surge threat to Pensacola area

58

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Actual storm caused highest surge in Pensacola areag

59

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Storm Surge

Storm surge models output water surface l ti f ifi ( id ll)

What does a 20-foot storm surge really mean to your location?

elevations for a specific area (grid cell)

Water Surface Elevation = 20-foot surge*

Depth of

Depth of water = 5 ft

20 foot contourDepth of water = 0 feet

water = 10 ft

Depth of water = 20 ft

15 foot contour

Depth of water = 15 ft

10 foot contour

water 0 feet

land/sea interface

*Thi l t Th b t f th

0 foot elevation

5 foot contour10 foot contour

0 foot elevation

60

*This only represents surge. There may be waves on top of the surge.

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Key West Inundation Mapy pSource - FL Dept of Emergency Management

Cat 1Cat 2-3Cat 4-5D

61

Dry

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Calculating Wind vs. Water Risk• Start with SLOSH grids in Velocity Zones (pre-

defined areas of rapidly moving surge).y g g )• Rerun all the Cat 3 (high wind damage storms)

and higher MEOWS– For each grid cell, what percentage of tracks is the

cell both crossed by the RMW (maximum wind damage location) and also inundated?damage location) and also inundated?

– Reduce wind rates by the above percentage.• But wait for soon to be released SLOSHBut…wait for soon to be released SLOSH.• But…SLOSH does not natively do the above

(Additional programming will be necessary).62

(Additional programming will be necessary).

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Wind vs. Storm Surge Losses

In the Keys, hurricane damage resulting from flood, water and storm surge can far exceed d d b i ddamage caused by wind. We believe that, since not all hurricane damage

l i ill b id b th i d i thiclaims will be paid by the wind insurer, this fact should be reflected in our wind rates.

Homes may be washed away with no Homes may be washed away with no subsequent wind claims paid, this fact should be reflected in our wind rates.

November 13, 2009Slide 63

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SummarySummary

Meteorological factors that would indicate wind damage are misapplied when calculating PML f th Fl id Kfor the Florida Keys. Monroe County does not have the highest

i k i th St trisk in the State. Models used to estimate losses do not

adequately distinguish between damage fromadequately distinguish between damage from wind versus water.

November 13, 2009Slide 64

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CONCLUSIONCONCLUSION

Citizens Property Insurance Corporation is a Citizens Property Insurance Corporation is a tax-exempt, quasi-governmental entity providing insurance as a last resort.

Citizens Property Insurance rates should not need to include cost factors for taxes marketing and advertising expenses

h h ld di id d shareholder dividends private reinsurance surcharge

November 13, 2009Slide 65

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CONCLUSION (continued)CONCLUSION (continued)

Actual historical evidence indicates that Monroe County is not the riskiest county in the state.

Structural factors that reduce wind damage in Structural factors that reduce wind damage in Monroe County are not properly modeled and thus not accounted for in our rates. G hi f t i d i t l Geographic factors are ignored or inaccurately applied when factoring PML for the Florida Keys.

Meteorological factors that would indicate wind gdamage are misapplied when calculating PML for the Florida Keys.

November 13, 2009Slide 66

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CONCLUSION: Wind Rating Models G b I G b O– Garbage In, Garbage Out

Because the data for Monroe County is inaccurate theBecause the data for Monroe County is inaccurate, the resulting rate indications are inaccurate. Yet OIR has no authority to challenge the fundamental model assumptions or verify input data. Garbage in, garbageassumptions or verify input data. Garbage in, garbage out – and OIR has no way to clean it up.

And due to legislative changes in 2009, the FCHLPM will only review models in odd years.

So even if the data is inaccurate or a model is misapplied OIR anda model is misapplied, OIR and consumers must live with the garbage for at least two years. The next review cycle is 2011.

November 13, 2009Slide 67

y

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Precedent for Special CConsideration for Monroe

There is considerable legislative and operational precedent for treating Monroe County separately. Since 1973 Monroe County has been designated an Since 1973, Monroe County has been designated an

Area of Critical State Concern, subject to unique development regulations.

The Pilot Project in 2006 allowed the Office of The Pilot Project in 2006 allowed the Office of Insurance Regulation to consider Monroe County’s insurance rates differently, as there was no reasonable degree of competition for windstormreasonable degree of competition for windstorm insurance in the County.

The Florida Public Hurricane Model currently i l d M C t t

November 13, 2009Slide 68

includes Monroe County as a separate area.

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FIRM’S REQUESTFIRM S REQUEST

We respectfully request that the proposed windstorm rate increases from Citizens Property Insurance Corporation be denied as beingInsurance Corporation be denied as being unsupported and unfairly discriminatory, and the Florida Commission on Hurricane Loss Projection Methodologies conduct a full review ofProjection Methodologies conduct a full review of the Florida Public Hurricane Model with regard to the aforementioned realities, before OIR accept a

t t l “ t i ll d ”rate as truly “actuarially sound.”

November 13, 2009Slide 69