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Evolution of Insurance Incentives for Wind-resistant Construction


since Hurricane Andrew
J. C. Sciaudone1 and F. M. Lavelle1
1

Applied Research Associates, Intrarisk Division, 8537 Six Forks Road, Suite 600,
Raleigh, NC 27615-2963; PH (919) 582-3400; FAX (919) 582-3401; email:
jsciaudone@ara.com

Abstract
Lessons learned from building performance in Hurricane Andrew led to
immediate improvements in the South Florida Building Code in 1994 and the
eventual creation and adoption of the statewide Florida Building Code (FBC) in 2002.
Alongside these building code improvements, numerous public and private programs
to encourage wind resistant construction were also created. Concurrent with the
adoption of the FBC, Florida Statute 627.0629 required all property insurers in
Florida to recognize the wind resistive benefits of the FBC in their residential rate
filings by February 2003. In effect, this statute requires insurers to provide discounts
for homes that are built in accordance with the FBC, as well as to homes that were
built prior to the FBC with similar wind-resistive features. The creation and
implementation of this insurance incentive program has faced many challenges
including: determination of the appropriate discounts by feature or combination of
features, inspection protocols for documenting wind resistive features, dealing with
intentional and unintentional errors introduced in the inspection process, and ensuring
the actuarial soundness of the program. This paper discusses the evolution and current
state of the mandated insurance discount program in Florida, its basis in wind
engineering, and its implementation via wind mitigation inspections.

History of Florida Hurricane Insurance Discounts


Mandatory discounts for wind-resistive features of single family homes in
Florida date back to 1994, in the immediate aftermath of Hurricane Andrew.
Following Andrew, Florida Statutes 627.0629, section (1) was updated to read:
Effective July 1, 1994, a rate filing for residential property insurance must
include appropriate discounts, credits, or other rate differentials, or
appropriate reductions in deductibles, for properties on which fixtures
actuarially demonstrated to reduce the amount of loss in a windstorm have
been installed.

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While insurers
i
com
mplied with this law aand providedd discounts for visible
feattures like sttorm shutters, the discou
unts were nnot comprehhensive. Onee reason for
thiss was the lacck of researcch into how single familly homes perrform in hurrricanes and
how
w they shoulld be evaluaated to propeerly classifyy them in terrms of windd resistance.
Fig
gure 1 shows a timelinee that includ
des the majoor milestonees that havee led to the
currrent mandated insurancee discount prrogram in Fllorida.

Figuree 1. Timeline of Major Mileston


nes in History oof Florida Hurrricane Insurancce Discounts

The folllowing subsections discuss these miilestones, wh


which includee their basis
in wind engin
neering, their implemen
ntation by the Floridaa Office off Insurance
Reg
gulation (OIR
R) and wind
d mitigation inspections.
F.S
S. 627.0629
The Flo
orida hurricaane insurancce discount program is legislativelyy driven by
Flo
orida Statute 627.0629. While
W
insureers were reqquired to proovide discouunts as early
as 1994, as no
oted above, much greaater detail w
was added tto the statutte in 2000.
Speecifically, the 2000 statu
ute requires:
A raate filing forr residentiall property iinsurance m
must include actuarially
reaso
onable disco
ounts, creditts, or otherr rate differrentials, or appropriate
reducctions in ded
ductibles, fo
or propertiess on which ffixtures or cconstruction
techn
niques demo
onstrated to reduce
r
the aamount of looss in a winddstorm have
been installed or
o implemen
nted. The fiixtures or cconstruction techniques
shall include, bu
ut not be lim
mited to, fixxtures or coonstruction techniques
whicch enhance roof streng
gth, roof coovering perfformance, rroof-to-wall
stren
ngth, wall-to
o-floor-to-fo
oundation sstrength, oppening proteection, and
wind
dow, door, and
a
skyligh
ht strength. Credits, diiscounts, orr other rate
differrentials for fixtures an
nd construcction techniiques whichh meet the
minim
mum requireements of th
he Florida B
Building Codde must be included in
the rate
r
filing. All
A insurancce companiees must maake a rate fi
filing which
inclu
udes the cred
dits, discountts, or other rrate differenttials by Junee 1, 2002.
This ch
hange in thee statute waas made in parallel witth the adopption of the
stattewide Floriida Building
g Code. The effective daate for this requirementt was twice

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delayed in the 2001 and 2002 Florida Statutes to begin on February 28, 2003, one
year after the effective date of the Florida Building Code. Aside from the effective
date, the language added to Florida Statue 627.0629 in 2000 has persisted unchanged.
RCMP Inspections
One technical hurdle facing the original insurance discount requirements was
the rating method used for structures. At the time of Hurricane Andrew, structures
were rated using ISOs predominantly fire-based classes, such as masonry, semi-wind
resistive or superior frame. While capturing some of the differences in the
performance of the main structural system with respect to wind loads, these classes do
not address the key causes of wind damage and loss associated with the building
envelope and the buildings aerodynamics.
To fill this void, the Residential Construction Mitigation Program (RCMP)
initiated by the state of Florida in 1997 provided unique information on single-family
building construction features, mitigation options and costs for existing buildings, and
the expected mitigation loss reduction benefits. Detailed inspections were performed
for over 2,000 houses in selected coastal counties in Florida between 1998 and 2000
(Twisdale et al 1998). These pioneering wind mitigation inspections provided
necessary data to on which to base further research to quantify the insurance
incentives required by Florida Statute 627.0629 (2000).
FWUA Class Plan and Inspections
The Florida Windstorm Underwriting Association (FWUA), which would
later be incorporated into Citizens Property Insurance, developed a first generation
Class Plan in 1998-1999 to classify buildings by their wind risk characteristics rather
than the ISO fire-based characteristics (FWUA 2000). The FWUA Class Plan was
based on loss relativities developed from actuarial judgment and model calculations
similar to those used in the 2002 Loss Relativities Study. This first generation Class
Plan was used by FWUA from July 2000 until February 2003 when it was replaced
with a rating system based on OIR-03-001M.
2002 Loss Relativities Study
In 2001, the Florida Department of Community Affairs commissioned a study
to evaluate the effectiveness of various wind resistance features for single-family
homes. This study (ARA 2002) developed comprehensive sets of loss relativities for
homes built both before and after adoption of the 2001 Florida Building Code
(effective date March 1, 2002). This study involved modeling the Florida homes as
they are actually built at numerous locations around Florida using ARAs engineering
load and resistance based HurLoss methodology.

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Loss relativities were developed by dividing the average annual loss


calculated for a modeled house by the average annual loss for a typical Florida home.
In the study, the typical Florida home was classified as a gable roof house with a nonFBC roof cover, a B roof deck (8d nails at 6/12 spacing), clip-style roof to wall
connectors, and no opening protection. For homes located in terrain exposure B, this
resulted in the strongest home having a relativity of 0.41 and the weakest home
having a relativity of 2.37. This translates to no discount for the typical Florida home,
a 69% discount for the strongest home and a 137% surcharge for the weakest home.
OIR-03-001M (Tempered Credits)
Prior to the Florida Building Code going into effect, the Florida Office of
Insurance Regulation (OIR) distilled the information in the 2002 Loss Relativity
Study into a memorandum to assist insurers in adopting an appropriate credit
structure. In memorandum OIR-03-001M (OIR 2003), the OIR redefined the
relativities such that all houses, except for the very weakest, would get a discount and
no homes would be surcharged. To convert the relativities to discounts, the OIR renormalized the table to the weakest home (relativity = 2.37) instead of the typical
Florida home identified in the study and subtracted the resulting relativity from 1. At
the same time, the OIR also chose to compress the discounts by 50% in recognition of
the uncertainties inherent in the modeling and the lack of detailed claims experience
to validate the relativities. These changes resulted in the weakest home receiving no
discount or surcharge; the typical Florida home as defined in the study receiving a
29% discount; and the strongest home receiving a 41% discount.
In order to qualify for these discounts, homeowners were required to have a
wind mitigation inspection completed on their home at their expense and present the
results to their insurance company. Results were presented on insurance company
specific forms that were specified in each companys rate filing. Since all but the
weakest Florida homes were eligible for discounts, having an inspection was very low
risk for the homeowner with a potential reward of immediately getting a discount on
their insurance. However, since most homes would immediately be eligible for at
least some discount, the discounts were less likely to incent homeowners to mitigate
further to qualify for larger discounts.
My Safe Florida Home Program
The My Safe Florida Home (MSFH) program provided approximately
400,000 wind mitigation inspections at no charge to Florida homeowners between
2006 and 2009. Approximately 40,000 of these homeowners were awarded grants to
strengthen their homes through protecting windows, doors, and garage doors, or
bracing gable ends (www.mysafefloridahome.com). All homeowners receiving an
inspection received inspection forms to submit to their insurer to apply for discounts
for the existing wind resistive features of their homes.

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OIR-B1-1699 (Removal of Tempering)


In 2006, Florida Statute 627.0629 required the OIR to re-evaluate and
determine the discounts, credits, other rate differentials, and appropriate
reductions in deductibles that reflect the full actuarial value of such revaluation,
which may be used by insurers in rate filings. (F.S. 627.0629 2006). In response,
OIR removed the 50% tempering of the wind mitigation discounts recommended in
OIR-03-001M with Rule 690-107.017, which referenced memorandum OIR-B1-1699
(OIR 2006) for the applicable credit tables. The credits in this table followed the same
formula used to calculate discounts based on the 2002 Loss Relativities Study without
the 50% tempering. For homes located in terrain exposure B, this resulted in no
discount for the weakest house; a 59% discount for the typical Florida home (as
defined in 2002); and an 83% discount for the strongest house.
Uniform Mitigation Verification Inspection Form (UMVI)
In 2007, OIR created a standard form for reporting existing wind resistive
features of homes to all insurance companies. This form is called the Uniform
Mitigation Verification Inspection form (UMVI) and was designated form OIR-B11802. This form replaced all of the company specific forms that were previously used
to document wind resistive features.
UMVI Version 07/07
The first version of the UMVI was required for use starting in July 2007 (OIR
2007). At that time, MSFH inspectors were required to complete UMVI forms for
each home inspected in addition to the detailed MSFH inspection document.
However, a disconnect existed in that the MSFH inspectors were trained to perform
inspections and document the objective data on the detailed inspection form, but were
not trained to complete the generalized and subjective checkboxes on the UMVI
form. For example, the MSFH inspection required inspectors to classify the type of
roof to wall connectors observed, determine whether the connections were corroded,
and ensure they were properly aligned. The UMVI, on the other hand, only asked for
the type of connector and was silent on the condition requirements that were
established in the 2002 Loss Relativities Study (ARA 2002).
In addition, some of the classifications on the initial UMVI were not
consistent with the classifications that appear on the discount tables of OIR-03-001M
and OIR-B1-1699. For example, the credit tables published by the OIR indicate that
the Hurricane level of opening protection applies to Windows or All. However,
to achieve Hurricane level of protection on the 07/07 UMVI, All exterior
openings had to be protected. This meant that many homes that should have been
eligible for discount for have all glazed openings protected were deemed ineligible

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for the discount. It also meant that homes that only had protection on their glazed
openings, but received the Hurricane opening protection rating, while technically
eligible for the credit, had a material misrepresentation on their UMVI form.
UMVI Version 02/10
In February 2010, OIR promulgated a revised version of the UMVI to address
the deficiencies of the initial form published in 2007. The changes on the 02/10
UMVI form (OIR 2010) included:

Modified hip roof shape requirements based on non-hip features consisting of


less than 10% of the building perimeter instead of no non-hip features less
more than 50% of any wall;
Additional definitions for Opening Protection to address the inconsistency
previously noted on the 07/07 UMVI;
Introduced licensure requirements for inspectors (MSFH inspectors; Building
Code Inspectors; General, Building or Residential Contractors; Professional
Architects; or Professional Engineers) to certify the form; and
Required photos to document the features observed.

The enhancements addressed issues identified with initial version of the form
and made inspectors more accountable. However, revised language in the roof
covering section of the form made it unclear as to whether tile roofs could ever
qualify as being FBC compliant.
2008 Loss Relativities Study
In 2008, the OIR commissioned a new Residential Wind Loss Mitigation
Study that was performed by Applied Research Associates (ARA 2008). This study
focused on updating the original study from 2002 and to bring consider additional
wind resistive features of homes that research had shown to have an impact on
residential hurricane losses. New features considered included: number of stories,
roof cover material (tile versus shingle), roof slope, soffit construction, vinyl siding,
window and door water leakage, and FBC roof cover age. In addition, this study
reiterated and clarified the minimal condition requirements for each feature.
To date, OIR has not published any memorandum to insurers requiring or
recommending the results of this study. However, some insurers have recently
completed their own studies to incorporate selected features into their own unique
rate filings.

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Current State of Florida Hurricane Insurance Discounts

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The mandated hurricane insurance discounts in Florida have raised quite a few
questions and concerns from interested parties since their inception in 2000. A sample
of the responses to these concerns include:

The Florida legislature requiring the Florida Commission on Loss


Projection Methodology to review the program
Individual insurance companies performing re-inspections of homes
currently receiving discounts
Continuing efforts to clean-up the UMVI
Increased use of technology in the inspection process

Florida Commission on Hurricane Loss Projection Methodology Review


Florida Statute 627.0628(4) in 2009 required the Florida Commission on Loss
Projection Methodology (FCHLPM) to review the mandated windstorm mitigation
discount program and provide a report back to the Governor, the Cabinet, the
President of the Senate, and the Speaker of the House of Representatives by February
1, 2010. The FCHLPM is an independent commission that exists to review and accept
hurricane loss models for use in ratemaking studies in Florida. The commission held
several public hearings, heard testimony from multiple interested parties and
reviewed numerous documents. The final report (FCHPLM 2010) concluded that the
current system for assessing, determining, and applying windstorm mitigation
credits has failed to operate as intended and has contributed to problems in the
residential property insurance marketplace and that the current problems are
complex and systemic in nature.
The FCHLPM report makes several recommendations regarding:
(1) Determination of windstorm mitigation credits and the role of the
OIR in that process;
(2) Inspection of homes for mitigation credits, including increasing
penalties for inspection fraud, and the creation of an independent
inspection organization to provide oversight on the process;
(3) Ensuring data quality though centralization of the data collected and
improved policies and procedures; and
(4) Additional review of hurricane models by the FCHLPM to evaluate
their ability to be used to develop windstorm mitigation discounts.
Full details of the FCHLPM recommendations can be found in their final
report (FCHLPM 2010). It should also be noted that the OIR prepared a summary
document for the FCHLPM review that includes copies of several of the documents

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refeerenced in this
t
paper in
n one conveenient packaage. Details can be fouund in (OIR
200
09).
Re--inspections
y have a stakke in ensurinng that windd mitigation
Insurancce companiees obviously
insp
pections are completed in a correct and consisteent manner. However, a number off
facttors regardin
ng these inspections like the lack oof photo requuirements before 2010,
inco
onsistent baackground of
o inspectorss, and inconnsistencies oon the UMV
VI have led
man
ny insurers to begin ordering
o
re-iinspections of houses tthat they arre currently
receeiving discounts.
Citizenss Property Insurance
I
is in the midddle of an aaggressive eeffort to reinsp
pect all 400
0,000 homess they insuree that are reeceiving mittigation disccounts. The
pilo
ot phase of this program showed large error rates for seeveral featurres, but the
highest error rates were fo
or opening protection
p
((57%) and rroof-to-wall connection
(46
6%) (Citizens 2010). Fig
gure 2 show
ws the percenntage of hom
mes qualifyinng for each
classsification of
o opening protection
p
an
nd roof to w
wall connecction from tthe Citizens
pilo
ot re-inspection program
m.

Figure 2. Opeening Protecction and Roof


R
to Walll Connection
n Classification Rates
Before and
d After Re-iinspection for
f Citizens Property In
nsurance Piilot Reinsspection Pro
ogram (Citiizens 2010)
The Ciitizens re-insspection pro
ogram has ssince movedd into a full production
nt statistics on the proggram through April 30,
phaase. Table 1 summarizees the curren
201
12. Note th
hat the $95 million sh
hown for reecovered prremium reppresents the
premium recov
vered each year moving forward. Allso, note that
at the average change in
premium is av
veraged overr all homes,, including tthose that ddid not havee change in
use of the re--inspection.
premium becau

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Table 1. Summary of Homes with Wind Mitigation Re-inspections Performed by


Citizens Property Insurance as of April 30, 2012 (Citizens 2012).
Number of Homes Inspected
Homes with Increased Premium (discounts reduced)
Homes with Decreased Premium (discounts increased)
Average Change in Premium ($ (%) )
Gross Overall Premium Impact (1 year)

158,135
62%
6%
$602.21 (22.3%)
$95,230,525

2012 UMVI Updates


The UMVI is continuing to evolve. The OIR conducted two public workshops
in 2011 to identify improvements for the UMVI form. This process has culminated
with the 01/12 UMVI (OIR 2012). The latest version of the form includes several
enhancements to add objectivity to the form. The enhancements include:

Reporting of roof cover code by type of roof cover on the home, allowing
for multiple roof cover types to be identified and each can be classified as
to whether it meets the requirements of the FBC;
Incorporation of minimal condition requirements for roof deck attachment
and roof to wall attachment;
Clarification of the number of nails required on either side of a wrap-style
roof to wall connector; and
Inclusion of an opening protection level chart to make the classification of
opening protection as clear and objective as possible.

These changes increase the objectivity of the inspection form and reduce the
likelihood that inspectors make mistakes related to interpretation of the classification
of wind resistive features whether unintentional or intentional.
Taking Advantage of Technology
To improve inspection quality, many inspection companies are taking
advantage of the latest technology in smart phones, tablet computers, and the internet
to minimize mistakes and improve consistency of inspection results. For example,
ARA has developed a fully integrated system that collects objective inspection data
via an iPhone application, and transmits all data and photos in a single package to a
web-accessible database. Once uploaded, the website and database are used to
perform quality assurance reviews, create reports based on the data collected and
built-in decision tree logic, and deliver results. This technology supports improved
inspection quality by:

Eliminating errors introduced by transcribing field notes into a data


collection system;

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209

Eliminating errors introduced by shuffling of pictures taken of different


homes on the same day by the same inspector;
Basing all final decisions on feature classifications on a static set of rules
based on objective data fields; and
Providing transparency of the process to all parties.

Conclusions and Recommendations


Insurance incentives for wind mitigation have come a long way since
Hurricane Andrew. While the system that has been created in Florida is imperfect, it
is improving. Continued work to get the science, implementation, and inspections
correct will benefit everyone involved in the process. Getting the classifications and
credits correct will allow for a stable Florida insurance market where homeowners
can affordably insure their homes. It is critical to continually improve the science
behind the discounts, the implementation of the program, and the inspection
procedures and forms used to document wind resistive features.
In order to keep improving the insurance incentives for wind mitigation in
Florida, it is imperative that the OIR and insurance companies ensure that the features
that have the greatest impact on mitigating wind damage are included in the rating
structure. When considering the features discussed in the 2008 Loss Relativities
Study, this means including, at a minimum, the distinction for roof cover type
(shingle versus tile), number of stories, and reduction of the FBC compliant roof
credit as the roof ages.
When looking forward it is also important to establish criteria for wind
mitigation features in the program. In other words, how much of an impact should a
feature have to have, on average, to be kept in, or added to the program? For example,
if a feature is shown to have less than some threshold level of impact, say 2% on
average, then perhaps it should not be included as part of the discount program and
associated inspection forms.
On the opposite end of the spectrum, features can have an enormous impact.
Roof geometry is the feature with the greatest single impact on the discount program.
If a home has a hip roof with no other wind mitigation features, it is eligible for a
47% discount (OIR 2006). As a result, there is a significant consequence for either the
insurer or the homeowner if the roof is misclassified. This example illustrates the
need for criteria for when a feature needs to be divided into additional categories. For
the case of roof geometry, this may mean moving from the current hip or not-hip
classification to varying levels of non-hip features with respect to the building
perimeter that might include four or five classes instead of just two (hip or other). An

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alternative option is to allow for interpolation between the bounding cases of purely
hip and purely gable roof shapes.
Once appropriate features are identified, changes must be implemented
consistently and inspections must be performed consistently with the analyses
conducted to establish the discounts.

References
Applied Research Associates, Inc. (2002). Development of Loss Relativities for
Wind Resistive Features of Residential Structures, Florida Department of
Community Affairs, Tallahassee, Florida, March.
Applied Research Associates, Inc. (2008). 2008 Florida Residential Wind Loss
Mitigation Study, Florida Office of Insurance Regulation, Tallahassee,
Florida, October.
Citizens Property Insurance (2010). Citizens Property Insurance Corporation
Reinspection Pilot Study Preliminary Results as of 4/30/2010, report to the
Citizens Actuarial and Underwriting Committee, Jacksonville, FL, May.
Citizens Property Insurance (2012). Inspection Program Report, report to the
Citizens Actuarial and Underwriting Committee, Jacksonville, FL, March.
Fla. Stat. 627.0629, (1999 Statutes).
Fla. Stat. 627.0629, (2000 Statutes).
Fla. Stat. 627.0629, (2001 Statutes).
Fla. Stat. 627.0629, (2006 Statutes).
Florida Windstorm Underwriting Associates (2001), Manual of Rates, Rules, and
Procedures, Jacksonville, FL, July.
FCHLPM (2010), Windstorm Mitigation Discounts Report to the Governor, the
Cabinet, the President of the Senate, and the Speaker of the House of
Representatives, Florida Commission on Hurricane Loss Projection
Methodology, Tallahassee, February.
Office of Insurance Regulation (2003). Informational Memorandum OIR-03-001M;
Implementation of Revision to Section 627.0629(1), F.S. Concerning
Residential Property Insurance Rate Filings, Effective June 1, 2002, Florida
Office of Insurance Regulation, Tallahassee, January.

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Office of Insurance Regulation (2006). Informational Memorandum OIR-B1-1699;


Windstorm Mitigation Discounts Single Family Residence, Florida Office
of Insurance Regulation, Tallahassee, October.
Office of Insurance Regulation (2007). OIR-B1-1802; Uniform Mitigation
Verification Form, Florida Office of Insurance Regulation, Tallahassee, July.
Office of Insurance Regulation (2009). Summary for the Florida Commission on
Hurricane Loss Projection Methodology, Florida Office of Insurance
Regulation,
http://www.sbafla.com/method/portals/methodology/WindstormMitigationCo
mmittee/2009/20090812_supportdocsOIRMitigationDiscountsSummary.pdf
Tallahassee, August.
Office of Insurance Regulation (2010). OIR-B1-1802; Uniform Mitigation
Verification Form, Florida Office of Insurance Regulation, Tallahassee,
February.
Office of Insurance Regulation (2012). OIR-B1-1802; Uniform Mitigation
Verification Form, Florida Office of Insurance Regulation, Tallahassee,
January.
Twisdale, L.A., M.A. Young, and C. Driscoll (1998). Residential Construction
Mitigation Program Inspection Checklist Quality Assurance Analysis for Palm
Beach County, Applied Research Associates, Inc., Raleigh, North Carolina,
for Florida Department of Community Affairs, Tallahassee, Florida,
December.

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