About Aviva: Aviva Canada is…

About Aviva:
Aviva Canada is the second largest property and casualty insurance group in the country providing home, automobile, leisure/lifestyle and business insurance to approximately three million customers. A wholly-owned subsidiary of UK-based Aviva plc, the company has more than 4,000 employees, 27 locations across Canada and approximately 1,500 independent broker partners.

General Comments:
Climate change is impacting our environment and our lives in many ways. From an insurer’s perspective, property claims for the industry as percent of total claims have rises from 24.4% in 2004 to 34% in 2017. (source Insurance Bureau of Canada). Trends in Ontario/Canada mirror global trends, frequency and severity of extreme weather and catastrophic weather events are occurring – and of course, insurance premiums are based on risk.

Flood risk, including overland flooding, has been increasing across Canada. Right now, in spring 2019, communities in the Central Ontario and Ottawa regions are suffering severe flooding.
Communities and homeowners across the province are feeling the financial impacts of climate change and extreme weather events. Insured losses for extreme weather averaged $414 million per year between 1983 and 2008, and $1.9 billion per year between 2009 and 2018 (in 2018 dollars). Water damage is the key driver behind these growing costs. In Ontario, insured losses from severe weather accounted for $1.4 billion of the $2 billion in insured damage incurred across Canada in 2018.

In addition to this, there is an insurance gap in Canada. After disaster strikes, for every dollar of insured losses borne by insurers in Canada, $3.00-$4.00 are borne by governments, home owners and businesses (source: Insurance Bureau of Canada). Families who experience the impact of flooding/property loss and damage face a very challenging recovery afterwards – this can have a detrimental impact on a family emotionally and economically, depending on their preparedness.
It really is the joint responsibility of all levels of government, insurers, businesses and individuals to prevent, mitigate and reduce the health, safety and financial risks associated with extreme weather and climate change related perils.

Aviva is very supportive of the commitments in Ontario’s new Made-in-Ontario Environment Plan in general because it seeks to help Ontarians adapt to climate change in a way that is consistent with a whole-of-society approach.

Land use planning:
In addition to upgrades/maintenance in grey infrastructure, natural infrastructure is a key priority for risk reduction. We encourage the preservation and strategic management of natural lands, wetlands, forests, open lands, etc. to effectively manage risk. We were pleased with the government’s announcement last year regarding preservation of the Greenbelt, for example. Continued diligence and sound policy making is required going forward.

Housing:
Aviva is cognizant of housing supply constraints and the regulatory burden that is preventing housing from being built in a timely fashion. Efforts to eliminate regulations that are overly burdensome, for whatever reason, and that unnecessarily delay construction in areas where there are no flood hazards or environmentally sensitive land should be encouraged, to improve affordability.

Any changes to the power, governance and funding models of conservation authorities should serve to strengthen the ability of conservation authorities to prevent residential or commercial development in flood plains or other areas at risk of flooding.

The safety and economic welfare of Ontario families should be paramount in any decision that weighs housing availability/affordability with increasing the risk of disaster/loss/injury. Recognizing that this is a challenging public policy issue to grapple with, we implore due diligence and careful consideration in the matter.

Conclusion:
Thank you for the opportunity to provide comments. We look forward to working with the government in the future.