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

2nd April 2009

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?



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



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


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?


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


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


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


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


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


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?


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


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


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


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?


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?


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?



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.


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


Thank you for taking the time to consider our response. If you have any further queries please contact Graeme Trudgill, BIBA’s Technical and Corporate Affairs Executive for further information on 02073970218 or on [email protected] or Steve Foulsham, BIBA’s Technical Services Manager on 02073970234 or [email protected] .



Yours sincerely



Eric Galbraith

Chief Executive


Direct Tel:  020 7397 0201

Direct Fax: 020 7626 9676

Email: [email protected]