That, following a significant natural disaster such as the 2022 flood, the Inspector-General for Emergency Management conduct a review at an appropriate time to provide feedback for continuous improvement.

That the Victorian Government confirm the powers of the Inspector-General for Emergency Management to undertake reviews on a self-referral basis or, if such powers do not exist, to legislate to provide these powers.

That the Victorian Government consider all the evidence, findings and recommendations from this Report when developing a new Victorian Floodplain Management Strategy.

That the new Victorian Floodplain Management Strategy detail the coordination responsibility of the Victorian Government to ensure all flood studies for all local government areas are fully funded and completed.

That the Victorian Government make public the internal, de-identified after-action review conducted by the Department of Energy, Environment and Climate Action.

That the Victorian Government clearly state the operational role and responsibilities of each emergency service in preparation for a flood emergency, outlining the appropriate chain of command, communication protocols, and engagement with the local community.

That the Victorian Government ensure regional catchment management authorities, with local councils, are funded and resourced to conduct and implement up to date flood studies on a regular basis.

That the Victorian Government require peer review of publicly funded flood modelling as part of the next Victorian Floodplain Management Strategy.

That Melbourne Water and other floodplain management authorities review flood models every five years and update the models at least every 10 years and after the occurrence of a major flood.

That the Victorian Government provide Victorians with access to appropriate data contained within the FloodZoom platform

That the Victorian Government introduce amendments to the Sale of Land Act 1962 (Vic) to require vendor disclosure statements to include a simple statement on flood risk. In addition, houses or dwellings previously flooded must be included in any vendor declaration statement.

That Emergency Management Victoria work with local government authorities and local State Emergency Service units to provide access to local flood guides to all residents in a flood zone, that identify the likely flood impacts on individual properties.

That the Victorian Government improve individual and community awareness about their own roles and responsibilities in emergency management, and make available information resources for preparing for flood and other emergencies.

That the Victorian Government require the emergency management sector to ensure that the needs of vulnerable communities including people with disability are included in all disaster preparation and response plans and ensure that sufficient funding is available to make all disaster emergency responses inclusive for people with disability.

That the Victorian Government provide flood risk and planning information in a way that is appropriately accessible to people with additional needs, including people with disability.

That the Victorian Government ensure early warning systems include consideration of a voluntary register of people in need of additional support to receive early warning and support during natural disasters.

That the Victorian Government fast-track the implementation of flood studies into planning schemes. This should be done cooperatively with local councils and relevant stakeholders, group together flood studies into regional amendments, and use the Minister for Planning’s powers as required, within two years of completion.

That the Victorian Government introduce amendments to the Planning and Environment Act 1987 (Vic) and Victoria Planning Provisions so that planning and other authorities must address climate change at all levels of the planning process.

That the Victorian Government work with floodplain management authorities and climate scientists to understand how flood modelling can be used to better predict the impact of climate change on flooding and update its flood management policies in line with this understanding.

That regional local councils work closely with their regional catchment management authorities to better understand, manage, and mitigate the risk of building on floodplains in regional Victoria.

That Victoria’s strategic land use planning limit inappropriate new housing and business developments inside 1% AEP floodplains.

That the Victorian Government support residents within 1% AEP floodplains, including with funded programs, to manage the risk facing their existing properties and make their properties more flood resilient.

That the Victorian Government fund a resilient homes program to raise or retrofit residential properties at risk of flood inundation, and which prioritises homeowners affected by the 2022 flood event.

That the Victorian Government require planning authorities, floodplain management authorities and other relevant actors to take account of the change in land use and especially projected changes to land use when setting flood levels for planning and development and the application of the land subject to inundation overlay.

As part of the development of the new Victorian Floodplain Management Strategy, that the Victorian Government review the operation of the last Strategy, in consultation with local councils, community representatives, expert advisory groups and other relevant stakeholders

That the Victorian Government’s review of the last Victorian Floodplain Management Strategy (and development of the new Strategy) examine levee funding and management arrangements to determine if they are still fit for purpose based on new information and insights from the October 2022 flood event.

That the Victorian Government fund floodplain managers to develop maps modelling scenarios demonstrating the impact on landholders of specified levee breeches.

That the Victorian Government review the Victorian Floodplain Management Strategy to examine issues around rural levee management. This should include the roles and responsibilities of local councils and private landowners and consider the adequacy of taxpayer support for maintaining these systems.

That the Victorian Government fund the pilot of a ring levee development program in Northern Victoria to protect house and curtilage in flood-prone areas.

That the Victorian Government ensure that future flood mitigation efforts include updated and rigorous hydraulic modelling before implementation, ensuring the effectiveness of compensatory measures. Additionally, these strategies should undergo independent peer review to validate their expected performance.

That the Victorian Government ensure that major flood mitigation measures be assessed and reviewed to ensure they perform as intended.

That the efficacy and impact of the Flemington Racecourse flood wall be considered as part of Melbourne Water’s review of mitigation in the Maribyrnong River catchment announced following the updated flood modelling.

That the Victorian Government further investigate options for increasing outlet capacity at Lake Eppalock. This investigation should involve:
- conducting a cost-benefit analysis to evaluate financial feasibility
- extensive stakeholder engagement to gather input from affected parties and communities
- examination of environmental effects
- environmental risk assessments to understand potential impacts on local ecosystems, wildlife and water quality
- reviewing water-sharing arrangements to ensure: –appropriate adjustments to maintain equitable water distribution and –compliance with legal and regulatory requirements.

That the Victorian Government ensure that, for future events that are expected to replicate high storage and high rainfall conditions, new temporary operating rules for water storage and release are developed. These new rules must take account of the interest of those who are affected by Eildon and Eppalock’s storages including downstream landholders and water entitlement holders.

That the Victorian Government ensure that the state’s existing culvert infrastructure in high-risk flood areas is fit for purpose, and that the Government also consult with local councils and other relevant stakeholders and prioritise betterment in any upgrade works deemed necessary.

That the Victorian Government audit transport links in and out of disaster-prone areas.

That the Victorian Government clarify responsibility for flood mitigation infrastructure, with clear accountability and transparency for who is responsible for each asset.

That the Victorian Government work with the Commonwealth Government to ensure the Disaster Recovery Funding Arrangements are not unduly burdensome.

That the Victorian Government prioritise investment in betterment projects to improve the resilience of mitigation infrastructure, and in doing so work with the Commonwealth Government to achieve this goal.

That the Victorian Government adapt policies and funding models to prioritise betterment initiatives, including ensuring that financial resources are allocated effectively to meet long-term needs of at-risk communities, and in doing so work with the Commonwealth Government to achieve this goal.

The transfer of ownership and responsibility for public gauges to the Bureau of Meteorology should be completed as a priority, and the Victorian Government should request the Commonwealth Government provide a public update by the end of 2024 on these transfer timelines.

That the Victorian Government identify and fill critical gaps in the state’s gauge network. New gauges should be installed in priority locations as soon as possible, and existing gauges should be upgraded with telemetry services. Information from flood gauges and telemetry services should be easily accessible by the public.

That the Victorian Government use the experience of warnings transmitted during the 2022 flood event to identify and adopt best practice for community warning frequency.

That the Victorian Government improve the accuracy, timeliness, and relevance of the VicEmergency service during an emergency. In doing so, the Government should actively seek input from non-government and government stakeholders to ensure that the service can meet the diverse needs of different communities during a crisis.

That the Victorian Government improve the flood warning system so that warnings are:
- accurate with the most up-to-date information
- delivered in a timely way
- clear and easily understood
- consistently disseminated across different communities
- accessible in relevant formats and languages, where appropriate.

That the Victorian Government ensure the emergency warning system is inclusive and able to be used by all Victorians, and should:
- include real-time translation of warnings into multiple languages during a crisis event
- deliver information in easier to understand ways which meet the needs of people with a disability.

Given the essential role of digital connectivity in emergency management and response, that the Victorian Government, working with the Commonwealth Government as necessary, address connectivity limitations, focusing on rural and remote areas. Potential options to consider are the need for:
- enhanced infrastructure investment
- geographically based coverage
- rapid deployment of temporary satellite vans.

That the Victorian Government establish long-term community awareness initiatives to ensure the public understand flood risk and actions. Successful bushfire awareness campaigns could be used as a basis for such initiatives.

That the Victorian Government increase funding for training of volunteers to boost the capacity of State Emergency Service units and Shepparton and Echuca and Moama Search and Rescue squads to respond during emergencies.

To improve the management and distribution of sandbags during a flood event, that the Victorian Government:
- ensure that there is sufficient supply quantity of sandbags available for preparation for floods in a wet year.
- assess the benefits of a coordinated sandbag management system in Victoria. This system could include capacity for scalable sandbagging stations and address resource gaps in high-risk flood areas.
- ensure that emergency management plans are regularly updated to reflect current resource and logistical capabilities.
- explore options for supplementing reliance on sandbags with innovative new products such as floodgates or water inflated barriers.

That the Victorian Government develop a strategic rescue plan in areas at high risk of flooding, so that they have appropriate resources and expertise for rescues during a crisis event. This plan should include consideration of procurement, expansion of reserve caches and processes for rapid deployment of resources.

That the Victorian Government, in collaboration with the Victoria State Emergency Service, review its approach to evacuation warnings to identify opportunities for improvement and increased community responsiveness.

That the Victorian Government and the Victoria State Emergency Service work with:
a. New South Wales to finalise the MOU that has been initiated, and to make it publicly available
b. South Australian counterparts to initiate and establish a MOU or other mechanisms for cross-border cooperation in relation to shared emergency events, and to make this publicly available.

That the Victoria State Emergency Service undertake a strategic review of its resources, leadership and personnel allocation. This review should focus on enhancing communication systems, ensuring adequate availability of essential resources like rescue equipment, and implementing robust volunteer recruitment processes, support and training programs.

That the Victorian Government increase funding and support for the Victoria State Emergency Service to enable a comprehensive upgrade of emergency communication technologies, ensure a steady supply of critical response resources, and expand volunteer recruitment and retention programs, thereby bolstering the agency’s capability to manage and respond to emergencies effectively.

That the Victorian Government ensure that incident control centres include a mechanism for local expertise to be included in their operations and help inform processes to assist managing localised warnings and response.

That the Victorian Government increase funding to Shepparton and Echuca and Moama Search and Rescue squads to ensure optimal response capabilities in future emergencies.

That the Victorian Government, working with local councils, establish statewide operating guidelines for Emergency Relief Centres. These guidelines should include protocols on rapid activation, streamlined communication and resource mobilisation. Local councils should remain empowered to tailor protocols to meet local needs.

In line with Recommendation 58, that the Victorian Government, working with local councils, investigate options for emergency funding arrangements to assist operating Emergency Relief Centres and include these arrangements in statewide operating guidelines.

That the Victorian Government plan and resource recovery hubs (including online access) sufficiently to fulfil their role in long-term community recovery and resilience building.

That the Victorian Government simplify the application process for disaster recovery funding. This could include reducing paperwork, providing hands-on assistance and investigating technology to streamline processes.

That the Victorian Government evaluate the criteria and funding arrangements for financial assistance post-disaster with a view to:
a. better aligning support with costs of recovery
b. proposing options for quickly deploying support mechanisms according to the scale and complexity of the event.

That the Victorian Government review its framework for providing housing support following an environmental disaster. In particular, the Government should assess the application system to ensure that genuinely affected households are provided support in a timelier manner and to mitigate the risk of fraudulent claims.

That the Victorian Government recognise caravan parks as essential businesses in disaster-prone areas as providers of housing and emergency support and ensure support is available (including grants) under Disaster Recovery Funding Arrangements to caravan park operators, including those operating on Crown Land.

That the Victorian Government, noting that repair of natural environment is often overlooked in disaster recovery, assess and make funding available for natural environment and restoration.

To assist with ongoing clean-up of flood-affected areas following disasters, that the Victorian Government establish a dedicated financial support program for local businesses involved in debris removal and restoration efforts. This should include reimbursement mechanisms for businesses, such as earthmoving companies, that contributed equipment and personnel to the clean-up but suffered significant financial losses doing so.

That the Victorian Government pay its bills on time, especially following natural disasters.

That the Victorian Government work to support better collaboration between local communities, contractors, and government agencies, ensuring swift deployment of additional human resources for efficient post-disaster clean-up efforts.

That the Victorian Government collaborate with local authorities and community groups to develop and implement a debris management strategy and ensure that it aligns with broader disaster management plans as part of future-proofing for environmental events.

That the Victorian Government develop community-based initiatives and resource-sharing mechanisms, fostering resilience and solidarity among towns facing challenges from environmental disasters. These should ensure timely and effective responses to future crises, leveraging collective strength and kindness to aid in the recovery process.

That the Victorian Government provide long-term funding contracts for mental health services in flood-affected regions, with a focus to securing dedicated mental health professionals and effective service delivery in communities impacted by natural disasters.

That following the outcomes of the House of Representatives’ Inquiry into insurers’ responses to 2022 major floods claims, the Victorian Government advocate to the Commonwealth Government that it take action to ensure that residents and businesses in flood-affected areas can obtain and maintain necessary insurance.

That the Victorian Government’s response to this Inquiry identifies the responsible authorities for each recommendation and provides a timeframe for action and reports back to Parliament on progress made implementing the recommendations.

The Committee recommends the Australian Government define the following terms in the Insurance Contracts Act 1984:
- All major forms of water damage, including “rainfall runoff”, “storm surge”, “tidal surge” and “riverine flood”.
- Key terms relating to exclusions relating to the maintenance of the property including “wear and tear” and “lack of maintenance”. The Committee recommends that the Insurance Council of Australia accelerate its work with the Australian Competition and Consumer Commission in developing and approving the standardising of these terms and that consumers be provided with greater clarity in relation to the meaning of “pre-existing defect and/or damage”.

The Committee recommends that:
- the Australian Government legislate a requirement for general insurers to provide policyholders with information regarding insurers’ expectations of policyholders conducting “reasonable maintenance” to their property and the potential consequences for claim outcomes if a reasonable level of maintenance is not undertaken, and
- the Insurance Council of Australia in conjunction with the Australian Securities and Investments Commission and key consumer group representatives develop clear guidance regarding ‘reasonable maintenance’ across insurers, including for roofs, gutters, fences and stumps.

The Committee recommends that a distinction be made in the General Insurance Code of Practice (the Code) between aspects of properties where maintenance is:
- Observable (for example, roofs and gutters) versus where it is not observable (for example, typically, stumps).
- Where regular upkeep is reasonably within the remit of the householder or business versus where maintenance is infrequent, costly and highly irregular (for example, stumps).
- Where maintenance is not observable and infrequent maintenance is required, there should be a presumption of coverage by insurers unless exceptional circumstances can be established. It should be noted that this may have an impact on premiums for some policies (for example, for older houses) but that the trade-off is that it will reduce the likelihood of dramatically different outcomes for households with the same experience from the natural disaster while making no difference to the observed risk or behaviour of policyholders. This presumption should be reflected in the industry-wide guidance issued under Recommendation 2.

The Committee recommends that the Australian Government consider amending Sections 46 and 54 of the Insurance Contracts Act 1984 so as to better give effect to the original intent of the provisions. This could reduce unintended, arbitrary divergences in claims outcomes based on wear and tear and maintenance exclusions at odds with reasonable consumer understanding of their coverage.

The Committee recommends that Engineers Australia in conjunction with the Insurance Council of Australia develop guidelines for hydrologists that are providing insurers with hydrology reports relating to flood and storm claims, with a view to providing a more robust evidence base for insurers to rely on to make claim decisions. These guidelines should be shared with state and territory governments and appropriate authorities such as planning agencies and resilience authorities. This could include the following matters:
- The appropriate qualifications and experience of the hydrologists that are relied upon to provide expert reports.
- In order to better use scarce hydrologist resources, the potential for reports to jointly cover multiple properties, particularly where they are co-located and were affected by the same flow of water. Where appropriate, such reports should acknowledge differential considerations across properties.

The Committee recommends that the Australian Securities and Investments Commission produce regulatory guidance clarifying that insurers cannot rely solely on hydrology and expert reports to deny a claim where the report has not properly linked the damage observed with the cause of the damage, consistent with Recommendations 75 - 78 of the Independent Review of the General Insurance Code of Practice (the Code).That the Code provisions in relation to the appointment of experts be strengthened to ensure that:
- the purpose of the Code include the intent that experts are to provide independent, detailed, clear, comprehensible and professional assessments of the cause and extent of loss.
- insurers be required to ensure the expertise, professionalism and independence of experts appointed by them.
- expert reports are in a standardised format to improve consumer accessibility and understanding.
- clauses 161 and 162 of the Code require the insurer to provide policyholders with any expert reports including, but not limited to, any reports that insurers have relied upon to deny a claim in whole or in part

The Committee recommends the Australian Government establish a mechanism for creating and funding an independent expert panel of hydrologists to undertake hydrology reports if the policyholder disputes the findings of the first report.
- One model for such a panel could be the use of medical panels for compensation cases.
- Government and industry should explore how such a panel could be funded.

The Committee recommends that the General Insurance Code of Practice be amended to require that insurers implement mechanisms to:
- periodically review the evidence relied upon to deny a claim based on lack of coverage under the policy or the application of an exclusion, where a hydrology and other expert report is one component of the evidence, to determine whether reports with insufficient evidence are being given too much weight in the decision to deny the claim
- communicate the level of quality expected by insurers to third parties providing expert reports, and
- more effectively identify concerns with, and provide feedback to, external experts.

The Committee recommends the Insurance Council of Australia in consultation with the Australian Securities and Investments Commission provide guidance to insurers about providing greater detail and clarity to policyholders on their rights and risks when an offer is made for a final cash settlement, including the risks policyholders should be aware of for the project management of repairs. This would align with elements of recommendation 71 of the Independent Review of the General Insurance Code of Practice’s Initial Report, and the Committee recommends that this recommendation be implemented in full.

The Committee recommends that the General Insurance Code of Practice provide that final cash settlements:
- Be provided in a template form that is standardised across all insurers. The template should include a clear itemisation of all key elements of the total sum. The template be designed with input from peak consumer organisations and the Australian Securities and Investments Commission.
- Should include actionable, comprehensive, and transparent quotes.
- Should clearly identify compensation for unforeseen risks and project management risk (as identified in Recommendation 9).

The Committee recommends that the General Insurance Code of Practice be amended to include a minimum 30 day ‘cooling off period’ with respect to cash settlements.

The Committee recommends that the General Insurance Code of Practice be amended to require insurers, when offering a final cash settlement, to:
- Advise the consumer to obtain legal advice in relation to a final cash settlement;
- Advise the consumer of their rights to reopen a final cash settlement under the General Insurance Code of Practice and any rights they may have in respect of common law;
- Refer the consumer to community legal advisers and financial counsellors in the local area.

The Committee recommends that the General Insurance Code of Practice be amended to require insurers when offering final cash settlements to include areasonable uplift/contingency sum to reasonably compensate policyholders for the risks they take on in project managing the repairs to their property.

The Committee recommends the General Insurance Code of Practice be amended to allow policyholders to have a 12-month period to seek a review of a final cash settlement where there is a change in the facts upon which the original determination was made.

The Committee recommends that the General Insurance Code of Practice prohibit the use of the terms “without prejudice” or “confidential” (or other misleading terms) on final cash settlement offers. This could be supplemented by regulatory guidance by the Australian Securities and Investments Commission.

The Committee recommends that a new service be offered to support vulnerable cash settlement recipients to project manage rebuilds and major repairs. This could be similar to the Service Navigator role in Queensland’s Resilient Homes Fund.

The Committee recommends that the Insurance Council of Australia in consultation with the Australian Securities and Investments Commission:
- develop standardised industry requirements for obtaining Scopes of Work to ensure common items are included and costings itemised (for example, in a template form),
- provide itemised costings in Scopes of Work to policyholders as part of the cash settlement offer process, and
- develop standardised mechanisms for insurers to implement quality control over the Scopes of Work they receive.

The Committee recommends that there should be insurer and regulator oversight of Scopes of Work through the following mechanisms:
- Stronger Code provisions in relation to quality of Scopes of Work (as per Recommendation 74 of the Independent Review of the General Insurance Code of Practice).
- Random vetting of Scopes of Work quality by the Australian Securities and Investments Commission.

The Committee recommends that insurers amend their home insurance policies to provide fully paid temporary accommodation until the insurer has closed the claim, unless the extension of the time required can be demonstrated to be a result of behaviour on the part of the policyholder that is unreasonably causing delay; That final cash settlements include a provision for temporary accommodation that takes account of the Scope of Works; progress on the project to date; and a reasonable uplift; and That the cost of covering temporary accommodation should be a separate entitlement and not be funded out of the sum insured amount.

The Committee recommends the Insurance Council of Australia amend the General Insurance Code of Practice to include an appropriate mechanism for ensuring policyholders that are being provided with temporary accommodation as part of their claim have at least 3 months’ notice of any proposed substantive changes to the policyholders’ living situation or the insurers’ payments for the accommodation.

The Committee recommends that the Insurance Council of Australia in conjunction with the Australian Securities and Investments Commission develop guidelines on how insurers can apply tighter internal controls on the oversight of building contractors, including guidelines on community expectations for industry to improve their oversight practices.

The Committee recommends the Australian Government consider appropriate regulatory or other mechanisms to reduce the instances of third-party builders and other contractors making changes to properties without the policyholder’s consent, including the practice of gaining entry, removing property (strip-outs) or conducting repairs without the policyholder’s knowledge or consent. Solutions should take into account the unique circumstances and challenges created by catastrophic flood events.

The Committee recommends that the Australian Government investigate mechanisms to require insurers to more clearly communicate the basis for the price of premiums. This could include:
- at a high level, highlighting the nature of risk for the property for each major peril type (for example, a traffic light rating system)
- last year’s premium alongside the current year’s premium, along with a descriptive analysis of why there has been a change if it is material (for example, over 10 per cent). The analysis could include highlighting different factors that may influence pricing such as changes in building costs or changes in the assessment of one or more perils, or the impact of household or community level mitigation, without attaching numerical estimates to each factor.

The Committee recommends that the General Insurance Code of Practice be amended to require that insurers, at policy commencement and renewal, communicate key information on the consumer’s policy, including:
- A clearly highlighted plain English explanation of common obligations policyholders have under their policies and the application of certain exclusions if they are not undertaken, and
- general advice in relation to property maintenance and the expectations of the insurer regarding key aspects of the property such as roofs, gutters and fences, and
- general information around the calculation of a policyholder’s sum insured and factors a policyholder may wish to consider to ensure full coverage in a total loss event.

The Committee recommends that the General Insurance Code of Practice be amended to require that insurers inform policyholders when they suspect the policyholder’s sum insured does not cover the full rebuild costs according to their calculations, both at sign-on and renewal. The insurer should encourage the consumer to review their sum insured amount and ask them to confirm with a response.
The Committee further recommends that the General Insurance Code of Practice be strengthened to require insurers to ensure that sum insured calculators are accurate and up to date, consistent with Recommendation 56 of the Independent Review of the General Insurance Code of Practice. The calculators should include updated information on rebuild costs, including cost increases relating to rebuilding to current building standards, and increases in labour and materials costs.

The Committee recommends that the General Insurance Code of Practice be amended to require that insurers adopt a more flexible approach in relation to rebuilds and that, in particular, a like-for-like replacement not be required and that consumers be permitted to swap out size/scope for resilience and efficiency in “sum insured” repairs and rebuilds.

The Committee recommends that insurance brokers and insurers be required to provide clear guidance on the operation of averaging provisions to small and medium sized businesses.
The Australian Government should also consider prohibiting averaging provisions for small businesses.

The Committee recommends that all large insurers commit to having a physical presence at major emergency hubs in affected communities as soon as possible following a natural disaster.

The Committee recommends the Insurance Council of Australia in consultation with the Australian Securities and Investments Commission and state, territory and local governments:
- Develop guidance for policyholders on the actions they can take to clean up their properties following a natural disaster.
- Include in the guidance any actions policyholders should take to document damage to their properties, such as taking photos to assist with their claim.
- Obtain a commitment from insurers that they will have regard for the guidance when assessing claims.
- Distribute the guidance as soon as possible to disaster-impacted local government areas.
- Make the guidance part of information distributed by insurers when a natural disaster occurs, including making the guidance available at recovery hubs in hard copy form.
- Develop debris cleanup guidance for councils.

The Committee recommends that the General Insurance Code of Practice be amended to require that insurers, in the immediate aftermath of a natural disaster, provide policyholders with updated information about:
- what policyholders can expect from making a claim and the claims process,
- realistic time estimates for each step of the claims process, and
- customers’ rights to challenge decisions or raise concerns about the insurers’ conduct.
This guidance should take the form of a comprehensible and standardised diagram or flowchart. Following major flood events, insurers should also build into their systems pathways for policyholders to receive quick responses to commonly asked questions.

The Committee recommends the General Insurance Code of Practice be amended to require insurers to contact customers within 5 business days of the insurer becoming aware of a material change in the expected timing of any stage outlined in the guidance provided under Recommendation 30.

The Committee recommends, in alignment with recommendation 3 of the 2023 Deloitte report, that insurers be required to build into their staff resourcing plans, strategies to adequately increase resourcing for key services, including call centre and claims management staff, when significant or catastrophic events occur.

The Committee recommends that the General Insurance Code of Practice be amended to require insurers to provide all policyholders with access to realtime information about their claim’s progress and key documentation on their claim. This could be through a mobile application or other platform.

The Committee recommends the General Insurance Code of Practice be amended to require that insurers use the ‘single point of contact’ claims management approach to the extent possible when responding to major natural disasters and ensure policyholders are informed of who their assigned case manager is as soon as practicable. The Committee further recommends that insurers be required to accommodate the preferred communication channel nominated by a policyholder during the claim processing period.

The Committee recommends that clauses 103c and 103d of the General Insurance Code of Practice be strengthened to ensure that key information is translated and available on insurers’ websites and that clause 103a should specify that this includes translating and interpreting services for Indigenous Australians.

The Committee recommends that insurers invest in their IT systems to improve the storage of policyholders’ key documentation and case notes, including correspondence and discussions. Case managers should also be suitably trained and resourced to implement quality record-keeping.

The Committee recommends that the Australian Securities and Investments Commission review how insurers are identifying vulnerable policyholders with a view to ensuring vulnerable policyholders are:
- consistently being identified when they make a claim;
- being identified in numbers commensurate with their prevalence; and
- provided with appropriate support throughout the claims process.

The Committee recommends that insurers devote additional resources to providing vulnerable customers with assistance. Insurers should evaluate the effectiveness of this assistance after each declared event.

The Committee recommends that the General Insurance Code of Practice be amended to require insurers’ identification of vulnerable customers and training of staff be designed so that customer interaction is compliant with ISO 22458 2022-04, the International Organization for Standardization’s document Consumer vulnerability – Requirements and guidelines for the design and delivery of inclusive service.

The Committee recommends that insurers improve staff training to ensure staff adopt a trauma-informed approach when communicating with policyholders. This should include:
- Explicit reference to trauma-informed policies and training in the General Insurance Code of Practice (as per Recommendation 26 of the Independent Review of the General Insurance Code of Practice).
- Priority should be given to the recruitment of staff with experience from natural disasters.
- Recording, with consent, personal information to better assist people experiencing vulnerability (as per Recommendation 27 of the Independent Review of the General Insurance Code of Practice).
- Clear communication, via insurer websites and other forms of communication (such as mobile applications), the types of additional supports that the insurer makes available to consumers experiencing vulnerability.

The Committee recommends that the Australian Securities and Investment Commission update RG 271 Internal Dispute Resolution to provide further guidance on what constitutes a complaint and how complaints should be recorded. The goal should be to ensure that the definition of an internal dispute is set at a level that captures appropriately serious disputes and that this threshold is applied consistently across all insurers.

The Committee recommends that all insurers be required to establish a dedicated internal dispute resolution monitoring and review team to identify systemic issues arising through complaints and implement the Australian Financial Complaints Authority’s feedback to improve internal dispute resolution and claims handling processes

The Committee recommends that insurers put in place strategies to ensure their internal dispute resolution teams will be appropriately resourced and trained to respond to future significant natural disasters, and able to critically analyse expert reports and investigate the circumstances of the claim.

The Committee recommends that insurers improve their processes to facilitate the escalation of cases that remain unresolved after 12 months to a more experienced case manager.

The Committee recommends that all insurers create a role for a ‘consumer advocate’ which has oversight of and, where appropriate, involvement in, the disputes managed within the firm, cases that have moved to the Australian Financial Complaints Authority (AFCA), and claims which have taken a long period of time to resolve. The consumer advocate should report to the Chief Executive Officer quarterly and the Board each year and provide a summary of the activities of the office over the preceding 12 months including a summary of cases where the consumer advocate was involved, the disputes that went to AFCA and the firm’s overturn ratio, and where long delays occurred before the case was resolved (longer than 12 months).

The Committee recommends that the Insurance Council of Australia seek to have the General Insurance Code of Practice approved by the Australian Securities and Investments Commission after implementing any recommendations of the Independent Review of the 2020 General Insurance Code of Practice.

The Committee recommends that the General Insurance Code of Practice be incorporated as a contractually enforceable clause in insurance Product Disclosure Statements (as is the Banking Code of Practice).

The Committee recommends that the General Insurance Code Governance Committee publish aggregate data on code breaches by clause, individual insurer, and brand.

The Committee recommends that the Australian Securities and Investments Commission (ASIC) appropriately use powers that it has as a result of the removal of the exemption of claims handling of insurance products under the Corporations Act 2001. The Committee notes that ASIC has only recently been granted such powers and they are as yet untested.

The Committee recommends that the Australian Securities and Investments Commission and the General Insurance Code Governance Committee share data so that it is possible to evaluate breaches of the General Insurance Code of Practice in the context of an insurers’ overall claims profile.

The Committee recommends that the Australian Securities and Investments Commission develop and define key outcomes measures for the consumer experience, including:
- Communication (outcome measures)
o Overall customer satisfaction, such as a customer satisfaction score o Consumer comprehension of communications (random sample)
- Claims processing
o Average time taken to respond to a customer after first making an enquiry or initiating a claim
- Vulnerable customers o Proportion of customers identified as vulnerable (BAU, quarterly)
o Proportion of customers identified as vulnerable (designated events, monthly)
- Internal dispute resolution o Proportion of total cases that involved internal dispute resolution
o Average time taken to resolve internal dispute cases
- External dispute resolution
o Proportion of total cases that were referred to the Australian Financial Complaints Authority
o Success rate at the Australian Financial Complaints Authority
- Cash settlements
o Proportion of resolved cases that are final cash settlements
- Claims acceptance rates
o Percentage of claims acceptedPercentage of claims closed (at key points in time, for example 6 months, 12 months, 18 months)
- General Insurance Code of Practice Compliance Breaches of the General Insurance Code of Practice per thousand claims by clause, insurer, and brand.

The Committee recommends that legislation provide the Australian Securities and Investments Commission with sufficient data-gathering powers to obtain the information required to monitor and report on the metrics recommended in Recommendation 51.

The Committee recommends the Australian Securities and Investments Commission consider seeking data from insurers on their performance based on the metrics recommended in Recommendation 51:
- Quarterly, for business-as-usual operations
- Monthly, for each declared event.

The Committee recommends the Australian Securities and Investments Commission publish quarterly insurer and brand level data on their performance on the metrics recommended in Recommendation 51.

The Committee recommends that the Australian Securities and Investments Commission’s MoneySmart life insurance claims comparison tool be extended to general insurance.

The Committee recommends that for each declared event, insurers be required to report the number of unresolved cases after 12 months to the Australian Securities and Investments Commission and the overarching strategy for resolving these cases. This report should include the total number of outstanding claims and the most common reasons for the delay.

The Committee recommends that the General Insurance Code of Practice (the Code) be reformed to implement Recommendation 63 of the Independent Review of the 2020 General Insurance Code of Practice, that is: where the insurer has not made a decision on a claim within 12 months, and the delay is not due to the consumer or other reasons beyond the control of the insurer, the Code should require the claim to be accepted. The Committee further recommends that Australian Securities and Investments Commission consider using its powers in relation to claims management to enforce this obligation.
- This would not be triggered where a claim has been lodged with the Australian Financial Complaints Authority.
- This would be triggered where internal dispute resolution has commenced but is not resolved. If the insurer has not made a decision by 12 months, the claim must be paid.

The Committee recommends that insurers report case management key performance indicators to the Australian Securities and Investments Commission.

The Committee recommends that insurers recognise standard third-party authorisation forms and that this obligation be reflected in staff training.

The Committee recommends that, if a policy renewal falls due when there is long delay in claim handling or the completion of the project, the insurer should:
- be required to offer a reduced form of cover, with an appropriately lower premium
- this cover should include public liability cover and sufficient cover for the building in its damaged state (noting that some consumers are being sent standard premium renewals, which amounts to excessive cover).

The Committee recommends that insurers be required to ensure that people paying premiums monthly do not pay more.

The Committee recommends that the Australian Government work with state and territory governments to ensure flood maps are produced to a high standard across the nation, regardless of the size of the local government area producing the modelling. This may require:
- increased funding for local government areas and water authorities, and
- the development of agreed standards to ensure that flood mapping is completed to at least an agreed minimum standard.
That, over time, this higher quality flood modelling be made freely accessible to homeowners and the general public along with easy to understand information about flood risk exposures at each property. This may be best undertaken in the first instance by local councils and/or water authorities responsible for generating the flood modelling, consistent with Recommendation 3 of the Actuaries Institute’s Funding for Flood Costs report (August 2023).

The Committee recommends that the Australian Government ultimately move towards a national, centralised, public-facing portal containing flood risk data at the household level for:
- all households and small businesses across Australia, and
- all land being considered for release for development and all land that has been released for development, but not yet developed.
Agencies tasked with developing the portal should reflect upon governments’ past efforts to develop similar portals and lessons learnt. The portal should be easily accessible, user friendly and display high-quality flood risk information in a way that is readily understandable to communities. That before data is released on such a portal for existing properties (residential and small business), that the entity creating the flood study release that data through a staged process involving appropriate community consultation and engagement.

The Committee recommends that the Australian Government commission research into effective ways of communicating flood risk to communities. The research may explore communities’ understanding of the Average Recurrence Interval, categories such as High, Medium or Low flood risk, and the Annual Exceedance Probability percentage. The research should be used to establish standard best-practice communication strategies for local governments and other stakeholders in communicating flood risk to communities.

The Committee recommends that the Australian Government continue to work with the insurance industry through the Hazards Insurance Partnership to collate:
- data contained in the National Flood Information Database, and
- household-level data held by insurers (de-identified where appropriate).

The Committee recommends that the Australian Government continue to work with the states and territories through National Cabinet to ensure that disaster and resilience funding, and non-financial support, are accessible and adequate for all councils, particularly smaller councils. The Committee recommends that the Government work with the states and territories through National Cabinet to ensure more disaster support can be triggered at the sub-Local Government Area level when needed.

The Committee recommends a more flexible approach to post-flood grant arrangements, to expand eligibility to include some insured people, including:
- The Australian and state governments, in consultation with local governments and the insurance industry, make design, implementation and communication improvements to recovery programs to avoid future delays due to unanticipated or poorly managed interactions with insurance claims processes.
- The Australian and state governments review eligibility criteria for recovery programs, including grants, to ensure they are fit for purpose. This should include consideration of extending support currently restricted to uninsured people to include some insured people, where justified by local and individual circumstances.
- The Australian Government investigate the advantages and risks of enabling access to the Home Equity Access Scheme for resilience improvements by people who cannot access or afford flood cover.

The Committee recommends that all levels of government should work together to ensure that, as far as is possible, people don’t need to resubmit the same information multiple times for different disaster support. Just as insurers should aim for one point of contact, government should aim for ‘tell your story once’.

The Committee acknowledges the increased funding for the community legal sector recently announced. While the focus of this funding will be for family violence services, the Committee recommends that an appropriate proportion be dedicated to natural disaster services.

The Committee recommends the Australian Government consider measures to improve the affordability of flood insurance for existing policyholders with high flood risk properties, including the appropriateness of a government supported reinsurance arrangement. Any interventions to improve the affordability of flood insurance should be pursued in accordance with to the following interdependent principles:
- Affordable cover for even high-risk properties. Flood insurance should be available to all Australian homeowners and body corporate lot owners at an affordable price, but with conditions.
- Price signals. Any assistance to affordable insurance should not compromise price signals against full cost of risk. This could be achieved by partial (but not full) reduction of the premium and/or a gradual phasing out of some assistance.
- Cross-subsidies. Any scheme of reinsurance support or subsidies should minimise cross-subsidisation through premiums where possible as this could raise issues of fairness (for example, low-income households cross-subsiding higher risk high-income households) and could be economically inefficient in that it may create a disincentive to insure.
- Phase-out. That any scheme involving public funding being devoted to a reinsurance pool or subsidies, should be phased out over time in line with ongoing investment in community and household mitigation to reduce the underlying risk over time.
- The underlying risk: no new developments. Governments at all three levels should commit to arrangements (including more public disclosure) to ensure that no new developments occur in high-risk areas.
- The underlying risk: community mitigation. Federal and State governments should commit to ongoing investment in community mitigation. This should include a guaranteed minimum annual investment level and the development of rigorous business cases.
- The underlying risk: household mitigation. Households and small business should be provided with information on mitigation options and their premiums should be reduced immediately when they undertake such mitigation.

The Committee recommends that the Australian Government work with State, Territory and local government through National Cabinet to ensure that further development does not occur in areas of 1-in-100 flood risk or greater. The boundary for no future development should take account of climate modelling of future increases in risk, in addition to current estimates of risk. The Committee further recommends that the Australian Government explore mechanisms that it can adopt to give effect to this unilaterally, including:
- Publicly disclosed risk information at the individual property level, including for new developments. This could be through a range of mechanisms, including:
- a portal informed by data provided to the Commonwealth government through the Hazards Insurance Partnership for all property released for development.
- A regulatory mechanism to discourage banks from loaning for further development at a 1/100 risk or higher (such as risk rating banks’ capital to appropriately reflect flood risk; an agreement between government, the Australian Prudential Regulation Authority, and major banks that such loans will not occur, or other regulatory mechanisms). These measures could apply to lending to both developers and to residential purchasers.
- Access to any flood pool (or subsidies) would not be available to properties approved in high-risk areas after the creation of the scheme.

The Committee recommends that the Australian Government work with state, territory and local governments through National Cabinet to ensure that publicly disclosed risk information at the individual property level is available through the property conveyancing process or mandated in state rental agreement regulation.

The Committee recommends that building codes and planning rules be strengthened and future-proofed to improve the resilience of communities and households, consistent with Recommendation 2 of the Actuaries Institute’s Funding for Flood Costs report.
- This should take into account not just current flood risks, but also projected increases in risks based on climate modelling
- Consideration should be given to the publication of a freely available disaster risk rating system.

The Committee recommends the Australian Government continue to fund community level mitigation, ensuring at least $200 million per year ongoing.

The Committee recommends that a climate financing framework be developed in relation to government mitigation and adaptation funding. That this framework create the appropriate incentives for both public sector and private sector investment in mitigation and more resilient buildings and infrastructure. This would include:
- Rigorous project evaluation and prioritisation, including cost benefit analysis and the incorporation of climate modelling.
- Strong project governance including reporting, monitoring and evaluation.
- Post-project price monitoring where appropriate.
- The development of resilience financing where feasible and appropriate.
- The exploration of public-private partnerships to coinvest in new or upgraded infrastructure.

The Committee recommends the General Insurance Code of Practice be amended to require that insurers be required to consider relevant propertylevel mitigation measures in any new or renewing insurance policy, and to demonstrate how those measures have been reasonably reflected in the proposed premium. After the Code is registered with the Australian Securities and Investments Commission, the Committee also recommends that the Treasurer issue a ministerial direction for the appropriate regulator to periodically review insurers’ compliance with passing on premium reductions.

The Committee recommends the Australian Government consider measures to reduce household level risks, including whether it would be appropriate to extend the Bushfire Resilience Rating Home Self-Assessment App to flood risks.

The Committee recommends the Australian Government work with the Insurance Council of Australia to develop and publish advice on the mitigation measures households could undertake to improve the flood resilience of their property.

The Committee recommends the Australian Government and Insurance Council of Australia explore measures to facilitate the exchange of substantiated information about the resilience of a property to insurers, including new mitigation measures undertaken through state-based grant and loan programs.

The Committee recommends insurers facilitate options for policyholders to provide additional information to insurers about the resilience of their property to flood risks, and make further investments to better integrate reported resilience measures into the calculations of premiums.

The Committee recommends that state and territory governments develop buyback and resilience programs for households with very high flood risk and where alternative mitigation measures are unlikely to manage the risk. The Australian Government should consider working with state and territory governments, including through co-funding models, where appropriate.

The Committee recommends the Australian Government work with state and territory governments to review the operation of existing buy-back schemes to ensure they are targeted appropriately and to evaluate the outcomes for households that have received assistance.

The Committee recommends the Australian Government collaborate with state governments to implement measures to repurpose areas with high flood risk for alternative purposes, including returning developed land into a predeveloped state or repurposing land for recreational or agricultural use.

The Committee recommends that insurers explore offering innovative insurance products that have the potential to improve the operation of the insurance market, including:
- More flexible insurance products for small business, including:
- partial coverage for small businesses in high-risk areas; and
- cashflow assistance or other temporary benefits that might help a small business survive the immediate aftermath of a natural disaster.
- Parametric insurance, particularly in high-risk areas and/or for consumers facing affordability stress.

The Committee recommends that the New South Wales and Tasmanian governments collaborate with industry and local governments to reform emergency services levies, aiming to enhance premium affordability and reduce barriers to insurance uptake.

The Committee recommends that state and territory governments remove state-based taxes on general insurance products and shift the tax burden toward less distortionary taxes. Where state or territory governments reduce taxes or levies on insurers, that insurers commit to passing these savings on in full through lower premiums.

That the NSW Government consider a restructure of the NSW State Emergency Service with consideration to: realigning the focus of the organisation to harness local knowledge and networks; coordinating more closely with other rescue agencies to bolster its capacity to respond; and increasing salaried staff and resources, and driving volunteer recruitment.

That the NSW Government consider abolishing Resilience NSW if it is unable to ensure:
• the organisation's role is clear after reviewing its policies, objectives and funding
• the organisation and its policies are focused on meeting community needs.

That the NSW Government embed into its emergency plans the appointment of a senior police officer with combat experience to lead recovery efforts following natural disasters.

That the NSW Government ensure that all emergency and recovery plans, including state plans, local emergency management plans and functional area plans, are reviewed and updated regularly and provide clarity on the role of non-government partners.

That the NSW Government work with the Commonwealth to develop a national cross-agency app to integrate all community services and agencies into a single platform so that everyone can receive accurate and timely information from one source during emergencies.

That the NSW State Emergency Service, in partnership with the Bureau of Meteorology, investigate ways in which local communities and local media with local knowledge can play a stronger role in flood predictions and warnings.

That the NSW Government advocate through the National Cabinet for the Bureau of Meteorology to review its rain data infrastructure and flood modelling tools, to ensure forecasting locations, rain and flood gauges and other infrastructure are appropriately placed, maintained and updated.

That the NSW Government, in consultation with telecommunication providers and satellite communication providers, investigate ways to minimise the complete loss of telecommunication services in natural disasters, including:
• the distribution of satellite phones and satellite terminals to community hubs in flood prone areas
• the prioritisation of services for communities that are highly likely to become isolated in a natural disaster
• the establishment of appropriate protocols to ensure that this equipment is readily available and 'charged' for use with a battery supply.

That the NSW Government review its public awareness and communication strategies in relation to natural disasters.

That the NSW Government work with the community broadcasting sector to identify ways in which community broadcasters could be better supported to provide critical services during natural disasters, with a view to providing them adequate long term funding.

That the NSW Government invest in the required personnel, training and vessels to ensure that all agencies involved in flood rescue can be mobilised to their fullest potential.

That the NSW Government allocate funding to the improvement of the Pitt Town Evacuation Route and other key possible evacuation routes in Sydney's northwest.

That the NSW Government work with local governments to identify alternative routes to vulnerable roads, and that the NSW and Australian Governments fund the construction of these important routes to improve evacuation and access options in times of disaster.

That the NSW Government ensure that the current review of evacuation centres considers the role, accreditation and support of community evacuation centres, with the outcomes of this review to be made public and incorporated into the update of state emergency plans.

That the NSW Government develop a more proactive, rapid response to manage animal welfare following natural disasters which includes improved collaboration and communication with local veterinarians and animal welfare organisations.

That the NSW Government ensure that community groups, both existing and emerging, including First Nations groups, are well integrated into disaster recovery, by incorporating them into state recovery plans and engaging with them in between and in the lead up to natural disasters.

That the NSW Government, in partnership with community groups, including First Nations groups, develop initiatives to build community resilience, particularly in regions at high risk of future natural disaster events. 

That the NSW Government establish a standing workforce from within the public service to staff evacuation and recovery centres, with this workforce to be trained ahead of time and mobilised as soon as a natural disaster occurs. 

That the NSW Government overhaul the way in which it conducts its grants process as it frustrated applicants and further traumatised them by repeatedly re-interviewing them and making them prove that they were flooded. 

That the NSW Government ensure that flood affected individuals can continue to access financial assistance for as long as there is demonstrated need. 

That Service NSW establish teams of assessors that can be on the ground to assess and approve grant applications. 

That the NSW Government consider entering into a service agreement with an organisation that has the resources and capacity to manage donations and activate quickly during natural disasters.

That the NSW Government address the mental health needs of local communities following the February-March 2022 floods by: • embedding within state emergency and recovery plans a strategy that provides surge capacity for mental health and social workers by: • prioritising funding for community groups that are currently providing social and mental health support to their local communities • ensuring all flood-impacted communities receive the mental health support they need to fully recover. 

That the NSW Government accelerate its caravan program and ensure it is made available as an option to all displaced residents from the February-March 2022 floods. 

That the NSW Government consider investing in supporting relocations, land swaps and providing fair and adequate compensation for landowners who wish to relocate from severely flood-impacted areas. 

That the NSW Government review the provision of temporary and long term housing options provided to those affected by the February-March 2022 floods, with a view to: • ensuring a range of options are identified and embedded within emergency and recovery plans, so that solutions can be implemented as soon as possible after a natural disaster • ensuring that housing options meet individual and community needs • removing planning impediments that prevent those from accessing more safe and secure housing in times of crisis. 

That the NSW Government work with First Nations peoples to support Aboriginal organisations in their capacity to operate and respond in times of natural disasters. 

That the NSW Government work in partnership with key Aboriginal stakeholders, including the Jali Local Aboriginal Land Council, to prioritise the rebuild of Cabbage Tree Island, and ensure a safe and resourced evacuation plan is in place. 

That the NSW Government prioritise support for the full restoration of sewage treatment facilities on the Richmond River, for the benefit of communities in the Northern Rivers region. 

That the NSW Government provide an increased level of targeted support to flood affected communities contending with widespread mould. 

That the NSW Government advocate through the National Cabinet to widen eligibility under the Disaster Funding Recovery Arrangements to allow local councils to build back better.

That the NSW Government invest in the restoration of the Wilsons and Richmond Rivers to include riparian restoration, water quality and river health improvement. 

That the NSW Government provide immediate support to the Hawkesbury City Council to remediate the riverbank erosion affecting Cornwallis Road, Cornwallis without any further delay.

That the NSW Government significantly increase its investment in flood mitigation and preparation, including its support of local governments to do the same, by: • increasing ongoing, long term funding and access to technical guidance and assistance for local councils • ensuring that land-use planning and development takes a risk-based approach. 

That the NSW Government work with local government, industry and sustainable planning experts, including the Government Architect, on policy initiatives in the New South Wales planning system that will help deliver more resilient and sustainable homes, buildings and places. 

That the NSW Government work with relevant agencies and local landowners to find ways to improve the management of drainage channels including looking for recommendations to reduce red and green tape. 

Relief and recovery capability: The Inspector-General for Emergency Management recommends that Emergency Management Victoria and the entity referred to in Recommendation 13, or otherwise responsible government department – in collaboration with the relevant relief and recovery organisations:
(a) identify the core capabilities required for operational relief and recovery roles at state, regional and incident levels
(b) coordinate capability development opportunities to develop a consistent level of capability in relief and recovery for relevant agencies at the state, regional and incident levels.

A revised Victoria Flood Management Strategy is needed and should clearly articulate the principles, roles and responsibilities for the ownership, management and ongoing maintenance of Victoria’s levees. Neither land tenure nor prior government involvement will dictate ownership of public levees:
• the beneficiary pays principle will determine ownership and management;
• outside Melbourne, the ownership of, and responsibility for, the management and ongoing maintenance of all urban levees, including modern urban levees created under formal schemes, is assigned to local councils;
• in all other non‐metropolitan areas, CMAs are confirmed as the responsible authority for the management and ongoing maintenance of priority rural levee systems, where such levees, (a) have clearly identified beneficiaries who are willing to fund ongoing maintenance, and (b) are located, at least in part, on public land;
• in situations where there is a clear benefit and the majority of stakeholders are in agreement, consideration should be given to a special charge scheme, as determined by the Water Act 1989 (section 196); and
• privately built rural levees on private land remain owned and managed by the landholder.

The revised Victoria Flood Management Strategy should provide a strategic framework for the management and ongoing maintenance of Victoria’s levees. The Victoria Flood Management Strategy will provide criteria for a consistent statewide approach to the prioritisation of the state’s levees for future management and investment:
• as part of their revised Regional Flood Strategies, CMAs will identify and prioritise levees within their catchments;
• that the Statements of Obligations for CMAs under the Water Act 1989 be amended to reflect these assigned roles and responsibilities; and
• prioritisation will be underpinned by the beneficiary pays principle.

All priority public levees not currently the subject of approved schemes, will become subject to approved schemes under Division 5, Part 10 of the Water Act 1989. Such schemes will articulate an agreed set of terms, including:
• the public authority with ownership and management responsibilities for the levee;
• the beneficiaries of the levee;
• clear standards and expectations for the levee’s performance and its maintenance;
• where appropriate, a rationale for the rating of beneficiaries for ongoing maintenance; and
• all ad hoc township levees deemed to be permanent priority levees must be brought under an approved scheme.

Where a levee has been identified as low priority, and beneficiaries are not willing to contribute to its maintenance, public authorities will inform levee beneficiaries that they will not fund the repair of their levee following a flood event.

Responsible authorities will identify low priority levees for potential removal, and have them removed when funding becomes available.

Streamlined processes to enable access to levees for the purposes of conducting works, including maintenance, must be implemented. Where a levee is managed by a public authority as part of a formal scheme, and is sited on either private land, or on a mixture of public and private land, access to private land for works will be negotiated as part of any scheme agreement. Where a levee is sited on public land, but is not managed by a public authority, local beneficiaries willing to conduct maintenance will be given access to do so, provided:
• the public land manager and beneficiaries reach agreement on types of access and upgrading or maintenance works to be performed, and the limits to such access; and
• the land manager consults with the floodplain manager to ensure reasonable standards are adhered to – modification of the levee will require a permit.
If required, legislation, such as the National Parks Act 1975, be amended to allow access to public lands by local landholders.

The Department of Sustainability and Environment will develop guidelines for streamlining the permitting system for conducting works on levees for incorporation in the revised Victoria Flood Management Strategy, in order for maintenance on all levees to occur more quickly. The guidelines will outline circumstances in which exemptions from current approval processes are appropriate. Councils will be permitted to obtain exemptions within their planning schemes for:
• the construction of appropriately designed rural ring levees around private assets;
• maintenance works on existing levee banks that do not exceed the original height of the levee, or alter the footprint of the levee; and
• where exemptions are granted, councils will ensure that an inspection regime remains to ensure new levees do not adversely impact others, and are not raised above their original height. The state government to also consider changing the referral role of CMAs under the Planning and Environment Act 1987, to that of an advisory role.

The funding model for works on levees and their ongoing maintenance be revised, to be primarily based on the beneficiary pays principle. The state government should give consideration to wholly funding, or contributing to, the initial upgrade of high priority levees to an agreed standard. The construction of any new public levees will be the subject of a cost‐benefit analysis to be undertaken by DSE and the public authority, and be supported by a floodplain management study. Levees deemed low priority will be wholly the responsibility of the beneficiaries.

A regular inspection and maintenance regime will be undertaken for all high priority levees managed by a public authority. All such levees will be inspected by the relevant public authority on an annual basis, and after a flood event. All levees will have a regular maintenance schedule.

That the Department of Sustainability and Environment continue to invest in the auditing of Victoria’s levee systems, both public and private, so that the Victoria Flood Database contains reliable and up to date data, including information on levees’ location, height, condition and ongoing viability for flood protection.

The current technical guidelines for the construction of levee systems will be reviewed. A revised Levee Design, Construction and Maintenance technical guidelines will include guidelines for the construction of both priority public levees, and private levees on private land, such as ring levees, which protect key assets. These guidelines will be made available to all rural councils, who will make landowners constructing new levees on their property aware of the principles and specifications contained in the guidelines and encourage construction based on them.

The Department of Sustainability and Environment to review ownership of Grampians Wimmera Mallee Water’s Yarriambiack Creek levee, with a view to the appointment of a more suitable public managing authority/authorities.

In consultation with local communities, local councils will develop flood response plans as subplans to their current Municipal Emergency Management Plans. As part of the flood risk assessment process, these plans will be informed by the best available flood mapping and modelling, and will identify agreed activities to be undertaken during floods including, where appropriate, the construction of temporary levees. The condition of levees will be incorporated into such plans to enable improved emergency response.

The Department of Sustainability and Environment will develop guidelines for the management of levees in emergencies, during and after a flood event, which can be incorporated into local flood response plans. The department will also provide, as part of these guidelines, a set of criteria for assessing the ongoing viability of ad hoc levees post‐flood. The Emergency Management Act 1986 will be amended to support the implementation of these guidelines. A more effective means for councils to remove illegal levees will also be examined by the Department of Sustainability and Environment.

Where flood investigations show positive and cost effective outcomes, infrastructure providers, such as VicRoads, will consider enhancing their infrastructure to act as levees. Any development of this nature will require collaboration with, and the approval of, the relevant floodplain authorities.

The state government will work with Grampians Wimmera Mallee Water and stakeholders to determine ongoing ownership and associated responsibilities for redundant channel infrastructure in the Wimmera and the Mallee.

The Victorian Government should work with the New South Wales Government and the Murray Darling Basin Authority to establish an appropriate floodplain management committee and to develop a floodplain management strategy for the Murray River. The strategy will define priority regions for the development of floodplain management plans, address ways of improving the management of all levees on the Murray River, and seek agreement in relation to improved approvals processes, levee heights and maintenance regimes.

The Victorian Government to implement the recommendations of the Victorian Floods Review in relation to the development and implementation of appropriate flood mitigation and protection strategies for essential services.

When developing flood mitigation options in lowland areas, local governments should give consideration to the use of temporary levees as an alternative or addition to permanent structures. To maximise the use of these structures and limit flood damage, and aid affordability, consideration should be given by local governments to the sharing of temporary levees among different townships and different council areas.

A revised Victoria Flood Management Strategy should identify and assign roles and responsibilities for the management and ongoing maintenance of Victoria’s waterways, for the purposes of flood protection and flood mitigation:
• CMAs are confirmed as the responsible authority for the management and ongoing maintenance of waterways, including vegetation management, for the purposes of flood protection; and
• CMAs will negotiate with landholders, councils and other authorities, and conduct agreed flood mitigation works on the basis of beneficiary pays.

The role of flood risk management planning rests with CMAs and Melbourne Water (under the Water Act 1989), and is a shared responsibility with local government. Shared responsibilities for flood risk management planning and implementation will be consistently reflected in government policy.

The revised Victoria Flood Management Strategy should clearly articulate the policy guidelines for the management of vegetation and debris in Victorian waterways, for the purposes of flood protection and mitigation, taking into account the localised potential flooding effects of in‐stream vegetation in townships.
To that end:
• the Victoria Flood Management Strategy will provide flood risk criteria for identifying specific reaches of rivers and streams that require ongoing vegetation management and maintenance, and to be subject to a revised permitting system;
• in their Regional Flood Strategies, CMAs will identify specific reaches of rivers and streams in their catchments, that require ongoing vegetation management and maintenance, and to be subject to a revised permitting system;
• each CMA will develop an In‐stream Management Policy to clarify responsibilities for the management of all waterways, including vegetation management. This will clearly articulate the circumstances under which the CMA will approve the removal of vegetation. This policy to be reviewed every three years; and
• where appropriate CMAs will develop agreements with local regional councils.

The Department of Sustainability and Environment should develop guidelines for streamlining the permitting system for works on waterways for incorporation in the revised Victoria Flood Management Strategy. An exemption process will be introduced, with particular application to identified reaches of rivers and streams that require ongoing vegetation management and maintenance:
• that government will amend the Victorian Planning Provisions to create a new exemption for native vegetation removal under clause 52.17, for the purpose of ‘flood protection’; and
• Catchment management authorities will amend their respective ‘Works on Waterways’ bylaws to reflect these changes.

The Department of Sustainability and Environment will develop a code of practice on the removal of vegetation around critical public assets, in consultation with councils, CMAs and asset managers. Regional Flood Strategies will support this code of practice as part of shared flood risk management planning.

Significant modification of waterways in urban or rural areas will only be considered after the completion of a flood risk management process, undertaken in consultation with members of the community.

The revised Victoria Flood Management Strategy should clearly identify authorities and assign responsibilities for stream blockage and debris removal in waterways posing a high risk to public infrastructure both during and after a flood:
• in the aftermath of a flood event, CMAs, in liaison with local councils, will manage debris posing a high risk to public infrastructure;
• the In‐stream Management Policy of CMAs will guide the post‐flood management of debris affecting the assets of private owner beneficiaries;
• DSE will review the woody debris removal practices of CMAs and develop new management guidelines; and
• engagement with stakeholders, including councils and landholders will take place prior to any large scale removal of woody weeds, such as willows, is undertaken by CMAs.

Local knowledge on the management and ongoing maintenance of waterways, including vegetation clearing and debris removal, needs to be incorporated in the development of regional flood mitigation strategies and local flood plans. Specifically:
• the process of flood risk assessment must include community consultation, and these views will inform development of both floodplain management studies, and floodplain implementation plans;
• in the absence of a formal planning process, councils and authorities undertaking significant ad hoc works on waterways for flood mitigation and protection must involve the local community; and
• the revised Victoria Flood Management Strategy and Victorian River Health Strategy will clearly articulate this process.

The Department of Sustainability and Environment will develop clear policy for the coordinated management of rural drainage, clarifying the legal framework, and identifying authorities with responsibility for the management and ongoing maintenance of formal schemes, and their development:
• where appropriate, an expedited approvals process for works be applied in line with recommendation 5.4; and
• a central component of policy will be the principle of beneficiary pays.

Within the jurisdiction of Melbourne Water, it shares with local councils the responsibility to manage local drainage systems as outlined under the Water Act 1989 and the Local Government Act 1989 respectively:
• Melbourne Water, in conjunction with metropolitan councils, will undertake an audit of drainage infrastructure to identify drains that are not currently managed by a public authority; and
• following this audit Melbourne Water will work with relevant councils to develop best practice models for the management of the drainage asset.

Flood studies will be undertaken to determine the flood extent on the basis of a greater than 1 in 100 ARI, where appropriate:
• The Water Act 1989 to be amended.

The state government give consideration to enacting legislation to provide protection from legal liability for public authorities conducting works on priority levees in good faith, acting reasonably and responsibly in the public interest, and in accordance with standards agreed to under approved schemes. Public authorities should not be excluded from liability if they have acted negligently.

That statements of obligations, issued under the Water Industry Act 1994 for water authorities, be amended to include a provision whereby managing authorities must:
• make available to the public information designed to inform and educate local communities, particularly those communities living downstream of water storages ‐ this information will relate to dam operations, the rules governing those operations, and the capacity, or lack thereof, of storage infrastructure to provide protection in the event of major flooding; and
• ensure this information forms part of an ongoing program of interaction with local communities, to be conducted at a minimum of every two years, and providing community members with the opportunity to raise questions, discuss issues, and be informed on current dam operations.

The state government accept recommendations 25 to 28, inclusive, of the Victorian Floods Review.

The state government implement the Victorian Floods Review recommendation 8, to review the flood gauging network. As part of the review, consideration should also be given to the use of portable telemetered river gauges, and to the replacement of manual gauges with telemetered gauges over time and where appropriate.

The state government establish a well coordinated and formalised system for the reading of river gauges by local people, including flood wardens. Furthermore, the knowledge of local people in predicting flood heights and impacts should be considered by emergency management agencies when predicting floods.

The state government review the current funding approach used for the operation, maintenance and upgrade of river gauges, with a view to improving the river gauge network.

The state government implement the Victorian Floods Review recommendation 10 in relation to the datums used to describe river and stream heights.

Public authorities such as councils and CMAs should continue to seek local knowledge in relation to flood management issues. In particular, councils will collaborate with VICSES and other key stakeholders in reviewing the system of flood wardens. Roles and responsibilities of flood wardens, and the process for their recruitment, should be formalised and clearly articulated in relevant flood management plans.

The state government should provide core, ongoing funding to the responsible authority for the FloodSafe community education program. Funding should be provided for education about prevention, response and recovery phases and include information on rates notices about the height of particular floods.

The state government should implement the recommendations of the Victorian Floods Review in relation to the creation of resilience committees and resilience plans, with responsible authorities.