If you have an opinion about whether Insurance Commissioner Kent Sullivan should approve or deny a 10 percent increase in the rates Texas consumers along the coast must pay for windstorm insurance, now’s the time to make it known.

We suggest Sullivan should reject the rate increase and urge the Texas Legislature to reform the program in ways that ensure its financial health, without putting this vital commodity beyond the reach of many working Texans.

The Texas Department of Insurance, which Sullivan leads, is taking public comment on the proposed rate increase through Oct. 1.

At issue is a July vote by the Texas Windstorm Insurance Association’s board of directors to increase rates for both residential and commercial policyholders by 10 percent.

The rate increase will go into effect Jan. 1 if Sullivan approves it.

It would be the eighth rate increase the windstorm board has approved in the past 10 years and the largest since 2009, when the association raised residential rates 12.3 percent and commercial rates 15.6 percent.

Association staff members, the insurance industry and its advocacy groups argue there’s compelling evidence that rates must increase to keep the organization in financial shape to meet its obligations to policyholders after storms to come.

In fact, they argue 10 percent increases are well short of what the rates actually need to be. Those supporting the rate increase argue residential rates are about 32 percent under, and commercial rates about 37 percent under, what actuarial risk assessments demand.

Locally, we think of Hurricane Harvey as a flood, which it was, but it was a windstorm in other parts of the state, racking up about $1.6 billion in claims against association policies, according to the Insurance Council of Texas.

Groups advocating for the rate increase say the association since Hurricane Harvey is woefully underfunded to meet damage claims if another major windstorm hits the state. The association went into the 2017 hurricane season well-funded, including a record-high $737 million in the Catastrophic Reserve Trust Fund; but Harvey left it strapped, according to association reports.

Harvey Claims consumed the entire reserve trust fund, $96 million from premiums and other revenue, $449 million in bond proceeds and at least $174 million from assessments charged to insurance companies, according to the association. The association board in July also instructed its staff to seek another $107 million from the companies.

Be all that as it may, there’s disagreement about whether the 10 percent hikes are necessary and appropriate. The association’s own board was closely split on the increase — five members representing industry voted for, four members representing other constituencies voted against.

State Rep. Wayne Faircloth and other coastal lawmakers also have opposed the rate increase, in part for fear it would cause property owners to forgo buying windstorm insurance.

“At some point, you price people out of the market,” Faircloth said.

That’s no idle worry. Harvey caused about $19.4 billion in insured losses of all kinds from both flooding and wind, according to the insurance council. The uninsured losses, however, were a staggering $100 billion, according to the council.

As with flood insurance, low participation rates are a greater problem than low premium rates. Both systems — wind and flood — now allow too many property owners to ride the bubble without coverage, hoping for the best, or government bailout in event of the worst.

The association might be underfunded after Harvey, but the rate increase Sullivan is considering won’t help that for this year because it wouldn’t go into effect until January, a month after the official end of hurricane season.

Better than another incremental rate increase, which even advocates say is 20 percentage points or so less than enough, lawmakers who convene in January should pursue real, lasting reform.

• Michael A. Smith

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