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By Anne Obersteadt, CIPR Senior Researcher Interna onal focus centered on adap ng and mi ga ng the effects of climate change has intensified in recent years. This was exemplified when nearly 200 countries agreed late last year to take steps to cut global emissions to a level that would avoid the worst effects of climate change. The agree-ment, termed the Paris Accord, comes on the heels of new research indica ng the world is already facing the impacts of climate change. Scien sts warn climate change could reach devasta ng levels without significant proac ve efforts to curb emissions and increase resiliency. The Paris Accord could provide the impetus for a transi on to a lower carbon world—as long as countries execute their commitments. Insurers will need to prepare for the adverse weather im-pacts from an unavoidable warmer world, as well as new risks arising from a transi on to a low carbon future. This ar cle examines the Paris Accord, U.S. efforts to lower carbon emissions, and what scien sts are telling us on the current and future environmental impacts of climate change. Addi onally, the ar cle iden fies the risk of climate change to insurers and how they are responding to the low carbon movement. T P A On Dec. 12, 2015, leaders from 195 countries signed a his-toric accord to limit the rise in greenhouse gas emissions to below 2% of the pre-industrial level at the 21st Conference of Par es (COP21) in Paris. The accord establishes a legally binding framework for countries to monitor and report their efforts to transi on to a lower carbon world. As part of the framework, countries are required to submit their long-term emission-cu ng plans by 2020. Countries are then required to reassess and adjust their plans and publicly re-port their progress on mee ng their commitments every five years. Limi ng global warming to two degrees Celsius above pre-industrial levels is an important threshold. Many scien sts predict this threshold cannot be surpassed if the worst effects of climate change are to be avoided. According to the Intergovernmental Panel on Climate Change (IPCC), the average global temperature rose 0.85 degrees Celsius be-tween 1880–2012. Scien sts warn na ons will need to cut emissions substan ally to stave off destruc ve and unstable weather pa erns that would contribute to rising sea levels, droughts, flooding and water shortages. Many scien sts have advocated for a stronger target to safely avoid irre-versible devasta ng weather pa erns. Addi onally, several countries have advocated for a lower emissions target to

limit the impact to small island states at risk of losing the most from climate change, despite contribu ng the least to it. For this reason, the accord also includes language to pur-sue efforts to limit long-term global temperature rise to 1.5 degrees Celsius. T G Although ambi ous, the emission targets established during COP21 are es mated to achieve only about half of the nec-essary emissions cuts needed to reach the two-degree Celsi-us target and avoid the most devasta ng consequences of climate change. Many na ons submi ed their intended na-

onally determined contribu ons (INDC) prior to the confer-ence, publicly outlining what climate ac ons they intend to take to cut emissions through 2030. The United Na ons Environment Programme’s (UNEP) annually published Emis-sions Gap Report provides a scien fic assessment of the mi ga on contribu ons from the countries that submi ed INDCs. The 2015 report analyzed 119 INDCs from 146 coun-tries, represen ng 88% of global emissions. It es mated emission levels in 2030 from fully implemented INDCs would result in the earth warming to almost three degrees by the end of the century. An addi onal 12 gigatonne in emission cuts will be needed to reach the level sufficient to achieve the target of two degree Celsius by 2100.1 To bridge the gap, the report suggests an expansion of efforts around en-ergy efficiency, renewable energy technologies, city and regional ini a ves, and forest mi ga on ac ons. T R N The accord provides an interna onal framework for cu ng emissions with legally required measuring and repor ng requirements, but countries’ individual commitments are voluntary. As such, its success hinges largely on countries’ abili es to implement their agreed upon carbon reduc ons. The U.S. commitment was largely based on curbing carbon emissions from power plants, which account for about one-third of all domes c greenhouse gas emissions, and transi-

oning to renewable energy.2 As a first step, the U.S. Envi-ronmental Protec on Agency (EPA) proposed carbon stand-ards for new power plants in September 2013. In November 2014, the U.S. and China issued a bilateral announcement to jointly reduce emissions. In September 2015, the U.S. and China then issued a Joint Presiden al Statement of Climate Change, building on the previous year’s agreement and

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1 United Na ons Environment Programme (UNEP), 2015. “UNEP Emissions Gap Report 2015: 2°C Goal S ll Within Reach,” accessed from h p://climate-l.iisd.org/news/unep-emissions-gap-report-2c-goal-s ll-within-reach/. 2 Accessed from h ps://www.whitehouse.gov/climate-change.

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se ng common goals for an agreement at COP21. This agreement between the U.S. and China, the world’s largest polluters, helped secure commitments from other na ons. However, the U.S.’s ability to comply with the accord has recently been put into ques on, leading to addi onal con-cerns on the commitments of other countries. On Feb. 9 of this year, the U.S. Supreme Court halted the implementa-

on of the current administra on’s Clean Power Plan fol-lowing a lawsuit filed by 27 states challenging the plan’s legality. The plan was aimed at reducing carbon emissions 32% from 2005 levels by 2030 by se ng carbon emission reduc on standards for exis ng power plants and imple-men ng incen ves for states to transi on to renewable energy. The D.C. Circuit Court of Appeals will take the issue up on June 2, 2016.3 Although any mandatory implementa-

on of the plan’s regula ons are suspended un l a er the Court takes up the issue, individual states can s ll choose to implement the plan voluntarily. Addi onally, new power plants would s ll be addressed under the proposed EPA regula ons, which the EPA has stated will be finalized by mid-summer 2016. C C H The COP21 accord comes at an important me. The world is already beginning to experience the effects of climate change, making the need to respond to the inherent risks both a current and a long-term need. Given its probability and poten al for significant worldwide disrup on, the World Economic Forum 2016 Global Risks Survey iden fied failure to adapt and mi gate climate change as the risk with the greatest poten al impact in 2016. Addi onally, the re-port found climate change is amplifying other risks such as water crisis, food shortages, migra on and security, which in turn further hampers mi ga on and adapta on efforts. The report is based off of an annual survey of 750 experts’ perspec ves on 29 global risks over a 10-year me frame.4 The IPCC’s Fi h Assessment Report (AR5) found the globally averaged combined land and ocean surface temperatures warmed 0.85 degrees Celsius between 1880–2012 (Figure 1). Figure 1 also shows global average surface temperatures warmed 1 degree Celsius from the preindustrial mean tem-perature. Addi onally, the IPCC AR5 found emissions of green-house gases have con nued to rise over the last three decades and are currently the highest in history. The report found more than half of the earth’s warming is linked to hu-man ac vi es. The recent rise in temperature was primarily driven by economic and popula on growth increasing fossil fuel carbon emissions, par cularly from coal. The IPCC report is designed to inform policymakers and assist the work of the United Na ons Framework Conven on on Climate Change

(UNFCCC). The IPCC is an intergovernmental organiza on that leverages the research of scien sts globally to produce re-ports on climate change. The UNFCCC is the main interna on-al treaty on climate change5.

(Continued on page 18)

3 New Europe, 2016. “U.S Supreme Court Torpedoes Paris COP21 Accord,” accessed from h p://neurope.eu/ar cle/u-s-supreme-court-torpedoes-paris/. 4 World Economic Forum, 2016. The Global Risks Report 2016: 11th Edi on, accessed from h p://www3.weforum.org/docs/GRR/WEF_GRR16.pdf. 5 IPCC, 2014: Climate Change 2014: Synthesis Report. Contribu on of Working Groups I, II and III to the Fi h Assessment Report of the Intergovernmental Panel on Climate Change [Core Wri ng Team, R.K. Pachauri and L.A. Meyer (eds.)]. IPCC, Geneva, Switzerland, 151 pp.

Source: IPCC AR5 Synthesis.

F 1: C C I

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The implica on of a warming world is evidenced across the globe. The IPCC AR5 concluded rising surface temperatures have likely changed the global water cycle, contribu ng to the Arc c sea-ice mel ng, ocean warming and sea-level rise observed since the mid-20th century. Arc c sea-ice has de-creased every decade since 1979. In annualized mean terms, Ar c sea-ice decreased 3.5% to 4% per decade be-tween 1979–2012. More than 90% of the earth’s tempera-ture rise between 1971–2010 is stored in oceans. This has resulted in a 0.11 degree Celsius increase in temperature in the upper ocean during this period, as well as a 26% in-crease in water acidity from pre-industrial mes. Terrestrial ice melts from higher surface temperatures and water ex-pansion from ocean warming con nue to increase sea lev-els. Global average sea level rose 19 cm to 21 cm from 1901 to 2010. These environmental changes have been accompanied by changes in the earth’s ecosystems, weather pa erns and crop yields. Addi onally, changing precipita on pa erns combined with snow and ice melt are affec ng water quan-

ty and quality in many regions. Weather-related ex-tremes—such as heat waves across Europe, Asia and Aus-

tralia; droughts; floods from extreme precipita on; and wildfires—are increasing in frequency. It should be noted there is s ll some controversy surrounding the anthropogenic nature underlying climate change. Howev-er, the AR5 report points out changes in the climate are re-sponsible for these observed impacts on natural systems, regardless of a ribu on to the cause of climate change. F C C P Climate change is projected to con nue to increase in the coming decades, but the extent to which it will change de-pends greatly on how and when the world responds. The IPCC AR5 predicts average global surface temperatures will likely rise by 0.3 degrees Celsius to 4.8 degrees Celsius above the 1986–2005 average by 2100. This predic on is based on a range of emissions scenarios predic ng future climate change (Figure 2). The scenarios incorporate various assump ons such as climate policy, advances in technology, energy de-mand, and popula on and economic growth. The scenarios assess the resul ng impact of various response levels, ranging from no ac ons to aggressive ac ons, taken to mi gate cli-

(Continued on page 19)

F 2: C IPCC M A M S ‘B U ’ S

Change in average surface temperature (a) and change in average precipita on (b) based on mul -model mean projec ons for 2081–2100 rela ve to 1986–2005 under the RCP2.6 (le ) and RCP8.5 (right) scenarios. The number of models used to calculate the mul -model mean is indicated in the upper right corner of each panel. Source: IPCC AR5 Synthesis.

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mate change. Figure 2 compares changes in average surface temperature and average precipita on under the most strin-gent mi ga on scenario to the scenario of no ac on.6 Surface temperature over the 21st century is predicted to increase under all the scenarios. However, the lowest-end emissions scenario (0.3 degree Celsius to 1.7 degree Celsius rise) ensures average global surface temperatures remain safely below the 2-degree target. It should be noted this scenario includes stringent mi ga on efforts, including not-yet developed carbon sequestering technologies. Irrespec ve of which emissions scenario proves most valid, the earth will con nue to experience extreme weather events. Heat waves and extreme precipita on will con nue with increased frequency, intensity and dura on. The earth and ocean will con nue to warm, and ocean acidifica on will intensify. Sea levels will con nue to rise by 26 cm to 82 cm for the period 2081–2100 rela ve to 1986–2005. By the end of the 21st century, 70% of all coastlines will be affect-ed by sea level rise. Arc c sea-ice will con nue to melt, with the Arc c Ocean becoming nearly ice-free in the summer months by mid-century under the worst-case scenario. Climate change will con nue to nega vely affect crop produc on and water resources, which, when combined with rising popula on, will challenge food and water security. Certain popula ons will become displaced, and health risks are an cipated to rise from heat waves. The most vulnerable popula ons are expected to feel the brunt of many of these climate change impacts.7 C C I I There is a growing movement among insurers on the need to prepare for the poten al impact of climate change-related risks. Many insurance segments are facing changing risks from the increase in frequency and severity of extreme weather events in recent decades. Beyond weather-related risks from a warming world, insurers could also face risks from a changing economy. As the world prepares to mi -gate the most extreme effects of climate change through interna onal policy agreements, insurers could face addi-

onal risk from changing economic condi ons. These addi onal risks were outlined in the Pruden al Regu-la on Authority (PRA) of the Bank of England report, The Impact of Climate Change on the U.K. Insurance Sector.8 The PRA report, released in September 2015 ahead of COP21, provides a framework for considering the financial risks arising from climate change. The report iden fies three

main channels through which climate change may affect the insurance sector: 1) direct and indirect physical risks from weather-related events; 2) transi on risks from the transi-

on to a lower-carbon economy; and 3) liability risks from par es who have suffered loss and damage from climate change and are a ribu ng causa on to the insured. Physical Risks The PRA report warned increases in physical risks due to climate change could present significant challenges to insur-ers’ business models. Physical risks include losses stemming from weather-related events. According to Munich Re, se-vere weather events, heat waves, droughts, floods and trop-ical storms have accounted for 85%–90% of natural hazards since 2005. Insurers’ exposure to physical risks is largely from indirect exposure to the physical assets they insure. Addi onally, insurers face poten al losses from first-party claims to business interrup on, con ngent business inter-rup on and builders’ risk from weather disasters. Insurers may also face direct losses to real estate holdings, which could pressure the asset side of the balance sheet. It is well accepted that poten al losses from physical risks are rising as popula ons migrate to areas with higher natural catas-trophe risk, such as coastlines and wildfire-prone regions. However, the PRA warns there are indica ons climate change is also influencing loss pa erns, which could chal-lenge insurers’ modeling assump ons because of higher weather vola lity. Liability Risks The PRA report highlighted coverage for insured liability risks from climate change is an emerging risk for insurers providing liability coverage. Climate change could affect third-party claim costs for coverages such as directors’ and officers’ liability, comprehensive general liability, employers’ liability, and errors and omissions liability. The PRA report points out liability insurers could be legally liable for losses from par es seeking compensa on for the insured’s alleged failure to prevent climate change damages. Legal liability for climate change damages could poten ally result from the insured’s failure to mi gate and adapt to climate change. This would include acts such as failure to reduce emissions, protect against physical risks or ins tute proper governance. Failure to properly disclose climate-related risks or comply with climate legisla on or regula ons could also poten ally be a legal liability for insurers.

(Continued on page 20) 6 Ibid. 7 Ibid. 8 Available at: www.bankofengland.co.uk/pra/documents/supervision/ac vi es/pradefra0915.pdf.

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Transi on Risks The PRA warned insurers face poten al risks from the tran-si on to a lower-carbon world. Climate policies, technology advances and physical asset risks could poten ally devalue certain assets. This could place pressure on insurers’ assets and investment income. According to IPCC AR5 emissions scenarios, the world will reach its carbon budget limit—the maximum emi ed car-bon allowable to remain at the 2-degree Celsius warming target—in approximately 20 years.9 This will leave a good deal of the earth’s oil, gas and coal reserves as undevel-oped. Assets dependent on fossil fuels would become stranded, resul ng in the repricing of carbon-heavy invest-ments. Insurers who do not account for this poten al in repricing could see nega ve impacts to their long-term as-sets and the liabili es they were meant to match. Regula ons or climate policies can also nega vely affect fossil fuel prices, leading to stranded assets. Addi onally, economic factors unrelated to climate change could affect the produc on and pricing of fossil fuels. Changes in inves-tor preferences and sen ment can also affect asset values. For instance, a large natural catastrophe or new climate science findings can change investor preferences related to fossil fuel investments. Furthermore, technological advanc-es could facilitate a shi from high-carbon to low-carbon energy sources by making clean technologies more afforda-ble. Shi s in investment strategies from companies volun-tarily embracing the social campaign for fossil fuel divest-ment could also intensify a demand shi from high- to low-carbon investments. A I P C R As some of the world’s largest investors, insurers must as-sess the asset implica ons of an interna onal move to low-er-carbon energy sources. Insurers should an cipate the poten al risks arising from this transi on and allocate in-vestments in a way that supports their strategic long-term objec ves. Insurers who fail to adequately address climate-related risks in their investment por olios expose them-selves to reputa onal risk and poten al solvency stresses. In January 2015, Towers Watson published a paper, Fossil Fuels: Exploring the Stranded Assets Debate, outlining a framework for investor response to fossil fuel investments. In the paper, the consultancy firm stated it did not advocate for a par cular response but it did believe companies with medium- to long-term investments should consider the poten al for stranded asset risk. Companies are an cipated

to use the framework based on their individual exposure assessments and unique investor beliefs and strategies. The framework calls on investors concerned with stranded asset risk to influence policy and investor prac ces through en-gagement. Investors may limit downside risk by reducing their por olio’s exposure to carbon intensive investments. Another strategy is to hedge against downside risk by in-ves ng in clean and renewable technologies. Addi onally, investors may choose to eliminate stranded asset poten al by dives ng carbon intensive investments.10 Timing of dives ture is a key market considera on. The flu-idity in assump ons required in predic ng the path of car-bon-intensive asset demand and prices will complicate in-surers’ ability to iden fy which fossil fuels to priori ze for dives ture. Addi onally, unpredictability in ming of invest-ment risk could poten ally leave insurers at risk for di-ves ng too soon or too late. Asset stress tes ng should be an important part of an insur-er’s risk management protocols. Addi onally, insurers should consider related investments along the value chain when measuring their por olio’s carbon exposure. There are several methods used to measuring carbon risk in equity and credit investments. The most commonly used approach is the Greenhouse Gas Protocol (GHGP), which categorizes carbon emissions as either direct or indirect. Other prac ces include measuring exposure to fossil fuels in rela on to a par cular financial metric.11 T I I B R L -C M Insurers contribute to climate change ini a ves in several ways. They support financial viability and sustainability by compensa ng damages from extreme events and lowering risks through mi ga on ini a ves. Insurers enable renewa-ble energy products and green infrastructure development by providing innova ve product coverage. Addi onally, a growing number of insurers are suppor ng a lower carbon economy through investments in clean and renewable tech-nologies and energy efficiency. In May 2015, AXA announced it would divest $554 million in coal investments. The company stated it would divest in-vestments in mining companies with more than half their

(Continued on page 21) 9 Ibid. 10 Towers Watson, 2015. “Fossil Fuels: Exploring the Stranded Asset De-bate,” accessed from www.towerswatson.com/en-US/Insights/IC-Types/Ad-hoc-Point-of-View/2015/01/Fossil-fuels-Exploring-the-stranded-assets-debate. 11 Ibid.

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turnover from coal mining. It also planned to divest electri-cal u li es with more than half their energy derived from thermal coal plants. Addi onally, the company commi ed to tripling its green investments to $3.3 billion by 2020 and providing more climate related disclosures.12 QBE an-nounced the following month a three-year plan to invest up to $78.11 million in green bonds. Zurich has also stated it will invest more than $2 billion in green bonds.13

Aviva joined the list of companies entering divestment cam-paigns in July 2015 when it announced it would divest from fossil fuel companies not inves ng in emissions reduc on technologies.14 It also stated it planned to invest £500 mil-lion ($698 million) a year over five years in low-carbon tech-nologies. In November, Alliance also stated it would elimi-nate €4 billion ($4.4 billion) in coal investments in favor of wind power investments.15 Addi onally, Munich Re reached its goal to become carbon-neutral in 2015.16

In January of this year, California Insurance Commissioner Dave Jones called for U.S. insurers doing business in his state to join the list of interna onal insurers de-carbonizing their investment por olios. The divestment request is the first from a state insurance regulator. Divestment is volun-tary and applies to thermal coal investments or any compa-ny deriving 30% or more of its revenues from thermal coal. Commissioner Jones also stated an annual data call will be ini ated this April requiring insurers licensed in California and wri ng more than $100 million in premium to disclose carbon-based investments. In his announcement, Commis-sioner Jones stated public disclosures will assist regulators, policyholders and investors in examining financial risk from carbon-based assets.17 California’s call for coal dives ture is aimed at protec ng insurers from the poten al for stranded assets. Recent price devalua ons for both coal and coal extrac on companies illustrate the poten al for stranded assets. The coal indus-try has lost about three-quarters of its value, with coal pric-es falling to $50/tonne in 2015 from its peak of $200/tonne almost seven years earlier.18 Falling prices are the result of declining demand and rising coal supplies. The reduc on in demand is linked in part to reduced consump on from coal’s biggest consumer, China, as it transi ons to renewa-ble energy sources. In the U.S., cheaper natural gas prices and new regula ons have decreased the demand for coal. It should be noted that coal accounts for about half of the world’s carbon risk.19 Future prices and mine asset valua-

ons could deteriorate further as the world transi ons to lower carbon energy sources.

T F As the IPCC AR5 illustrates, the effects of a changing climate are becoming more prevalent. The frequency and intensity of extreme weather events, likely exacerbated by climate change, have increased notably in recent decades. Further-more, even the best-case emissions reduc on scenario re-ported in the IPCC AR5 predicts irreversible warming. If le unchecked, the world could face trillions of dollars in finan-cial losses. This could challenge insurers’ exis ng business models and have adverse effects on the availability and affordability of insurance. Many researchers warn the inter-connec vity of risk will eventually result in every asset being directly or indirectly affected by climate change. Many in-surance segments are already facing changing risks. As such, it is important insurers examine their role in the transi on to a lower carbon world. Adapta on and mi ga on of the worst of climate change’s impacts should be a central focus to help stabilize vulnerability to the changing risk landscape.

A A

Anne Obersteadt is a researcher with the NAIC Center for Insurance Policy and Re-search. Since 2000, she has been at the NAIC performing financial, sta s cal and research analysis on all insurance sectors. In her cur-rent role, she has authored several ar cles for the CIPR Newsle er, a CIPR Study on the State of the Life Insurance Industry, orga-

nized forums on insurance related issues, and provided support for NAIC working groups. Before joining CIPR, she worked in other NAIC Departments where she published sta s cal reports, provided insurance guidance and sta s cal data for external par es, ana-lyzed insurer financial filings for solvency issues, and authored com-mentaries on the financial performance of the life and property and casualty insurance sectors. Prior to the NAIC, she worked as a com-mercial loan officer for U.S. Bank. Ms. Obersteadt has a bachelor’s degree in business administra on and an MBA in finance.

12 Harvey, F., 2015. “Axa to Divest from High-Risk Coal Funds Due to Threat of Climate Change, The Guardian. 13 Jergler, D., 2015. “Insurers Stepping Toward Greater Green Investment Footprint,” Insurance Journal. 14 Morales, A., 2015. “UK’s Aviva to Target $3.9B in Renewable Energy Investments,” Insurance Journal. 15 Associated Press, 2015. “Allianz to Cut Investments in Companies Using Coal in Favor of Renewable Energy,” The Guardian. 16 Munich Re. “Climate Protec on–Leading by Example,” accessed from www.munichre.com/corporate-responsibility/en/management/environment/climate-protec on/index.html. 17 California Department of Insurance, 2016. “California Insurance Commissioner Dave Jones Calls for Insurance Industry Divestment from Coal,” accessed from www.insurance.ca.gov/0400-news/0100-press-releases/2016/statement010-16.cfm. 18 Seth, S., 2016. “Is the Coal Investment Story Over?” Investopedia. 19 Carbon Tracker Ini a ve, 2015. “The $2 Trillion Stranded Assets Danger Zone: How Fossil Fuel Firms Risk Destroying Investor Returns.”

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© Copyright 2016 Na onal Associa on of Insurance Commissioners, all rights reserved. The Na onal Associa on of Insurance Commissioners (NAIC) is the U.S. standard-se ng and regulatory support organiza on created and gov-erned by the chief insurance regulators from the 50 states, the District of Columbia and five U.S. territories. Through the NAIC, state insurance regulators establish standards and best prac ces, conduct peer review, and coordinate their regulatory oversight. NAIC staff supports these efforts and represents the collec ve views of state regulators domes cally and interna onally. NAIC members, together with the central re-sources of the NAIC, form the na onal system of state-based insurance regula on in the U.S. For more informa on, visit www.naic.org. The views expressed in this publica on do not necessarily represent the views of NAIC, its officers or members. All informa on contained in this document is obtained from sources believed by the NAIC to be accurate and reliable. Because of the possibility of human or mechanical error as well as other factors, however, such informa on is provided “as is” without warranty of any kind. NO WARRANTY IS MADE, EXPRESS OR IM-PLIED, AS TO THE ACCURACY, TIMELINESS, COMPLETENESS, MERCHANTABILITY OR FITNESS FOR ANY PARTICULAR PURPOSE OF ANY OPINION OR INFORMATION GIVEN OR MADE IN THIS PUBLICATION. This publica on is provided solely to subscribers and then solely in connec on with and in furtherance of the regulatory purposes and objec ves of the NAIC and state insurance regula on. Data or informa on discussed or shown may be confiden al and or proprietary. Further distribu on of this publica on by the recipient to anyone is strictly prohibited. Anyone desiring to become a subscriber should contact the Center for Insur-ance Policy and Research Department directly.

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