The renewal notice arrived on a Tuesday, in the same post as the council rates. A retired diesel fitter in a coastal Queensland town north of Rockhampton opened it at the kitchen bench, read the number twice, then went to the filing drawer to find last year's notice and check he had not misremembered. He had not. The premium on a low-set brick house he has owned outright since 1994 — no claims, no alterations, the same roof he re-screwed himself after Cyclone Marcia came through in 2015 — had risen by roughly a fifth in a single year, and by a similar order the year before that. Nothing about the house had changed. Nothing about his behaviour had changed. His income, an age pension plus a modest superannuation drawdown, had risen by the indexation rate and not a cent more.
He did what a growing number of Australian households now do. He rang the insurer, lifted the excess from $500 to $2,000, cut the contents cover back to a nominal sum, and moved from annual payment to monthly instalments, which costs a little more again across the year. He is still insured — insured for less, against a larger first loss, on a house that is the whole of his net wealth. The industry would call him underinsured. At his kitchen bench he did the only arithmetic available to him.
That household is a composite, drawn to match a pattern that is measurable rather than anecdotal — and measuring it is what this article is for. What makes the pattern politically strange is that no one chose it. No bill, no regulation, no announcement, no minister at a lectern. Insurance affordability deteriorated through a chain of building costs, weather and global capital markets, and arrived in letterboxes without ever passing through a parliament. That is why it has been under-analysed, and why it deserves an audit.
What happened, and what the government actually did about it
Start with the size of the movement, because everything else in this article depends on it. The average Australian household home insurance premium rose about 14 per cent across 2025, from roughly $2,452 to roughly $2,795 (Actuaries Institute, Home Insurance Affordability reporting — secondary source, an independent professional body rather than a government statistical agency). Over the longer run the compounding is what matters: home insurance premiums grew at an average of about 7.2 per cent a year between 2010 and 2025 (Actuaries Institute — secondary), while the Wage Price Index, the ABS measure of what an hour of the same work is paid, grew at about 3.1 per cent a year over the same period (ABS, Wage Price Index, 2010–2025).
Two growth rates four percentage points apart do not sound dramatic in a sentence. Compounded across fifteen years they are transformative: a premium growing at 7.2 per cent a year roughly triples, while a wage growing at 3.1 per cent rises by a bit over half. The premium does not become slightly harder to pay. It becomes a structurally different share of the household budget.
The consequence shows up in the affordability measure. On the Actuaries Institute's definition — a household is in affordability stress when its home insurance premium exceeds four weeks of gross household income — the share of Australian households in stress reached 15 per cent, about 1.61 million households, on the most recent reporting. That is up from 12 per cent in 2023 and 10 per cent in 2022 (Actuaries Institute — secondary). Half again as many households in three years, on a measure designed to be conservative.
Now the part that makes the topic analytically interesting. Over roughly the same window, the Australian Bureau of Statistics reported its insurance and financial services CPI group up 2.4 per cent in the year to February 2026 (ABS, Consumer Price Index) — a little below the general run of consumer prices. Read only that number and insurance looks like one of the quieter parts of the basket. Both figures are correct and neither is spin. Explaining why they diverge is the single most useful thing this article can do, and it gets its own section below.
What governments did — and did not — do
The Commonwealth did not sit still on this. The most substantial intervention is the cyclone reinsurance pool, established under the Treasury Laws Amendment (Cyclone and Flood Damage Reinsurance Pool) Act 2022 and administered by the Australian Reinsurance Pool Corporation (ARPC), a Commonwealth entity. The pool began operating from 1 July 2022. It is backed by a Commonwealth guarantee in the order of $10 billion (approx.; Treasury and ARPC materials), and it covers cyclone and cyclone-related flood damage for eligible home, strata and small business policies in northern Australia. Participation was made mandatory on a staged timetable — larger insurers were required to join by the end of 2023 and smaller insurers by the end of 2024 (ARPC; Treasury).
"Reinsurance pool" is jargon hiding a simple idea. Insurers buy their own insurance — reinsurance — on a global market, to protect themselves against one catastrophic event wiping out a year of premiums. The pool inserts a government-backed reinsurer into that chain for cyclone risk specifically, priced below what the private global market charges, with the taxpayer standing behind the difference. The intended effect is to cut the reinsurance cost embedded in northern premiums, and so the premiums themselves.
Alongside it, the Commonwealth replaced the Emergency Response Fund with the Disaster Ready Fund under the Disaster Ready Fund Act 2022, making up to $200 million a year available from 2023-24 for disaster prevention and resilience work — levees, flood mitigation, house raising, retrofits — administered through the National Emergency Management Agency (NEMA). That was a real change of purpose: the predecessor fund was largely oriented to recovery, and the successor is explicitly oriented to mitigation.
The record before that matters too. The Australian Competition and Consumer Commission ran a three-year Northern Australia Insurance Inquiry, reporting in late 2020 (ACCC, Final Report, Dec-2020). It documented northern premiums far higher than the rest of the country, rising faster, with a substantial share of northern households underinsured or entirely uninsured, and recommended a long list of changes covering pricing transparency, standardised definitions and the removal of state insurance taxes. That inquiry was commissioned and completed under the previous government; the pool that followed was legislated in 2022 and operated since. The credit and the responsibility are genuinely shared.
And there is a layer of government that appears in almost every premium and is almost never discussed: the states. Premiums attract GST, and then state stamp duty on top — around 9 per cent in Queensland (approx.; Queensland Revenue Office), with duty at comparable orders elsewhere. New South Wales additionally funds the bulk of its fire and emergency services through the Emergency Services Levy, which insurers recover through premiums on property policies. The ACCC recommended removing these taxes precisely because they are levied as a percentage of the premium: they rise automatically, without any decision by anyone, exactly as the underlying premium rises. A household in a high-risk postcode therefore pays more duty than one in a low-risk postcode, on the same house value, for the same reason it pays more premium.
The strongest case for the policy
The price is telling the truth, and most of what drives it is outside any Australian government's reach
Put the government's position at its best and it is unusually strong — strong enough that a fair critic has to concede most of it before saying anything at all. Begin with the driver. Australian insurers do not carry catastrophe risk alone; they lay a large share of it off to global reinsurers, who price that cover from a worldwide book of losses. When hurricanes strike the Gulf of Mexico, when wildfire losses mount in California, when European floods run into the tens of billions of euros, the global price of catastrophe reinsurance rises — and it rises for Australian insurers whether or not Australia had a bad year. No Australian minister sets that price, no Australian regulator can veto it, and no Australian parliament can legislate it lower. Blaming a treasurer for the cost of catastrophe capital is a category error of the same kind as blaming one for the yield on a ten-year bond.
Second, the underlying risk genuinely increased. This is not a story about a price detaching from reality. Australia has absorbed a run of major insured catastrophes — the 2019-20 bushfires, the 2022 eastern Australia floods across south-east Queensland and the Northern Rivers, and repeated severe storm and hail events — with insured losses running into the billions of dollars per event (Insurance Council of Australia catastrophe data — secondary source, an industry body; and ACCC inquiry findings). A premium is a forecast of expected loss plus the cost of capital held against it. When the expected loss rises, the honest premium rises with it.
Third, the part critics most often skip: an insurer that underprices catastrophe risk does not become a public benefactor. It becomes insolvent, at exactly the worst moment — after the event, when its policyholders need it. The prudential architecture APRA supervises exists to ensure a general insurer can actually pay the claims it has promised. Premiums that fully reflect risk are that architecture working, not failing.
Fourth, the price signal is doing a job nothing else in the system does as well. A high premium in a flood-prone street is information: it tells a buyer what the ground is worth, tells a council what it is permitting, and tells a builder what the standard should be. Suppress that signal with a price cap and the cost does not disappear — it moves, to taxpayers through a subsidised state scheme, to other policyholders through cross-subsidy, or out of the market entirely as insurers withdraw. Comparable overseas jurisdictions that have capped catastrophe-exposed premiums have generally ended up with some combination of insurer withdrawal, a state-run insurer of last resort carrying enormous concentrated exposure, and an eventual taxpayer bill. That is the observed pattern, not a hypothetical objection.
Fifth, and decisively for attribution: the government did intervene, structurally, at the sharpest end of the problem. The cyclone reinsurance pool is a legislated, Commonwealth-backed reinsurer, mandatory for participating insurers, aimed with precision at the region where premiums are highest. Whatever its limits, it is the kind of intervention that critics of government inaction normally say they want.
Sixth, the deepest driver is a legacy, not a decision. Australian premiums are high in specific places because Australian houses were built in specific places — on floodplains, on low-lying coastal land, in cyclone corridors — under planning approvals granted by state and local governments across decades, under councils and state governments of every political stripe. Those approvals are the accumulated inheritance of the twentieth century. No federal government elected in the twenty-first can unbuild them.
The evidence
Fifteen years of compounding, drawn
No parliament voted for this. It arrived through a reinsurance treaty, a building cost index and a floodplain approved in 1974.
The divergence: why the CPI says 2.4% and the renewal notice says 14%
This is the section that matters most, so it is worth going slowly. Two official-looking numbers describe insurance prices. The ABS reports its insurance and financial services CPI group up 2.4 per cent over the year to February 2026. The Actuaries Institute reports the average home premium up about 14 per cent across 2025 (secondary). A careless writer picks whichever supports the argument. The honest answer is that the two measures are answering different questions, and there are at least five reasons they separate.
First, the CPI category is much broader than home insurance. The ABS group is called insurance and financial services for a reason. It combines an insurance component — which itself blends motor vehicle insurance, house and contents insurance, and health insurance — with a financial services component covering things such as deposit and loan facilities and other financial services (ABS, CPI structure). Home building insurance is therefore a fraction of a fraction of the reported number. A large movement in one part can be substantially diluted by flat or falling movements in the others. A 2.4 per cent group figure is entirely compatible with home insurance inside it moving several times faster.
Second, the two numbers cover different windows, and the base matters enormously. The insurance component of the CPI did not miss the shock; it recorded it. The ABS reported the insurance group up 14.0 per cent over the year to the June quarter of 2024 (ABS, CPI, Jun-2024) — one of the sharpest rises of any component in the basket. The 2.4 per cent to February 2026 is a growth rate measured on top of a level that has already climbed steeply. A small percentage increase on a much larger base is not relief. Households do not pay the rate of change; they pay the level. Reporting the deceleration as though the problem had resolved is the single most common error made with this series.
Third, the CPI is constructed to isolate a constant unit of cover, and a renewal notice is not a constant unit of cover. A price index exists to measure pure price change, holding the thing being bought fixed. If a car gets safer, or a laptop faster, the ABS strips out the quality change so the index does not confuse "better product" with "higher price". Insurance receives the same treatment in principle: the ABS constructs its insurance price measure to track the change in the price of a like-for-like quantity of cover, adjusting for changes in the amount insured (ABS, Consumer Price Index: Concepts, Sources and Methods). But a household's actual premium rises for two reasons at once. The price of a unit of cover rises, and the number of units rises, because the sum insured is indexed upward each year to keep pace with what it would now cost to rebuild the house. Building costs have risen sharply since 2020 (ABS, Producer Price Indexes, output of the house construction industry). To the ABS, an increase in the sum insured is more cover, not a higher price. To the household, it is simply a bigger number on the notice. Both are right. Only one of them is the number that has to be paid.
Fourth, the CPI is a capital-cities measure, and the shock is not concentrated in capital cities. The Australian CPI is compiled as the weighted average of the eight capital cities (ABS). Cairns, Townsville, Mackay, Rockhampton, Bundaberg, Lismore, Ballina and the rest of the Northern Rivers and northern Queensland are not in that sample. The regions where premiums have risen most, and where the affordability stress is heaviest, are structurally outside the number that the national debate treats as the measure of insurance cost. This is not an ABS failing — the CPI is designed as a national macroeconomic price measure and its capital-cities basis is a documented, deliberate feature. It is a failing of how the number is used.
Fifth, an average conceals a distribution, and the distribution is the story. Even the 14 per cent average rise is a mean across every household in the country, including low-risk inner suburbs whose premiums moved modestly. The 15 per cent of households in affordability stress are by definition worse off than the average, and the households at the extreme — a low-set house on a flood-affected block in a cyclone region — face changes no national average will ever show. The ACCC found precisely this shape in the north (Final Report, Dec-2020).
Put those five together and the picture resolves. The CPI is not wrong and it is not being manipulated. It is a national, capital-cities, quality-adjusted, broadly-defined macroeconomic price index, and it is doing exactly what it was designed to do. The Actuaries Institute figure is a different instrument: the average dollar amount actually charged for a home policy, unadjusted, across the whole country. Asking which is the "real" insurance number is like asking whether a thermometer or a rain gauge gives the real weather.
The problem is what happens next. When the insurance number decelerates to 2.4 per cent, insurance drops out of the cost-of-living conversation — at the same moment that 1.61 million households are paying more than four weeks of gross income for a home policy.
The affordability series, drawn
The drivers, in plain English
Four forces explain most of the movement, and only one of them is even partly within an Australian government's short-run control.
Global reinsurance pricing. No insurer can hold enough capital to cover the worst imaginable cyclone alone, so it buys catastrophe reinsurance — cover that pays out once losses from a single event exceed a threshold. That cover comes from a global pool of capital that also carries US hurricane risk, Japanese earthquake risk and European flood risk. When worldwide insured catastrophe losses run high, that capital becomes scarcer and dearer, and the price of catastrophe cover rises everywhere. Australian insurers renewing their treaties face a higher input cost, which flows into what they charge. It is an international price, moving for reasons that have nothing to do with Australian policy.
A real increase in Australian catastrophe losses. The second driver is domestic and physical. Australia has absorbed an unusually costly run of declared insurance catastrophes — the 2019-20 bushfire season, the February–March 2022 floods across south-east Queensland and the Northern Rivers, and a series of severe storm and hail events — with individual events running to billions of dollars of insured loss (Insurance Council of Australia catastrophe data — secondary source). When the loss experience worsens, the forecast worsens and the premium follows. Whether the underlying frequency of these hazards is itself rising is a scientific question this article does not adjudicate; pricing responds to the recorded loss history and the models built on it.
Building cost inflation. The third driver is the quietest and, cumulatively, one of the largest. A home policy promises to rebuild the house, and the cost of that promise is the price of labour and materials in the local building market, which rose steeply from 2021 as materials, freight and trades tightened (ABS, Producer Price Indexes, output of the house construction industry). Because insurers index the sum insured upward to keep pace, every household's cover becomes more expensive even where its risk has not changed at all. This has nothing to do with cyclones, floodplains or reinsurance. It is simply the cost of the thing being promised.
Concentration of exposure. The fourth is geography. Australian housing is heavily concentrated on the coast, including in cyclone-exposed northern regions and on river floodplains subdivided and approved for housing across many decades. Risk-based pricing turns that concentration into a very uneven premium map: a national average that is merely uncomfortable becomes, in specific postcodes, a premium that consumes a serious fraction of a pension or a single income. The ACCC found exactly this concentration in the north (Final Report, Dec-2020).
Attribution, stated precisely
This site's discipline is to separate what a government caused from what it inherited and what it merely presided over, and this topic requires that discipline more than most.
The current federal government did not cause the global price of catastrophe reinsurance. That is set in international capital markets and moves with worldwide losses. It did not cause the run of Australian catastrophe events. It did not cause post-pandemic construction cost inflation, which was a global supply-chain and labour-market phenomenon. And it emphatically did not cause the planning decisions that placed Australian houses on floodplains and low-lying coastal land; those approvals were granted by state and local governments across decades, under administrations of both major parties, and they are an inherited legacy in the strictest sense.
What it has presided over is the period in which affordability stress rose from 10 per cent of households in 2022 to 15 per cent (Actuaries Institute — secondary). Presiding is not causing, and this article does not claim otherwise. What can fairly be assessed is the response: whether the measurement used to size the problem is fit for purpose, and whether the balance between preventing damage and paying for it afterwards is right. Those are choices, and they sit with government.
One boundary belongs here. This article does not allege that insurers have profiteered. The place to test such a claim is APRA's quarterly general insurance performance statistics — net earned premium, net incurred claims and underwriting results — assessed across a full catastrophe cycle rather than a single strong or weak year. The argument made here does not depend on that question, and it would be dishonest to imply an answer the evidence does not supply.
The critique: a problem measured wrongly and prevented too little
The critique has two parts, and they are connected. The first is measurement. The second is the balance between mitigation and recovery. Both are within government control, and neither depends on blaming anyone for reinsurance prices.
Measurement: the policy is calibrated to a number that understates the problem
Australian cost-of-living policy runs on the CPI. Relief packages are designed around it, indexation is written to it, and the political cycle treats each release as the scoreboard. That is reasonable for most of the basket. For insurance it produces a systematic blind spot, for the five reasons above: the category is too broad, the base effect flatters the recent rate, quality adjustment strips out the sum-insured increase households actually pay, the sample is capital cities, and the average conceals the tail.
The consequence is not abstract. Energy prices generated four consecutive budgets of rebates, largely because electricity is a single, visible, well-measured CPI class that produced dramatic headline numbers. Insurance generated a reinsurance pool for one hazard in one region and very little else, because after mid-2024 the published insurance number stopped looking alarming. The policy response tracked the measurement, not the household.
The fix is unglamorous and entirely achievable: a published, regular, official measure of home insurance affordability at a geographic resolution finer than the eight capital cities. The data exists. Insurers hold premium and sum-insured data by address, APRA already collects extensive general insurance returns, and the ACCC compelled and analysed exactly this kind of data for northern Australia across three years — which proves the exercise is feasible. What is missing is a standing series rather than a one-off inquiry: something that would let any Australian, or any minister, see how premiums are moving in their own postcode relative to local incomes. Without it, the country is managing a regionally concentrated problem using a national average structurally incapable of showing it.
You cannot govern what you do not measure, and the number the country governs by was never designed to see this.
Mitigation: still small beside the cost of cleaning up
The second part of the critique is about where the money goes. A government can spend before, on mitigation — levees, house raising, roof retrofits, drainage, buy-backs of the most exposed properties, and land-use rules that stop the problem being enlarged. Or it can spend after, on recovery — emergency payments, reconstruction, and the shared Commonwealth-state cost of putting things back.
The imbalance between the two is long-standing and well documented. The Productivity Commission's inquiry into natural disaster funding arrangements found Commonwealth funding heavily weighted toward post-disaster recovery relative to mitigation, and recommended a substantial reallocation toward mitigation (Productivity Commission, Natural Disaster Funding Arrangements, Inquiry Report No. 74, Dec-2014). More than a decade on, the direction of that finding still holds, even though the absolute numbers have moved.
The scale comparison makes the point. The Disaster Ready Fund makes up to $200 million a year available for mitigation from 2023-24 (Disaster Ready Fund Act 2022; NEMA). Commonwealth disaster recovery spending under the Disaster Recovery Funding Arrangements has run to billions of dollars in years following major events, with the 2022 eastern Australia floods alone generating recovery commitments an order of magnitude larger than a single year of the mitigation fund (Budget papers; NEMA). That is not an argument that recovery spending is wasted; people whose houses have gone under need help immediately. It is an argument about ratio, and a country spending several dollars cleaning up for every dollar spent preventing is choosing to keep paying the larger bill.
Mitigation is also the only lever that moves premiums in the right direction, because it is the only one that changes the underlying risk. A levee that takes a suburb out of the one-in-a-hundred-year flood extent changes the expected loss, and an insurer pricing that suburb will eventually reflect it. A rebate does not change the expected loss; it changes who pays. A price cap changes who bears the shortfall. Raising a house above the flood level is one of the very few interventions available that attacks the cause rather than the symptom.
The second mitigation lever is land use, and it is almost entirely a state and local responsibility. Every new dwelling approved on a floodplain or in a high-risk coastal zone adds a household to the affordability problem twenty years from now. This is where the inherited legacy becomes an ongoing choice: the past approvals cannot be undone, but the future ones are being made right now, by councils and state planning departments, under pressure from a housing shortage that makes cheap flood-exposed land look attractive. A housing target met partly by building in hazard zones is an insurance crisis with a delay.
What the cyclone pool does and does not reach
The cyclone reinsurance pool is a real intervention and the caveats here do not withdraw that. But its scope is defined narrowly, and the definition determines who it can help. It covers cyclone and cyclone-related flood damage, in northern Australia, for eligible home, strata and small business policies (ARPC; Treasury Laws Amendment (Cyclone and Flood Damage Reinsurance Pool) Act 2022). Three limits follow directly.
It is hazard-limited: riverine flooding unconnected to a cyclone, bushfire, hail and severe storm all sit outside it, so a household in the Hawkesbury-Nepean, or on the Northern Rivers away from a cyclone event, or on a bushfire-exposed fringe, is outside the pool entirely. It is geography-limited: affordability stress now touches roughly one household in seven nationally, well beyond the northern footprint. And it is a cost-of-capital instrument rather than a cost-of-rebuilding one — it can compress the reinsurance margin inside a premium, but it does nothing about building cost inflation, which works on every policy in the country regardless of hazard or postcode.
None of that makes the pool a failure. It makes it a targeted instrument aimed at one driver in one region, being asked, in public debate, to carry a problem several times its size.
What they got right, and the honest caveats
The credit here is substantial and it should be stated before anything else, because the critique above is only credible if the credit is given plainly.
The cyclone reinsurance pool is a genuine structural intervention. Not a rebate, a campaign or a review, but a legislated, Commonwealth-backed reinsurer with mandatory insurer participation, standing behind a specific catastrophe risk in the region where premiums are highest. Governments are routinely accused of reaching for temporary relief instead of structural reform; this is the opposite. The ARPC has reported premium reductions flowing to northern policyholders as insurers joined and re-priced (ARPC reporting).
Mitigation funding has increased, and its purpose has been sharpened. Replacing a recovery-oriented fund with the Disaster Ready Fund and directing up to $200 million a year specifically at prevention and resilience is a change in the right direction, and it moves against decades of institutional habit. The critique above is that the scale is small relative to recovery spending — not that the direction is wrong.
Premium growth is forecast to moderate. Industry forecasts point to home premium growth easing to around 5.9 per cent in 2026, down from about 14 per cent in 2025 (industry forecast — secondary source, and a forecast rather than an outcome). If that eventuates, the acute phase of the shock is passing. That should be said clearly, because a site that only ever reports deterioration is not auditing, it is campaigning.
And the ABS is not the villain of this story. The CPI is a well-constructed, internationally comparable price index doing the job it was designed for. The criticism here is aimed at how the number is used, not at how it is built.
Now the caveats, stated with equal honesty. Growth easing to 5.9 per cent is still roughly double long-run wage growth, so affordability keeps deteriorating, only more slowly. A forecast is not an outcome, and one severe season would revise it. The pool's hazard and geographic limits leave most of the 1.61 million stressed households outside it. Up to $200 million a year is a fraction of what a serious national retrofit and levee program would cost. And nothing in the current architecture closes the measurement gap.
The risk to the future
An uninsurable class of Australian housing, and what that does to the mortgage market
The forward risk is not that premiums keep rising. It is that in some places they stop mattering, because cover ceases to be available on terms a household would recognise as insurance. That end-state has a shape: premiums rise until the household drops flood cover, then contents, then lets the policy lapse; or the insurer restricts what it will write in that postcode; or cover is technically available at a price nobody in the street can pay. The house is not condemned. It is simply outside the insured economy.
The consequence least examined runs through the mortgage market, and it deserves reasoning rather than assertion. Australian lenders generally require building insurance as a condition of a mortgage. That requirement is not ceremonial: the dwelling is the security, and a lender holding security that could be destroyed without compensation holds a much worse asset. If cover becomes unavailable or unaffordable in a location, the logical chain is that new lending there becomes harder to obtain, which shrinks the buyer pool to those paying cash, which reduces what the houses are worth. The family home is the largest asset most Australian households own, so a fall in value concentrated in the most exposed regions is a transfer of wealth away from places already less wealthy than the capital cities.
The probability of this occurring at national scale is low, and it would be alarmist to suggest otherwise. Australia's insurance market remains competitive, the great majority of dwellings are readily insurable, and even the measure that has moved most sharply still describes a minority of households. The realistic risk is localised rather than systemic: specific streets, specific floodplains, specific coastal pockets, appearing first as quiet withdrawals of appetite rather than as an announced event. The direction of travel is adverse; the magnitude is genuinely uncertain. What raises the probability is inaction on the two things government can control. If mitigation stays small relative to recovery, the underlying risk does not fall and nothing pushes premiums back down. If new housing keeps being approved in hazard-exposed locations, the exposed cohort grows rather than stabilises. And if the country keeps judging the problem by a capital-cities, quality-adjusted, broadly-defined price index, it will not see the deterioration until the withdrawal has already happened.
The retiree at the kitchen bench north of Rockhampton is not, in any sense, a policy failure. He is a price signal. The question this article leaves is whether the country intends to answer that signal by lowering the risk — raising houses, building levees, retrofitting roofs, and refusing to approve the next subdivision on the floodplain — or by continuing to describe the problem with a number that was never built to see him.