Alberta Private Passenger Usage Based Insurance (UBI) Implementation Process Consultation The Co-operators January 30, 2015

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1 Alberta Private Passenger Usage Based Insurance (UBI) Implementation Process Consultation The Co-operators January 30, 2015

2 Friday, January 30, 2015 Mr. Mark Prefontaine Superintendent of Insurance 402 Terrace Building Street Edmonton, Alberta T5K 2C3 Dear Mr. Prefontaine: Subject: Private Passenger Usage Based Insurance Implementation Process Thank you for the opportunity to provide feedback on the government s DRAFT notice to establish the process requiring insurers to follow in implementing Usage Based Insurance (UBI) discount programs for private passenger vehicles in Alberta. We believe we bring a unique perspective as a co-operative insurer who has experience in this area. About The Co-operators The Co-operators is a group of Canadian companies focusing on insurance. As a co-operative, our 42 member owners include co-operatives and credit union centrals representing a combined membership of millions of Canadians. In Alberta we employ approximately 526 staff, 103 Advisors and insure 353,676 vehicles, 117,323 homes, 18,669 farms, and 22,802 businesses. In 2014 alone, The Co-operators has contributed over $276,000 to Alberta charities and community organizations. We are not full members of the Insurance Bureau of Canada as we prefer to contribute to the policy development process directly. We are a co-operative as well as an insurance company and believe we bring a uniquely Canadian and co-operative perspective to public policy consultations. Our philosophy regarding the delivery of the automobile insurance product to the consumers of Alberta is based on the following fundamental guiding principles: Security: At its most basic level, insurance provides peace of mind. To provide peace of mind, insurance must provide adequate coverage and have an appropriate measure of financial protection. Affordability: Insurance must be affordable for a compulsory insurance system to work. Availability: Insurance consumers have the right to expect reasonable access to a variety of providers who can meet their coverage needs. Simplicity: Insurance consumers have a right to understand the product they are purchasing and the benefits to which they are entitled if they are injured.

3 Telematics In the United States, companies began offering monitoring devices in In Europe, two million drivers have chosen to go this route. By 2017 the number of monitored drivers worldwide will rise to 89 million, up from 1.85 million in 2010, according to ABI Research 1. The Alberta Auto Insurance Rate Board (AIRB) is currently conducting a poll on their website regarding UBI. As of January 26, 2015, 67 per cent of respondents said they would sign up for Usage Based Insurance. Telematics creates a financial incentive to drive safe; attracting safer drivers and rehabilitating other drivers. A handful of Canadian Insurers have started testing the software in pilot programs, including The Co-operators. Our Experience In April 2014, The Co-operators introduced our en-route Auto Program in Ontario which allows for more customized auto insurance and lower premiums for safe drivers, based on usagebased insurance. Clients who sign up for this voluntary program receive an automatic five per cent discount and could earn up to 25 per cent off their auto insurance, depending on their driving behaviour, when the policy comes up for renewal, and once the vehicle has passed 125 days and 1,000 km. The discount will be recalculated on each subsequent renewal while the client remains enrolled in the program, and is based on the data collected. A small wireless telematics device is plugged into a vehicle s port to track participating clients driving in real time. Data collected include instances of sudden braking and rapid acceleration; as 1 https://www.abiresearch.com/press/89-million-insurance-telematics-subscribers-global Page 2

4 well as the total distance driven and times of day. The information collected as part of the program is used to reward safe drivers. Our en-route Auto Program is as customized as auto insurance gets. It s an innovative program that not only allows premiums to reflect personal driving behaviour, but also provides clients with reports they can use to become safer drivers. Participating clients can access their driving data online, including routes traveled, mileage, travel time, sudden braking and acceleration, as well as coaching tips. The information can be used by drivers to improve their driving behaviour, which could in turn result in more savings. Community Feedback Prior to implementation, The Co-operators collaborated with our Community Advisory Panels (CAPs) across the country to provide a forum for community members to comment, provide advice and make recommendations to senior management on matters relating to the product/service and any interactions with the community and consumers. Unlike a focus group, CAPs provide a venue for meaningful, in-depth dialogue on topics which help support our strategic areas of focus. We have 4 CAP panels across the country (Moncton, Ottawa, Guelph and Calgary). Each panel has 14 community members from sectors such as: business, education, healthcare, seniors, co-operative sector, youth, emergency services, etc. During our Calgary CAP consultation, members noted a great impact in terms of improved driver behaviour and also a positive impact on the environment. Specific Alberta UBI Notice Feedback As noted, based on our en-route Auto Program in Ontario, clients automatically receive a five per cent discount on their auto insurance, and could earn a discount up to 25 per cent, depending on their driving behaviour. The innovative program not only allows premiums to reflect actual driving behaviour, it also provides a wide range of personalized information online. Using technology developed by Intelligent Mechatronic Systems (IMS), participating clients are provided with helpful information through the myenroute Dashboard including: Page 3

5 Ratings based on a five-star system for each of the factors that make up the discount, so the driver is aware of what to change to earn a greater discount. These factors include: sudden braking, rapid acceleration, late night driving and distance travelled. Tips based on the driving data to help become a safer driver Detailed information about every trip, displayed on a map The vehicle s environmental impact, including information about idling time, fuel consumption and the vehicle s overall carbon footprint The ability to set up text message or alerts for a number of user-defined events, including exceeding a speed threshold, leaving a defined area, or driving during certain times of day or night Information about the vehicle s health and performance This is an innovative tool that has the potential to help our clients become safer drivers and reduce their premiums. It s a great way to learn about one s own habits or, if there is a young driver in the home, to monitor their driving and help keep them safe behind the wheel. We understand and support the Superintendent s DRAFT guideline above, however, while The Co-operators does not currently use speed nor location to rate, we believe it is important to note this is a starting point for implementation, and should not be limited for potential future use. For example, GPS data could be used in the future to help drivers make informed choices of driving routes by showing them areas where irregular driving events are more common and thus, helping them manage/reduce risks before they get behind the wheel. We agree with the government s intent in the above excerpt with exception to the reference to scripts. We can note that with our Ontario program experience, scripts change often. For example, our script regarding delivery of the device has changed from 5 day delivery, to 10 day delivery, back to 5 day delivery within the short 10 month span of the program. Advising the Superintendent or the AIRB each time there is a script change would be incredibly cumbersome, and would not be a true reflection of the intent of the notice. Our suggestion is to delete the reference to scripts above. Page 4

6 We believe every consumer is entitled to enrol in a UBI program where technology permits. Car models manufactured before 1996 do not have the current standard ODB2 port necessary to install the device. For newest model years, some advances in technology can make the devices incompatible with that vehicle. Moreover, the program will not work in areas within the province where cellular network coverage is limited or unavailable. We believe data collected through UBI programs should have the potential to be used for claims purposes where it benefits the client. Moreover, once UBI is more familiar to clients, there could be a cost reduction realized by allowing insurers to use the UBI data to confirm rating variables and for underwriting purposes other than declining, cancelling, or non-renewing risks. According to a 2014 Towers Watson s survey 2, consumers are showing a very strong interest in various value-added services that are enabled by the technology underlying UBI. For example 86 percent of survey respondents found interest in vehicle theft tracking and 85 percent in automated emergency response. The GPS in the UBI device can be used to track a vehicle in the event that it is stolen, increasing the likelihood of recovery. The UBI device can also often detect when an accident occurs and notify emergency response, providing the exact GPS location to get help faster. 2 https://www.towerswatson.com/downloadmedia.aspx?media=%7b d2ae-4c89-b ff031c07%7d Page 5

7 Concluding Remarks Innovation and choice are necessary for a healthy and competitive marketplace. Insurers should be able to apply and receive approval for other UBI criteria using the Automobile Insurance Rating Factors Framework. Studies have suggested, and our own experience has confirmed, consumer attitudes towards UBI programs are improving and public demand is increasing. The Towers Watson survey (noted earlier) revealed three important findings about the Canadian UBI consumer: 1. The marketplace is ready for widespread UBI adoption, with nearly 94% of participants expressing openness to buying a UBI policy if there is no risk of a premium increase. 2. UBI is about more than just price, as respondents want value-added services, presenting opportunities for auto insurers to decommoditize their offerings. 3. Almost half of insured interested are willing to change their driving behaviour, reinforcing the potential of driver coaching to make roads safer. Page 6

8 Higher risk segments tend to be more willing to change behaviour, potentially resulting in lower loss costs. As an organization, The Co-operators group of companies takes great pride in its open dialogue and regular communication with all stakeholders government, consumers and industry. We welcome the opportunity to have further discussion. Independent of IBC, we remain committed to working directly and collaboratively with the Alberta government to offer a unique voice for the Alberta policyholder to ensure the delivery of products that provide security, remain accessible, affordable, and easy to understand. Please contact our Director of Government Relations and Public Affairs, Frank Bomben at or to arrange future discussions or any other public policy consultations. With best regards, Vice-President, Personal Lines & Underwriting The Co-operators Page 7

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