Last month California Insurance Commissioner John Garamendi sponsored a national catastrophe insurance summit attended by Florida Insurance Commissioner Kevin McCarty, New York Insurance Superintendent Howard Mills and Illinois Insurance Director Michael McRaith that called for a private-state-federal partnership to fund mega-catastrophe losses and creation of a new all-perils homeowners policy that would cover the cost of flood losses.

The program was then detailed and refined for presentation at a public hearing by the NAIC's Catastrophe Insurance Working Group.

For the past several weeks, Allstate has engaged in a major public relations effort involving newspaper advertisements in the Wall Street Journal and major studies to drum up support for the state and federal funding called for in the catastrophe program proposal.

The so-called all-perils policy, which would have private insurers cover flood losses for the first time, is drawing the most serious opposition at this point to widespread acceptance.

At Saturday's public hearing, Mr. McCarty acknowledged that some perils could be excluded such as mold and vermin. But for the most part he remained confident that flood could be included in such a policy, although it would involve a major revamping of the current National Flood Insurance Program.

Allstate representative Jim McCabe said that flood losses should be excluded at this point in the discussions.

Mr. McCarty said that he hoped to refine the proposal for a meeting in February of the Catastrophe Risk Group where it could be approved for possible final adoption at the March NAIC meeting.

The two main issues have come down to flood coverage, and the dollar loss figures that would trigger state and federal involvement in funding catastrophe losses.

Mr. McCarty said the current shortcomings of federal flood insurance necessitates that some sort of radical overhaul of the nearly 40-year-old program should be undertaken.

He said that the number of homeowners who lost their dwellings in Hurricane Katrina and did not have flood coverage, an estimated 50 percent to 60 percent, underscores the scope of the problem.

The federal flood program also has been criticized for failing to operate as a risk-based insurance program but rather like a federal subsidy that fails to encourage sound land use policy in flood zones.

Mr. Snyder said the catastrophe program proposal "first came to light just last month at an invitation-only NAIC partially sponsored summit and then they held a public hearing on Saturday with very short notice with the final proposal only delivered days before."

The one-in-50-year event that would trigger catastrophe supports, according to some critics, is too low to involve government funding as events at that level have been adequately handled so far by the private market.

Mr. McCarty said that figure was just a starting point, which had been used in previous federal legislative funding proposals over the past decade.

The full NAIC body passed a resolution Sunday calling for exploration of programs to deal with national catastrophes. While Mr. McCarty insisted that the resolution merely restated long-standing NAIC policy, Mr. Snyder expressed concern that there were enough "buzzwords" to give the impression the commissioners were lining up behind the controversial proposal.