CDI approves every rate change. Between marginally higher risks, inflation, new costs (e.g. re-capitalising the FAIR Plan for people who like living inside wildfires) and the risk that future rates won't be approved, the cost basis is likely quite a bit higher than 50%, particularly if you take into account prior years covered by the pandemic rate-hike moratorium [1].

[1] https://www.insurancebusinessmag.com/us/news/breaking-news/a...