Water that is pushed toward the shore due to the force of winds swirling around a storm advancing across a body of water. This advancing surge combines with the normal tides to generate the hurricane storm tide, which can lead to severe flooding in coastal areas. Numerous coverage disputes over the applicability of flood exclusions to storm surge losses caused by major hurricanes, such as Katrina (often called "wind versus water" cases), have arisen because this term is not often listed as an excluded peril in property insurance forms. Most courts, however, have ruled against coverage for these losses under standard property insurance policies, stating that "storm surge" is little more than a synonym for a "tidal wave" or "wind-driven flood," both of which are excluded under most property forms. In summary, the courts have generally ruled that only flood insurance policies cover these losses.