A flood risk zone is identified in Map V2-3.4b which covers parts of our site at the old mill in Ballymore Eustace. The boundary of this zone appears to have been drawn arbitrarily perhaps using hydrological modelling done at a much larger scale.
Our site adjoins the River Liffey at a point close to the Golden Falls dam, and therefore represents a managed water body. The risk of flooding only arises in the event of failure of the dam or management procedures, since there is no signficant catchment area to provide a source of flood water. This is beyond the scope of probaibilities normally appropriate for conventional risk assessment.
Futhermore, even in the event of flooding the zone identified is not appropriate, taking in areas of our land that rise some 20mtrs above the Liffey. Indeed, the building complex is designed to manage mill race water influx and egress through its comprehensive system of races and sluices.
While identifying a zone for flood risk assessment may not, in itself, be intended to communicate an actual risk of flooding, the effect is to communicate that our lands may be subject to flood. This is not appropriate having the effect of underming our efforts to return this site to a sustainable new use as a craft whiskey distillery with bonded warehousing of valuable spirit.
We submit therefore that flood risk zoning is not appropriate. If a flood risk assessment zone is to be identified the boundary should be amended to reflect the topography of the site, as submited in the attached.
Remove the zone, or amend the flood risk zone as per the attached map.
Since the Liffey at Golden Falls dam is a managed water body, there is no catchment of flood water at this location. Identifying a flood risk zone inappropriately communicates a potential risk that undermines our efforts to conserve this site in a sustainable new use as a whiskey distillery.