Objection/Observation to flawed/incomplete data used in classifying areas of Portmagee as being a flood zone

To whom it concerns,
I would like to formerly object to the classification of my premises/property held under portfolios : 17789,17455,16792 & 21409 as being considered to be classified as being in "flood zone A/B" and "highly vulnerable"  as stated on pages 114 & 115 respectively on the Draft Kenmare MD LAP Strategic Flood risk assessment.

The assessment is based on flawed and outdated data which incorrectly places my property and the adjacent properties to the West held respectively by the O'Connell & Conway families as being "highly vulnerable" and as also being " identified as being at risk of 
tidal flooding"

This assessment has taken no consideration to the private capital expenditure under taken collectively by the O'Connell, Conway & Whelan families from 1997 to 2004 to install the only modern reinforced concrete seawalls spanning over 60 linear meters complete with one-way drainage valves to be built in any build up settlement in South Kerry in decades.

Further to reinforce our assertion to the fact it is a flawed assessment to included the properties of the O'Connell, Conway & Whelan families as being as in a "flood zone " and "highly vulnerable" to "Coastal flooding" is the fact that there has been no claims for flood damages in records we have going back over 20 years, unlike several properties in other areas that have made claims for flooding , yet these same properties are not included as being at risk of flooding from fluvial, pluvial or coastal waters, which clearly indicates a flawed/incomplete data set is being employed solely on predictive & historic data yet is ignoring or indeed failed to take into consideration modern day claims, occurrences when classifying areas. & further in our case the installation of modern RC seawalls to pre-empt any risks to our properties has been totally overlooked in respect to this report.

On further review of the draft plan in respect to page 27 of the report from MWP it states "Dingle Bay Flood Risk Management Plan indicates that pluvial flooding occurred in December 2015 which came from higher ground in Coomanaspig"

We would like to point out that the inclusion of this is to an extent ill informed. The issue of the pluvial flooding was not solely derived from waters that came from "higher ground" as was simply stated. The issue arose through the continued expansion of surface drainage for areas to the Southwest of the village up past the national primary school without the accompanying capital investment into the drainage infrastructure of the main village drainage system which was constructed in the 1960's to serve the lower village area. 

Secondly & further to the above it clearly has been omitted and did not merit mention in the report the very clear lack of investment in the sewage/drainage system of portmagee in respect to pluvial water management. This is in reality the largest potential risk for premises located predominately in the West of the village where continued lack of infrastructural investment in simple road/area drainage coupled to a suitably sized pumping station would afford protection for generations from run off originating from higher land entering the main village area.

To surmise the facts that have been laid out in respect of both my property & those of the O'Connell & Conway's properties are based on sound fundamental engineering & up to date information coupled to the opinion of an engineering professional with over 20 years experience.  Thus in light of the clearly outlined facts of preempted steps taken by us to protect/maintain our properties I formally request for the properties outlined by me to be removed from being classified as being in a flood zone at risk of "coastal flooding" per page 167 of the report "Figure 5.33: Portmagee CFRAMS Coastal & NCFHM 1% & 0.1% AEP MRFS"

I or my representatives are at your disposal to discuss further.