A Technical Review of Irish Rail's Reports on Option 7

Option 7 scores Highly Negative on Noise & Vibration — the worst of all eight options assessed

The Depot Access Road Option Selection Report (OSR) and the Depot Access Road Presentation use a Multi-Criteria Assessment (MCA) scoring system on a scale of 1 to 7, where 1 is Highly Negative Impact and 7 is Highly Positive Impact. Option 7 receives the lowest possible score of 1 (Highly Negative) on the Noise & Vibration criterion. No other option received this score on this criterion.

The Depot Access Road Presentation contains the following text in its comparison of Options 7 and 8 on the Noise & Vibration criterion:

The following table shows the Noise & Vibration scores across all Do-Something options as recorded in the MCA:

Option 7 is the only option that permanently acquires residential garden land

The OSR states explicitly, in relation to Option 7's impact on property:

This is repeated in the Presentation, which records that Option 7 scores 2 (Negative) on the Material Assets: Property sub-criterion due to this residential land take. Residents confirm that the proposed road goes through three residential front gardens as well as three or more agricultural landowners' property. It also requires the felling of many mature Irish trees.

Of the Do-Something options:

• Option 4: Impacts agricultural properties only — no residential front garden impacted
• Option 5: Impacts residential properties in a different context (properties adjacent to an offline new route)
• Option 6: Impacts agricultural properties only
• Option 7: Permanently acquires private residential front garden land from multiple households
• Option 8: Impacts agricultural properties only — no residential front garden impacted

The MCA scoring methodology systematically dilutes residential harm

The MCA used in the OSR applies an equal weighting to all seven assessment criteria. These criteria are averaged within each category, then each criterion is given equal weight in the final score. The Presentation itself acknowledges a consequence of this approach:

This averaging mechanism has a specific and measurable effect on Option 7's overall score. Option 7 receives the worst possible score (1 — Highly Negative) on Noise & Vibration, affecting nine households with properties within 10 metres of a new road. It also scores 2 (Negative) on residential property impact due to permanent land take. However, because these two sub-criteria are averaged with 18 other sub-criteria — many of which rate Option 7 positively on accessibility, transport network, and planning alignment — the severe residential impacts are diluted to the point where they do not materially affect the final score.

The specific effect of equal weighting

Option 7's overall MCA score is 4.7 (Slightly Positive), as recorded in the Presentation. If the Noise & Vibration criterion and the Material Assets: Residential Property sub-criterion were weighted to reflect the severity and irreversibility of direct harm to people's homes — as would be appropriate under any proportionality assessment — Option 7's score would be substantially lower, and the case for preferring it over Options 5 or 8 would be significantly weakened.

Protected bat species confirmed using the Option 7 corridor as a commuting route

An independent Ecological Impact Assessment (EcIA) was commissioned by HW Planning and conducted by APEM Group Woodrow (March 2026) for the Water-Rock Large Residential Development (LRD) — the residential development planned at Water-Rock, Midleton. The Water-Rock LRD site is located very close to the corridor that Option 7 would use.

This EcIA was prepared to professional CIEEM guidelines (2018, updated 2024) with full seasonal field surveys from December 2024 to October 2025. It is an independent document not commissioned by Irish Rail.

Bat species confirmed

The EcIA's nighttime bat walkover (NBW) surveys confirmed five species of bat actively using the hedgerows and treelines near this corridor:

Static detector surveys from May to October 2025 recorded five species in total: common pipistrelle, soprano pipistrelle, Leisler's bat, Myotis sp. and brown long-eared bat. The static detector recording the highest activity levels (Detector D.03, recording thousands of bat passes per month) was positioned on the western boundary of the site, adjacent to the treeline and the Ballyrichard More stream corridor — the same corridor alongside which Option 7's new road would run.

Hedgerows confirmed as bat commuting corridors

The Ballyrichard More stream corridor is a mapped bat connectivity route

Figure 13 of the EcIA ("Post-development ecological connectivity for bats, as identified during the NBW surveys and current suitable habitat") explicitly maps the retained bat connectivity corridors running along the Ballyrichard More stream and south through the site. This mapped corridor runs directly alongside the line that Option 7's new road would take.

Protected species status of bats confirmed

The EcIA records the Landscape Suitability Index for bats at this site (Table 4, page 20). Leisler's bat (Nyctalus leisleri) has a suitability index of 39, rated Very High. Common pipistrelle (Pipistrellus pipistrellus) and soprano pipistrelle (Pipistrellus pygmaeus) also rate Very High.

All bat species confirmed at this site are protected under:

• EU Habitats Directive 92/43/EEC, Annex IV (strict protection)
• Wildlife Acts (as amended), Ireland

Red-listed breeding and wintering birds confirmed in the corridor

The Water-Rock LRD EcIA (March 2026) conducted four breeding bird surveys in May and June 2025, and four wintering bird surveys from December 2024 to March 2025. The surveys covered the site boundary and a 100m buffer for breeding birds and a 500m buffer for wintering birds.

Yellowhammer — Red-listed, breeding behaviour confirmed

The EcIA records Yellowhammer (Emberiza citrinella) as a BoCCI Red-listed species with breeding behaviour (singing) confirmed in and around the site. The report states:

Yellowhammer is a species of High Conservation Concern in Ireland (BoCCI Red List), dependent on hedgerow habitat for nesting. The hedgerows confirmed to support Yellowhammer territories are the same hedgerows that Option 7 would require to be cleared.

Snipe — Red-listed, confirmed wintering

Snipe (Gallinago gallinago) was recorded in all four winter surveys, indicating a regular wintering population using the wet grassland adjacent to the corridor:

Connectivity to European designated sites

The Ballyrichard More stream, which runs along the western boundary of the surveyed area and alongside the Option 7 corridor, discharges to the Owenacurra Estuary and connects to the Great Island Channel Special Area of Conservation (SAC) and the Cork Harbour Special Protection Area (SPA), located approximately 2km downstream. The EcIA confirms:

Any construction or operational drainage impacts from Option 7 affecting the Ballyrichard More stream would require assessment in the context of this hydrological connectivity to the Great Island Channel SAC under the Habitats Directive.

No cumulative ecological or Flood Risk impact assessment exists for Option 7 and the Water-Rock development together

No such joint assessment has been published as part of this consultation.

This means:

• Irish Rail's OSR has not assessed cumulative ecological impacts in combination with the Water-Rock development
• No assessment exists of what happens when both projects proceed near the same corridor simultaneously

The Water-Rock development itself will result in the removal of approximately 488 metres of hedgerow and treeline, as stated in the EcIA:

Option 7 would require additional hedgerow clearance through the same corridor. The combined loss of hedgerow habitat, on top of the confirmed bat commuting corridors, Yellowhammer breeding territories, and Snipe wet grassland, has never been jointly assessed by any party.

Photographic evidence — flood risk on the Option 7 route

The same report, in its detailed water quality assessment, acknowledges that historic flood events have been recorded at Turloughs within 2.5km east and west of the option. Despite this, Irish Rail scored Option 7 as Neutral on flood risk. The photographs below directly contradict that assessment.

The photographs were taken by local residents during periods of heavy rainfall. They show the land along the proposed Option 7 route already flooding under existing conditions, and the Castle Rock Avenue culvert — the location where Irish Rail proposes to discharge surface water drainage from the new road — already at or beyond capacity. These photographs predate the Water-Rock residential development's drainage beginning to discharge to this same location. No flood impact assessment has been published as part of this consultation.

Option 7 route — existing flood risk

The field along the proposed Option 7 access road route, showing standing floodwater under existing conditions — before any additional drainage load from the new road or the Water-Rock development.

Castle Rock Ave — proposed drainage destination

The bridge and culvert at Castle Rock Avenue, already overwhelmed during heavy rainfall. Irish Rail proposes to route surface water drainage from the Option 7 road to this location.

Culvert at capacity — both pipes submerged

Both culvert pipes fully submerged. This infrastructure is already at capacity before the additional drainage from Option 7 or the Water-Rock development is added. A flood impact assessment is essential before any works proceed.

Alternative routes exist that avoid residential properties and should be reconsidered

Irish Rail assessed seven other options before selecting Option 7. Several of them reach the depot without acquiring residential garden land, without scoring Highly Negative on noise, and without severing a planned cycling greenway. The margin between Option 7 and the alternatives was described in Irish Rail's own report as "narrow."

A material inconsistency in Irish Rail's justification for preferring Option 7 over Option 8

Option 8 scores identically to Option 7 on the overall MCA (4.7 — Slightly Positive). It takes no residential land and exposes only two households to noise, compared to nine for Option 7. The OSR states that Option 7 "narrowly edges out Option 8 on Land Use Impacts and Local Environment Impacts" and gives two reasons: that Option 7 requires no bridge construction, and that the scale of works is smaller.

However, the OSR's own description of Option 8 (Section 4.2) states that Option 8 accesses the N25 via an existing road overbridge (CC.N25-014.00). Option 8 does not require a new bridge to be built. The claim that Option 7 has a Local Environment advantage over Option 8 because it avoids bridge construction is not supported by the OSR's own description of Option 8. This is a material inconsistency in the reasoning used to select Option 7 — and it goes directly to the narrow margin that justified that selection over an alternative that harms no residents.

We have prepared a detailed review of all seven alternatives — including a full analysis of Option 5 and notes on Options 1, 2, 3, 4, 6 and 8 — on a dedicated page.

Option 7 adds 24-hour depot traffic to an N25 junction already acknowledged as congested and unsafe

The Access to Option 7 is to and from the N25 via Midleton. The N25 Carrigtwohill–Midleton section is one of the most congested roads in east Cork. Cork County Council has publicly acknowledged — in press coverage of recent planning and road decisions — that an upgrade for this stretch "will take at least a decade," and has previously described the road as "unsafe," with lives, traffic, and housing plans at risk on a road "not fit for purpose." (Source: local and national press reporting; exact press references to be added in formal submission.)

Irish Rail's consultation documents do not include a Traffic Impact Assessment for Option 7's operational phase. Depot operations will generate 24-hour HGV movements for maintenance deliveries and shift-change staff traffic. All of this will feed to roads that are already failing under existing conditions, before any additional load is added.

The Ballyadam bridge diversion problem

Drivers approaching the depot from Cork City, travelling east on the N25, will regularly encounter queuing traffic before the Water Rock exit. In practice, many will divert before the Amgen site, cross the Ballyadam bridge, and approach via the Carrigtwohill–Midleton back road instead.

This is the same road corridor assessed by Irish Rail as Option 4. Option 4 was assessed and not selected. If Option 7 generates diversion traffic along the same route — as residents and road users expect it will in practice — then the operational effect of Option 7 is to route a portion of depot traffic through a corridor Irish Rail's own assessment process did not progress. A Traffic Impact Assessment that models actual driver behaviour, not only the designated exit route, is required before this selection can be finalised.

Selecting Option 7 does not avoid the need to upgrade the Ballyadam bridge

If one of the reasons Option 4 was not progressed is that the Ballyadam bridge would require upgrading to carry depot traffic, that objection is undermined by the selection of Option 7. If depot traffic using Option 7 diverts via Ballyadam to avoid N25 congestion — as it predictably will — then the bridge upgrade becomes necessary regardless of which option is chosen. Irish Rail cannot use the Ballyadam bridge upgrade as a reason to reject Option 4 while selecting an option that will, in practice, require the same upgrade to be carried out.

Option 4 should therefore be reconsidered on the basis that its principal infrastructure objection — the bridge — does not represent a genuine cost saving compared to Option 7 once real-world traffic behaviour is taken into account.

Option 7 conflicts with and would destroy the character of a strategically planned, publicly funded cycleway for East Cork

Cork County Council has prepared a Part 8 Planning Application for the Carrigtwohill to Midleton Inter-Urban Cycle Route Phase 2 (December 2023, prepared by WS Atkins Ireland Limited for Cork County Council). Phase 1 of the route received Part 8 Planning Approval from Cork County Council in 2022. Phase 2 — the section under planning — runs through agricultural land parallel to the Cork to Midleton Railway Line, through the Ballyrichard More area, crossing Castle Rock Avenue and connecting to the Water Rock UEA. This is the same agricultural corridor that Option 7 proposes to use for a new depot access road.

The cycleway was designed as a peaceful, traffic-free route through open farmland

The Part 8 report describes Phase 2 as:

The scheme's stated safety objective is:

And its economy objective includes:

Option 7 would place a two-lane vehicular road — used 24 hours a day by HGVs and depot staff — through the same corridor that the cycleway was designed to pass through as a quiet, off-road amenity. A path alongside an active industrial access road is not the same amenity as a path through open farmland. The difference in user experience is like that between the Midleton–Mogeely Greenway and a footpath running alongside the road from Waterrock to Midleton.

The cycleway is backed by national and regional policy that Option 7 directly conflicts with

The Cork Metropolitan Area Transport Strategy 2040 (CMATS) describes Route IU-1 — of which this cycleway is a section — as:

The Cork County Development Plan 2022 Objective TM12-2-1 mandates delivery of IU-1 as a high-quality pedestrian and cycle facility. The National Cycle Policy Framework requires active reduction of HGV volumes near cycling infrastructure. The Climate Action Plan 2023 identifies active travel corridors of exactly this kind as essential to meeting Ireland's transport emissions targets. Option 7 routes 24-hour depot HGV and staff traffic through a corridor that national and regional policy has designated as a traffic-free active travel amenity.

The cycleway involved proper public consultation and landowner engagement; Option 7 bypasses this through a Railway Order

Both phases of the cycleway went through the Part 8 process — public consultation, Cork County Council oversight, ecological assessment, and engagement with landowners. The Part 8 scheme objectives commit explicitly to:

Landowners in this corridor agreed to the cycleway through a transparent planning process. Option 7 is being progressed via a Railway Order to An Coimisiún Pleanála, which bypasses Cork County Council entirely and overrides its planning decisions. The very authority that planned, funded, and approved the cycleway is required to comply with a Railway Order it had no part in designing. The routing of depot access traffic is being placed above a publicly funded amenity for the communities and tourists of East Cork, through a process that overrides the democratic planning decisions of the local authority.

Irish Rail's own OSR acknowledges the cycleway conflict — but proposes to resolve it by merging the cycleway into an HGV road

The OSR explicitly acknowledges that the depot severs the planned cycleway. In its assessment of the Existing Transport Network (Section 4.4.2), the report states, in relation to Options 1–4:

For Options 7 and 8, the OSR claims this problem is resolved through "active travel integration." But the nature of that integration is described clearly in Section 3.5.2, which sets out what all Do-Something options consist of:

In other words, Irish Rail's solution to the cycleway conflict is to incorporate the cycle path as a footway alongside a two-lane carriageway built for HGVs and low-loaders. This is not the cycleway Cork County Council planned. The Part 8 cycleway application is explicit that its safety objective is a "traffic free route that is segregated from vehicles wherever practicable" through "open agricultural lands." A path on the verge of a depot access road is neither of those things.

The Irish Rail engineering drawing below — issued to affected landowners as part of this consultation — shows the reality of this proposal. The cycleway runs directly alongside the Option 7 depot access road: the same road that will carry HGVs and low-loaders 24 hours a day.

Irish Rail engineering drawing — issued to affected landowners

The proposed Option 7 depot access road (blue shading) with the cycleway running directly alongside it. This is Irish Rail's own drawing. The cycleway Cork County Council planned as a traffic-free route through open farmland would share a corridor with 24-hour HGV and low-loader traffic.

The OSR also cites Cork County Development Plan Objective MD-U-07 in support of Option 7 (Section 4.4.7, page 44). That objective requires that:

Option 7 requires the felling of the mature native trees and clearance of the hedgerows along this corridor. Irish Rail cites this objective as support for Option 7 while proposing works that directly contradict it.