I have received a request for a Regulation 5 screening opinion for an 82 bed care home on an 0.51 ha parcel of land. The agent's conclusion is that although the development could be considered Schedule 2 development as the site area is more than 0.5 ha, nevertheless with regard to Circular 02/99 the development : • would not be of more than local importance; • would not fall within an environmentally sensitive site, and; • would not have unusually complex or hazardous environmental effects. As such, it is not considered that an EIA would be required to support a planning application. I tend to agree with these conclusions. However, the site falls within a larger Greenfield employment site that has outline planning permission supported by an EIA and which is currently the subject of an 'Application for a new planning permission to replace an extant planning permission in order to extend the time limit for implementation', which is also supported by a corresponding EIA. To complicate matters further, I am also engaged in pre-application discussions for the provision of a 400 space car park on an adjoining parcel of land within the same host site in relation to which a Regulation 5 screening opinion will also be sought. My 'planning instinct' tells me that both schemes would/should require an EIA to support a planning application on grounds relating to the potential cumulative effect of piecemeal development of the host site that would differ in form, scale and nature from that proposed by the host outline/renewal application and as assessed by the corresponding EIA's. If a similar approach to the sub-division and development of the host site was taken then over time it could result in a situation whereby a number of individual planning permissions exist for the development of separate parcels of the host site but without the need for EIA being triggered or the environmental effects of any of them being assessed individually or cumulatively. The Regulations, Circular, DCP, etc seem to be silent on this issue. Is anyone aware of something that I may have missed or does anyone have advice/experience of a similar situation/s that would help please?
