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Dear Ms Davidson
I am responding on behalf of the Scottish Resources Group (SRG) of companies (which
includes Scottish Coal and Scottish BioFuel) in respect of the Consultation Paper ‘Revision of
Circular 15/1999; the Environmental Impact Assessment (Scotland )Regulations 1999’. As
many of the developments for which the SRG Group seeks consent require Environmental
Impact Assessment, any proposed change to the regulatory regime is of interest.
In the case of this current consultation exercise, we only have a few largely minor comments
to make, as follows (using the paragraph and page nos. in the Consultation Paper):
(i)
Figure 1, page 10 – two arrows need to be placed below the box containing the text
‘Does it meet any of the relevant thresholds and criteria in Schedule 2’ in order to take the
reader to either the Yes or No boxes. There also appears to be an unnecessary arrow in the
Yes box above the aforementioned text box.
(ii)
Paragraph 29, page 9 notes that the lack of any reference to a development type in
Schedule 1 or 2 should not be taken to mean that such development falls outside the scope of
the Regulations. However, the Figure 1 flow chart appears not cater for this possibility i.e.
according to the diagram if it isn’t Schedule 1 or 2 it is outside the scope of the Regulations.
There does appear to be some potential for confusion here.
(iii)
It would be helpful to include Schedule 1 and 2 of the Regulations as Annexes.
(iv)
Whilst removal of the Annex A thresholds/ criteria is designed to avoid the ‘trigger’
effect referred to in the covering letter accompanying the draft circular, a potential
consequence is that a greater number of development proposals falling within the Schedule 2
categories will end up being subject to EIA, with planning authorities (and developers) more
likely to err on the side of caution in the screening process. With the recent publication of the
2007 Notification Regulations this could result in even more applications falling into the EIA
development referral category and having to be passed to Scottish Ministers.
A pdf copy of a completed respondee information sheet is attached.
Regards
Colin Ortlepp
Planning Manager
Scottish Resources Group
Castlebridge Business Park
Gartlove
Alloa
FK10 3PZ
Telephone: 01259 733883
Mobile: 07876 577899
Fax: 01259 733850
www.scottishresourcesgroup.co.uk
Colin Ortlepp
Planning Manager
Scottish Resources Group
Castlebridge Business Park
Gartlove
Alloa
FK10 3PZ
Telephone: 01259 733883
Mobile: 07876 577899
Fax: 01259 733850
www.scottishresourcesgroup.co.uk
This email is confidential and intended solely for the use of the individual to whom it is addressed.
Any views or opinions presented are solely those of the author and do not necessarily represent those of T
The Scottish Resources Group Limited. Registered in Scotland No. 143746. VAT No. 651984506
Registered Office: Castlebridge Business Park, Alloa, Clackmannanshire. FK10 3PZ
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