Ross & Cromarty East Local Plan Inquiry
THE HIGHLAND COUNCIL
ROSS & CROMARTY EAST LOCAL PLAN INQUIRY
STATEMENT OF OBSERVATIONS by the DIRECTOR OF PLANNING and DEVELOPMENT
ISSUE 29: Evanton – various issues and exclusion of Swordale as a settlement
1. Introduction
1.1 The Highland Council (THC) has undertaken to hold a Public Local Inquiry to consider objections lodged by Mr A Macdonald [CD30/140] in respect of policies contained within Chapter 16 of the Deposit Draft with reference to development factors.
1.2 THC will call Brian MacKenzie, Planning and Development Service and Jim Yuill, Principal Engineer, Transport, Environmental and Community Services as planning witnesses.
1.3 THC wishes to submit the following productions: - [CD1] The Highland Structure Plan: Approved Plan: THC: March 2001 [CD4] Easter Ross Adopted Local Plan: THC: July 1992 [CD6] Development Plan Policy Guidelines: THC: October 2003 [CD8] Ross & Cromarty East Local Plan: Consultative Draft: THC May 2002 [CD9] Ross & Cromarty East Local Plan: Deposit Draft: THC: October 2003 [CD10] Ross & Cromarty East Local Plan: Statement of Publicity, Consultation and representations: THC October 2003 [CD11] Ross & Cromarty East Local Plan: Proposed Modifications to the Deposit Draft (Prior to Public Local Inquiry): THC February 2005 [CD13] SPP1: The Planning System: Scottish Executive: November 2002 [CD15] SPP3: Planning for Housing: Scottish Executive: February 2003 [CD17] SPP15: Rural Development: Scottish Executive: February 2005 [CD25] Ross & Cromarty Area Planning Committee Item: Representations on the Consultative Draft Local Plan: The Highland Council: 15 September 2003 [CD26] Planning Development Europe & Tourism Committee Item: Representations on the Consultative Draft Local Plan: The Highland Council: 1 October 2003 [CD27] Ross & Cromarty Area Planning Committee Item: Objections and Representations on the Deposit Draft Local Plan: The Highland Council: 25 January 2005 [CD30] Letters of objection and representation to the Deposit Draft Local Plan [CD31] Objections to the Proposed Changes to the Deposit Draft Local Plan [THC 29/1] Map depicting Swordale planning history – A MacDonald [THC 29/2] Statement regarding Swordale road capacity, Jim Yuill, Principal Roads Engineer, TEC Service, THC
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[THC29/3] Scottish Executive: Inquiry Reporters Unit, Decision Letter 31/03/03 Swordale Farm, Evanton, Dingwall (02/00257/FULRC). [THC29/4] An Inventory of Gardens and Designed Landscapes, pp 29-31 extract.
2. Background
National Planning Guidance/Advice
2.1 Scottish Planning Policy 15: Planning for Rural Development [CD17], was published in February 2005 following an earlier consultation draft and supersedes NPPG15. The following paragraphs are relevant: -
18. This states that SPP 3 remains the first point of reference on the general policy for housing; and that “This SPP advances policy in respect of small scale rural housing developments including clusters and groups in close proximity to settlements,………. The overall message is that there is considerable scope for allowing more housing developments of this nature and that this should be expressed in development plans, either as part of general settlement policy or as a separate sub-set on rural housing policy.”
21. This states that the amount and location of housing that can be developed in rural areas is determined by a number of factors, including proximity to services e.g. schools, shops (ideally within walking or cycling distance); ease of access; and drainage or sewerage capacity; and that fit in the landscape will be an important consideration.
2.2 Scottish Planning Policy 1: The Planning System para 41 states that, “Supplementary Guidance can be useful where: ….the level of detail is inappropriate for a development plan….”
42 states that “Supplementary guidance should be used to support statutory development plans, not as an alternative………………The relevance to the decision making process will also depend on the extent of public consultation on the guidance and it being kept up to date”
2.3 The Councils Development Plan Policy Guidance was drafted in May 2002 as supplementary guidance to the Structure Plan and approved in October 2003. In respect of its context to the Local Plan it was part of the consultation of the Consultative and Deposit Draft Ross and Cromarty East Local Plan.
2.4 In light of the production of the new SPP15: Planning for Rural Development a review of the Development Plan Policy Guidance is likely on criteria and opportunities for housing in the countryside. The land management criteria will remain but other justifications may be included.
Highland Structure Plan
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2.5 The Highland Structure Plan [CD1] was approved in March 2001. Paragraph 1.7.1 refers to the emergence from the sustainability objectives and the strategic themes the development of a number of general policies demonstrating the expectations of The Council with regard to any proposal for development. They cover a range of issues relating to sustainable development and are considered vital to the implementation of the Plan's strategic themes. More specifically, Policy G2 Design for sustainability indicates that “Proposed developments will be assessed on the extent to which they: “are compatible with service provision (water and sewerage, drainage, roads, schools, electricity); …………”
2.6 Policy H3 Housing in the countryside states that “housing development will generally be within existing and planned new settlements.”
Development Plan Policy Guidelines
2.7 In October 2003, following previous consultation on a draft published in May 2002, THC published Supplementary Development Plan Policy Guidelines (DPPG) on Housing in the Countryside and Affordable Housing [CD6]. DPPG1 contains a more detailed interpretation of Structure Plan Policy H3 on Housing in the Countryside. This was drafted after discussions with Scottish Executive Planning officials and defines “existing settlements” as: • those identified through the Structure Plan and local plan settlement hierarchies (based on the provision of services); • groups of houses which have one or more of the following facilities: mains drainage or a scheme in SW’s 3-year plan; a public septic tank; street lighting; a 30 mph speed limit; a school, a doctor’s surgery, a shop, a post office, a petrol filling station, a public hall, or a pub; • established groups which comprise cluster, linear, or other recognisable forms of building without such a facility, but which are contained within a clear visual envelope; or • dispersed grouping with a crofting settlement pattern.
2.8 DPPG1 makes clear that such settlements are only to be defined where there are opportunities to make use of spare capacity to accommodate new housing, and where this would be consistent with, or enhance, the cohesiveness and visual appearance of the group. Generally, this will be within the existing boundary of the group, although there may be opportunities for some limited extension where the development will help to enhance the appearance of the group as a whole.
Planning History 2.9 Previous planning decisions in respect of Swordale – A MacDonald(Cairnhill Ltd), are detailed below, use in conjunction with base map depicting application sites, A, B & C[THC29/1]
A - North Steading, Swordale RC/1998/401 - Change of use of East Wing of Steading to House Planning Permission 19.07.98;
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RC/1998/592 -Conversion of Middle Barn to House - Planning Permission - 09.11.98; RC/1998/593 - Conversion of West Wing to Two Houses (Detail) - Planning Permission -09.11.98; RC/1999/623 - Conversion to House (Amended Layout for West Wing and Relaxation of Conditions 2, 4 and 6 (RC/1998/593)) - Planning Permission 5.1.00; 00/00136/FULRC - Conversion of West Wing North to House - Planning Permission 17.4.00; 00/00654/FULRC - Amend Consent for West Wing North to include corner section of Steading - Planning Permission 12.09.00. 01/00287/FULRC - Amend Layout of Approved House to Include a Further House Unit (RC/1998/401) - Withdrawn 26:04;01; 01/00050/FULRC - Sub-Division of House & Extension of Middle Barn to Form Two Houses - approved 01/003 3 6/FULRC - Amend Layout of House & Conversion of Part of Steading to Form Additional House (Two Units) (Amended to One House) 01/00539/FULRC - Conversion of East Wing North of Steading to House (Re- application) – planning permission 17.9.01. 02/00255/ FULRC – Conversion of remainder of north steading to three dwellings PP, 05/08/02
B - South Steading, Swordale 02/00256/FULRC – Conversion of south steading to three dwellings, PP-22/11/02
C - Erection of Farmhouse, Swordale 02/00257/FULRC – Erection of Farmhouse, Swordale Farm – REFUSED APPEAL TO S.E. DISMISSED 31/03/03 04/00344/FULRC – Erection of Farmhouse, Swordale Farm - REFUSED
2.10 Applications in relation to the North and South Steadings relate to successful applications in relation to the conversion of existing farm buildings at Swordale. These applications have resulted in the development of 13 dwellings in compliance with Structure Plan policy H3 and the Development Plan Policy Guidance. The development of the Steadings has meant an increase of properties at Swordale from 13 to 23 houses, of which 3 at South Steading are still under construction, have provided a significant increase in traffic to the Swordale Road.
2.11 The applications in relation to the provision of a farmhouse both brought refusals in relation to non-compliance with the Development Plan Policy Guidelines[CD6] in regard to agricultural justification.
2.12 The appeal dismissed by the Scottish Executive, Inquiry Reporters Unit, Decision letter [THC29/3] relate to the requirement for a house in relation to national guidance and Structure Plan policy H3 in relation to land management requirement and granting of a previous application under agricultural justification relating to Swordale Farm, paras 20 and 21 of the decision letter.
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Adopted Local Plan
2.13 The Easter Ross Local Plan [CD4] was adopted in July 1992. Development of single houses in the countryside was generally acceptable subject to certain conditions being met, para 2.9 Page 4.
Consultative Draft Plan
2.14 The Consultative Draft [CD8] of the Ross and Cromarty East Local Plan was published in May 2002. In advance of this, basic checks were then made to determine whether these settlements were located in areas free of servicing problems or where these could be overcome. Thereafter the planning history was checked and a series of site visits undertaken to determine whether additional housing would be consistent with, or enhance, the cohesiveness and visual appearance of each settlement.
2.15 Consultation with service providers such as SEPA, Scottish Water and The Council’s TEC services (Roads) were made in respect of the capacity of settlements to accept further development. In the case of Swordale advice relating to wastewater treatment was that a proliferation of septic tank drainage posed questions regarding the viability of further provision. In respect of the access road, advice that the current single track road was not capable of accepting further increases in traffic without further improvements to the southern section at Evanton. A previous survey in 1999 had suggested that there was further capacity on the Swordale Road but there has been a significant increase in housing since that appraisal. In addition the potential for development within the visual envelope of the settlement was exhausted, taking into account conversions at the North and South Steadings (para 2.9 above). Further development would require an extension to the group of existing houses and change the scale of development at Swordale. The inadequate infrastructure combined with no further potential infill development opportunities led to the decision to exclude Swordale from the Plan
Deposit Draft Local Plan
2.16 The Deposit Draft [CD9] of the Local Plan was published in October 2003. No changes were made in respect of the exclusion of Swordale from the Plan
2.17 Objections were received from Mr A Macdonald [CD30/140] in respect of various settlement policies and also in regard to the exclusion of Swordale as a settlement from the draft plan. THC’s response and reasoning is set out in [CD27]. Objections were received in respect of various settlement policies and also in regard to the exclusion of Swordale as a settlement from the draft plan.
Deposit Draft with Modifications (Proposed Changes)
2.18 Proposed Changes to the Deposit Draft [CD11] were approved in January 2005.
2.19 The proposed changes in relation to objections and comments are indicated:
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Page 63, Development Factors, paragraph 1 - MODIFY text in final sentence to read " Account should be taken of its location within the essential setting of the Historic Garden and Designed Landscape of Novar House.”
- After the final sentence INSERT "Where development proposals will impact on facilities or require the the upgrade of services or infrastructure the Council shall seek provision of necessary works or contribution towards the provision or upgrading of services and infrastructure."
Page 63, Housing, paragraph 8 - MODIFY policy to read "The Council will favour further infill development at Knock Rash subject to the provision of adequate access and required road improvements."
3. The Council’s Observations
The Objections
3.1 Development Factors Para 1. The land at Novar Crescent is not located within the Historic Garden and Designed Landscape of Novar House. The area is wrongly named Novar (m map p.65). The land is part of Culcairn Farm and Culcairn is its historic & present name. Culcairn Estate is that area of Kiltearn Parish lying to the east of the Allt Graad. It is important that historic names are retained.
3.2 Village Centre Para 2 Garage and “hanger” I would hope that the area purchased and cleared by R.A.C.E. could be developed principally as public open space and incorporate the wooded strip to the east & the area adjacent to the River Skiach. I would also hope that the original timber framed & slate roofed garage building could be retained to give a degree of continuity to any built development.
3.3 Housing Para 8 Knockrash Infill The Council should indicate by means of a draft plan how shared access to Swordale Road could be achieved.
3.4 Amenity Para 16 Protect Open Spaces The plan does not indicate the location of the archaeological site “The Priest’s Sepulchre” – probably and early Christian chapel & burial ground, possible on a pre-Christian site. The site should be protected.
Consideration should be given to improving Swordale Road by constructing a second single track carriage way to the south of the existing so as to save and incorporate the mature oak & beech trees.
The Swordale Road footpath should be extended to the limit of the Evanton
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Settlement Boundary.
3.5 Evanton – Map Why is the caravan site zoned as business? The area has been zoned Leisure & Recreation for many years and its potential as parkland recognised. "Business" leaves the land use too open to undesirable development. The L & R zoning should remain.
3.6 Development Plan Policy Guidelines – Housing in the Countryside I wish to maintain my objection to the exclusion of the Swordale Farm Area from the BP1 zoning and my objection to the unlawful amendment to the approved Structure Plan contained in the Draft Development Plan Policy Guidelines - Housing in the Countryside, and your definition of countryside.
1.Swordale Steading and adjacent dwellings constitute a settlement in its own right of some twenty six houses capable of all service provision, is contained within a clear visual envelope with capacity to accept additional housing, particularly low density, low impact housing as described & recommended in National Planning Policy Guideline NPPG15 Rural Development p.11 as reproduced below.
“29. Low density housing, sometimes referred to as "lowland crofting", is one approach that has been adopted in the commuter area of West Lothian and could be emulated in other appropriate rural areas characterised by low grade agricultural land and degraded land. The policy promotes the restructuring of farms, with at least one third of the total area planted as native or amenity woodland, one third (the better farmland) retained in agricultural use (tenanted) and the remainder providing the land for about a dozen holdings of 1-10 hectares each. Occupants are encouraged to run businesses from them but there are restrictions on the type of businesses e.g. no heavy goods vehicles are allowed. The tree planting, public access and other planning objectives are usually secured by Section 75 agreements. The Central Scotland Countryside Trust, the body responsible for promoting the Central Scotland Forest (CSF), in conjunction with other bodies, has completed a review of the lowland crafting initiative.”
Swordale is eminently suitable for such land use and should be included in the Local Plan. BP1 zoning in that it would meet a genuine local need and comply with national policy. Consequently Swordale should be removed form the list on pages 35/36 of the Written Statement.
2.The approved Structure Plan encourages and sanctions the reuse of traditional buildings in the countryside and the provision of new housing required for land management purposes. Your Draft Policy Guidelines unlawfully alter the Structure Plan to exclude new house provision if ‘inter alia’ other buildings are available for conversion to housing.
As a farmer I can properly expect to benefit from the conversion of redundant farm buildings and equally can properly expect that the needs of the farm in respect of new housing provision required for land management are recognised and honoured
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within the terms of the approved Structure Plan. Your Draft Policy Guidelines deny me the latter right. This is quite wrong.
3) I object to your use of the term "open countryside" to include all countryside. NPPG3 Land for Housing p.14 Housing in The Countryside clearly differentiates between "countryside" and "open countryside". To define all countryside as "open countryside" is contrary to the meaning & intention of NPPG3. The distinction should be maintained.
Limited housing is possible where the aims of NPPG3 pp14,15&16 can be achieved. The blanket ban which you wish to impose is not in the public interest.
NPPG3 Aims are reproduced below. 56. There is a need therefore to improve both the expression and the application of the policy where development plans provide for housing in the countryside. Controls on siting and design area all the more important to ensure that new building is in keeping with the beauty and variety of Scotland’s rural environment and natural heritage. Planning authorities and developers should therefore have regard to the following aims in providing for additional housing in the countryside: - Appropriate siting and design of new housing will often be crucial to integrating development successfully into the countryside; good design cannot always redeem the damage done by inappropriate siting; - New housing should respect the scale and character of traditional housing in the area. - Greater attention should be given to the landscape character, the local land form and the pattern of vegetation and the physical suitability of an area to accommodate development; landscaping of sites should be regarded as secondary but where this is necessary there should be greater use of indigenous trees and shrub species characteristic of the area; - Conspicuous sites should be avoided especially where important public views are affected; and -Consultation with the local community, and their views considered.
NPPG3 recommends a positive approach. Regrettably Highland Council approach is principally negative.
The Council’s Response
3.7 Development Factors Para 1. The site at Novar Crescent forms part of the essential setting of the Garden and Designed Landscape of Novar House and as you state falls outwith the landscape boundary[THC29/4]. Modifications made to text in final sentence of Development Factors to read “Account should be taken of its location within the essential setting of the Garden and Designed Landscape of Novar House.”
The name used for the allocation refers to the area sited behind Novar Crescent which forms part of Novar Estate land.
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3.8 Housing Para 8 Knockrash Infill The further development at Knockrash would be best served by the use for shared access. There is an acknowledgement that there is some capacity for further new accesses to serve new infill development, subject to the provision of adequate visibility and the possible provision of any required road improvements. There is a need therefore to amend the policy as stands. Modifications were made to the policy of the Deposit Draft to read "The Council will favour further infill development at Knock Rash subject to the provision of adequate access and required road improvements." Infill potential at Knockrash is subject to the provision of adequate access and required road improvements, these will require to be carried out within the curtilage of the properties to the north of the road.
The wording in this respect has not been correctly transferred to the Deposit Draft with modifications version of the Plan and the wording, ”no direct access to Swordale Road”, should be deleted from the text.
3.9 Village Centre Para 2 Garage and “hanger” The site owned by RACE is allocated for community use, the final purpose for the site through consultation with the public has not yet been finalised. The adjacent site has been the subject of a planning application and both sites cleared for development.
3.10 Amenity Para 16 Protect Open Spaces Novar Estate have a management agreement with the Forestry Commission for the afforested area in question. This accords with the policy protection afforded by its amenity status
3.11 Evanton – Map The adopted Local Plan contained a policy reference to consider the development of a village park at the site, this was on an area of land to the north east of the caravan park on the opposite side of the river. This area of land is covered by an amenity policy which seeks to protect areas of open space and amenity value. The annotation on the Deposit Draft mapping reflects the current use, which is currently that of a caravan park. Any development proposals for the site would take into consideration the merit held in the sites amenity value.
3.12 Development Plan Policy Guidelines – Housing in the Countryside The Development Planning Policy Guidelines provide supplementary policy guidance and are consistent with advice from Scottish Planning Policy 1: The Planning System (para 2.2 above) which indicates where they may be useful, “where the level of detail is inappropriate for a development plan”. In respect of consultation the guidance has formed part of the consultation process throughout the various stages of the Plan review.
1. Swordale has not been identified as having suitable potential for further development. Settlements have only been defined where there are opportunities to make use of spare capacity both in terms of infrastructure and also where there are opportunities to infill or round of existing development.
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3.13 Information from The Council’s TEC Services (Roads) cements concerns over the current capacity of the road serving Swordale at this time. The road to the settlement is single track with passing places, as such this access is nearing capacity and no further development can safely be attained without further improvement to the Ashill/Knockrash section. The statement in this respect from THC TEC Services [THC 29/2] reinforces the point in relation to the lower section of Swordale Road in the stated extract below:-
“It is the TEC Services view that the critical section of Swordale Road is the 410 metre long section of single track road leading to the Ashill/Knockrash housing development. Here you have a concentrated traffic movement relative to the housing development plus any traffic from further up the road. There are only the two passing places though there is good intervisibility. Complaints have been received about speeding traffic and from observation a contributing factor is traffic moving downhill speeding up to clear traffic stopped in the passing place. There is also the difficulty of accessing the properties fronting the road from the single road which is further accentuated with development behind these same houses.
Concerns have also been expressed as to the increase in traffic using Swordale Road in relation to road safety at the village hall.
There is no opportunity to widen the adopted road over this critical section. There is no within curtilage width available and on the south side there is a row of mature trees which are very much part of the amenity of Evanton. Beyond this critical section the problem is not directly a capacity one and is more a need to improve forward visibility and passing places.
It is the TEC Services view that a requirement for further development on Swordale Road is an alternative route out. This should be considered in relation to the proposed development of east and west Teandallon.”
This statement reaffirms The Councils position that further development at Swordale is constrained, by infrastructure deficiency and no further consideration of development until such time that infrastructure provision at Teandallon provides an alternative to the existing road access.
3.14 The reference to lowland crofting is inappropriate in the context of Swordale, SPP3: Planning for Housing now contains the reference in para 52. The lowland crofting policy initiative refers to the rehabilitation and renewal of environmental damage from past industries, not the case with Swordale.
3.15 2. The national policy framework for housing development, including housing in the countryside, is set out in Scottish Planning Policy (SPP) 3, Planning for Housing and National Planning Policy Guideline (NPPG) 15, Rural Development. The Council’s policy on housing development is set out in section 2.2 of the Highland Structure Plan, approved by the Scottish Ministers in March 2001. Housing in the open countryside is covered in Policy H3 and the supplementary Development Plan
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Policy Guideline (DPPG) 1 to the Draft Local Plan.
3.16 National policy on development in the countryside continues to be founded on the following propositions: - (i) Existing settlements are more likely to be able to accommodate additional development with least servicing costs and minimum impact on agriculture and amenity generally. Development should therefore be encouraged on suitable sites in existing settlements. (ii) Urban sprawl and, in particular, the coalescence of settlements, and ribbon development should be avoided. (iii) Isolated development should be discouraged in the open countryside, except where: - (a) circumstances are clearly identified in development plans, including where a dispersed pattern of housing might be appropriate in more remote areas; or (b) there are special needs, e.g. the nature of employment requires residence in a particular location.
In many rural areas close to large towns and city regions experiencing pressure for various forms of development, planning policy is concerned with managing these pressures.
3.17 Apart from the obvious infrastructure problems, the idea that supportive policies be formulated for those seeking top of the range housing and plots to assist entrepreneurs and investors to live in the countryside of commuter areas around the main towns and cities and start new businesses hardly squares with social justice. This suggests one policy for the better off and another for the rest. A policy that allows housing to provide early funding to support a yet untested business is open to abuse. There are many examples of spurious ill-considered business propositions put to Councils as a means of justifying houses. There is no major concern if this is an operational requirement of an established business, which should be the main driver. Setting aside the related housing considerations, the Council currently supports the establishment of rural businesses and following the publication of the new SPP on Rural Development, this Council is to revise DPPG1 to allow for houses required in connection with other rural businesses that have been established for at least 2 years. At present this provision only extends to agricultural activities. The consensus amongst planning authorities is that where housing is not acceptable on its own merits, it should not be allowed purely to fund a business venture.
3.18 As stated above, housing in the countryside does not serve a purpose in pressurised areas where demand is driven by a city housing market, depopulation is not a problem and jobs tend to be within easy commuting distance. In more remote locations (outwith the hinterland area) it can aid repopulation and create jobs. It is more likely that employment in established communities like Evanton, Alness and Invergordon, combined with improved public transport provision, will reduce the need to commute to larger settlements. While employment land allocations and other opportunities already exist in these communities, there has been little or no take up.
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3.19 In many respects the Rural Development policy guidance brings national policy into line with the Council’s current Structure Plan policy. More specifically in relation to: (a) the considerable scope for small scale rural housing developments as additions to existing ‘clusters' and groups; (b) replacement housing; (c) conversions of traditional buildings; and (d) affordable housing, where efforts to provide the latter in existing settlements have been exhausted.
3.20 Also, within the spirit of existing national and Highland wide policies, the establishment of new small clusters or groups of dwellings on the site of non traditional buildings, derelict or otherwise, is another aspect that the Council is prepared to make an exception for without a land management or other rural business justification.
3.21 3) The reference within NPPG 3 refers to where development plans may provide for housing in the countryside where they might safeguard or contribute to economic activity. This accords with the Councils policy regarding Housing in the Countryside. NPPG3 further states that "isolated development should be discouraged in the open countryside unless particular circumstances are clearly identified in development plans or there are special needs". The Councils use of the term "open countryside" concurs with that of NPPG 3, existing settlements and groups that have development potential are identified within the Plan, those assessed as having no development potential have been omitted from the Plan.
3.22 SPP3: Planning for housing para 56 states that "some limited new housing along with converted or rehabilitated buildings may be acceptable where it result in a cohesive grouping well related to its landscape setting", at Swordale there has been conversion of existing buildings and potential for development within the clear visual envelope and potential for further development is now exhausted. Any further development would not be adding to the cohesiveness of the existing built extent and would appear outwith the existing visual envelope. It is also now recognised there is no further potential for new housing in this location until such time that further improvements can be made in respect of the road access from Evanton.
4. Conclusion
4.1 Levels of previous development at Swordale have utilised the development potential within the housing group at Swordale. Further development would be outwith the clear visual envelope and fall under the requirements of Structure Plan policy H3 Housing in the Countryside.
4.2 Concerns regarding the capacity of the road, in particular in relation to stretch at Knockrash, Evanton, to Swordale have added to the decision not to include Swordale as having further development potential.
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4.3 The inclusion of Swordale as a settlement within the Plan and subsequent development would increase the levels of traffic to the detriment of Evanton.
4.4 Applications for new housing are subject to the requirements of Structure Plan policy H3 in relation to criteria for development within the hinterland around towns. This policy basis was key in respect of refusals of a farmhouse at Swordale.
4.5 The status of the Development Plan Policy Guideline has been reinforced through consultation as part of the Ross & Cromarty East Local Plan review.
4.5 Accordingly, The Council would ask that the Reporter recommends no change to the content of the Deposit Draft with Modifications, in respect of these matters, excepting the amendments highlighted in paragraph 3.8 above).
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