THE SITE

The site in question is located on the outskirts of Invergordon, a small Highland town in Ross-shire. Invergordon is poised for significant industrial growth, having been awarded ‘Green Freeport’ status. This designation is intended to drive regeneration, foster innovation, and promote inclusive growth, all while maintaining the highest environmental standards. Developing this site, however, contradicts these very principles.

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Misuse of Freeport status in planning decision

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Planning officers have justified the development by citing the Freeport status as a reason for non-compliance with the local and national policy. They argue that the new Inner Moray Firth Local Development Plan 2 (IMFLDP2) did not account for the Freeport and its impact on housing. This, however, is not true.

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An Examination Report of IMFLDP2, published in January 2024, explicitly addressed housing and the Freeport before the plan’s formal adoption, including a detailed analysis of housing needs in relation to the Freeport. The report for the meeting at which IMFLDP2 was eventually ratified also made explicit reference to IMFLDP2’s “comprehensive analysis & discussion” of future housing requirements in relation to the Freeport. The proposal went back to the Planning Committee in January (only be deferred to March) yet no new evidence was presented to justify the reliance on the Freeport status for determining the application.

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Conflict of interest and purchase of alternative site

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In June 2024, the Highland Council purchased the site, creating a significant conflict of interest when the final decision on the development was yet to be made. In arguing for this development, the January Committee Report also stated that other potential sites "may take years" to be developed, but neglected to acknowledge the Council's recent purchase of a neighbouring allocated site, with plans for 250 houses and potential for 400.

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Housing Emergency Delivery Plan

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The most recent January Committee Report highlighted the national housing emergency but overlooked key documents. Notably, it failed to reference the Council's own Delivery Programme for IMFLDP2, which stressed the importance of accelerating the development of allocated sites rather than building on unallocated land. It also ignored the November 2024 Planning & Housing Emergency Delivery Plan, which underscores the importance of adhering to the plan-led system. The plan advocates against releasing land not supported by existing plans, especially greenfield sites.

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There is no doubt that the local area urgently needs housing. The core issue, however, is where this housing should be built. The site in question is a greenfield site, and national planning policy clearly states that greenfield land should only be developed as a last resort, where no alternatives exist. Multiple alternative sites exist in Invergordon that are closer to the town, already allocated in the local development plan, and many of which involve regenerating brownfield sites. These alternatives would avoid the needlessly destroying greenspaces and the value they hold.

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