Consider Notice of Review Request: Land South of Fernbank, Rahane (Ref: 25/0006/Lrb)

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25/0006/LRB Re: Roads’ AB7 Response

26th September 2025
This document comments on the response from Argyll and Bute Roads Department to the request for further
information regarding Local Review Board case 25/0006/LRB and planning application 24/01389/PP.

The information presented by Argyll & Bute Roads is used to imply that strict application of standards is the cause of a
reduction in roads-related casualties. Presumably this is to justify the refusal to consider any departures from standard.
However, no data is presented on adherence to standards over the period 2014 to 2023, and correlation is not proof of
causation. Indeed, there have been a number of departures from standard that would have been included in the
underlying dataset, contradicting the claim that the reduction in casualties could not have happened by allowing any
such departures from standard.

Additionally, the statistics cover the whole of Scotland and do not consider the merits of this particular case. The
specific visual obstruction in question has had no real-world effect on safety over the last 25 years. In terms of risk
assessment, actual data refutes the theoretical risk implied by failing to meet the standard on paper.

As such, and considering the overall visibility/safety improvements that would accrue, a minor departure from standard
is proposed with the following conditions:

	
Visibility splay to the south of the proposed new access measuring 75 x 2 x 1.05 metres

	
Visibility splay to the north of the proposed new access measuring 40 x 2 x 1.05 metres

If further mitigation is considered necessary, the applicants are amenable to funding signage or road markings that
would enhance road-user awareness.

The roads design guidance allows for departures from standards specifically because the limitations of standards when
applied to the real world are understood. Thus, the proposed access would be non-standard, it would not be sub-
standard.

Additionally, visibility would be improved for the accesses to:

	
Ach-Na-Cloich Cottage - from 0 m to at least 60 m (north)

	
The electricity sub-station - from 0 m to at least 60 m (north)

	
Mambeg Farm - from 0 m to 75 m (south) and 0 m to at least 55 m (north)

	
Ach-Na-Cloich - achieving the original 75 m condition (north)

	
Ach-Na-Cloich Lodge - achieving the original 75 m condition (north)

	
Fernbank

	
Rosnevyth

This would achieve a higher standard for all of these accesses and make the road significantly safer than it currently is.
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