Proposals to build 16 homes at Viewhill Farm, around 400 yards north east of the key battlefield site near Inverness, are currently being considered by planners.
Kirsty Cameron, archaeologist at Highland Council, has advised colleagues that the land could still hold “buried information” about the last pitched battle fought on British soil, on April 16 1746, and its aftermath.
In a written response to planners, Ms Cameron said: “This area is sensitive due to its location partly within the inventoried Battlefield of Culloden and although it has been previously developed, it still has the potential to contained buried information relating to the battle and its aftermath.”
While basic archaeological survey work has already been carried out at the site, Ms Cameron said “there remains the potential for buried features or finds to survive and be impacted by the development.”
She added: “While this risk is not such as to warrant a full excavation , it is important that the nature and extent of any features is identified and recorded before destruction.”
The comments come as Historic Environment Scotland confirm it won’t be making any fresh representations on the planning application.
Developers are seeking approval from Highland Council that conditions attached to earlier planning consent for the site, including housing design and road layout, have been met.
Approval was given by the Scottish Government reporter in January 2014 for the new homes at Culloden after the local authority initially rejected the bid.
The houses were never built but a new developer has since revived the proposals.
Historic Scotland, the predecessor to Historic Environment Scotland, did not object to the original housing proposals.
It did not believe the development, much of it inside the northern edge of the designated battlefield, would have an adverse impact on the integrity or significance of the battlefield.
Today, it said that the current application to discharge planning conditions did not relate to them.
A spokesperson for Historic Environment Scotland said: “We are not aware of any new planning application in relation to the site at Viewhill.
“We have recently been consulted on the discharge of planning conditions attached to planning consent Ref 11/04653/FUL.
“As neither Historic Environment Scotland, nor its predecessor body Historic Scotland were referenced in any of the outstanding conditions, we had no comment to make.”
Michael Nevin, chairman of the 1745 Association, urged Historic Environment Scotland to think again.
He said that since the original application was lodged, the area around Viewhill Farm has been included in the expanded Culloden Muir Conservation Area.
The map was expanded to include the “significant” site given that British lines are likely to have encroached into the area.
Mr Nevin said mapping of the battlefield site carried out since 2013 suggested that the Irish Brigade, a brigade of the French army made up of Irish exiles, were located to the south east of Viewhill Farm on the day of Culloden.
Brigadier Walter Stapleton was killed during the battle, but it is claimed the Irish Brigade stood ground and allowed many members of Clan Donald to escape the onslaught.
Mr Nevin said clan members may have headed to Inverness through land at Viewhill Farm.
He added: “We would like HES to revisit their 2012 assessment of the historic importance of the Viewhill Farm site in the light of new information that has come to light since then.”