The Planning Application to “smooth and regrade land”  to create a new beginner’s ski area at Cairn Gorm will be considered by the Cairngorms National Park Authority Planning Committee tomorrow.  Officers have recommended the application should be approved.   While the revised application does go some way to address issues that have been raised on parkswatch over the last six months  (see here), (here), (here), (here) and (here), fundamental issues remain.  This post explains why the CNPA should reject the application.

Absence of a Masterplan

On 29th March the CNPA Board approved a set of principles for CairnGorm Mountain one of which stated:

“Any proposals for the ski area should be part of a masterplan for the ski area as per the proposed Local Development Plan”

Highlands and Islands Enterprise agreed that a proper plan should be developed for Cairn Gorm  back in October 2016 when they signed up to the Cairn Gorm and Glenmore Strategy, i.e three years ago.  Despite repeated attempts by the CNPA to get HIE and their then tenants Natural Retreats to  progress this, nothing happened.  Meantime individual planning applications kept rolling in.  The Principles document was an attempt to stop this.  It has not worked.  Since then HIE/Cairngorm Mountain Scotland Ltd pursued planning applications for a tube slide  (see here) and for an expansion of the Ptarmigan(see here) both of which were approved.   Then the current application.

Not only this, but there are, as the Committee Report reveals, more planning applications are in the pipeline.  Meantime, 3 years 3 months later work on a masterplan is only about to begin (Parkswatch understands consultants have been appointed).

The Committee Report, however, states that it would be unreasonable to refuse this application in the absence of a masterplan.  I believe that is wrong and the current application demonstrates this, without any need to consider what might be sensible for Cairn Gorm as a whole.

HIE – or is it Jim Cornfoot? – is asking to create a new beginner’s ski area WITHOUT ANY PLAN for lifts.  So, having smoothed and regraded the land as part of these engineering works will some of it be dug up again to install a new lift?   Just three years ago the sunkid rope tow was installed at the Shieling, with much consequent destruction (see here), with the intention of creating a new beginner’s slope. How are  the two slopes supposed to fit or will the sunkid tow now be removed?  In the absence of a masterplan we simply don’t know.

The snow making machines could not be worse located, below the slope rather than above it.  Does the recent agreement from Highland Council, referred to in the report, to extend the temporary planning consent for these snow making machines in the Coire Cas carpark for another yearmean that HIE/CMSL plans to relocate the snow machines to somewhere where they might work better?  If so, that – which will require significant ground works – and the positioning of any uplift should have ALL been considered in the one planning application.

In the absence of any coherent plan for this slope, let alone a masterplan which would describe how all this infrastructure might work for Cairn Gorm as a whole, it seems wrong to me that the CNPA Planning Committee are being asked to approve anything.

 

Setting unwelcome precedents for the future

If they approve this planning application, the CNPA will effectively be saying to HIE that its principles document is worthless and that its acceptable for another public authority to break their promises.  This creates a strong precedent for HIE to submit further new applications in future without any masterplan..

It also set the precedent that planning creep is acceptable.  The risks of this should be obvious.  For example, in the SE Group vision for Cairn Gorm there were outline proposals to smooth and regrade large areas of Coire Cas to create new ski runs.   The issues which Parkswatch raised about increased flood risks if the beginner’s area went ahead (see here) have, I am pleased to report, been  accepted by Highland Council in its role Flood Risk Management Authority.  They have, however, decided those risks can be mitigated:

Mitigation might be acceptable for this small area but what if HIE starts to submit a series of planning applications which incrementally extend the areas of smoothed land?   Where is CNPA going to draw the line?   Individual planning applications , whether they have implications for flood risk, species or the landscape make this much harder because each time the applicant can say “but last time you agreed to X and Y and we are only proposing a small increase”.  A masterplan would enable lines to be drawn and stop unwelcome precedents being set.

Skiing and climate change

Last week, based on recent research by the CNPA (see here) I argued that any new ski infrastructure for Cairn Gorm should be based on a proper analysis of snow lie.

While I appreciate that since the photos shown here were taken it has started to snow at Cairn Gorm, what the CNPA’s research indicated was that snow would become increasingly rare both in October and November and between 600 and 800m in altitude.  That in my view raises considerable questions about the sustainability of snow making here, both in terms of whether it will create any worthwhile new ski area and in terms of energy consumption.  As a consequence of the Scottish Government’s declaration of a climate emergency, all planning applications and any future masterplan for Cairn Gorm should be evaluated in terms of how sensible they are in terms of the predicted rise in global temperatures and the need to reduce carbon emissions.

There is a strong case for new snowsports infrastructure at Cairn Gorm but it needs to be climate resilient.

 

Unfortunately a number of local interests have rushed to support the application without any consideration of these issues and whether its sensible or not:

“I refer to the above application and must inform you that Aviemore and Vicinity Community Council fully support the proposal. Skiing plays a very important role in the economic development of Badenoch and Strathspey district. The survival of communities in the area depends upon the continuing activity of skiing as a tourist attraction, which can bring a great deal of money and employment”.

Will this area, as a snow school director claims:

“allow a greater number of Instructors work and employment. In busy periods, we could have 40 Instructors working.”?

40 instructors, really!  Instead of grasping at the straws in the wind offered by HIE, its time that snowsports interests on Speyside got together with other interests and started to plan properly for how snowsports might continue with climate change, building on some of the ideas developed by the Save the Ciste Group.

Within this context, the CNPA Planning Committee should not be swayed by all the trumpeting locally about the opening of the ski patch last Saturday and instead insist that all planning applications at Cairn Gorm are based on sound climate science.

Issues with the planning documentation and proposed planning conditions

While the revised application is an improvement on the original issues remain which have not been addressed in the planning documents or the conditions recommended in the Committee Report:

Restoration of vegetation

The Method statement then goes on to say that:

“Across the works area the undulating nature of the landforms will allow a surplus of good surf for re-instatement”

Sounds good?   But why then is there any need for the Construction Method Statement to deal with re-seeding?

The two are contradictory, either HIE plan to replace the vegetation or not.   As soon as you look at the Construction Method Statement in detail parts of it start to unravel.

Use of machinery

The applicant proposes to use an 8 tonne, 6 tonne and 3 tonne excavator in the construction works.

Whether, the small excavator referred to is the 3 or 6 tonne vehicle is not clear but size make a huge difference when working on peat.  Indeed, if its true that “the majority of site works involves peat” – as stated above – why are 6 or 8 tonne excavators even being considered?

When will the works take place?

Planning Condition 5 recommended by CNPA officers says that the development should be carried out in strict accordance with section 4.2 of the Ecological Report.  This includes the recommendation that the works should be carried out outside of the bird breeding season from March to August but if not there needs to be a bird breeding survey and if any bird nests are found vegetation cannot be removed.  A pretty strong requirement that could scupper any work during this period.

This conflicts with HIE’s own working with the environment at Cairn Gorm document which has been lodged with the CNPA which states that vegetation removal and restoration should take place in the summer and with the declaration by Susan Smith, head of CMSL, that the work needed to take place BEFORE the end of August (see here).  This makes  sense as it allows a much better chance of the vegetation recovering properly.

The CNPA have failed to address the issues and the consent, as worded, could well allow HIE to undertake the work in the colder and wetter half of the year when site restoration becomes far more problematic.  The CNPA Planning Committee, if minded to approve the application, need to specify the period when work will be allowed to take place.

HIE’s record at Cairn Gorm and the need for independent oversight

Parkswatch started to take a detailed look at HIE’s mismanagement of Cairn Gorm as a result of the construction of the Shieling Rope tow, where planning conditions were widely ignored (see here for example).  This led to significant damage  Many of the staff who may have had a role in allowing this to happen are still employed at HIE at Cairngorm Mountain Scotland Ltd.  Neither organisation has shown it can be trusted since then.  Its extraordinary therefore that the recommended planning conditions don’t include basic planning requirements which might prevent this happening again such as:

•  that the site boundaries and work areas should ALL be marked out BEFORE work commences and checked by the planning officer (this was meant to happen at the Shieling rope tow), and
• the applicant should pay for an independent ecological clerk of works who will monitor the site on a daily basis during works until satisfied that the contractors understand and carrying out the works strictly according to planning requirements.

The ground works planning application and the future of Cairn Gorm

This application provides yet more evidence, as if more evidence was required, that HIE is simply not capable of producing a coherent plan for Cairn Gorm.

There is every reason for the CNPA Planning Committee to reject this application and insist  a new masterplan is provided first, based on proper analysis of snow lie, appropriateness of infrastructure etc.  However, the fundamental issue here, which is causing all the problems is not a planning one but rather about how HIE works.

Their appointment of consultants to develop a new masterplan illustrates the issue.  HIE is wedded to top down approaches where consultants are forced to follow HIE’s brief and then come up with a solution which fits HIE’s preconceived ideas.  This then gets “consulted” on with a number of interests agreeing with whatever is proposed on the basis that if they don’t do so they will get nothing. This I believe explains the “support” for the beginner’s ski area and  is a recipe for failure.

Instead what is needed at Cairn Gorm is a bottom up approach involving all interests, where ideas and proposals are based on sound science and developed far more co-operatively.   Yes there may then need to be negotiation and hard decisions but unless such an approach is taken the very real problems at CairnGorm mountain are unlikely to ever be addressed.

I suspect the CNPA Board would be supportive of such an approach but to make that happen I believe they will have to stand up to HIE at some point.