(Editor’s note. The planning application for the mountain coaster (see here) , misdescribed by Cairngorm Mountain Scotland Ltd as a toboggan run, is due to be considered by the Cairngorms National Park Authority (CNPA), this Friday.  It has taken CNPA planning officers six months to get the planning application to a state where they can recommend approval of a development more suitable for a theme park.  I am pleased here to publish this objection from Gordon Bulloch which critiques the planning process and the further planning paperwork supplies by CMSL)

Supplementary Objection to Planning Application 2026/0135/DET

Proposed mountain toboggan track and associated structures, buildings, platforms, landscaping and infrastructure works

This is a supplementary objection to my earlier one dated 25 May 2025 on the planning portal.  This supplementary objection takes account of the 46 documents posted after the end of the formal public consultation period.

It is appreciated that significant additional information and updated information has been submitted to support this application.  It is regrettable that this information was not made available for the formal public consultation process.

Despite the publishing of these new documents, most of my criticisms and objections still remain.  The main objections I have to this application are summarised as follows:

1. Potential operational conflict between the toboggan facility and the Day Lodge Poma
   A refurbished snow fence between the Day Lodge Poma line and the toboggan uplift track is now being proposed.  However, the boundaries of the existing Day Lodge Poma run are not clearly shown on any drawing.  In fact, it would appear that the proposed ATV track would overlay the Poma run on parts of the Poma run.  This produces a safety conflict unless the toboggan is not in operation whilst the Poma is in operation.  Additionally, if the Poma and ATV track overlay each other even in part, this will compromise the use of the Poma, unless the ATV track is kept snow covered when the Poma is in use. (Fairhurst Dwg 400858-PC-1000 dated 04-02-2026 refers).  I cannot find any clear justification within the supporting documents as to why the ATV track is needed.

• ATV track design
  The design of this track is not clear.  The potential conflict between the line of the ATV track and the Day Lodge Poma is covered in point 1 above.  The simplistic plan of the ATV track shows a track which is almost straight (only a few very minor kicks).  The average gradient is about 1:5.  This design breaches:
  – The NatureScot guidelines for the design of such tracks as there will be a severe erosion risk on such a track with this average gradient.  It is disappointing that the NatureScot response as a Statutory Consultant does not mention this design problem.
  – The HIE guidance document “Working with the Environment at Cairngorm”, states, “Construction of proposed new tracks must be guided by SNH’s Constructed Tracks in the Scottish Uplands (LUC, 2005; second revised edition, SNH, 2013), which contains much information on issues and techniques”.  It is clear that this proposed ATV does not meet this guidance, despite the use of the word “must”.  So, CMSL as the applicant, is in breach of its owner’s guidance.

• ATV track visualisations
  The revised visualisations produced by Brindley Associates do not present the full visual impact of the ATV track.  In fact, the visualisations mainly just partially show the line of the track and not its visual impact.  I appreciate that there are numerous other tracks in Coire Cas, but that should not justify adding to this by adding another scar up a hillside that has been until now relatively untouched.  CNPA Planning should recall that application 2018/0177/DET for installation of a dry ski slope was overwhelmingly rejected because of the negative visual impact of the proposal.  This ATV track is on the same hillside as the rejected dry ski slope, but as the track is higher up the hillside it has potentially even wider visual impact than the dry ski slope.  I note that the CNPA Landscape Officer has been persuaded to reduce her concerns over the visual impact and other landscape matters concerning this application.  It is regrettable that the same opportunity has not been allowed for the several public objections to this application.  For such controversial planning applications, CNPA should insist on the applicant undertaking a public consultation.  Will CNPA take this as a learning point?

• Mitigation Tree Planting
  The additional documents did at least provide descriptions of the proposed tree planting plan around the proposed toboggan run.  However, the documents do not make clear that montane tree regeneration is already occurring (photos taken in September 2026 can be provided as evidence of this natural regeneration).  The new photomontages attempt to provide a visualisation of the effect of the additional tree planting after 10 years.  However, no account is given for the significant effect of natural regeneration on the surrounding landscape after 10 years.  The need for this additional tree planting (using public money) has not been justified as it would seem the significant effect of natural regeneration has been ignored.

• Viability of the project
  I raised this issue in my original objection, but nothing in the additional supporting documents changes any of the flimsy data presented on the viability of the toboggan run in the Planning & Design Statement.  Given the many inflated financial statements made by HIE and/or CMSL included in many previous planning applications over the years, the flimsy economic impact data in this application needs to be questioned.

• Discrepancies and lack of clarity
  Despite pointing out errors and discrepancies in my original objection, most of these remain, plus a few more.  These include:
  – The Planning & Design Statement should have been updated to include references to the additional supporting documents.  The statement in response to public representations produced by Ryden is inadequate in achieving this.
  – New photomontages and visualisations were added, but reference is only made to them in the Rebuttal Letter produced by Brindley Associates.  The original Landscape and Visual Appraisal Report should have been updated to include these updates and effectively describe them.
  – The additional documents of Habitat Management Plan and National Vegetation Classification Survey produced by Envirocentre should have been better integrated and cross referenced rather than being self-standing documents.
  – The revised CEMP still retains the discrepancies I highlighted in my original objection.  Additionally, the revised CEMP states that it is not aware of any GWDTEs on the site, despite the National Vegetation Classification Survey identifying several of these on the site.
  – Altogether a rather shoddy collection of supporting documents which demonstrate a lack of checking and integration.

These reasons for objection make clear that this application should be rejected by the CNPA Planing Committee.