Two weeks ago the Cairngorms National Park Authority added responses from their ecology adviser (see here) and landscape adviser (see here) to the retrospective planning application from Natural Retreats for the hill track at Cairngorm (see here). While welcoming the transparency of the CNPA in making these public at an early stage (which has given the public a chance to comment) I believe the content of these assessments are not worthy of a National Park.
The Landscape Adviser has no comments to make about most of the unlawful works undertaken by Natural Retreats, such as the reprofiling of banks or the dumping of boulders or the poor quality of the finishing.
The Landscape Adviser’s main comment concerns the track itself:
Within the ski area, on land previously integrated in the infrastructure of skiing, this track is acceptable as part of the landscape. The track in question consists of a short stretch, level with surrounding ground and vegetated with initial grass growth which will provide organic matter and
prevent erosion of the track. Addition of drainage channels will further prevent erosion.
This is factually wrong and the thinking dangerous. The track is not a short stretch, its several hundred metres long. The angle of the top half of the track is 12 degrees, compared to the maximum angle of 8 degrees recommended by Scottish Natural Heritage to prevent erosion (see Alan Mackay’s excellent critique of the retrospective planning application in which he went out and measured the angle of the track! Its essential reading for anyone concerned about this and should be read by all Board Members on the Park’s Planning Committee). The Landscape report contains no consideration of the implications of installing “access tracks” alongside all the ski tows in Scotland – the cumulative impact would be considerable. The tracks are also completely unnecessary. CNPA staff seem totally unaware of the publication “Environmental design and management of ski areas in Scotland: a practical handbook” which showed tracks were unnecessary back in 1987. Nothing has changed except our Public Authorities are no longer prepared, it seems, to enforce basic environmental standards.
The Ecology assessment is also wrong on several points. In commenting on the re-profiled bank below the tow the assessment claims:
Re-grading has taken place at the bottom end of the track which has reduced the steepness of the slope, reducing erosion in this area. This slope is revegetating well.
This is wrong, there was no erosion previously as this photo from Alan Mackay’s response shows:
The ecology assessment further states:
The restoration works associated with the ski tow construction appear to be going well, won heather turves have been replaced on disturbed ground and bare areas seeded
No mention here that Natural Retreats was supposed to store all vegetation on terram matting and then replace it so there should have been no need to “win” vegetation from anywhere else. The need for re-seeding should have been minimal but in fact has been required over large areas. The Ecological Assessment makes no mention or comment on this.
Its hard to see how converting a slope from heather to grass can have no ecological impact and the ecological assessment furthermore fails to refer to the extent of the unlawful works.
The assessment also wrongly claims “There is evidence of erosion on the new path which occurred during the late December 2015 storms.” The track – its not a path, another piece of misinformation – has eroded several times already. So, who told the ecology adviser this only happened once back in December? The hill track is too steep but the ecology adviser, like the landscape adviser, appears unaware of the SNH guidance on hill track construction.
The truth is that the CNPA’s ecological assessment of the hill track and associated works is nothing of the sort. A proper ecological assessment would have looked at the extent of the damage, the impact of the failure to restore vegetation (yes it will recover eventually but how long will this now take?), the impact of the hydrology of the area, including more rapid water run-off, and the impact on wildlife. The assessment does not even refer to the impact the works may have had on the water vole in the area, let alone other wildlife (see the response of the Badenoch and Strathspey Conservation Group for the potential impact of works on wildlife).
The one positive suggestion in the assessment is that “there is a good opportunity to plant Dwarf Willow, Birch and Scots Pine on the re-graded bank” but why only here? As I have argued previously, one way to compensate for the extensive destruction would be for the CNPA to require Natural Retreats to employ a properly qualified contractor to plant montane scrub across the area.
I suspect responsibility for the sub-standard quality of these assessments does not lie with the staff concerned but somewhere above them in the management chain. To put it bluntly, the staff concerned have been told to tick a box. The CNPA was first made aware of the unlawful works at Cairngorm on 4th September 2015 (I have seen the emails) and did nothing to intervene and stop Natural Retreats destroying vegetation and soils outwith the area granted planning permission. They subsequently failed to do anything substantive for over 10 months but, after being forced to admit a retrospective planning application was required, it appears that staff are doing everything they can to ensure this is approved. This behaviour is not worthy of a National Park. It provides further evidence that there must be other things going on which explain why the CNPA is allowing Natural Retreats to do what it likes at Cairngorm.
What needs to happen to ascertain the extent of the damage and its impact on Cairngorm
The argument that the CNPA should require Natural Retreats to pay for an independent ecological and landscape assessment is even stronger now that the National Park has shown it is incapable of doing this properly. Such an assessment should detail ALL the damage that has been caused at Cairngorm – not just the areas granted planning permission – and the options for restoration of the ground and vegetation.
Any proper assessment should be informed by the guidance contained in the following documents:
- The past vegetation surveys that have taken place at Cairngorm (I asked Highlands and Islands Enterprise for copies of these under FOI but they have told me all surveys since the construction of the funicular are held by Cairngorm Mountain! Why didn’t the CNPA landscape adviser ask for a copy?)
- SNH’s Guidance on the construction of hill tracks
- “Environmental design and management of ski areas in Scotland: a practical handbook”
The CNPA Planning department have lost all credibility in relation to Cairn Gorm Mountain. It is my view that the wider public have a right to know just exactly how they handled the original application for the construction of the Sheiling Rope Tow. It would be of interest to read the original Ecology Report as well as the Environmental Impact Assessment…….and these will be asked for by an FOI request. It would also be of interest to know if reference was made to the SEPA document ”Guidance in the Assessment of Peat Volumes, re-use of excavated peat and minimisation of waste. The retrospective planning application makes reference to the fact that peat to a depth of 0.8m lies within the site…..so we’d expect that would have been taken into account. It is also clear that the illegally constructed track is much steeper than the maximum gradient suggested by SNH…….why? Why was that allowed? The evidence uncovered up to now is very damning……..the alarm was raised on a number of occasions but the CNPA Planning dept did nothing to halt the destruction…..a quite shameful dereliction of their duty.
Well that’s a discentive to visiting, the primary reason to visit the Cairngorms is to enjoy the wild environment not view an out of character, scar on the landscape and damaged environment,what’s the point of visiting if the beauty of nature is put aside and trashed.