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Item 5 Appendix 4b Reps Objections 20260135DET CairngormMountain RED

Cairngorms Nation­al Park Authority

Ùgh­dar­ras Pàirc Nàiseanta a’ Mhon­aidh Ruaidh

Item 5 Appendix 4b 13 Novem­ber 2026 Page 1 of 15

Agenda item 5

Appendix 4b

2026/0135/DET

Rep­res­ent­a­tions — objections

Com­ments for Plan­ning Applic­a­tion 2026/0135/DET

Applic­a­tion Sum­mary Applic­a­tion Num­ber: 2026/0135/DET Address: Land 284M East Of Cairngorm Moun­tain Glen­more Aviemore Pro­pos­al: Pro­posed moun­tain tobog­gan track and asso­ci­ated struc­tures, build­ings, plat­forms, land­scap­ing and infra­struc­ture works Case Officer: Heath­er Boswell

Cus­tom­er Details Name: Mr Nick Kempe Address:

Com­ment Details Com­menter Type: Mem­ber of Pub­lic Stance: Cus­tom­er objects to the Plan­ning Applic­a­tion Com­ment Reas­ons: Comment:I wish to object to this applic­a­tion on the fol­low­ing grounds: 1) The primary jus­ti­fic­a­tion for per­mit­ting any devel­op­ment at Cairn Gorm, one of the finest and most access­ible moun­tains in the Nation­al Park, is its snow cov­er and that it provides an oppor­tun­ity for snowsports that is not avail­able else­where. Oth­er vis­it­or attrac­tions, such as this coast­er, are not appro­pri­ate and should be built else­where. 2) There is no Fin­an­cial Busi­ness case for the devel­op­ment and no evid­ence that it meets the Park’s stat­utory aim to deliv­er sus­tain­able devel­op­ment. 3) The pro­posed per­man­ent access track along­side the coast­er uplift is a) con­trary to Policy 4a in the Nation­al Park Part­ner­ship Plan which states there should be a pre­sump­tion against new roads on moor­land b) con­trary to the NatureScots Guid­ance on Con­struc­ted Tracks in the Uplands that says the gradi­ents of tracks should not be more that 14% — the pro­posed route appears to be 20% and will be highly prone to erosion c) can­not serve its claimed pur­pose for main­ten­ance and emer­gency pur­poses because it is cut off from the down­hill coast­er track by the uphill track 4) The visu­al­isa­tion points in the LVA do not provide an adequate assess­ments of its visu­al impact, omit­ting close up views of the bridges and fail­ing to con­sider its vis­ib­il­ity in sunny con­di­tions when the rail could gleam and glint. If the CNPA is nev­er­the­less minded to approve the pro­pos­al on land­scape grounds it should: a) require the met­al rail to have a matt fin­ish so it reflects as little light as pos­sible b) require the applic­ant to pro­duce a detailed wood­land plan, includ­ing plant­ing, designed to screen the track which it is then leg­ally bound to deliv­er c) con­sider altern­at­ive solu­tions to the pro­posed coast­er cross­ing the foot­path by two bridges — these met­al bridges will be more prom­in­ent than the rest of the track and very dif­fi­cult to screen with trees.

Com­ments for Plan­ning Applic­a­tion 2026/0135/DET

Applic­a­tion Sum­mary Applic­a­tion Num­ber: 2026/0135/DET Address: Land 284M East Of Cairngorm Moun­tain Glen­more Aviemore Pro­pos­al: Pro­posed moun­tain tobog­gan track and asso­ci­ated struc­tures, build­ings, plat­forms, land­scap­ing and infra­struc­ture works Case Officer: Heath­er Boswell

Cus­tom­er Details Name: Mr Ken Thom­son Address

Com­ment Details Com­menter Type: Mem­ber of Pub­lic Stance: Cus­tom­er objects to the Plan­ning Applic­a­tion Com­ment Reas­ons: Comment:I write on behalf of the North East Moun­tain Trust (NEMT; Scot­tish Char­ity SCIO 008783), which rep­res­ents the interests of around 1000 hill-goers and oth­ers those who enjoy vis­it­ing moun­tains and remoter areas, via indi­vidu­al and club mem­ber­ship. The Trust objects to this pro­pos­al, on the fol­low­ing grounds:

  1. The loc­a­tion, alti­tude and ori­ent­a­tion of this track and its ​“asso­ci­ated struc­tures”, i.e. access tracks for con­struc­tion and main­ten­ance, drain­age, fences, bridges, huts, etc., will make it highly vis­ible from many miles away (and not only ​“from the sur­round­ing hills”, as in the CNPA EIA Applic­a­tion Screen­ing Opin­ion Check­list). This will be espe­cially so when lying par­tial-cov­er snow emphas­ises all arti­fi­cial struc­tures on the hillside.
  2. The steep gradi­ent (which is unclear from the plan­ning inform­a­tion but appears to be about 1 in 5) will make erosion (and flood­ing dur­ing heavy rain­fall and snow­melt) highly likely. Erosion might be reduced by using a hard sur­face rather than the usu­al grit, but this will mean high­er vis­ib­il­ity from afar. Redu­cing the gradi­ent by zig­zag­ging would also mean fur­ther (i.e. worse) visibility.
  3. A new track would con­tra­vene the CNPA’s policy pre­sump­tion against new tracks on moor­land (policy 4a in the Nation­al Park Part­ner­ship Plan).
  4. Such ​“fair­ground attrac­tions” are inap­pro­pri­ate to a moun­tain envir­on­ment, and the cumu­lat­ive effect is an ever grow­ing ​‘indus­tri­al­isa­tion’ of the area.
  5. If CNPA is minded to approve the applic­a­tion, it should insist upon a. adequate anti-vis­ib­il­ity meas­ures, e.g. non-shiny sur­faces to tracks, rails, etc., and b. wood­land plant­ing which will help to shield the install­a­tion over time. Also, at this alti­tude, any ​“trans­lo­ca­tion of excav­ated turf” will prob­ably fail. Great­er efforts are needed to pre­vent the mess that was cre­ated in 2016 dur­ing work on the Shiel­ing access track (and which in places is still vis­ible today).

Pro­posed Tobog­gan Track Cairngorms Nation­al Park

Plan­ning applic­a­tion no. 2026/0135/DET

Objec­tion from Dave Mor­ris I object to this plan­ning applic­a­tion by High­lands and Islands Enterprise/​Cairngorm Moun­tain (Scot­land) Lim­ited on the fol­low­ing grounds:

  1. The plan­ning applic­a­tion con­tains lim­ited detail on the land­scape impacts of the pro­posed devel­op­ment which are likely to be sig­ni­fic­ant. No inform­a­tion is provided on pos­sible altern­at­ive loc­a­tions for such a facil­ity, such as in the exist­ing forest zone or fur­ther afield in Badenoch and Strath­spey where land­scape impacts are likely to be less and expos­ure to wind and rain is reduced. The prin­ciple of wheth­er a tobog­gan track should be estab­lished high on Cairn Gorm, or else­where in the strath, should be addressed before any con­sid­er­a­tion is giv­en to the details of con­struc­tion. where there is bet­ter pro­tec­tion from wind and rain and less land­scape impact. To make a plan­ning decision at this stage would com­prom­ise future devel­op­ment require­ments on Cairn Gorm and risk waste­ful expendit­ure of pub­lic funds. The cur­rent applic­a­tion should be withdrawn.
  2. Before any plan­ning approv­al is gran­ted for this pro­posed devel­op­ment it needs to be referred to Scot­tish min­is­ters to exam­ine both the plan­ning mer­its of the pro­pos­al as well as the fin­an­cial implic­a­tions as regards the expendit­ure of pub­lic funds. Account needs to be taken not only of the over­all devel­op­ment needs on Cairn Gorm but also the devel­op­ment require­ments of oth­er ski resorts in Scot­land in the con­text of cli­mate change and dimin­ish­ing snow cov­er and the res­ult­ant demands for sub­stan­tial pub­lic expendit­ure to sus­tain sum­mer and winter oper­a­tions. need to call in and determ­ine this plan­ning applic­a­tion, tak­ing into account both the future devel­op­ment pro­spects on Cairn Gorm and oth­er ski resorts in Scot­land, along with the fin­an­cial implic­a­tions for pub­lic fund­ing expendit­ure at the oth­er ski resorts at Aon­ach Mor, near Fort Wil­li­am, Glen­coe, Glen­shee and the Lecht. Only the lat­ter two resorts lie with­in the Cairngorms Nation­al Park. The future of all the Scot­tish ski resorts needs to be appraised in the con­text of cli­mate change and the increas­ing lack of snow. HIE is not cap­able of mak­ing the neces­sary evaluations.
  3. On Cairn Gorm HIE have known for the last 8 years that the con­struc­tion of a tobog­gan track on the moun­tain, whatever its mer­its in plan­ning terms, was not a pri­or­ity. Their own con­sult­ants on future Cairn Gorm devel­op­ment, the SE Group, pro­duced a report in 2018 which out­lined the future options. That report was pub­lished a few months before the funicu­lar rail­way was with­drawn from oper­a­tion because of repair needs. It did not become fully oper­a­tion­al again until early 2025. Because of the funicu­lar repair needs HIE com­mis­sioned fur­ther work from the SE

Group who pro­duced a sup­ple­ment­ary report in 2019 which took account of the non-oper­a­tion of the funicular.

  1. Both of the SE Group reports high­light the need for new chairlift uplift as essen­tial devel­op­ments to improve the winter exper­i­ence for ski­ers as part of the pri­or­ity ​“Phase One” devel­op­ments. And both reports include the pro­posed devel­op­ment of a coast­er with­in Phase one. But the 2019 report states that ​“the moun­tain coast­er is included in Phase One as a key source of rev­en­ue without the funicu­lar”. In oth­er words, the pri­or­ity attached to the coast­er related dir­ectly to the non-oper­a­tion of the funicu­lar. New chairlifts, not a moun­tain coaster/​toboggan track should now be the abso­lute pri­or­ity once the funicu­lar has been repaired and resumed oper­a­tions. That should be a cent­ral con­sid­er­a­tion of CNPA plan­ning policy giv­en the CNPA’s stat­utory duty to sup­port sus­tain­able moun­tain development.
  2. It is aston­ish­ing, giv­en these reports, that HIE appears to have done noth­ing over the last 8 years to advance the devel­op­ment of new chairlifts on Cairn Gorm, des­pite the fact that this would do far more to sup­port the loc­al eco­nomy than a tobog­gan track. Even more sur­pris­ing, giv­en the com­plex­it­ies that arose dur­ing the funicu­lar repair pro­cess, that HIE have not advanced new chairlifts to the stage of plan­ning applic­a­tions giv­en that the funicu­lar repairs took far longer than anti­cip­ated and many people expect the funicu­lar to fail again in the future.
  3. Fur­ther­more, the SE Group reports emphas­ise that, even when the funicu­lar is work­ing, it is not fit for pur­pose for winter use. The reports demon­strate that the funicu­lar is oper­ated at too low a speed to provide suf­fi­cient uplift in winter for both ski­er and snow­board vis­it­ors along­side the increas­ing num­ber of non-winter sports vis­it­ors who also want to enjoy the exper­i­ence of rid­ing the funicu­lar and using the view­ing and res­taur­ant facil­it­ies at the top sta­tion. Hence the pri­or­ity, now and in the pre­vi­ous 8 years, is to build new chairlift facil­it­ies rather than a tobog­gan track. The lat­ter has no value in terms of uplift for ski­er and snow board vis­it­ors and could be installed in many oth­er loc­a­tions. Meet­ing their needs is abso­lutely essen­tial for regain­ing Cairn Gorm’s repu­ta­tion as the primary winter sports des­tin­a­tion in Scotland.

  4. Irre­spect­ive of all the above points, the plan­ning applic­a­tion for the tobog­gan track is wholly inad­equate. Two crit­ic­al issues that have to be taken into account on this moun­tain, with any major devel­op­ment, is visu­al appear­ance, with its asso­ci­ated land­scape impacts, along with the impact on soils and veget­a­tion. The visu­al sim­u­la­tions provided by the con­sult­ants to demon­strate the close and dis­tant views of the pro­posed devel­op­ment, includ­ing the uphill and down­hill tracks, access track and build­ings, are very poor. There is no way that such a devel­op­ment in such a sens­it­ive loc­a­tion should be approved without a far more com­pre­hens­ive explan­a­tion of what it would look like.

  5. The plan­ning applic­a­tion is also woe­fully defi­cient on its treat­ment of soil erosion and veget­a­tion dam­age issues. Con­struc­tion of a steep access track in such a loc­a­tion, where erod­ing bare ground is a ser­i­ous prob­lem, is most inadvisable.

  6. In con­clu­sion I again emphas­ise that this pro­posed devel­op­ment should not be approved without ref­er­ence to Scot­tish min­is­ters. It would seem appro­pri­ate that, at the very least, a pub­lic inquiry should be held into this pro­pos­al and set with­in the wider con­text of what is best for Cairn Gorm, as well as the oth­er ski resorts, in both plan­ning and pub­lic expendit­ure aspects. An inde­pend­ent review is urgently needed into future devel­op­ment options. The last occa­sion that took place on Cairn Gorm was in 1980 when the Lurch­ers Gully Pub­lic Inquiry led to the rejec­tion of pro­pos­als for the west­ward expan­sion of ski facil­it­ies from Coire Cas across the North­ern Cor­ries. It is incred­ible that no sub­sequent inde­pend­ent invest­ig­a­tion has been car­ried out in the fol­low­ing 50 years of Cairn Gorm devel­op­ment. At the heart of that prob­lem is the own­er­ship of the upper slopes of the moun­tain, since 1971, by the High­lands and Islands Devel­op­ment Board, fol­lowed by HIE. Any pub­lic inquiry needs to also address how to cor­rect this own­er­ship prob­lem, either restor­ing own­er­ship of the whole north­ern slope of the moun­tain to Forestry and Land Scot­land, or to anoth­er pub­lic body, such as NatureScot or the CNPA, or to estab­lish a Com­munity Trust to secure respons­ib­il­ity for the devel­op­ment and con­trol of key facil­it­ies. This was all explained to the Scot­tish Parliament’s Pub­lic Accounts Com­mit­tee in Janu­ary 2026, with the main con­clu­sion from wit­nesses to the effect that the most import­ant next step was the remov­al of HIE from this mountain.

May 2026

Objec­tion to Plan­ning Applic­a­tion 2026/0135/DET Pro­posed moun­tain tobog­gan track and asso­ci­ated struc­tures, build­ings, plat­forms, land­scap­ing and infra­struc­ture works

I wish to object to this application.

Des­pite vari­ous (reput­able) con­sult­ants being involved in pro­du­cing the sup­port­ing doc­u­ments there are numer­ous omis­sions and con­flicts in the sup­port­ing doc­u­ments. There are also state­ments made which are not illus­trated or fully described. Col­lect­ively the sup­port­ing doc­u­ments are not brought togeth­er in a cohes­ive report which should guide the read­er through the doc­u­ments. The res­ult is that any apprais­al of exactly what is being pro­posed in the applic­a­tion very dif­fi­cult, to the point that I strongly recom­mend that this applic­a­tion is rejec­ted as not being a com­pet­ent set of doc­u­ments to sup­port this application.

Omis­sions and con­flict­ing inform­a­tion and con­fu­sions include:

  1. The Pro­posed Site Plan and Loc­a­tion Plan (pro­duced by Fairhurst): These draw­ings do not show the rel­at­ive pos­i­tion­ing of the exist­ing ski tow (Day Lodge Poma) and the pro­posed tobog­gan ATV track and lift­er sys­tem. Do the pro­posed facil­it­ies over­lap the Day Lodge Poma? Could both facil­it­ies oper­ate side by side? If yes, has a safety risk assess­ment been com­pleted to demon­strate that both facil­it­ies can oper­ate side by side, safely?
  2. LVA Graph­ics pho­tomont­ages (pro­duced by Brind­ley Asso­ci­ates): All these visu­al­isa­tions do not answer my ques­tions in point 1 above, but under­line the con­fu­sion on how the Day Lodge Poma and the pro­posed tobog­gan facil­ity can oper­ate togeth­er. Inter­est­ingly, and reveal­ing, the report authors in the body for their main report state on page 16, ​“The reas­on for this [the dia­gram­mat­ic present­a­tion of the track] is that the com­plex­ity of the exist­ing ski lift infra­struc­ture and the ton­al­ity of the pro­posed ele­ments res­ults in it being chal­len­ging to dis­tin­guish the pro­pos­als from the baseline con­di­tion sur­round­ing the Base Sta­tion in Fig­ure 08d”. Yes, I agree – that’s why a clear detailed draw­ing of the interrelationship/​juxtaposition of the Day Lodge Poma and the pro­posed tobog­gan facil­it­ies is very neces­sary along with a safety risk assess­ment cov­er­ing how the two facil­it­ies could oper­ate togeth­er, safely.
  3. The Site Lay­out Plan – Top View (pro­duced by SunKid): This draw­ing has the appear­ance of part of a com­mer­cial pro­pos­al to CMSL for dis­cus­sion, rather than a doc­u­ment sub­mit­ted in sup­port of a plan­ning applic­a­tion. It shows sug­ges­ted and/​or option­al facil­it­ies, and the uphill trans­port link is just a dashed line. Although it does mark out the bridges for the exist­ing paths, it doesn’t show the pro­posed new path­way at the bot­tom of the facil­ity which the Fairhurst draw­ing shows. Are the suggested/​optional facil­it­ies included in this applic­a­tion or not?
  4. The Tobog­gan Bridge draw­ings (pro­duced by Fairhurst): I assume that the tobog­gan would travel over the realigned foot­paths, but this is not made fully clear. Also, des­pite there being elev­a­tion draw­ings of the pro­posed safety fen­cing, there are no draw­ings show­ing the details of the bridges (con­struc­tion, mater­i­als or lay­out – just a simplist­ic sketch. The details of the con­struc­tion of one of the bridges is giv­en in one of the SunKid draw­ings, but this draw­ing does not depict the realigned foot­paths. Is the cut­away in both bridges the same, with the same steel pil­lar heights?
  5. Plan­ning & Design State­ment (pro­duced by Ryden):
    • This doc­u­ment attempts to bring togeth­er all the vari­ous sup­port­ing doc­u­ments and draw­ings, but is too vague and doesn’t provide a coher­ent cata­logue and descrip­tion of the oth­er sup­port­ing doc­u­ments. page 6: states that there will be a 10 metre buf­fer around the tobog­gan route, but nowhere is this buf­fer illus­trated or described.
    • page 9: states, that the stan­dalone uplift sys­tem will not inter­fere with the exist­ing ski uplift, 1

but no men­tion of the new ATV track.

  • page 12: Import­antly, the rejec­ted applic­a­tion for a dry ski slope in this same area is not included in the plan­ning his­tory. It should have been, as plan­ning his­tory is not just the gran­ted applications.
  • page 14: Men­tion is made of wider land­scape mit­ig­a­tion, includ­ing tree plant­ing in the tobog­gan site area, but no descrip­tion of what is pro­posed is included in this applic­a­tion. It is nor­mal for any land­scap­ing pro­pos­als to be included in a plan­ning applic­a­tion, and not segreg­ated into anoth­er pro­ject. A land­scap­ing plan with pro­posed tree plant­ing needs to be included in this application.
  • page 16: Stat­ist­ics on tick­et sales on three oth­er alpine coast­ers in the UK, which appear encour­aging. How­ever, they all emphas­ise tick­et sales in the first year, and there is no inform­a­tion of later years’ tick­et sales (i.e. for the Welsh and N Ire­land alpine coast­ers). To demon­strate sus­tain­ab­il­ity of this pro­posed new facil­ity more than just first year tick­et sales need to be shown. Also it must be remembered that all these oth­er alpine coast­er facil­it­ies are sited closer to large centres of pop­u­la­tion and will have more favour­able weath­er con­di­tions than 700 and over metres in a moun­tain­ous area where in about 1 in 3 days the area is in the clouds.
  • pages 17 – 19 Sum­mary of the eco­nom­ic impact (and the sep­ar­ate eco­nom­ic impact assess­ment report): The meth­od­o­logy used in the assess­ment by Ref­er­ence Eco­nom­ic Con­sult­ants is fine, how­ever the con­sult­ants make it very clear that all their work is based on demand fore­casts provided by CMSL, with advice from an unnamed third party. Without authen­tic­a­tion of how the fig­ure of over 75,000 rides annu­ally was cal­cu­lated, the eco­nom­ic impact assess­ment is inval­id and frankly, ​‘built on shift­ing sands’. 75,000 annu­al rides appears to be more than any of the oth­er alpine coast­ers in oper­a­tion with­in the UK, thus this fig­ure needs care­ful jus­ti­fic­a­tion. There is also no coher­ent fin­an­cial case for this devel­op­ment which giv­en CMSL’s track record raises sig­ni­fic­ant ques­tions over sus­tain­ab­il­ity of the proposals.
  • For the sake of brev­ity, I have delib­er­ately omit­ted from this objec­tion any com­ments on the com­pat­ib­il­ity or oth­er­wise of this pro­pos­al with NPF4 and the CNPA LDP policies, as I’m aware that oth­er object­ors are cov­er­ing this.
    1. Con­struc­tion Envir­on­ment­al Man­age­ment Plan (CEMP) (pro­duced by Cnoclee Envir­on­ment­al Ser­vices): There are sev­er­al ques­tions and dis­con­nects with this plan:
  • work dur­ing the bird nest­ing sea­son — the Plan­ning & Design State­ment says that eco­lo­gist sur­veys should be no more than 48 hrs pri­or to works com­men­cing, where­as the CEMP states max­im­um 2 weeks on page 38 Sec­tion 14.5, but changes to no more than 48 hrs on page 40 Sec­tion 14.10. Which is it?
  • vehicle speeds: page 37 Sec­tion 14.4 gives a restric­tion of 10mph, where­as page 44 Sec­tion 16.3 sets a lim­it of 15mph. pages 12 & 13 cov­er an ATV Access Track, but I can­not see any­where else in the doc­u­ment that the use of this track is described. Con­versely, page 11 Sec­tion 2 describes access to the top sta­tion via exist­ing track net­work to the Ptar­mig­an Res­taur­ant. The pur­pose of this pro­posed ATV track with all its envir­on­ment­al impact is not covered. Addi­tion­ally, the envir­on­ment­al impact of a steep (aver­age 1 in 5 slope) track is not covered (erosion etc.). This track appears to not com­ply with NatureScot guidelines. This is a major issue and should have been described and dis­cussed in some detail in this report.
  • many illus­tra­tions and appen­dices are miss­ing from the CEMP. In all, this CEMP attempts to cov­er all the bases, but has many incon­sist­en­cies and omis­sions. I appre­ci­ate that this doc­u­ment is a ​‘live’ doc­u­ment and will be reg­u­larly updated, if the pro­ject pro­ceeds, how­ever, a clear­er and more accur­ate doc­u­ment is needed even at this plan­ning applic­a­tion stage. 2
  1. Land­scape and Visu­al Apprais­al (pro­duced by Brind­ley Associates):
    • Sec­tion 1.2 men­tions a main­ten­ance and emer­gency access track. Details of this are not adequately covered or not even men­tioned in the asso­ci­ated doc­u­ments (Design & Access State­ment, CEMP). A num­ber of draw­ings show an ATV track run­ning up the side (or over) the Day Lodge Poma. Is this the main­ten­ance and emer­gency access track? Addi­tion­ally, there is a Fairhurst draw­ing of a ​“Typ­ic­al Main­ten­ance & Emer­gency Access Track”. Is this the draw­ing that will be used, or is it just indic­at­ive? Again, is this the design to be used for the ATV track? The Fairhurst draw­ing shows a track 2,000 mm wide, where­as the CEMP says nom­in­ally 1.8m wide. What design does the applic­ant want to sub­mit for approval?
    • Sec­tion 1.7 — wood­land cre­ation: This is deemed part of a sep­ar­ate ini­ti­at­ive and is thus not con­sidered. In any com­pet­ent Land­scape & Visu­al Apprais­al where the pro­posed devel­op­ment is very vis­ible, the wood­land cre­ation and its envir­on­ment­al and visu­al effects should have been described for this application.
    • Little or no men­tion is made about the visu­al impact of the main­ten­ance and emer­gency access track, espe­cially as the severe slope of this track is very likely to res­ult in erosion, although Fig. 08c shows a simplist­ic present­a­tion of the line of this track.
  2. I do not see any trans­port assess­ment as part of this applic­a­tion. If 75,000 rides are pre­dicted annu­ally, then there needs to be details of how exist­ing cark­ing facil­it­ies in Coire Cas can cope, espe­cially dur­ing the snowsport sea­son when already, in good days, the park­ing facil­it­ies can­not cope.

I appre­ci­ate that this is a long list of issues with the sup­port­ing doc­u­ments. I believe that giv­en time, I could dis­cov­er many more! I repeat, this applic­a­tion in its cur­rent form is not in a fit state for assess­ment by the CNPA Plan­ning Com­mit­tee. The fail­ings in the sup­port­ing doc­u­ments are so sub­stan­tial that they should not be covered by plan­ning con­di­tions. The most import­ant issues in this objec­tion are:

• The applic­a­tion does not clearly show how the pro­posed tobog­gan facil­it­ies oper­ate side by side with the Day Lodge Poma facil­it­ies. It is not explained how these facil­it­ies can oper­ate togeth­er without inter­fer­ence and without a safety risk assess­ment. • The descrip­tion of the Main­ten­ance & Emer­gency Access Track, its use dur­ing con­struc­tion and after­wards is very unclear. Addi­tion­ally, it appears that the design of the track will breach NatureScot guidelines on such tracks — level of steep­ness, lack of bends and sus­cept­ib­il­ity to erosion. Finally, how will such a track oper­ate in an emer­gency when the line of the track is the wrong side of the uphill track? • No trans­port assess­ment • Lack of evid­ence of the fin­an­cial sus­tain­ab­il­ity of the pro­pos­als — an unsub­stan­ti­ated eco­nom­ic impact and no busi­ness plan. • The numer­ous sup­port­ing doc­u­ments have the dis­tinct appear­ance of being thrown togeth­er rather than fully integ­rat­ing the doc­u­ments and ensur­ing that con­flicts and omis­sions are addressed and eliminated.

Yours faith­fully

Dr Gor­don Bul­loch 3

Badenoch & Strath­spey Con­ser­va­tion Group Fiod­hag, Nethy­bridge, Inverness-shire PH25 3DJ

Scot­tish Char­ity No. SC003846 Web­site bscg​.org​.uk/

Heath­er Boswell CNPA

25 May 2026

Dear Heath­er Boswell 2026/0135/DET Pro­posed moun­tain tobog­gan track and asso­ci­ated struc­tures, build­ings, plat­forms, land­scap­ing and infra­struc­ture works at Land 250M NE of Ranger Base Office, Cairngorm Moun­tain, Glen­more, Aviemore

I am writ­ing to object to the above plan­ning applic­a­tion for reas­ons includ­ing those set out below, and we request the oppor­tun­ity to address the com­mit­tee when the applic­a­tion is considered.

The pro­posed devel­op­ment would cause loss and degrad­a­tion of import­ant hab­it­ats. Such hab­it­ats on the pro­posed devel­op­ment site include: Wet Heath hab­it­at that cor­res­ponds to the Annex 1 Hab­it­at H4010 and is of major inter­na­tion­al import­ance with some 85% of its total glob­al dis­tri­bu­tion occur­ring in the UK and Ire­land. Con­ser­va­tion of this hab­it­at is an inter­na­tion­al respons­ib­il­ity. Moun­tain Heath hab­it­at of nation­al import­ance; Wet Flush hab­it­at of nation­al import­ance. Hab­it­ats at these alti­tudes can be con­sidered fra­gile and already under grow­ing pres­sures, includ­ing from cli­mate change and the nature crisis. These con­sid­er­a­tions add weight to the import­ance of apply­ing the pre­cau­tion­ary prin­ciple. The con­sult­ant in their Eco­lo­gic­al Assess­ment has rightly repor­ted that the nearby leg­ally des­ig­nated sites are ​“eco­lo­gic­ally con­nec­ted to the [pro­pos­al] site” by wet­land hab­it­ats and spe­cies assemblages. We are con­cerned that there is insuf­fi­cient inform­a­tion provided in the applic­a­tion to estab­lish that impacts on the integ­rity of the nearby des­ig­nated sites will not be sig­ni­fic­ant. We are fur­ther con­cerned that there has been insuf­fi­cient assess­ment of the cumu­lat­ive impacts of the present pro­pos­al and the mul­tiple recent devel­op­ments in the ski area involving extens­ive destruc­tion and dam­age of nat­ur­al veget­a­tion and soils, through earth mov­ing, groom­ing, smooth­ing, drain­age impacts, and dam­age and dis­rup­tion to soil structures.

We can find no spe­cif­ic field sur­vey of inver­teb­rates for this pro­pos­al. Inver­teb­rates play a pivotal role in eco­lo­gic­al webs, and are fun­da­ment­al to biod­iversity at Cairngorm. As well as the pro­pos­al impact­ing inver­teb­rates with­in and in the vicin­ity of the devel­op­ment site itself, there are likely to be wider ran­ging impacts on inver­teb­rates that use a vari­ety of dif­fer­ent hab­it­ats, for example at dif­fer­ent stages in their life cycle. The pro­posed devel­op­ment site poten­tially includes the hab­it­at of the extremely rare Spring­tail Bour­leti­ella viri­des­cens for which the first con­firmed UK record was from Cairn Gorm in 200

The pro­posed devel­op­ment is inap­pro­pri­ate in the spe­cial and sens­it­ive loc­a­tion of Cairn Gorm. The many devel­op­ments in the ski area should not be used as a jus­ti­fic­a­tion for adding to them

with the cur­rent pro­pos­al and adding to what is becom­ing an increas­ingly indus­tri­al­ised area. Cairn Gorm is an out­stand­ing loc­a­tion in the Nation­al Park, and as BSCG and oth­ers have repeatedly main­tained, it should nev­er be treated as a sac­ri­fi­cial moun­tain. The many devel­op­ments with­in the ski area should cer­tainly not be used to back up an argu­ment for fur­ther devel­op­ment here. The pro­posed devel­op­ment has no par­tic­u­lar require­ment for snow cov­er and is not reli­ant on being situ­ated on Cairn Gorm. The pro­posed site has the dis­ad­vant­ages of being exposed and sub­ject to extreme, cold, wet, windy weath­er; and the coast­er would be vul­ner­able to clos­ure due to the weather.

The pro­posed devel­op­ment would be visu­ally intrus­ive and have sig­ni­fic­ant land­scape impacts. It would add a par­tic­u­larly unnat­ur­al, metal­lic struc­ture to the moun­tain side, which in addi­tion would glint when catch­ing the sun; and the two bridges would be par­tic­u­larly visible.

The exper­i­ence of users of the pop­u­lar and read­ily accessed Windy Ridge path, that runs through the pro­pos­al site, would be sig­ni­fic­antly neg­at­ively impacted. The path would be crossed twice, by the two bridges of the coast­er going over the path; and the path would be impacted by the pres­ence of the tobog­gan return facil­ity on one side of the path, and the coast­er track being on the oth­er side. The prox­im­ity of these devel­op­ments would sig­ni­fic­antly detract from the moun­tain exper­i­ence provided by this route.

The design of the pro­posed Vehicle Main­ten­ance and Emer­gency Access Track is not in accord­ance with NatureScot’s ​‘Guid­ance on Con­struc­ted Tracks in the Uplands’ (2nd edi­tion 2013). The gradi­ent of the track appears to be some 20%. NatureScot’s guid­ance states that track gradi­ents should not exceed 14% and points out that ​“gradi­ents exceed­ing this threshold in the Scot­tish uplands are highly prone to severe sur­face erosion, as run­off velo­city accel­er­ates and scours the track mater­i­al”. There is a neg­lect of the need for sus­tain­ab­il­ity in a core areaof the np. The pro­posed track would be par­tic­u­larly prone to erosion and this is liable to add to its envir­on­ment­al and land­scape impacts and hab­it­at degrad­a­tion. The pro­posed track is not in accord­ance with the Nation­al Park Part­ner­ship Plan Policy A4f. This states ​“Con­serve and enhance the spe­cial land­scape qual­it­ies of the Nation­al Park, with a par­tic­u­lar focus on … f) Apply­ing a pre­sump­tion against new con­struc­ted tracks in open moor­land”. The pro­pos­al would be con­trary to the aims of the Nation­al Park. The devel­op­ment would des­troy and dam­age hab­it­ats and their asso­ci­ated spe­cies rather than con­serving and enhan­cing nat­ur­al her­it­age (1st aim); and the pro­posed devel­op­ment would not amount to ​‘sus­tain­able devel­op­ment’ due to the envir­on­ment­al unsus­tain­ab­il­ity of the development’s nat­ur­al her­it­age impacts, as well as its poten­tial lack of fin­an­cial sus­tain­ab­il­ity (4th aim). Regret­tably, the fig­ures for pri­cing, costs etc presen­ted in the Eco­nom­ic Impact Assess­ment on the pub­lic plan­ning portal are redac­ted. This is unhelp­ful. How­ever, the accounts for Cairngorm Moun­tain (Scot­land) Ltd to Com­pan­ies House (for year end­ing 31 March 2025) reveal that the oper­a­tions at Cairngorm received ongo­ing pub­lic fund­ing of over £2.8 mil­lion for that year, or nearly £8000 every day. In the accounts it is explained that pub­lic fund­ing provided from HIE ​“is paid monthly based on cash need … The com­pany is reli­ant on con­tinu­ing fin­an­cial sup­port from its par­ent under­tak­ing, HIE, to enable it to con­tin­ue oper­at­ing and to meet its fin­an­cial oblig­a­tions as they fall due” (from 1.2 Going Con­cern, CMSL Accounts, Com­pan­ies House). In light of the amount and neces­sity of this eye water­ing pub­lic sub­sidy for the fore­see­able future, any net income that may arise from the pro­posed coast­er can be pre­dicted to pale into insig­ni­fic­ance. The wider fin­an­cial con­text also under­mines any claims that may be made that the fin­an­cial gains from the pro­posed devel­op­ment can jus­ti­fy the impacts.

Yours sin­cerely

Gus Jones Convener

Tree Plant­ing – We are con­cerned at the tree plant­ing pro­pos­als. The consultant’s Eco­lo­gic­al Assess­ment reports that there are already Juni­per and Scots Pine on the colder and win­di­er Moun­tain Heath hab­it­ats on the pro­pos­al site, with Scots pine sap­lings recor­ded through­out this heath hab­it­at. Can cre­ate an eco­lo­gic­ally inco­her­ent mix of spe­cies (as HIE and CMSL and oth­ers have unfor­tu­nately cre­ated at Coire na Ciste); dis­rupt and dam­age inher­ently fra­gile moun­tain soils and peat-rich soils, that would both dam­age the soil struc­ture and biod­iversity of the soils and be likely to release car­bon. 1) The primary jus­ti­fic­a­tion for per­mit­ting any devel­op­ment at Cairn Gorm, one of the finest and most access­ible moun­tains in the Nation­al Park, is its snow cov­er and that it provides an oppor­tun­ity for snowsports that is not avail­able else­where. Oth­er vis­it­or attrac­tions, such as this coast­er, are not appro­pri­ate and should be built else­where. 2) There is no Fin­an­cial Busi­ness case for the devel­op­ment and no evid­ence that it meets the Park’s stat­utory aim to deliv­er sus­tain­able devel­op­ment. 3) The pro­posed per­man­ent access track along­side the coast­er uplift is a) con­trary to Policy 4a in the Nation­al Park Part­ner­ship Plan which states there should be a pre­sump­tion against new roads on moor­land b) con­trary to the NatureScots Guid­ance on Con­struc­ted Tracks in the Uplands that says the gradi­ents of tracks should not be more that 14% — the pro­posed route appears to be 20% and will be highly prone to erosion c) can­not serve its claimed pur­pose for main­ten­ance and emer­gency pur­poses because it is cut off from the down­hill coast­er track by the uphill track 4) The visu­al­isa­tion points in the LVA do not provide an adequate assess­ments of its visu­al impact, omit­ting close up views of the bridges and fail­ing to con­sider its vis­ib­il­ity in sunny con­di­tions when the rail could gleam and glint. If the CNPA is nev­er­the­less minded to approve the pro­pos­al on land­scape grounds it should: a) require the met­al rail to have a matt fin­ish so it reflects as little light as pos­sible b) require the applic­ant to pro­duce a detailed wood­land plan, includ­ing plant­ing, designed to screen the track which it is then leg­ally bound to deliv­er c) con­sider altern­at­ive solu­tions to the pro­posed coast­er cross­ing the foot­path by two bridges — these met­al bridges will be more prom­in­ent than the rest of the track and very dif­fi­cult to screen with trees

Com­ments for Plan­ning Applic­a­tion 2026/0135/DET

Applic­a­tion Sum­mary Applic­a­tion Num­ber: 2026/0135/DET Address: Land 284M East Of Cairngorm Moun­tain Glen­more Aviemore Pro­pos­al: Pro­posed moun­tain tobog­gan track and asso­ci­ated struc­tures, build­ings, plat­forms, land­scap­ing and infra­struc­ture works Case Officer: Heath­er Boswell

Cus­tom­er Details Name: Mr Keith Char­man Address:

Com­ment Details Com­menter Type: Mem­ber of Pub­lic Stance: Cus­tom­er objects to the Plan­ning Applic­a­tion Com­ment Reas­ons: Com­ment: The Cairngorms Cam­paign objects to this applic­a­tion as fol­lows: This devel­op­ment is yet anoth­er example of an inap­pro­pri­ate struc­ture with­in the Nation­al Park and anoth­er move towards the ​“Dis­ney­fic­a­tion” of an area of spe­cial land­scape char­ac­ter. In the Park’s own Policy 5 in its Land­scape non-stat­utory guid­ance doc­u­ment the value of the spe­cial land­scape qual­ity and the need for its con­ser­va­tion or enhance­ment is recog­nised — this applic­a­tion meets neither of those cri­ter­ia. There is no busi­ness case evid­ence that the social or eco­nom­ic bene­fits out­weigh such a fur­ther desec­ra­tion of the nat­ur­al envir­on­ment and the visu­al impact of the devel­op­ment will be sig­ni­fic­ant — even from a dis­tance. The struc­ture will require per­man­ent access tracks for con­struc­tion and main­ten­ance and fur­ther track­ways in the Cairngorm land­scape will cause fur­ther envir­on­ment­al dam­age and do not relate to the dis­tinct­ive char­ac­ter­ist­ics of the land­scape qual­ity. The dam­age to such sens­it­ive areas takes many years to recov­er. Keith Char­man Dir­ect­or The Cairngorms Campaign

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.
  2. 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.
  3. 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 1

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?

  1. 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.
  2. 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.
  3. 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.

Yours faith­fully,

Dr Gor­don Bul­loch 2