Item5Appendix3aObjections20200076DET

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 5 Appendix 3a 22/05/2020 AGENDA ITEM 5 APPENDIX 3a 2020/0076/DET REP­RES­ENT­A­TIONS OBJECTIONS

Com­ments for Plan­ning Applic­a­tion 2020/0076/DET Applic­a­tion Sum­mary Applic­a­tion Num­ber: 2020/0076/DET Address: Cairngorm Moun­tain Glen­more Aviemore High­land PH22 1RB Pro­pos­al: Engin­eer­ing works for strength­en­ing funicu­lar via­duct Case Officer: Stephanie Wade Cus­tom­er Details Name: Mr Alan Brat­tey Address: 5 Pater­son Road Aviemore Com­ment Details Com­menter Type: Mem­ber of Pub­lic Stance: Cus­tom­er objects to the Plan­ning Applic­a­tion Com­ment Reas­ons: Comment:This plan­ning applic­a­tion should be rejec­ted for the fol­low­ing reasons:

1. The entire area that will be sub­ject to involve­ment in the pro­ject has not been delin­eated on the applic­a­tion doc­u­ments. Only the area where work around each sup­port­ing pier will be done has been marked off. How­ever, pre­vi­ous applic­a­tions for the Sheil­ing rope tow and for the ​‘smooth­ing’ work out­side the Daylodge have clearly shown the whole area that would be sub­ject to disturbance.
2. There is no clar­ity with respect to tem­por­ary access tracks. It’s unclear just exactly how many are being pro­posed and there is no indic­a­tion of the routes that these track[s] would take or of the mater­i­als to be used in their con­struc­tion far less how they will be removed and rein­stated. Pre­vi­ous exper­i­ence on CairnGorm has shown that pre­cise details needs to be included oth­er­wise CNPA plan­ning will have dif­fi­culty in ensur­ing that a qual­ity job is done.
3. The scale of this work would sug­gest that this plan­ning applic­a­tion should be clas­si­fied as a major devel­op­ment and as such a pre-applic­a­tion con­sulta­tion report would be a require­ment. No such con­sulta­tion has taken place. In addi­tion a design and access state­ment should also be included. As a min­im­um, the applic­ant should be required to resub­mit the plan­ning applic­a­tion with the addi­tion­al details referred to above.

Com­ments for Plan­ning Applic­a­tion 2020/0076/DET Applic­a­tion Sum­mary Applic­a­tion Num­ber: 2020/0076/DET Address: Cairngorm Moun­tain Glen­more Aviemore High­land PH22 1RB Pro­pos­al: Engin­eer­ing works for strength­en­ing funicu­lar via­duct Case Officer: Stephanie Wade Cus­tom­er Details Name: Mr Alan Mack­ay Address: 9 Bish­ops Park Bishop’s Park Inverness Com­ment Details Com­menter Type: Mem­ber of Pub­lic Stance: Cus­tom­er objects to the Plan­ning Applic­a­tion Com­ment Reas­ons: Comment:I am object­ing on the fol­low­ing bases — as attach­ments are not pos­sible here, I have sub­mit­ted a doc­u­ment by email, but have included a sum­mary below:

1. Firstly, that this applic­a­tion should be rejec­ted without fur­ther con­sid­er­a­tion because the applic­a­tion is incom­plete. It does not include details of the access tracks required and the des­ig­nated areas iden­ti­fied as need­ing plan­ning per­mis­sion do not cov­er the full site that will be affected.
2. The stated eco­nom­ic case for repair­ing the funicu­lar does not exist, the applic­ant has not provided any evid­ence in sup­port of these claims.
3. Thirdly, that the repair of the Funicu­lar Rail­way is incom­pat­ible with object­ives B, D, F and G of the CNPA Work­ing Prin­ciples for CairnGorm Moun­tain approved by the CNPA Board on 29^th March 2019.
4. Finally, the mono­lith­ic nature of the Funicu­lar via­duct requires that it will even­tu­ally have to be removed entirely. Prop­ping up the via­duct now is a £10m plus can kick­ing exer­cise, not merely delay­ing the inev­it­able but sub­stan­tially increas­ing the extent of the ground dis­turb­ance required to ulti­mately remove the viaduct.

Plan­ning Applic­a­tion: 2020/0076/DET Engin­eer­ing works for strength­en­ing funicu­lar via­duct | OBJEC­TION Objec­tion to Plan­ning Applic­a­tion — ​‘Engin­eer­ing works for strength­en­ing funicu­lar via­duct’ Page 1

Plan­ning Applic­a­tion: 2020/0076/DET Engin­eer­ing works for strength­en­ing funicu­lar via­duct | OBJEC­TION I am object­ing on the fol­low­ing bases, I shall expand on points 2 & 3 fur­ther through this document:

1. Firstly, that this applic­a­tion should be rejec­ted without fur­ther con­sid­er­a­tion because the applic­a­tion is incom­plete. It does not include details of the access tracks required and the des­ig­nated areas iden­ti­fied as need­ing plan­ning per­mis­sion do not cov­er the full site that will be affected.
2. The stated eco­nom­ic case for repair­ing the funicu­lar does not exist, the applic­ant has not provided any evid­ence in sup­port of these claims.
3. Thirdly, that the repair of the Funicu­lar Rail­way is incom­pat­ible with object­ives B, D, F and G of the CNPA Work­ing Prin­ciples for CairnGorm Moun­tain approved by the CNPA Board on 29^th March 2019.
4. Finally, the mono­lith­ic nature of the Funicu­lar via­duct requires that it will even­tu­ally have to be removed entirely. Prop­ping up the via­duct now is a £10m plus can kick­ing exer­cise, not merely delay­ing the inev­it­able but sub­stan­tially increas­ing the extent of the ground dis­turb­ance required to ulti­mately remove the via­duct. As stated in the sup­port­ing doc­u­ment­a­tion, the Funicu­lar is not cur­rently oper­a­tion­al and will not oper­ate again unless repaired. 5.1. The funicu­lar via­duct, a sig­ni­fic­ant struc­ture in the land­scape, already exists. The Funicu­lar doesn’t and won’t exist in an oper­a­tion­al sense without the pro­posed repairs. Remov­al of the Funicu­lar via­duct will very sub­stan­tially reduce the visu­al intru­sion of the snowsports area from the wider Strath, thus sig­ni­fic­antly improv­ing the land­scape qual­it­ies of CairnGorm Moun­tain, while improv­ing snow hold­ing of the sig­na­ture White Lady Run and allow­ing more appro­pri­ate uplift to be installed. Page 2

Plan­ning Applic­a­tion: 2020/0076/DET Engin­eer­ing works for strength­en­ing funicu­lar via­duct | OBJEC­TION Objec­tion to Plan­ning Applic­a­tion — ​‘Engin­eer­ing works for strength­en­ing funicu­lar via­duct’ An eco­nom­ic case for repair­ing the Funicu­lar? Eco­nom­ic viab­il­ity of the Funicu­lar Does the Funicu­lar Sup­port the Wider Eco­nomy? 1 3 4 6 Dur­ing Sum­mer the Ptar­mig­an is in Cloud 1 day in 3 6 CairnGorm Moun­tain — CNPA Work­ing Prin­ciples 7 B) Any pro­pos­als should be part of a mas­ter­plan for the ski area as per the pro­posed new Loc­al Devel­op­ment Plan. 7 D) CairnGorm Moun­tain should provide a good Scot­tish ski exper­i­ence with facil­it­ies and uplift com­men­sur­ate with scale. 8 Funicu­lar vs Nevis Range Gon­dola & Glen­coe Access Chair 10 F) Sum­mer vis­it­ors should be provided with an oppor­tun­ity to enjoy the moun­tain envir­on­ment and be close to nature and wild­ness. 12 G) The oper­a­tion­al mod­el for CairnGorm Moun­tain needs to be fit for pur­pose and afford­able in the long-term. 14 Con­clu­sion 16 Page 3

Plan­ning Applic­a­tion: 2020/0076/DET Engin­eer­ing works for strength­en­ing funicu­lar via­duct | OBJEC­TION An eco­nom­ic case for repair­ing the Funicu­lar? From read­ing the sup­port­ing doc­u­ment­a­tion, this applic­a­tion to repair the funicu­lar rests on the claimed eco­nom­ic import­ance of the funicu­lar and the already sub­stan­tial visu­al impact of the funicu­lar via­duct. Sup­port­ing State­ment has the fol­low­ing para­graphs: 4.1 The oper­a­tion of the Funicu­lar deliv­ers a sig­ni­fic­ant eco­nom­ic con­tri­bu­tion to the loc­al and region­al eco­nomy, and it is essen­tial in provid­ing all-sea­son access and access­ib­il­ity to Cairn Gorm. 5.1 The funicu­lar via­duct, a sig­ni­fic­ant struc­ture in the land­scape, already exists. The plan­ning applic­a­tion is for works to strengthen the funicu­lar via­duct and to ensure its return to oper­a­tion as an import­ant part of the loc­al eco­nomy. Eco­nom­ic viab­il­ity of the Funicu­lar In the Guard­i­an on Wed­nes­day 28^th April 1999, Dav­id Hayes from Land­mark Forest Adven­ture Park is quoted: ​“The pro­ject is without any doubt, com­mer­cially unvi­able.” 21 Years later HIE is unable to provide evid­ence to refute that claim in sup­port of this plan­ning applic­a­tion. I sus­pect that the reas­on for this omis­sion is that quite simply no such evid­ence exists. With hind­sight it is dif­fi­cult not to con­cur with Dav­id Hayes state­ment because: • • CairnGorm Moun­tain Lim­ited accu­mu­lated £2.753 mil­lion of losses dur­ing the peri­od the Funicu­lar and the cur­rent Ptar­mig­an Res­taur­ant were both in full oper­a­tion. CairnGorm Mountain’s oper­at­or was twice taken into pub­lic own­er­ship by HIE in 2008 (to stave off a form­al insolv­ency) and in 2018 (after enter­ing admin­is­tra­tion). Page 4

Plan­ning Applic­a­tion: 2020/0076/DET Engin­eer­ing works for strength­en­ing funicu­lar via­duct | OBJEC­TION Dav­id Pat­tis­on (former head of the Scot­tish Tour­ist Board) pro­jec­ted the non ski sea­son vis­it­or num­bers for the Funicu­lar would be between 77,000 to 104,000 and thus be 50,000 below the break­even point of viab­il­ity for the Funicu­lar. Press and Journ­al WED­NES­DAY DECEM­BER 16 1998 Moun­tain railway’s viab­il­ity dis­puted EUROPEAN offi­cials are being urged to with­hold £2.7million in grant for the pro­posed Cairn Gorm moun­tain rail way. A study sug­gests the pro­ject will lose money In a report pub­lished yes­ter­day. tour­ism con­sult­ant Dav­id Pat­tis­on, for- mer chief exec­ut­ive of the Scot­tish Tour­ist Board, estim­ates the rail­way will attract 50,000 few­er tour­ists a year than it needs to break even. He also sug­gests that the pro­pos­al will have 100,000 vis­it­ors few­er than ori­gin­ally pre­dicted by High­lands and Islands Enter­prise. which is com­mit­ting £9.5million of pub­lic money. The study was com­mis­sioned by Dav­id Hayes, man­aging dir­ect­or of the Land­mark Her­it­age and Adven­ture Park at Car­rbridge and a long-ime oppon­ent of the rail­way. He is now using the find­ings in a last-ditch attempt to block fund­ing. Mr Hayes believes the pro­posed Cairngorms Nation­al Park, togeth­er with a gon­dola tak­ing people up. would be the best solu­tion for the area. He has writ­ten to the dir­ect­or gen­er­al of the European Com­mis­sion. Patrick Amblard. urging him to sus­pend the Object­ive One money for the pro­ject. The cash has already been approved by the High­lands and Islands Object­ive One Part­ner­ship, so the European Com­mis­sion approv­al is expec­ted to be a form­al­ity. Sup­port­ers of the moun­tain rail­way rejec­ted the report’s find­ings yes­ter­day. An HIE spokes­man said: ​“We have to remem­ber these are the opin­ions of someone who con­siders him­self a com- petit­or of the pro­ject. ​“The eco­nom­ic and envir­on­ment­al case for the funicu­lar has been closely examined over the years by a num­ber of bod­ies includ­ing HIE, the Scot­tish Office. Scot­tish Nat­ur­al Her­it­age. Scot­tish Tour­ist Board. High­land Coun­cil and the High­lands and Islands Object­ive One Part­ner­ship.” The Cairngorm Chairlift Co hopes the rail­way will be ready by the winter of 2001 and the build­ings and exhibi- tion areas by the fol­low­ing sum­mer. Lin Brief Wretched life for refugees MOST asylum-seekers in the UK are sleep­ing rough, go hungry every day and are com­pletely pen­ni­less, accord­ing to a sur­vey pub­lished today. The Refugee Coun­cil said its research showed that asylum-seekers were ​“some of the most wretched people on Earth” and their plight was made worse by These pro­jec­tions strongly backed up Dav­id Hayes asser­tion in a let­ter pub­lished in the Press and Journ­al in May 1996 that the funicu­lar pro­ject would be ​“risk­ing the viab­il­ity of the Cairngorm Chairlift Com­pany as a whole”. On 17^th Septem­ber 2004, then CairnGorm Moun­tain Ltd CEO Bob Kin­naird wrote to sea­son pass hold­ers in a let­ter form­al­ising the ​‘core lifts policy’. This let­ter her­al­ded the suc­cess of the Funicu­lar, and strongly implied that CML was able to provide snowsports as a ser­vice off the strength of the funicu­lar. Many ski­ers and snow­boarders had long sus­pec­ted the reverse was true, that snowsports was sub­sid­ising year round oper­a­tion of the Funicu­lar as a tour­ist attrac­tion, to the severe det­ri­ment of the snowsports oper­a­tion. When Nat­ur­al Assets Invest­ments Lim­ited decided to change CML’s fin­an­cial year from the fisc­al year to the cal­en­dar year, CML pos­ted a shortened account­ing peri­od cov­er­ing April to Dec 2015, basic­ally an unique insight to the fin­an­cial real­ity of CML in sum­mer with the funicu­lar oper­a­tion­al. Over the ​‘sum­mer’ trad­ing peri­od in 2015 CML pos­ted a loss of £1.248 mil­lion! Jan­nete Jan­son, then Gen­er­al Man­ager of CML under Nat­ur­al Retreats affirmed what many ski­ers had long thought, “…our winter rev­en­ue which is cru­cial to sus­tain the oper­a­tion dur­ing the sum­mer months.” It is clear that funicu­lar rail­way is not the eco­nom­ic suc­cess and import­ance that HIE pro­claim in the sup­port­ing state­ment, rather the funicu­lar has been a fin­an­cial mill­stone around the neck of CML that has dir­ectly con­trib­uted to the run down and derel­ict nature of the built envir­on­ment on CairnGorm. Page 5

Plan­ning Applic­a­tion: 2020/0076/DET Engin­eer­ing works for strength­en­ing funicu­lar via­duct | OBJEC­TION Does the Funicu­lar Sup­port the Wider Eco­nomy? The Sup­port­ing Statement’s con­clu­sion starts with the fol­low­ing para­graph: 6.1 The CairnGorm Moun­tain Funicu­lar has con­trib­uted sig­ni­fic­antly, dur­ing the past two dec­ades, to a sus­tain­able eco­nomy in Aviemore and the Spey Val­ley, and to the High­lands in gen­er­al. It has helped extend vis­it­or num­bers and eco­nom­ic activ­ity bey­ond the core tour­ist sea­son and assist in the aspir­a­tions for a more viable year round eco­nomy. This is a bold state­ment, but like those in para­graphs 4.1 and 5.1 no evid­ence is provided to back the claim up. In the Park Authority’s own ​‘Loc­al Devel­op­ment Plan 2020 evid­ence paper’ the CNPA notes that there has been a 13.4% increase in vis­it­ors to the nation­al park between 2009 and 2016. How­ever over the same peri­od non-snowsports funicu­lar usage actu­ally declined by 3%. (Annu­al non ski trips fell from 142,039 to 137,776) Dur­ing Sum­mer the Ptar­mig­an is in Cloud 1 day in 3 A sur­vey of the Loch Mor­lich Win­ter­high­land web­cam at 1pm dur­ing the months of May to Septem­ber in 2013, 2014 and 2015 indic­ate that even dur­ing the core sum­mer trad­ing months the Ptar­mig­an Res­taur­ant at the top of the Funicu­lar Rail­way is in cloud 1 day in 3 on aver­age. This con­trasts to the Base Sta­tion being in cloud an aver­age of just 1 day in 35. This sug­gests that the Ptar­mig­an is too high up the moun­tain to optim­ise the poten­tial of CairnGorm for paid sight­see­ing. Restor­ing the Funicu­lar status quo will thus sig­ni­fic­antly lim­it the poten­tial eco­nom­ic bene­fit of invest­ing in CairnGorm com­pared to a vari­ety of poten­tial altern­at­ive approaches at a lower elev­a­tion on the moun­tain. Increas­ing the size of the Ptar­mig­an Res­taur­ant will do noth­ing to address the lack of view and res­ult­ant lack of appeal on days when the build­ing is inside a cloud. Page 6

Plan­ning Applic­a­tion: 2020/0076/DET Engin­eer­ing works for strength­en­ing funicu­lar via­duct | OBJEC­TION CairnGorm Moun­tain — CNPA Work­ing Prin­ciples Approv­al of this applic­a­tion to repair the Funicu­lar Rail­way via­duct would be con­trary to points B, D, F and G of the work­ing prin­ciples agreed by the CNPA Board on 29^th March 2019. B) Any pro­pos­als should be part of a mas­ter­plan for the ski area as per the pro­posed new Loc­al Devel­op­ment Plan. HIE have con­sult­ants work­ing on a Mas­ter Plan for CairnGorm Moun­tain, who under­took a num­ber of pub­lic engage­ment events dur­ing the winter sea­son. This plan­ning applic­a­tion com­pletely pre­ju­dices the pur­por­ted Mas­ter Plan­ning / con­sulta­tion pro­cess on the future of CairnGorm by seek­ing to rail­road through fix­ing of the Funicu­lar as a fait accom­pli. A sim­il­ar scen­ario occurred with HIE pre­ju­dicing the uplift review by the SE Group, by demol­ish­ing the Coire na Ciste Chairlifts in early autumn 2017, after the terms of ref­er­ence for the uplift review were pub­lished but before the SE Group were con­trac­ted in Janu­ary 2018. At the time of writ­ing this objec­tion state­ment, a fur­ther plan­ning applic­a­tion from HIE for CairnGorm Moun­tain has been lodged seek­ing to install auto­mat­ic bar­ri­ers to enforce car­park char­ging in Coire Cas. The sup­port­ing state­ment for that applic­a­tion lists no less than 7 plan­ning applic­a­tions (2 lodged and 5 in the pipeline) for CairnGorm. This scat­ter­gun approach is wholly unac­cept­able and com­pletely incom­pat­ible with ref­er­ence to the CNPA Board’s require­ment for a widely con­sul­ted and agreed CairnGorm Mas­ter­plan to be in place. The cred­ib­il­ity of the CNPA as a plan­ning author­ity is on the line with HIE’s beha­viour and the plan­ning com­mit­tee must uphold the pub­lished work­ing prin­ciples or risk com­pletely los­ing con­trol of the situ­ation on CairnGorm and under­min­ing the new Loc­al Devel­op­ment Plan. Page 7

Plan­ning Applic­a­tion: 2020/0076/DET Engin­eer­ing works for strength­en­ing funicu­lar via­duct | OBJEC­TION D) CairnGorm Moun­tain should provide a good Scot­tish ski exper­i­ence with facil­it­ies and uplift com­men­sur­ate with scale. Scot­tish Snowsports is due to our mari­time cli­mate oppor­tun­ist­ic in nature. This holds true for both for the ski­ers and snow­boarders them­selves, but equally resort oper­at­ors too must be in a pos­i­tion to make the most of the oppor­tun­it­ies when good con­di­tions pre­vail. Giv­en our cli­mat­ic con­di­tions and loc­a­tion, wind is an issue for all five com­mer­cial Scot­tish Snowsports areas, but an addi­tion­al factor is in play on CairnGorm. The propensity for strong kata­bat­ic winds blow­ing downslope off the plat­eau means that even in rel­at­ively benign syn­op­tics, strong winds and sub­stan­tial drift­ing can occur. Winds from the South­erly quad­rant can be amp­li­fied hugely by a com­bin­a­tion of kata­bat­ic and topo­graph­ic wind accel­er­a­tion, with severe ground drift­ing shift­ing large quant­it­ies of snow from high­er elev­a­tions on to both the ski road into Coire Cas and over the Funicu­lar via­duct. Staff dig­ging out funicu­lar run­ning gear by hand dur­ing the after­noon of Sun 16^th Feb 2014. Page 8

Plan­ning Applic­a­tion: 2020/0076/DET Engin­eer­ing works for strength­en­ing funicu­lar via­duct | OBJEC­TION Superb Half Term con­di­tions and weath­er but Funicu­lar out of ser­vice lead­ing to lar­ger queues on sur­face tows and no lift served sight­see­ing. The Funicu­lar was in part pre­dic­ated on being able to uplift ski­ers to the Ptar­mig­an in 70mph winds, but improved weath­er fore­cast­ing and inform­a­tion dis­sem­in­a­tion vs 20 years ago neg­ates that require­ment. People are more choosy when to travel (and where to travel), the crit­ic­al factor to provid­ing a good exper­i­ence (in line with the CNPA work­ing prin­ciple D) and com­mer­cial suc­cess is being to open in a timely man­ner once the storm abates. Once the wind has gone a chairlift and gon­dola can be opened quickly, where­as the Funicu­lar is fre­quently delayed or doesn’t open at all after sig­ni­fic­ant snow storms. The unfor­tu­nate para­dox is that the more fresh snow and thus bet­ter con­di­tions are, the big­ger the drift prob­lems with the funicu­lar and the longer it is out of action. The funicular’s abil­ity to oper­ate in high­er winds vs chairlifts / gon­dolas is often over­stated as with regards CairnGorm this debate is fre­quently framed in terms of the 25mph oper­at­ing lim­it which was applied to the White Lady Chairlift. Where­as the Glen­coe Access Chairlift which itself is 10 years older than the Funicu­lar has an uplift lim­it of 50mph across the line. A mod­ern high speed 6 seat detach­able chairlift would, with good tower pos­i­tion­ing on a sens­ible align­ment, be able to exceed the wind tol­er­ance of the Access Chairlift, to around 60mph. Page 9

Plan­ning Applic­a­tion: 2020/0076/DET Engin­eer­ing works for strength­en­ing funicu­lar via­duct | OBJEC­TION A good exper­i­ence for both snowsports and sight­see­ing cus­tom­ers, and eco­nom­ic viab­il­ity of the oper­at­or, requires that the lift in ques­tion is able to oper­ate reli­ably when snow con­di­tions are good. Demand for both snowsports and winter sight­see­ing will be high­er in peri­ods of good snow cov­er — the lift com­pan­ies need ​‘to make hay when the sun­shines’! Funicu­lar vs Nevis Range Gon­dola & Glen­coe Access Chair The Feb­ru­ary Half Term peri­od is a crit­ic­al junc­ture in determ­in­ing the com­mer­cial suc­cess or oth­er­wise of the sea­son. Assess­ing the per­form­ance of the CairnGorm Funicu­lar against the Nevis Range Gon­dola and Glen­coe Access Chairlift for the last 10 sea­sons of Funicu­lar oper­a­tion is insight­ful. Days of oper­a­tion in the month of Feb­ru­ary by year CairnGorm Nevis Range Glen­coe Year Funicu­lar Gon­dola Access Chair 2009 21 25 22 2010 22 27 24 2011 20 25 24 2012 25 24 21 2013 23 25 25 2014 4 22 21 2015 20 22 25 2016 21 20 22 2017 18 22 24 2018 23 25 24 Accu­mu­lated 197 237 232 Aver­age Open 19.7 23.7 23.2 Days CLOSED 85 45 50 Avg Days LOST 8.5 4.5 5 While the Funicu­lar can oper­ate in high­er wind speeds than the oth­er two lifts, the oth­er factors which affect its oper­a­tion more than neg­ate the wind­speed advant­age. The Funicu­lar loses nearly twice as many Feb days on aver­age as the Gon­dola. Page 10

Plan­ning Applic­a­tion: 2020/0076/DET Engin­eer­ing works for strength­en­ing funicu­lar via­duct | OBJEC­TION In their report to HIE in 2018, SE Group noted that the funicu­lar can not in prac­tice match its nom­in­al 1200 per­sons per hour capa­city. That requires a depar­ture at the full 120 per­son car capa­city every 6 minutes, the shortest per­miss­ible jour­ney time is 4 minutes which leaves only 2 minutes for unload­ing and load­ing of the cars. Oper­a­tion­al real­ity is load times are around 6 minutes and to keep turn­arounds from con­sid­er­ably exceed­ing that only 100 pas­sen­gers are usu­ally loaded (the 120 capa­city is imprac­tic­al when major­ity are ski­ers / snow­boarders). Even with a 4 minute jour­ney time, that means only 6 depar­tures an hour are achieved giv­ing a prac­tic­al max capa­city of just 600 pas­sen­gers per hour. The mid-sta­tion not being at the mid point of the track requires a double stop, this effect­ively lim­its the funicu­lar to one uplift every 15minutes when mid-stop­ping which reduces the the­or­et­ic­al capa­city to 480 per hour, and apply­ing the same cri­ter­ia of load­ing only 100 per car means in prac­tice only 400 an hour get uplif­ted to the Ptar­mig­an (and only 200 an hour from each sta­tion, a fig­ure that is only a THIRD of the 600 pas­sen­gers per hour that both the White Lady and Car­park Chairlifts were indi­vidu­ally cap­able of). The Funicu­lar Rail­way is dys­func­tion­al in winter, it is low capa­city, high cost and sucks up a dis­s­porop­in­ate amount of staff time / resources deal­ing with track buri­als and buri­al of the tun­nel entrance. This has knock on effects delay­ing open­ing of oth­er tows and ter­rain which only serves to fur­ther degrade the snowsports customer’s exper­i­ence. Repair­ing the Funicu­lar Rail­way is thus con­trary to the CNPAs work­ing prin­ciple D that ​“CairnGorm Moun­tain should provide a good Scot­tish ski exper­i­ence with facil­it­ies and uplift com­men­sur­ate with scale.” Page 11

Plan­ning Applic­a­tion: 2020/0076/DET Engin­eer­ing works for strength­en­ing funicu­lar via­duct | OBJEC­TION F) Sum­mer vis­it­ors should be provided with an oppor­tun­ity to enjoy the moun­tain envir­on­ment and be close to nature and wild­ness. In com­par­is­on to the setup at Nevis Range and Glen­coe, CairnGorm with an oper­a­tion­al funicu­lar falls well short of meet­ing the object­ive of work­ing prin­ciple F. Sight­seers are con­veyed from one intern­al sta­tion to anoth­er by enclosed funicu­lar car­riage from which only a mod­est pro­por­tion of pas­sen­gers get a clear and unob­struc­ted view from. To arrive at a Top Sta­tion from which there is no exit and is all too fre­quently inside a cloud. Both the Funicu­lar and closed sys­tem at the Ptar­mig­an isol­ates sum­mer vis­it­ors from the moun­tain envir­on­ment and provides a poor vis­it­or exper­i­ence. While a gon­dola is also enclosed, fam­il­ies and groups can travel as indi­vidu­al groups in their own cab­in, all hav­ing unres­tric­ted views from a high­er vant­age point. Argu­ably the sense of both wild land and of trans­ition from forest to moun­tain plat­eau would be great­er in Coire na Ciste, and superb views which are less often obscured by cloud are avail­able at lower elev­a­tions. Page 12

Plan­ning Applic­a­tion: 2020/0076/DET Engin­eer­ing works for strength­en­ing funicu­lar via­duct | OBJEC­TION The dropped pro­pos­al to build a board­walk above the Funicu­lar Tun­nel to a view­ing plat­form was an admis­sion by CML that the Ptar­mig­an Res­taur­ant (while use­fully situ­ated for snowsports cus­tom­ers) is actu­ally too high up the moun­tain to give a con­sist­ently good vis­it­or exper­i­ence to sight­seers, being in cloud 1 day in 3. Expand­ing the Ptar­mig­an as per the pre­vi­ously approved plan­ning applic­a­tion does little to address the short­com­ings of the Ptar­mig­an in terms of appeal to sight­seers, par­tic­u­larly repeat vis­it­ors who are essen­tial to eco­nom­ic viab­il­ity. The closed sys­tem at the top and loss of egress at mid-sta­tion par­tic­u­larly affected less phys­ic­ally able bird watch­ers who were unlikely to ven­ture far but pre­vi­ously used the Chairlifts. The issue of winter con­ges­tion in the Ptar­mig­an build­ing could more effect­ively be addressed at less cost and provide a bet­ter over­all vis­it­or exper­i­ence by re-estab­lish­ing the Shiel­ing Res­taur­ant. In the event the Funicu­lar does re-open, year round use of a new Shiel­ing and funicu­lar pas­sen­ger egress and entry from the mid-sta­tion level would at least in part mit­ig­ate the Funicular’s short­com­ings as a sum­mer sight­see­ing attrac­tion and assist with meet­ing object­ive F. Page 13

Plan­ning Applic­a­tion: 2020/0076/DET Engin­eer­ing works for strength­en­ing funicu­lar via­duct | OBJEC­TION G) The oper­a­tion­al mod­el for CairnGorm Moun­tain needs to be fit for pur­pose and afford­able in the long-term. The Funicu­lar Rail­way from pub­lic­ally avail­able evid­ence (see pages 2 to 4) would fail to meet this cri­ter­ia even if it was cur­rently oper­a­tion­al, far less facing a repair bill of upwards of £10million to return to oper­a­tion. In total over 2/​3rds of the piers are in need of strength­en­ing includ­ing every pier situ­ated above mid-sta­tion, which rep­res­ents 2/​3rds of total requir­ing remedi­al works. Thus 2/​3rds of the work is required where drift­ing issues are most pre­val­ent. There is lack of detail in the plan­ning applic­a­tion about the exact form and func­tion of the pier props, this raises the fol­low­ing con­cerns: • Though the scale of the props are mod­est com­pared to the via­duct as a whole, they will act to increase snow accu­mu­la­tion prob­lems for the funicu­lar. • That will fur­ther impact oper­a­tion­al reli­ab­il­ity of the funicu­lar and increase resources required to open the lift in good snow cov­er. Page 14

Plan­ning Applic­a­tion: 2020/0076/DET Engin­eer­ing works for strength­en­ing funicu­lar via­duct | OBJEC­TION • No evid­ence is provided that the props and anchors will them­selves will not require inter­ven­tions due to slope creep and down­hill pres­sure of deep snowpack accu­mu­la­tions. • The props them­selves will require to be mon­itored and main­tained, adding to the oper­at­ing costs of the funicu­lar which was already unvi­able as a vis­it­or attrac­tion. • There is no clar­ity over the pro­posed lifespan of the pro­posed repair or wheth­er it will allow the funicu­lar to be returned to full capa­city oper­a­tion. • No explan­a­tion as to how fre­quently the props will need to be mon­itored. If they require reg­u­lar inspec­tions through­out the year, this could render the Funicu­lar inop­er­able dur­ing peri­ods of good snow con­di­tions. It is clear that giv­en the poor con­di­tion of the Funicu­lar via­duct at only 20 years of age com­bined with the addi­tion­al struc­tur­al sup­ports that to a great­er or less­er extent the Funicu­lar will hence­forth incur ongo­ing high­er upkeep costs than had been expec­ted. In all like­li­hood the main­ten­ance and oper­at­ing costs of the funicu­lar will con­tin­ue to rise mak­ing it ever less viable. Such a scen­ario being unsus­tain­able was the exact reas­on giv­en for rul­ing out long term oper­a­tion of the Car­park and White Lady Chairlifts as means of link­ing a new Base and Ptar­mig­an Sta­tion — the do min­im­um uplift option that was con­sidered as the only altern­at­ive to build­ing the funicu­lar. Giv­en lack of clar­ity in the applic­a­tion and oth­er points raised in this doc­u­ment, this plan­ning applic­a­tion is not com­pat­ible with the work­ing prin­ciple that ​‘the oper­a­tion­al mod­el for CairnGorm Moun­tain needs to be fit for pur­pose and afford­able in the long term’ as the Funicu­lar is almost cer­tain to require ongo­ing pub­lic sub­sidy or will con­tin­ue to under­mine the viab­il­ity of the snowsports area, to the det­ri­ment of nation­al park. Page 15

Plan­ning Applic­a­tion: 2020/0076/DET Engin­eer­ing works for strength­en­ing funicu­lar via­duct | OBJEC­TION Con­clu­sion Repair­ing the Funicu­lar will res­ult in ground dis­turb­ance to at least 4 times as many sites in the White Lady cor­ridor as install­a­tion of a new over­head lift on broadly sim­il­ar align­ment to either the former White Lady Chairlift or T‑bar. More per­tin­ently in plan­ning terms, if the pro­posed repairs go ahead it will res­ult in greatly increased ground dis­turb­ance, dif­fi­culty and inflated final costs of the ulti­mate remov­al of the fail­ing Funicu­lar via­duct. This plan­ning applic­a­tion is incom­plete, its exist­ence means the applic­ant HIE has pre­judged the Mas­ter Plan­ning pro­cess cur­rently under way. Res­tor­a­tion of the Funicu­lar Rail­way to ser­vice as per this applic­a­tion is incom­pat­ible with CNPA work­ing prin­cipes D, F and G, while the fact this applic­a­tion (and oth­ers) exist without an approved Mas­ter Plan is incom­pat­ible with work­ing prin­ciple B and thus under­mines the whole set of work­ing prin­ciples and the CNPA as plan­ning author­ity. For all the reas­ons out­lined above, this plan­ning applic­a­tion should be refused. Alan Mack­ay 9 Bish­ops Park Inverness IV3 5SZ Page 16

BSCG info From:BSCG info Sent:20 Apr 2020 23:38:23 +0100 To:Planning;Stephanie Wade Subject:2020/0076/DET BSCG Com­ments (Resend with sub­ject) Badenoch & Strath­spey Con­ser­va­tion Group Fiod­hag, Nethy­bridge, Inverness-shire PH25 3DJ Scot­tish Char­ity No. SC003846 Email info@​bscg.​org.​uk Web­site bscg​.org​.uk/n 20 April 2020 Dear Stephanie Wade 2020/0076/DET | Engin­eer­ing works for strength­en­ing funicu­lar via­duct | Cairngorm Moun­tain Glen­more Aviemore High­land PH22 1RB BSCG wishes to object to this applic­a­tion and requests the oppor­tun­ity to address the plan­ning com­mit­tee when they determ­ine the pro­pos­al. The applic­a­tion red line bound­ary does not show the whole site that would be impacted by the pro­pos­al. Such impacts can be anti­cip­ated to res­ult in sig­ni­fic­ant dam­age to hab­it­ats and land­scape. The new tem­por­ary tracks that are required to gain access to the piers are not included in the red line bound­ary. The work­ing area where machinery may be driv­en and con­sequentlysig­ni­fic­ant impacts occur, is sig­ni­fic­antly great­er than the red line are­as­sur­round­ing each pier (e.g. as shown in the ​“Site Lay­out Detail” maps of Fig 1 of the Atmos report). It appears these addi­tion­al areas would bring the total area for plan­ning per­mis­sion to over 2ha and there­fore the applic­a­tion should be treated as a Major Applic­a­tion, with all that that requires, includ­ing a Pre-Applic­a­tion pro­cess. We are con­cerned about the tracks being called ​‘tem­por­ary’. Giv­en that there will be ongo­ing mon­it­or­ing, main­ten­ance, and poten­tially addi­tion­al repairs in the future, we have no con­fid­ence that the plan­ning author­ity could jus­ti­fi­ably refuse an applic­a­tion to retain some or all of the tracks.

Bey­ond the red line bound­ary, we under­stand there would be no plan­ning over­sight. We can­not under­stand how the CNPA can ful­fil the aims of the Nation­al Park if the con­struc­tion and use of access tracks and the use of machinery on unpro­tec­ted ground bey­ond any tracks, that could cause sig­ni­fic­ant eco­lo­gic­al, hab­it­at and land­scape dam­age in a sens­it­ive moun­tain envir­on­ment, is allowed to pro­ceed without any plan­ning con­trols. The Plan­ning State­ment by Ryden states the site bound­ary for work requir­ing plan­ning per­mis­sion is 0.98ha. The claim is made that ​“some of the strength­en­ing counts as repair work and does not require plan­ning per­mis­sion.” This includes work on the bear­ings and strength­en­ing the beams, requir­ing use of machinery that will impact on theground round about. Wheth­er or not this is a fair apprais­al of the plan­ning require­ments, there remains the issue of how machinery accesses the sites to carry out the work, which is a sig­ni­fic­ant mater­i­al con­sid­er­a­tion and clearly must fall with­in plan­ning, espe­cially at such a sens­it­ive site. There are dis­crep­an­cies about the num­ber of piers and anchor blocks between applic­a­tion doc­u­ments, which also relates to dis­crep­ancy over the total area of the rect­angles around these. We are con­cerned that this applic­a­tion has gone out for pub­lic con­sulta­tion in the absence of accur­ate and cor­rect inform­a­tion on these basic mat­ters. It is also stated that exist­ing tracks will be heav­ily used and will need to be upgraded. This too should be covered in plan­ning. Nor­mally the whole work­ing area would be included in an applic­a­tion, as was required for recent applic­a­tions on the hill. This applic­a­tion is for work at a high alti­tude, where con­di­tions are chal­len­ging and the envir­on­ment sens­it­ive. This applic­a­tion is com­plex and there are unknowns. There are sig­ni­fic­ant issues that are likely to arise once work is under­way. The plan­ning author­ity needs to ensure it can keep plan­ning con­trol of the works involved in this applic­a­tion. The CNPA should seek to avoid prob­lems of cut­ting corners and failed enforce­ment. The qual­ity of the res­tor­a­tion work is fun­da­ment­al to the land­scape impacts. We are con­cerned that the applic­a­tion does not provide suf­fi­cient inform­a­tion on the meth­ods and details to be used, to enable the CNPA to fully assess how robust the pro­pos­als are. We are also con­cerned at the abil­ity of the plan­ning author­ity to be able to enforce stand­ards of con­struc­tion, espe­cially at this site where there are sig­ni­fic­ant tech­nic­al and phys­ic­al chal­lenges with­in a sens­it­ive envir­on­ment. We find the level of inform­a­tion provided in the Atmos report on Hab­it­at Man­age­ment & Res­tor­a­tion far too gen­er­al. There is no reas­on why the applic­ant can­not spe­cific­ally detail what is required, how and where the meth­ods they refer to will be car­ried out, how water­courses will be crossed, how wet ground will be pro­tec­ted, and the like. There are

sound reas­ons why this inform­a­tion should be detailed now, at this appro­pri­ate stage of the plan­ning pro­cess. The pro­tec­tion of hab­it­ats and land­scape depends on these details. The suc­cess of this pro­ject in land­scape and hab­it­at terms is not helped if the­plan­ning author­ity adopts an approach of delay­ing requir­ing inform­a­tion. We are con­cerned that at this stage of the plan­ning pro­cess it is only an Out­line Peat Man­age­ment Plan that has been provided, rather than a Final PMP, and at the incom­plete­ness of the inform­a­tion provided on peat excav­a­tion and man­age­ment of peat. The Out­line PMP states that the excav­ated peat will be used for ​‘land­scap­ing’. How­ever, no inform­a­tion is provided on this, in spite of the fun­da­ment­al import­ance of con­serving and enhan­cing land­scape qual­ity at this site. For example, it is not spe­cified which areas are to be land­scaped with excav­ated peat; nor what will be the impacts and how they are to be mit­ig­ated, of car­ry­ing out this land­scap­ing, includ­ing access­ing the loc­a­tions with machinery. The Brind­ley Report on land­scape impacts fails to identi­fy Glen­more as a close set­tle­ment. The report only refers to Aviemore, at more than 10k dis­tant, and from that infers that the devel­op­ment is in a more remote loc­a­tion than is the case. Glen­more may have a small num­ber of per­man­ent res­id­ents, but it has a sub­stan­tial num­ber of vis­it­ors includ­ing to the camp site, the Youth Hostel, Glen­more Lodge, Loch Mor­lich beach, Glen­more Forest, the reindeer centre and so on. These are sig­ni­fic­ant recept­ors that should not be ignored. The repair of the funicu­lar does not change inher­ent prob­lems. A sur­vey of 40 Avi