Item5Appendix3cGeneralComments20190247DET

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 5 Appendix 3c 13/12/2019

AGENDA ITEM 5

APPENDIX 3C

2019/0247/DET

REP­RES­ENT­A­TIONS — GENERAL

Moun­tain­eer­ing Scot­land The Granary West Mill Street Perth PH1 5QP

By email to planning@​cairngorms.​co.​uk

16 August 2019

Dear Sir/​Madam

Engin­eer­ing works to smooth and re-grade land | Cairngorm Moun­tain Glen­more Aviemore High­land PH22 1RB

Ref­er­ence Num­ber: 2019/0247/DET

Moun­tain­eer­ing Scot­land wishes to com­ment on aspects of this pro­pos­al that raise con­cerns about its envir­on­ment­al impact and the visu­al effects of this.

Moun­tain­eer­ing Scot­land is a mem­ber­ship organ­isa­tion with over 13,000 mem­bers and is the only recog­nised rep­res­ent­at­ive organ­isa­tion for hill walk­ers, climbers, moun­tain­eers and ski-tour­ers who live in Scot­land or who enjoy Scotland’s moun­tains, and acts to rep­res­ent, sup­port and pro­mote Scot­tish moun­tain­eer­ing. Moun­tain­eer­ing Scot­land also acts on behalf of the 80,000 mem­bers of the Brit­ish Moun­tain­eer­ing Coun­cil (BMC) on mat­ters related to land­scape and access in Scot­land, and provides train­ing and inform­a­tion to moun­tain users to pro­mote safety, self-reli­ance and the enjoy­ment of our moun­tain environment.

We wel­come the call in of this pro­pos­al by Cairngorms Nation­al Park Author­ity as con­struc­tion work of this nature should be prop­erly scru­tin­ised. Unfor­tu­nately, we are of the opin­ion that the applic­ant has provided insuf­fi­cient detail to enable prop­er scru­tiny of the poten­tial visu­al and envir­on­ment­al impacts.

Our first point is that the Cairngorms Nation­al Park Author­ity has stated that all works for the ski area should be part of a devel­op­ment mas­ter­plan, which High­lands and Islands Enter­prise has agreed to. Yet this pro­pos­al comes in advance of such mas­ter­plan­ning – there is no con­text with­in which to assess this pro­pos­al. We urge the Park Author­ity to post­pone the assess­ment of this pro­pos­al until the Mas­ter­plan has been con­sul­ted upon and agreed.

Our second point is that the Work­ing with the Envir­on­ment at Cairngorm doc­u­ment pro­duced by HIE sets the con­text for devel­op­ment work in this very sens­it­ive envir­on­ment. It states that ​“spe­cial prin­ciples and prac­tices are needed to mit­ig­ate dam­age dur­ing con­struc­tion and man­age­ment oper­a­tions on the Estate and in the ski area.” It is our opin­ion that the pro­pos­al doc­u­ments do not provide the spe­cial prin­ciples and prac­tices that you require as Plan­ning Authority.

A con­struc­tion meth­od state­ment usu­ally accom­pan­ies such applic­a­tions detail­ing tech­niques for dif­fer­ent sec­tions of land. Each sec­tion will require more detail on work­ing prac­tices and the work­ing cor­ridor, how con­struc­tion traffic gets to and from hard stand­ing areas, soil con­ser­va­tion meas­ures and reseed­ing pro­ced­ures, for example.

Our third point is that the tim­ing of the pro­posed man­age­ment works requires care­ful con­sid­er­a­tion to avoid leav­ing an unfin­ished and unve­get­ated sur­face that would look unsightly and be prone to erosion. The poten­tial for soil com­pac­tion and the time needed for reve­get­a­tion are key con­sid­er­a­tions giv­en the expos­ure and short grow­ing sea­son. An Eco­lo­gic­al Clerk of Works and

even a Land­scape Clerk of Works, giv­en the sens­it­iv­ity of the loc­a­tion and the cur­rent con­di­tion of the ski area, are essential.

I hope that you find our com­ments help­ful and if you have any doubts at all on the prob­ab­il­ity of an appro­pri­ate out­come in the land­scape being achieved, then we would wel­come and sup­port a refus­al of this proposal.

Yours sin­cerely

Dav­ie Black Access & Con­ser­va­tion Officer Moun­tain­eer­ing Scotland