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To: Highland Council & Scottish Government AGAIN (since 2023 golf plans are similar to previously and developer is the same)

Save Coul Links protected nature (Loch Fleet Ramsar SSSI & SPA) from golf development vandalism

Prevent precious and beautiful wild dune habitats from being turned into a golf course.

Why is this important?

A planning application was submitted to Highland Council to construct an 18-hole international golf course on Coul Links, Sutherland but the applicant is not Trump Golf. The target lies within Loch Fleet Site of Special Scientific Interest, Special Protection Area for birds & international Ramsar wetland, which is predominantly estuary. Coul Links is one of very few expanses of undeveloped & largely unspoilt sand dunes remaining in Scotland, & its special wildlife & landforms are protected by those UK & European legal designations & international treaty. Development would be at odds with Highland Council’s environmental policies.

The government’s conservation agency, which objected, describes SSSIs as “areas of land & water that Scottish Natural Heritage (SNH) considers to best represent our natural heritage - its diversity of plants, animals & habitats, rocks & landforms, or a combination of such natural features. They are the essential building blocks of Scotland's protected areas for nature conservation … It is an offence for any person to intentionally or recklessly damage the protected natural features of an SSSI."

Trump got official approval to destroy Foveran Links SSSI after exaggerating economic benefits, much shenanigans & Scottish Government intervention. That site will probably be denotified as SSSI (confirmed Dec 2020). The present speculator is Coul Links Ltd. led by Mike Keiser, President of Bandon Dunes Golf Resort, Oregon, Trump Golf’s main global rival, & entrepreneur Todd Warnock who similarly claims 'I can make this environment better'.

From Oct 2015, press articles publicised proposals for the golf course. Developers blithely spoke of perceived advantages to golf & economy, ignored conservation designations but mentioned new nature trails & wildlife ‘information’. Development propaganda has not informed the public what wildlife, habitat, landforms & amenity will be destroyed & degraded. Exhibitions in Aug 2016 & Oct 2017, to elicit public votes of support, paid scant attention to wildlife & presented flawed ecology. The former relegated a habitat survey to just a tiny cryptic map at Scottie dog eye level. The less truth people know the less insensitive the plans appear.

Golf course construction would be an unnatural catastrophe. It would mean excavating, recontouring, burying wet slacks, reseeding with introduced grasses, addition of plastic membranes, irrigating & intensively mowing 40.5 ha, habitat fragmentation, under-grazing & eradication of (valuable grazers & browsers) rabbits & deer, fertilising & herbiciding (& run-off), with substantial collateral damage, immediate & insidious, & bulk habitat & species translocation of 4.5 ha. dune heath, with insects & rare lichens, & 100 rare dune juniper, with displacements on receptor areas, contrary to government's 'A Habitats Translocation Policy for Britain' (2003) recently relaxed.

Size & connectivity of habitats are ecologically critical, affecting species populations, diversity, interaction & survivability. Construction traffic, borrow pits & sand-moving would disturb & damage the geomorphology, hydrology (water quality & seasonality), low-nutrient profiles (on which plants rely) & habitat biodiversity over a much wider area. Fine irregular patterns of topography, micro-habitats & vegetation mosaics, like dry hummocks & wet slacks, would be destroyed, displacing specialised, scarce, rare & vulnerable plants & insects. Human disturbance would reduce bird populations in surviving habitats.

Dunes naturally have cycles of erosion & deposition. Plans include greens & fairways constructed near foredune crests & a burn outlet, eliminating important species & weakening natural sea defences regardless of risks. This would probably necessitate adding a culvert & an artificial expanse of boulder rip rap, leading to beach narrowing (part National Nature Reserve) & coastal erosion nearby, the judgement of leading geomorphologist Dr Jim Hansom of Glasgow University.

Compromise from 'invasive' species, the result of management neglect & rejected SNH grant aid (£230,000 since 2010), & regenerating North American lodgepole pines (misidentified by golf's ecologists as Scots pines), is being grossly exaggerated to excuse 'remediating' so much natural vegetation with manicured mediocrity. Naturalness is a key criterion in SSSI selection. Bracken, gorse, tall herbs & rank grassland support more wildlife than lawns: Fonseca's seed-fly, thought endemic to Sutherland dunes, requires 'weeds'. Claims about biodiversity net gain from moving fragile habitats & species, controlling Scots Pine, rare & native at Coul, & cessation of duck shooting are ludicrous.

Threatened habitats outside the SSSI, in a golf 'remediation' area, are of comparable biodiversity, including Fonseca's Seed-fly, Baltic Rush, Rough Horsetail, Moonwort, Skullcap, Butterwort, Fragrant, Frog & Creeping Lady's-tresses Orchids, Small Blue butterfly & plants at their northern UK limits, like Restharrow & abundant Rock-rose, the food-plant of scarce Northern Brown Argus butterfly.

The developers talk of 'sensitivity', 'minimalism', ‘naturalness’, 'utmost care' & the high repute of its designers, but Oregon track record conflicts:

Leading dune ecologist Dr Tom Dargie describes the developer’s surveys & Environmental Statement as ‘unfit for purpose’. He judges the site worthy of (European) Special Area of Conservation (SAC) status, which would have prevented such development being considered.

There is a superfluity of coastal golf courses in Scotland, many undersubscribed, some closing, mostly eroding. The environmentally responsible option is to avoid development within such special, rare & fragile habitats.

How it will be delivered

Petition was delivered to Highland Council Dec 2017 & May 2018. Councillors (except 1.5) voted to approve application. Scottish Government rejected it in Feb 2020 after Inquiry. Then a similar planning Screening Request surfaced in July 2020, becoming a full application in February 2023, so TWO PETITIONS will be submitted to Highland ePlanning, including

Loch Fleet, United Kingdom

Maps © Stamen; Data © OSM and contributors, ODbL


2023-03-18 16:08:07 +0000

FOR UPDATES to this 'Vandalism' Petition A please see its fellow 'Groundhog' Petition B in response to the March 2023 full planning application:
Details of why the net effects of the new proposals, described in the developer's Environmental Impact Assessment Report (EIAR), would be similarly destructive to those in the earlier rejected planning application, despite one major improvement with respect to dune Juniper, can be seen on that petition and on the Not Coul website:

2021-05-03 15:33:49 +0100

There are now two active petitions.
Save COUL LINKS protected nature from destructive 'Déjà Vu Groundhog Day' golf course:

Presently there is little difference between the earlier planning application and the new planning screening request, in terms of extensive environmental impacts, as the 18-hole golf course design plans are Bill Coore's and identical, and Mike Keiser will be the developer if the resubmitted golf course gets planning approval:
'Major milestone' as Communities For Coul tee up golf course architect Mike Keiser:

2020-09-14 20:40:19 +0100

THE SCOTSMAN 14 September 2020, extract:
"Permission for an 18-hole golf course at Coul Links, near Embo in East Sutherland, was refused by the Scottish Government in February this year.
"A separate golf proposal has now been lodged with Highland Council for the site, which hosts a dune ecosystem of national and international importance and is protected by multiple conservation 
designations ...
"The new application, made in the name of Embo Junior Football and Athletic Club c/o its chairman James McGillivray, is for 'development of an 18 hole championship links golf course and practise area' covering around 805 acres."

2020-03-14 19:30:21 +0000

DPEA REPORT to Scottish Ministers (who agreed to reject the planning application):

DPEA INQUIRY WEBCASTS (see 26 Feb to 22 March, 2019):

Impartial information for all things Coul:

COUL LINKS LTD (weblink presently not functioning):

WIKIPEDIA (few inaccuracies, like no mention of Mike Keiser):

2020-03-12 21:18:26 +0000


2020-03-07 11:39:37 +0000

Surfbirds blog

“I believe that golf courses, especially when they’re on a spacious site, will be deemed by scientists who quantify these things as carbon sponges,” Keiser says. “And wouldn’t that be good for golf?” [especially when sited on undisturbed wet peat bogs].

2020-03-03 20:43:28 +0000


2020-02-27 10:38:20 +0000

'in a joint statement given exclusively to the NT, Todd Warnock, Mike Keiser and Chris Haspell said: “We are reviewing the decision thoroughly and will respond in due course.”'
'The councillor, who lives next to the site, said: “If ever a place encapsulates sheer degenerative despair in a single miserable and depressing landscape, it must be Coul Links".'

2020-02-26 13:04:18 +0000

'Scottish golf: A game for all or a playground for the rich?'
"Elsewhere, the news that the contentious Coul Links development near Dornoch has been refused planning permission was at least a relief; a moral victory against the whims of marauding corporate interests."

2020-02-26 01:17:15 +0000

'Not Coul: Mike Keiser's dream to build new links course in Scotland is over ...
'“I’m moving on. I have so many other projects,” Keiser tells The Forecaddie. “God bless Dornoch.” ... He didn’t want to speak on behalf of Warnock, his partner, who may choose to appeal the ruling.'
Envirotec Magazine:

2020-02-26 01:12:34 +0000

The Coul Links proposed golf development PLANNING APPLICATION WAS REFUSED by Scottish Ministers on 21 February 2020. The Ministers’ decision is final but any individual unhappy with the decision has a right of appeal to the Court of Session within 6 weeks, so THIS PETITION WILL REMAIN OPEN for more signatures UNTIL AT LEAST 4 APRIL 2020.

STV News at Six- Coul Links

2020-02-24 09:22:06 +0000

Petition is successful with 91,985 signatures

2020-02-22 20:15:44 +0000

Waltham Forest Guardian:

2020-02-22 01:02:15 +0000

2020-02-21 17:54:01 +0000

SCOTTISH GOVERNMENT HAS REFUSED COUL LINKS DEVELOPMENT,planning-permission-refused-for-controversial-coul-links-golf-course_15146.htm