To: Highland Council & Scottish Government

Save protected nature at Loch Fleet from golf development vandalism

Contact Campaign Creator
Campaign created by
Andrew Weston
Save protected nature at Loch Fleet 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 has been submitted to Highland Council to construct a golf course on Coul Links, Sutherland but the applicant is not Donald Trump. The developer’s target lies within Loch Fleet Site of Special Scientific Interest, Special Protection Area for birds & Ramsar wetland, a site that is predominantly tidal mudflat. 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. Its development would be at odds with Highland Council’s environmental policies.

The government’s conservation agency, which has objected to the proposals, states on its website that SSSIs “are those 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 Golf got official approval to destroy Foveran Links SSSI (Aberdeen) after exaggerating economic benefits, much shenanigans & Scottish Government intervention. Similar could happen again but this time the 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.

From October 2015, articles in The Northern Times publicised proposals for the international 18-hole golf course. The developers blithely spoke of the perceived advantages to golf & economy, ignored nature conservation legal designations but mentioned new nature trails with wildlife ‘information’. Development propaganda would not inform the public how much wildlife, habitat, landforms & amenity have been destroyed & degraded. Exhibitions, to elicit public votes of support, have either paid scant attention to the wildlife, as in the August 2016 displays which relegated a habitat survey to just a tiny cryptic map at Scottie dog eye level, or in October 2017 presented flawed ecology. The less truth people know the less insensitive the plans appear.

Constructing the golf course on Coul Links would create an unnatural catastrophe. It would mean bulldozing, digging, recontouring, burying wet slacks, reseeding with introduced grasses, habitat fragmentation, under-grazing, control of wild grazing animals (rabbits & deer), fertilising & herbiciding (with run-off), irrigating & intensively mowing 40.5 acres, with substantial collateral damage, immediate & insidious. The attempted bulk habitat & species translocation, of dune heath & 100 rare coastal juniper, would not involve Kew Gardens staff.

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 & seasonal levels), low-nutrient profiles (on which plants rely) & habitat biodiversity over a much wider area. Wetlands would be filled with sand to reduce waterlogging for lawns, displacing specialised, scarce, rare & vulnerable plants & insects. Fine irregular patterns of topography, micro-habitats & vegetation mosaics, like dry hummocks & wet slacks, would be destroyed. Human disturbance would further reduce bird populations in surviving habitats.

'Compromise' from 'invasive' species [the result of management neglect & rejected SNH grant aid (£0.23M since 2010)] & stunted felled N American lodgepole pines (misidentified by developer'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. The endemic Fonseca's seed-fly, thought confined globally to Sutherland dunes, requires 'weeds'. Claims about an environmental net gain from moving fragile habitats & species, controlling Scots pine, rare at Coul & in its native zone, & cessation of duck shooting are ludicrous.

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

Threatened dunes outside the SSSI are of comparable quality, including the tallest foredune & spring habitats, supporting many species, including endemic Fonseca fly, rough horsetail, frog orchid, small blue butterfly & plants at their northern UK limits, like restharrow (destined for a golf green) & abundant rock-rose, the latter the food-plant of a dependent priority species, northern brown argus butterfly.

The developers talk of 'sensitivity', 'minimalism', ‘naturalness’, 'utmost care' & the high repute of its designers, but experience in Oregon paints a different picture:

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. The environmentally responsible option is to avoid development within such special habitats.

How it will be delivered

The petition was delivered to Highland Council on 22 Dec 2017 but is STILL ACTIVE. Frequent revisions to the planning application result in the public being given further 28 day EXTENSIONS for comment to Highland Council Planning. Please see Updates below about Public Notices allowing extensions for public comment. This petition will be submitted to Highland Council at any future deadline(s) with the additional signatures.

Loch Fleet

Reasons for signing

  • SSSI are there for a reason. They need to be respected so that we have a diverse planet rather than our endless destruction of this planet in 3 generations.
  • SAY NO TO TODD TRUMPINGTON WARNOCK’S ECO-DOME PROJECT AND BOGLECROFT!! Dornoch/Embo/Sunderland will be changed forever, and you won’t get it back!!!! If Bandon Dunes in Oregon, USA is designed based upon Royal Dornoch, smart Americans will golf Bandon Dunes. And Americans come to Scotland to see the Scots, not other Americans. Anyone with integrity would not come to Scotland to line the pockets of other Americans.
  • There are plenty of golf courses but not enough unspoilt habitat to support local wildlife - which is one of the reasons we have enjoyed visiting Dornoch and the surrounding area for many years.


2018-04-19 12:02:26 +0100

Internet search for 'Coul Links' still tells untruths:

"Coul Links: supported by the community| Dornoch and Embo/Coul Links is a fantastic opportunity to boost the local economy and protect a wonderful site. The local community supports Coul Links." Coul Links Limited

Of this petition's signatures before Christmas 2017 the demography was:
Signatures COUL LINKS PETITION on 22/12/2017: SCOTLAND Postcodes Totals: AB1,575 DD857 DG581 EH4,035 FK802 G3,195 HS76 IV1,820 KA873 KW342 KY1,166 ML636 PA950 PH863 TD437 ZE99; TOTAL SCOTLAND 18,307; TOTAL ENGLAND, WALES & NI: 68,479; TOTAL UK: 86,786.

IV=Inverness (including Dornoch & Embo); KW=Kirkwall (including Golspie).

One means of protecting the site would be to site golf ambitions elsewhere. Many locals, including golfers, are against the proposals.

Bandon geomorphological
Would bulldoze the biological:
Rare Fonseca’s seed-fly
And prime SSSI
Swatted aside as no obstacle.

2018-04-16 11:13:55 +0100

There are expected revisions to the planning application which should allow the public a further 28 days for comment, once processed & advertised. Please watch this space.

2018-04-05 11:01:00 +0100

Informative and impartial website, not to be confused with the very selective (propagandist) developer's website (as some have done), constantly updated:

2018-04-03 18:07:02 +0100

Excellent downloadable PODCAST (28 minutes):
'Dunes into Bunkers' ~ BBC Radio 4 'Costing The Earth'
Tuesday 3 April 15:30 & Wednesday 4 April 21:00
Peter Gibbs (meteorologist) investigates the environmental impact of Trump's golf development on 'protected' dunes at Menie and the controversy over the proposed new course at Coul Links.

Radio 4 Pick of the Week (episode available until 8 May: drag slider to 13:25):

NB Dornoch Courthouse was not derelict as described. I don't criticise what has been achieved for business & employment at the former Courthouse in Dornoch, but here is a photograph of the 'derelict' building in March 2015, before it was refurbished for a change to different uses:


2018-04-02 14:41:07 +0100

Wildlife in Scotland has weaker protection against damaging developments than wildlife in England and Wales, according to emails released by the government’s conservation agency, Scottish Natural Heritage.
"The regime for safeguarding vital wetlands under the international Ramsar Convention is “stricter” south of the border says SNH, prompting fears that Scotland’s wildlife could “lose out in a race to the bottom”.

2018-03-31 16:59:43 +0100

BBC Radio Scotland @BBCRadioScot 'Out of Doors' Saturday 31 March 2018 includes feature about Coul Links (available until 29 April: drag slider to 35:15):

2018-03-26 10:41:13 +0100

SEPA revised response:

SEPA's response pertains mostly to land outside the SSSI, some of which is of SSSI quality, particularly dunes, springs & heath near Embo, but doesn't mention the dangers of excavating latter's Big Dune sea defence.
Northern Times article refers to this petition's signatories as being from 'across the world' but the signatures are all from UK postcodes.

2018-02-22 00:35:39 +0000

News from an associated proposed development in Nova Scotia:

2018-02-19 11:22:51 +0000

Coastal erosion prospects for Coul Links Ltd & some Fonseca's seed-fly science:

Commissioned Report No. 618
"Survey and ecology of Botanophila fonsecai ... endemic to Scotland"
© Scottish Natural Heritage 2013
'...the greater part of Coul Links was out of bounds because of landowner objection'.

Mike Keiser donation to Heartland climate change denial institute:

Aftermath of storm at Embo, December 2012, after larger overnight waves had subsided:

2018-02-07 12:50:53 +0000
Greens' John Finnie challenges government over Coul Links:
Open Championship venues such as St Andrew's and Royal Troon could be under water by the end of the century if sea levels rise even slightly as a result of climate change, according to a new report:
Climate Coalition report:

2018-02-05 23:03:11 +0000

'The Ferret' with some Freedom of Information disclosures:

2018-02-04 11:27:42 +0000

American tycoon getting cosy with Scottish Government over golf course plans - can this be happening again?

2018-01-30 10:13:52 +0000

Meanwhile a parallel controversy is brewing in Inverness County, Nova Scotia, Canada over the proposed expansion of the Cabot Links & Cliffs golf courses, a Keiser private co-enterprise, into public state-owned dunes at West Mabou Beach:
'Eco-friendly' 'recycling [of] communities':

2018-01-16 15:59:25 +0000

The formation of a more detailed Recreation and Access Management Plan (RAMP) and revisions to hydrological proposals, by the developers, should mean that the public will be given a further 28 day EXTENSION TO OBJECT to the golf development.
Andrew Weston

2018-01-09 14:28:54 +0000

Golf developers and supporters still displaying ignorance, panto-style lack of ecological nuance and cavalier attitude towards nature conservation and protection designations, like Ramsar:

Not Coul rebuttal to fake information on developer's website:

2017-12-22 00:00:09 +0000

The PETITION is STILL ACTIVE but was delivered to Highland Council ePlanning on 21 December & again late on 22 Dec deadline, when it stood at 86,786 UK signatures.
18,307 signatories are resident in Scotland & of those 1,820 (c.10%) are from the Inverness postcode & 342 from the Kirkwall postcode (mainly Caithness & Orkney). Edinburgh, Perth, Shetland and Borders postcodes had very good results relative to population size. Population analysis shows strong support in N Scotland, followed by a weighting towards more eastern postcodes. Edinburgh, Glasgow, Aberdeen & Kirkcaldy postcodes led the numbers table, with respectively 4,035; 3,195; 1,575 & 1,166 signatures.
Thanks greatly for all this & continued support throughout the UK.
The applicants are still intent on development.
Andrew Weston

2017-12-21 21:27:36 +0000

2017-12-21 13:36:24 +0000

From Bandon's abandon in May & June 2014:
CONSERVATION TRACK RECORD of Bandon Dunes Golf Resort subsidiary Bandon Biota:
Article by courtesy of Oregon Coast Alliance (ORCA) November 2017
NB © Any reference or linking to this article should be credited to ORCA.
Andrew Weston

'The OREGONIAN' September 2015:
"Golf course developer abandons plans to buy Oregon state park land"

2017-12-19 11:44:07 +0000

Some very apt commentary here below the article (AW):

2017-12-17 10:55:21 +0000
"impinging on 1.1% of the Loch Fleet SSSI, seemed to make it a no-brainer."

This ignores several truths: the SSSI is predominantly tidal estuary; an ecological principle of comparing similar habitats, respecting specialised dependent wildlife, like dunes or dune micro-habitats or food-plants; the substantial damage inside & outside the golf lawn from construction & management. Half Coul's coastal juniper, national priority habitat, c.95 plants, saplings to 5m-wide bushes, would be moved but not by Kew Gardens staff. The 'finest team in the world' has a poor conservation track record in Oregon. The option of siting the golf course less destructively is ignored. The monopolising of all coastal dune systems of any extent for golf would be a national disgrace. What is Coul Links as a percentage of the UK? Temperate coastal dunes are much rarer than tropical rainforest.
Andrew Weston

2017-12-14 22:47:44 +0000

2017-12-12 19:59:12 +0000

which does not separate the golf course & reservoir applications:

2017-12-12 12:36:58 +0000

Regularly updated impartial website for MOST THINGS COUL, from science to propaganda (except for the more arrant nonsense of some press letters):

2017-12-09 15:17:15 +0000
Regarding armchairs, I am grateful for the publicity in the Golpunk articles but my photograph on its screenshot was not taken from one. I have recorded & quantified priority species & habitats on the Coul Links proposed lawns, that the developer's ecological surveyors failed to spot, & ecologically surveyed over a thousand square kilometres of land elsewhere for government bodies without an armchair; likewise Dr Dargie's survey of 95% of Scotland's dunes for SNH.
Councillor McGillivray of The Crofter 'armchair environmentalists' article (Nov 2017) should take note too when he peddles the same old invasive species & environmental net gain nonsense after SNH & many others have rejected them.
Andrew Weston

2017-12-05 22:03:31 +0000

"Golf course backers shrug off burgeoning opposition":

2017-11-28 10:51:16 +0000

"The [developer's] EIA lacks a suitable level of detail and accuracy for a proposal in such an environmentally sensitive location."

2017-11-27 21:28:10 +0000

50,000 signatures reached

2017-11-27 18:11:59 +0000

20,000 signatures reached

2017-11-24 22:30:16 +0000

2017-11-21 19:56:52 +0000
“Cars and cats kill more birds than golfers" (!):

BRACKEN for fritillaries & chats:
Some other SPECIES at Loch Fleet (incomplete data) for golf's net biodiversity loss (AW):

2017-11-11 14:45:16 +0000

2017-11-11 10:33:10 +0000

The communities of Dornoch & Embo are divided over the proposed golf course & some community group leaders are undemocratically speaking for their entire group & everyone else.

Since the bulk of Loch Fleet SSSI is tidal estuary, mudflats and saltmarsh, where Bandon Dunes Golf Resort or Coul Links Ltd did not consider development, and there is a large area of native Scots pine woodland (in different ownership), any 1.8% [1.1%] proportion of SSSI argument is unreasonable, taking into account the extent of DUNE HABITATS AFFECTED inside and outside the newly proposed 40 acres of lawn.

Andrew Weston
Ecological Surveyor

2017-11-07 14:01:43 +0000

2017-11-04 21:26:32 +0000


NB The earlier separate application appears like a case of the cart before the horse and based on a presumption of golf course development approval and perhaps even a second golf course outside the SSSI. The reservoir would influence the hydrology and ecology of the SSSI, so why was it not included with the main planning application for the golf course? This separation appears to be against Environmental Impact Assessment rules.
Andrew Weston

2017-11-04 21:26:08 +0000

'A parliamentary motion opposing a controversial £8million golf development in Sutherland has been lodged by MSP John Finnie, who claims it would be “catastrophic” for the local environment.'

2017-11-01 11:17:50 +0000

10,000 signatures reached

2017-10-28 11:22:35 +0100

2017-10-21 10:34:14 +0100

NB Dr Dargie and Mr Trump parted company when latter ignored ecological advice. Coastal juniper and shoreweed slacks are rare priority habitats, while the species are not rare:

2017-10-19 11:04:43 +0100

How can a golf course enhance diversity and duck the WINTER INUNDATION PROBLEMS? AW



Exhibitions, to elicit public votes of support, have either paid scant attention to the wildlife, as in the August 2016 displays which relegated a habitat survey to just a tiny cryptic map at Scottie dog eye level, or in October 2017 presented flawed ecology, like exaggerating invasive species to apply leverage to bogus arguments about a net biodiversity gain. The less truth people know the less insensitive the plans appear.
Andrew Weston

2017-10-12 12:05:53 +0100

2017-10-11 22:29:03 +0100

2017-10-09 10:55:57 +0100


One supporter and investor is the Embo Trust, a charity and trading company, both since March 2017 registered as a limited company, which does not represent all Embo.
The golf course would be at odds with one of its 'PURPOSES' (4.5):
"To advance environmental protection or improvement including preservation and conservation of the natural environment, the promotion of sustainable development, the maintenance, improvement or provision of environmental amenities for the community."
One director is an elected councillor who giving scope for multiple CONFLICTS OF INTERESTS between nature conservation, charitable status, business and democracy.
Andrew Weston

2017-09-28 14:13:30 +0100

"...Keiser says he wouldn’t have gone this far if he didn’t know every public body, politician and local citizen was solidly behind the project..."

NB This statement is inaccurate.
Andrew Weston

2017-09-11 14:48:29 +0100

2016-12-13 14:18:53 +0000

2016-10-14 20:32:13 +0100

5,000 signatures reached

2016-10-13 21:24:58 +0100

1,000 signatures reached

2016-10-13 16:45:18 +0100

500 signatures reached

2016-10-04 18:09:38 +0100

100 signatures reached

2016-09-27 23:34:35 +0100

"To develop a championship world class links course which reflects the existing landscape, embraces the natural, minimalist approach and benefits the East Sutherland Highlands."

2016-09-26 12:18:54 +0100

50 signatures reached

2016-09-23 17:08:58 +0100

PRESS ARCHIVE predating petition:

2016-09-12 15:15:13 +0100

25 signatures reached

2016-09-09 09:16:46 +0100

10 signatures reached