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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: https://butterfly-conservation.org/files/habitat-bracken-for-butterflies.pdf. 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: https://oregoncoastalliance.org/bandon-dunesbiota-bulldoze-roads

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 https://you.38degrees.org.uk/petitions/save-coul-links-protected-nature-from-destructive-deja-vu-golf-course-1

Loch Fleet, United Kingdom

Maps © Stamen; Data © OSM and contributors, ODbL

Updates

2018-06-16 23:32:10 +0100

https://www.pressandjournal.co.uk/fp/news/highlands/1498926/councillors-to-make-final-decision-on-coul-links-golf-course-plans/

NB Chair of Not Coul, Dr (not 'Mr' as is being repeated) Dargie, is one of the leading dune ecologists in the UK & has surveyed 95% of Scotland's dunes and machair habitats for Scottish Natural Heritage. Other members of the opposition campaign are surprised his judgement on hydrological impacts on the ecology have been dismissed by SEPA.

SNH's objection states: "The water table and water chemistry of Coul Links are very important as they influence the sand dune vegetation communities which they support, especially the sand dune habitats. Fertiliser, herbicide or pesticide could be washed towards or even into a dune slack potentially damaging these dune habitats."
AW

2018-06-16 10:18:27 +0100

Highland Council Planning Committee SPECIAL MEETING & WEBCAST about Coul Links is scheduled for Wednesday 20 June 2018. Scottish Environment Protection Agency has submitted new comments but no objections on hydrological or sea defence damage. Scottish Natural Heritage's objection remains: "We object to this proposal as it will result in significant adverse effects on sand dune habitat of national importance".
AW

https://highland.gov.uk/meetings/meeting/3992/north_planning_applications_committee

https://www.bbc.co.uk/news/uk-scotland-highlands-islands-44495020

2018-06-11 13:19:07 +0100

https://www.nts.org.uk/stories/conservation-bodies-ask-first-minister-to-step-in-on-coul-links-decision

2018-06-07 14:53:34 +0100

Planning meeting webcast 5 June 2018 (archived for 1 year):
https://highland.public-i.tv/core/portal/webcast_interactive/354088
The decision has been deferred, pending SEPA's consideration of extra material provided by Not Coul (timeously) about Ramsar wetland impacts & potential contaminated land. SEPA was 'relying on the accuracy of the habitat assessment that the applicant submitted' & Not Coul has questioned this with supporting evidence.
Andrew Weston

2018-06-06 12:08:33 +0100

https://www.pressandjournal.co.uk/fp/news/highlands/1491262/highland-councillors-defy-their-officials-by-voicing-unanimous-support-for-coul-links-plans/

Not all the Planning Committee spoke, so some may be minded to vote differently & follow the Planning Officer's recommendation to refuse planning permission, when the decision is made.
Several councillors spoke to say they are minded to approve of the development, disregarding the legal protection, Highland Council environmental policy, the recommendation of the Planning Officer, expert advice of Scottish Natural Heritage & the cogent & detailed objections of many conservation & access charities, Not Coul, independent ecologists, naturalists, golfers and other individuals, let alone the 89,000 petition signatories, c.2,000 of whom live in Highland Council region.
For reference (too late to object now): http://www.notcoul.com/object.html
AW

2018-06-05 23:05:08 +0100

"First minister must step in to save precious habitat from destruction"
http://thirdforcenews.org.uk/tfn-news/first-minister-must-step-in-to-save
http://thirdforcenews.org.uk/tfn-news/100-days-of-action-for-scotlands-endangered-species
http://www.golfpunkhq.com/news/article/coul-links-development-moves-another-step-closer
https://www.nts.org.uk/stories/conservation-bodies-ask-first-minister-to-step-in-on-coul-links-decision

2018-06-05 10:27:18 +0100

PLANNING MEETING & WEBCAST

Agendas, reports and minutes of North Planning Applications Committee

Agenda for Tuesday, 5 June 2018, commencing 10:30 am

Item 6.1 Coul Links golf course:
Development of 18 hole golf course, erection of clubhouse, renovation of existing buildings for maintenance facility, pro-shop, caddy hut, workshop, administration building, information booth, formation of new private access from C1026
Members are asked to agree the recommendation to refuse ...

Item 6.2 Coul Farm golf course reservoir & boreholes [outside SSSI]:
Members are asked to agree the recommendation to grant ...

https://www.highland.gov.uk/meetings/meeting/3981/north_planning_applications_committee

https://highland.public-i.tv/core/portal/webcast_interactive/354088

2018-06-05 00:33:29 +0100

https://www.pressandjournal.co.uk/fp/news/highlands/1487017/councillors-face-huge-decision-over-controversial-highland-golf-course-plans/
https://www.pressandjournal.co.uk/fp/news/highlands/1485264/coul-links-developers-welcome-renewed-objection-letter-from-scottish-natural-heritage/
http://www.thenational.scot/news/16265206.MSP_raises_hope_that_golf_course_plan_could_still_tee_off/

2018-06-01 10:17:01 +0100

https://www.thetimes.co.uk/article/sand-traps-trump-rivals-plan-to-build-450-acre-golf-course-3tjrkd6wm

2018-05-31 00:58:42 +0100

http://www.golfcoursearchitecture.net/content/coul-links-preparing-for-planning-hearing-set-for-5-june

Notes:

Dr Dargie surveyed 95% of Scotland's dunes for SNH. He parted company with Trump after his recommendation to avoid Foveran Links SSSI was ignored. That site may be denotified as an SSSI. Coul Links is more biodiverse and more highly protected (SSSI, SPA & Ramsar).

Aerial photo shows gorse in flower and the degree of developer's exaggeration about its invasion, which is being used to lever development.

Architect Coore told GCA: “Coul does not remind me of any site with which we have worked before. With its varied natural landforms and environments, it has a more multi-character feel than is generally seen at the majority of classic seaside links ... Coul has some of the most natural and interesting green sites we have ever discovered on any site ..."

So why create yet more of the same artificial biopoverty?
AW

2018-05-29 00:47:10 +0100

http://www.golfpunkhq.com/news/article/second-statutory-body-removes-key-objections-to-coul-links-golf-development-

NB
SEPA's objection pertains largely to areas outside the SSSI & doesn't mention the folly of building golf courses on eroding foredunes.
Earlier SNH objection to dune habitat loss and 'significant adverse effects' remains and ecologists not on the developer's payroll would judge is insurmountable:
http://www.notcoul.com/object.html
AW

2018-05-28 12:28:33 +0100

https://www.pressandjournal.co.uk/fp/news/highlands/1482079/campaigners-question-economic-claims-of-coul-links-developers/

2018-05-27 12:29:27 +0100

I believe the planning hearing is scheduled for 10:30 am on 5 June 2018 at Highland Council Inverness HQ. Public wishing to attend the planning meeting & listen to the case officer's Coul Links presentation could check with Communications & Resilience Office. I don't believe that public will be allowed to contribute. If too many attend, they might queue, camp or jostle for space & chairs:
https://www.highland.gov.uk/info/695/council_information_performance_and_statistics/386/communications_and_resilience_office

2018-05-21 13:50:18 +0100

SWT revised blog with new graphics:
https://scottishwildlifetrust.org.uk/our-work/our-advocacy/current-campaigns/coul-links/

2018-05-14 19:32:48 +0100

As advertised by Highland Council in The Northern Times and Edinburgh Gazette, an addendum to the planning application now results in a 28-day EXTENSION for PUBLIC COMMENT until 25 May 2018.
http://www.notcoul.com/object.html