Skip to main content

To: Highland Council & Scottish Government

Save COUL LINKS protected nature from destructive 'Déjà Vu Groundhog Day' golf course

Prevent destruction of beautiful, protected & internationally important dune habitats from golf course development.

Why is this important?

For the 2nd time in 6 years a planning application for an 18-hole international golf course threatens Coul Links, within Loch Fleet Site of Special Scientific Interest (SSSI), Loch Fleet & Dornoch Firth Special Protection Area (SPA) & Ramsar international wetland.

The Screening Request was from a councillor on behalf of a defunct football club, but the Scoping & Full application were adopted by an astroturfing & greenwashing stalking horse, Communities for Coul (C4C), purporting to represent the local populace (see Update 16 June, 2021), appointing the previous rejected developer/applicant team & intending to dissolve!

C4C represents golf & tourism interests in coastal Sutherland. The 2023 golf course plan is similar to the ‘environmentally friendly’ design of the previous Coul Links Ltd planning saga, first mooted in October 2015. 90% of the current proposed course area overlaps the earlier, refused in 2020 after Scottish Government intervention.

The government decision followed recommended refusal by Highland Council’s Planning Officer; 1864 planning objections, objection by government agency Scottish Natural Heritage (now NatureScot); a campaign by Buglife, Butterfly Conservation, Marine Conservation Society, National Trust for Scotland, Plantlife, RSPB, Scottish Wildlife Trust, Ramblers, Scotways & Not Coul (all objecting again); a Wembley Stadium capacity 38Degrees petition; & 4 weeks of Public Local Inquiry, whose Report recommended refusal.

Scottish Ministers summarised in February 2020:
“Reporters have concluded that the harmful impacts of this development to protected habitats & species would outweigh the potential socio-economic benefits. This proposal does not comply with the relevant provisions of the Highland Wide Local Development Plan & runs contrary to Scottish planning policy’s emphasis on protecting natural heritage sites & world class environmental assets. The Scottish Government has considered the reporter’s findings carefully & agree with the recommendation that planning permission should be refused”.

The earlier destruction is described in the vandalism petition: which you are also invited to sign, since the 'Groundhog' application is so similar.

The developer to re-emerge since planning refusal is Mike Keiser of Bandon Dunes in Oregon, Cabot projects in Nova Scotia & now Cabot Highland in UK. He is a past funder of Heartland climate change denial Institute & doesn’t have an impeccable conservation record in Oregon: In Nova Scotia, Cabot seeks permission to convert wild protected public dunes to a golf course:

One significant improvement to the previous course design is that most of the nationally important dune Juniper will not be destroyed: The application claims that wetlands are avoided but dune slack habitats remain on 13 of the 18 holes & two greens, because the driest forms of this habitat are inaccurately mapped.

Several assertions common to both planning applications & their inadequate Environmental Impact Assessments were refuted by Inquiry. One is that the golf course will only impact 1% of the SSSI, which is predominantly tidal estuary & also contains substantial areas of beach, saltmarsh & native pinewood. It ignores the effects of golf management & disturbance beyond constructed tees & greens of biopoverty lawns, & intensively mown fairways, & the effects of habitat fragmentation on ecological integrity.

Tees & greens would be excavated, recontoured, turfed with introduced amenity grassland, fertilised & irrigated. Fairways, ostensibly to preserve biodiversity & naturalness, would be mown weekly in the growing season, compacting irregular topography & gradually reducing any sward to the most mower-tolerant & trampling-tolerant grasses & mosses, with no opportunity for surviving herbs to flower. Dune heath, chiefly of heathers, mosses & lichens, with negligible & tussocky grasses, would be obliterated by mowing, leaving habitat susceptible to more wind erosion than desirable. Mowing would nowhere produce a world-class playing surface & eroded areas would likely be patched up with introduced grasses, & 'weeds' treated with herbicide.

The main contention is the claim that golf development is the only way to fund conserving Coul Links for nature, with golf management ending management neglect (by the landowner, a 2017 developer), initiating removal of ‘invasive’ species. This is untrue, as a land management agreement with NatureScot has commenced & generous funds are available for future work. Gorse, birches, Bracken, Meadowsweet & Burnet Rose are all perceived by the development team as undesirables to be severely controlled, despite their collectively supporting numerous insects & some nesting birds. While some control of first three species is desirable to preserve more valuable habitats, they are all natural & native components of dune vegetation. Bracken is commonly the target of prejudice but:

Coul Links is one of the most biodiverse & intact dune habitat systems surviving in Scotland, where much has already been lost to golf. Naturalness, supported by size, is a chief criterion for SSSI evaluation & selection. Golf would destroy that integrity.

50% of anticipated market for Coul Links golf would be from USA, jetting to Scotland to contribute to climate warming emissions & coastal erosion.

Planning: ref. 23/00580/FUL
Not Coul:

How it will be delivered

By email to Highland Council Planning as an objection and then, if the planning application gains traction, by email to Scottish Government.

Embo, Dornoch IV25, UK

Maps © Stamen; Data © OSM and contributors, ODbL



2023-11-04 13:55:36 +0000

The Coul Links proposed golf development is expected to be on the agenda of a Highland Council North Planning Applications Committee's meeting in early December 2023:

2023-10-07 00:05:25 +0100

Highland Council published a notice in The Northern Times on 28 September, stating that additional information in support of the Coul Links golf course planning application has been submitted on behalf of the applicant. Public comments relating to that information can now be made to the planning authority until 26 October, 2023. See the planning link at the foot of this petition main text & read the submitted documents of 19-25 September, 2023.

2023-09-04 11:13:46 +0100

The Northern Times, 1 September, 2023
Investigative journalism platform uncovers direct link between Communities for Coul and US golf developers
"The Coul Links planning application was due to be discussed at the North Planning Applications Meeting on September 12 but it is understood that it has now been put back to the following meeting on November 1."
Local opponents & this petition (with minor tweaks) have been making astroturfing criticism for a few years, but it's good to get press airing.

2023-08-29 00:58:00 +0100

The Ferret, 27 August, 2023
Group labelled ‘astroturfing front’ for US golf developers

2023-08-01 09:59:32 +0100

The Observer, 30 July, 2023
(not The Guardian at its most analytical!)
An ‘AstroTurf front’ for developers? Row over plans to build an eco golf course on a Scottish heritage site

2023-05-18 15:20:18 +0100

PLANNING LATEST DEADLINE for comment is often extended for consultees. If the Comment facility is open I believe that is an opportunity for public to comment or supplement previous objections.

Highland Council ePlanning: ref. 23/00580/FUL
Not Coul advice on how to object:
(NB Rue-leaved Saxifrage (Saxifraga tridactylites), mentioned in some objections, is recorded on drier dunes north of Loch Fleet SSSI & probably not on Coul Links.)

2023-05-18 15:08:26 +0100

16 May, 2023
Highland Council Ecology objects ref. 23/00580/FUL
See Documents Consultee Comment RESPONSE - ECOLOGY OFFICER for PDF
"NatureScot lead on advice regarding Protected Areas.
We fully support their objection to the development based upon the negative impact upon the Loch Fleet Site of Special Scientific Interest (SSSI) which contravenes National Planning Framework 4 (NPF4) Policy 4c.
We object to the proposed development due to insufficient current ecological information to allow a robust assessment of the ecological resources of the site and associated impacts ..."

2023-05-05 16:38:07 +0100

5 May, 2023
NatureScot (government conservation agency) objection lodged with Highland Council.
See Documents ref. 23/00580/FUL for PDF
"... the conclusion of our assessment is that this proposal is contrary to National Planning Framework 4 (NPF4) requirements not to compromise the objectives of SSSI designation and the overall integrity of Loch Fleet Site of Special Scientific Interest ... We consider that the EIAR underplays the adverse impact of the development. We advise that this proposal will have a significant adverse impact on the protected sand dune feature at Coul Links in respect of extent, structure and function, with consequent adverse impacts on the characteristic species. We therefore object to this proposal as it will result in unavoidable adverse effects on natural heritage interests of national importance ... If the planning authority intends to grant planning permission against this advice, you must notify Scottish Ministers."

2023-04-17 01:13:48 +0100

The Ferret, 16 April, 2023
Coul Links developer donated to climate change denial group

The National, 16 April 2023
Fears over donations of billionaire behind golf course plans

2023-04-07 12:52:48 +0100

The Scotsperson, 29 March, 2023
'Video featuring "fake" locals branded "embarrassing" in US billionaire’s bid to build championship golf course on scenic Scottish Highland dunes'

2023-03-08 14:07:32 +0000

28 February, 2023
FULL PLANNING APPLICATION validated by Highland Council has been advertised in press & public can comment until 9 April.
Longer comments are best prepared in Word & pasted into the form, as there is a time-out limit. Further guidance on objecting is available on the Not Coul website:
Planning application ref.: 23/00580/FUL
paste reference number into Highland Council search box

2022-03-29 00:45:22 +0100

BBC, 25 March, 2022
'Group says golf project would protect dune habitat'

Highland Council ePlanning, 21 March, 2022
Screening Request has now progressed to Scoping Request
with modified golf course design (I believe inappropriate for SSSI)
Planning ref: 22/01330/SCOP:
NB Comments may not be submitted at this time.
EIA regulations:

2021-10-27 23:56:02 +0100

Northern Times, 22 October, 2021
'Director of Communities4Coul (C4C), a group spearheading plans for a championship golf course at Coul Links near Embo has hit back after Brora Community Council declined to write a letter in support of the project.'

2021-10-17 10:57:17 +0100

Northern Times, 15 October, 2021
'Cool response to request for Coul Links support letter'
'Secretary Ruwan Uduwerage-Perera said he was concerned about the environmental implications of the development, which will cover one per cent (sic.) of the Loch Fleet Site of Special Scientific Interest.//Brora Community Council secretary Ruwan Uduwerage-Perera was against writing a letter of support for the planned Coul Links golf course.
He said: “Until the SSSI issues are resolved, it is a no. From my perspective the community council cannot be seen to by supporting something that breaches SSSI regulations even if there might be economic benefit.”'

2021-06-16 23:44:16 +0100

Northern Times, 16 June, 2021
'Local poll result shows majority backing for golf course at Coul Links'
This article is misleading. Only 44.4% of the ‘community’, in the selected postcodes targeted between Dornoch and Brora, voted! 69.2% of 44.4 means only 30.7% of the ‘community’ was in favour. The locals were posed with a paradoxical leading question, “Do you support a community planning application for an environmentally sensitive, world-class golf course to be built at Coul Links near Embo?” This was supported with just one sheet of propaganda about 'sustainable' golf and [strategic] philanthropy, a Coul Times ‘newspaper’ circulation and choreographed Zoom meetings.

2021-06-11 12:20:29 +0100

2 June, 2021
Communities for Coul Ltd published selected questions & answers from virtual 'Town Hall' Zoom meetings, for example:

"Mike Keiser ploughed through forest built a road and drilled bore holes before bandon dunes was built (sic.), without permission and found out by a forest ranger how does C4C reconcile such appalling behaviour?"

"This accusation is not true. There were problems at a potential second site at Bandon Dunes when a contractor did some work without permission from Mike Keiser’s organisation. This issue has now been resolved and the community are working happily with Mike Keiser."

Accurate track record:
NB The Keiser course was to have been the 6th in the Bandon, Oregon area but disconnected. It was rejected but the current course total is seven. My ORCA contact tells me that 'The community is not “working happily with Mike Keiser.”'

2021-04-29 21:51:11 +0100

Northern Times, 29 April, 2021
''Major milestone' as Communities For Coul tee up golf course architect Mike Keiser'

With Keiser's re-emergence as the developer, if the full planning application is made and approved, and because the Bill Coore golf course design is the same for both planning proposals to Highland Council, the earlier petition, with over 92,000 UK signatures, is still relevant, so

2021-03-31 23:12:30 +0100

Bunkered, 27 March, 2021
'Highlands farmer hopes to build new 'world class' Scottish course'


2021-03-22 12:43:12 +0000

The Guardian, 21 March, 2021
'Renewed Highland golf course plan has environmentalists crying 'Fore!''

The Scotsman, 21 March, 2021
'Coul Links: Leading economist says new Scottish government guidance could pave way for golf course approval as pandemic highlights need for ‘crucial’ investment':

The Quad, 21 March, 2021
'Coul Links Project To Get Another Shot Before Planners?':

2021-02-19 13:09:42 +0000

Northern Times, 19 February, 2021
'Dornoch hotelier plans four-star upgrade if renewed Coul Links golf course plan successful':

2021-02-18 11:50:22 +0000

Bunkered, 17 February, 2021
'Bandon Dunes: A little piece of Scotland in the USA':

"As for Keiser, he has gone on to cement his legacy as arguably the most influential and strangely underrated golf developer of all time. He has expanded his reach with Cabot Cliffs in Canada, Barnbougle Dunes in Tasmania and, more recently, had hoped to expand his portfolio by creating a new course, Coul Links, within striking distance of the source of his original muse, Royal Dornoch. Alas, political red tape means that is now unlikely to happen."

However, his Bill Coore golf course design is in the current screening request.

2021-02-11 09:00:49 +0000

Bunkered, 9 February, 2021
'"Defeated" Scottish golf course plans to be resurrected':

2021-02-10 16:18:20 +0000

Northern Times, 10 February, 2021
'Lease agreement reached over Coul Links':

2021-02-06 00:08:05 +0000

Press & Journal, 5 February 2021
'Highland community to lease site earmarked for revived golf course plan':

2021-02-05 00:44:14 +0000

BBC News, Highlands & Islands, 5 February 2021
'Coul Links: New plans for golf course in Sutherland':

2021-01-29 13:09:15 +0000

Northern Times, 29 January 2021
'Investors prepared to back Coul Links Hotel':

Press & Journal, 28 January, 2021
'Plans to build eco hotel if Highland golf course development is revived':

2021-01-27 16:03:04 +0000

Press & Journal, 26 January 2021
'Controversial golf course plans could be back on as campaign group calls refusal "grave disservice" to area':

2021-01-22 09:40:10 +0000

Northern Times, 22 January 2021
'Community group formed to revive Coul Links golf plan':
GOLF DEVELOPMENT WEBSITE 'Communities for Coul' launched:
Twitter: @Communities4Co1

2021-01-10 19:09:02 +0000

20,000 signatures reached

2020-10-20 20:02:47 +0100

Northern Times and Ross-shire Journal, 20 & 21 October, 2020
'Two-year obstacle to new Coul Links plan':
"A NORTH planning officer has advised the group behind an attempt to resurrect a championship golf course at Coul Links, Embo, to be cautious about proceeding."

2020-10-17 14:36:45 +0100

Northern Times, 9 October, 2020
'The Way I See It by [Councillor] Jim McGillivray'
supporting his planning application for Coul Links golf course,
showing misconceptions about who is responsible for SSSI management,
influencing local public opinion and perhaps displaying his conflicts of interests:

2020-10-02 19:52:38 +0100

Northern Times, 2 October, 2020
'Golf course at Coul Links in the frame again'
"A Highland Council spokeswoman said a consultation process would have to take place before a planning application for such a major development could be submitted."

2020-09-30 18:26:23 +0100

10,000 signatures reached

2020-09-29 14:41:19 +0100

5,000 signatures reached

2020-09-29 11:57:53 +0100

1,000 signatures reached

2020-09-29 11:51:42 +0100

500 signatures reached

2020-09-28 20:13:55 +0100

100 signatures reached

2020-09-28 19:12:07 +0100

50 signatures reached

2020-09-28 18:11:05 +0100

25 signatures reached

2020-09-28 17:44:55 +0100

10 signatures reached

2020-09-28 17:02:03 +0100

The Scotsman, 14 September, 2020
'Campaigners pledge to fight new plan for golf course at wildlife site':

2020-09-28 16:54:26 +0100

Holyrood magazine, 21 February, 2020
'Planning permission refused for controversial Coul Links golf course':,planning-permission-refused-for-controversial-coul-links-golf-course_15146.htm#.XlHJa0vWvIs.twitter

Scottish Government decision of February 2020 about previous planning application:

2020-09-28 16:51:41 +0100

PREVIOUS PETITION history & updates:
'Save Coul Links protected nature (Loch Fleet Ramsar SSSI & SPA) from golf development vandalism'
Please sign current Déjà Vu Groundhog Day petition in preference to the old vandalism one but NO HARM IN SIGNING BOTH, to get old petition over 100,000 threshold, as the planning applications (at time of writing) are practically the same!