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To: Highland Council & Scottish Government

Save COUL LINKS protected nature from destructive Déjà Vu Groundhog 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 wetland. Councillors approved of this Groundhog application by a whisker on 6 Dec 2023, but the Scottish Government called it in on 8 Feb 2024 for review.

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 Updates ↓ of 16 June 2021 & 27 Aug 2023) but representing golf & tourism interests in coastal Sutherland, appointing the same developer, applicant of the 1st failed planning application, & intending to dissolve! The 2023 golf course plan is similar to the ‘environmentally friendly’ design of the previous Coul Links Ltd planning saga, first mooted in Oct 2015, approved almost unanimously by councillors, but refused in 2020 after Scottish Government intervention.

The decision followed crucial objection by government agency Scottish Natural Heritage (now NatureScot); recommended refusal by Highland Council’s Planning Officer; 1864 planning objections, 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 (please sign); & 4 weeks of Public Local Inquiry, whose Report recommended refusal.

Scottish Ministers summarised in Feb 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 developer to re-emerge is Mike Keiser of Bandon Dunes Oregon, Cabot Nova Scotia (NS) & Cabot Highlands UK. He was a funder of Heartland climate change denial Institute & doesn’t have an impeccable conservation record in Oregon: Cabot NS failed to obtain a lease to convert wild protected public dunes to a golf course:

The only substantial improvement to the previous course design is the abandonment of the major juniper translocation experiment within the SSSI.

Assertions common to both planning applications & their inadequate Environmental Impact Assessments were refuted by Inquiry. One is that golf will only impact 1% of the SSSI, which is predominantly tidal estuary & contains substantial areas of beach, saltmarsh & native pinewood. This ignores the effects of the retreating coastline, expanding wetlands, 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 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 & trampling-tolerant (from 25,000 rounds per annum) grasses & mosses, with no opportunity for surviving herbs to flower. Dune heath, chiefly of heathers, mosses & lichens, with sparser & 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.

C4C claims 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 & 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 the 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:
Coastal Erosion Crisis:
Coul photos:

How it will be delivered

Both petitions have been submitted to Highland Council ePlanning as a Public Comment objection. Following approval of the planning application by councillors on 6 December 2023, the Scottish Government called-in the planning application on 8 February 2024 for review and determination. The government DPEA reporters will scrutinise objections as part of the Inquiry process (see Updates ↓).

Embo, Dornoch IV25, UK

Maps © Stamen; Data © OSM and contributors, ODbL



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 headline is misleading. Only 44.4% of the ‘community’, in the selected postcodes between Dornoch and Brora, voted! 69.2% of 44.4 means only 30.7% ‘community’ support. 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 one page of golf propaganda & [strategic] 'philanthropy', a 'Coul Times' flyer & choreographed Zoom meetings. C4C's website claims to have 70% support of local communities: I objected to Highland Council about the ballot & Dornoch Area Community Council's support.

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':