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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



2024-05-23 00:51:52 +0100

DPEA Note received on 21 May 2024
Following the virtual pre-examination meeting, held by DPEA on 13 May, to discuss arrangements and procedures for the Coul Links Inquiry, it was agreed that a Hearing will take place, perhaps at Embo, in the week commencing 11 November with the possibility of overrun sessions, if required, in the week commencing 25 November. The Hearing will consist of written presentations that will not be subject to cross-examination of evidence, as would normally occur at an Inquiry! This is worrying.

2024-04-25 12:42:38 +0100

The Northern Times, 19 April, 2024
Coul Links opponents claim controversial golf course plan faces erosion threat

The Times, April 21, 2024
Coul Links dunes are being washed away, golf course opponents say
"Campaigners say that extreme weather has caused coastal erosion to accelerate,"

2024-04-01 23:47:28 +0100

Bloomberg UK, 22 March, 2024
Scottish Golf Is Sliding Into the Sea

2024-02-09 10:21:27 +0000

8 February, 2024
Scottish Government calls in Coul links second planning application for review & determination.
Uncertain if this will lead to a repetitious Groundhog Public Inquiry.
"The Scottish Ministers have given this Direction in view of the proposed development’s potential impact on nationally and internationally important natural heritage assets and the need for an appropriate understanding of the scale and degree of potential economic benefits arising from the proposal."

2023-12-08 11:37:22 +0000

Bird Guides, 7 December, 2023
Highland Council grants permission for Coul Links golf course
"Members of the public can raise their voice in support of saving Coul Links and ask Ministers to reconsider the plans ... and signing this e-action."

2023-12-06 13:44:33 +0000

6 December, 2023
Highland Council North Planning Applications Committee councillors voted 8:6 in favour of permitting development of the Coul Links golf course, against the recommendation of its professional planners & the advice of the Scottish Government nature conservation agency, NatureScot. In respect of NatureScot's objection, the application should now be referred to Scottish ministers (MSPs) for possible call-in & review.
Planning meeting webcast (see item 6.2):

2023-11-30 01:05:35 +0000

The Coul Links proposed golf development is on the agenda of the Highland Council North Planning Applications Committee's meeting on 6 December 2023.
Highland Council's Area Planning Manager North report to committee recommends refusal of Communities for Coul's golf course planning application.
Councillors will discuss, decide and vote whether or not to follow her recommendation. If they decide in favour, the matter should be referred to Scottish Government ministers, since the government's own agency NatureScot strongly objected to the proposals, supported by Highland Council Ecologist (both May 2023). That might result in a government 'call-in' & a second ['Groundhog'] Public Inquiry for a nearly identical and equally damaging scheme, with the addition of worsening climate change impacts, which would be farcical.
See 6.2 of agenda.

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

Canadian Broadcasting Corporation (CBC) News, 20 April, 2023
N.S. [Nova Scotia] government says no to golf course in West Mabou Beach Provincial Park

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