5 May, 2023
NatureScot (government conservation agency) objection lodged with Highland Council.
See Documents https://wam.highland.gov.uk/wam/ 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."
To: Highland Council & Scottish Government
Save COUL LINKS protected nature from destructive Déjà Vu Groundhog golf course
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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 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 Scoping & Full application were adopted by an astroturfing & greenwashing stalking horse, Communities for Coul (C4C), purporting to represent local populace (see Updates ↓ of 16 June 2021 & 27 Aug 2023) but representing golf & tourism interests in coastal Sutherland, appointing same developer, applicant of 1st failed planning application, & intending to dissolve! The 2023 golf course plan is similar to the ‘environmentally friendly’ design of 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 https://you.38degrees.org.uk/petitions/conserve-coul-links-for-nature-not-golf-1 (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 https://littlesis.org/person/42895-Michael_Keiser & doesn’t have an impeccable conservation record in Oregon: https://oregoncoastalliance.org/bandon-dunesbiota-bulldoze-roads-and-dig-bore-holes-in-bandon-state-natural-area/. Cabot NS failed to obtain a lease to convert wild protected public dunes to a golf course: https://www.cbc.ca/news/canada/nova-scotia/west-mabou-beach-provincial-park-cabot-golf-tory-rushton-1.6817243.
The only substantial improvement to the previous course design is 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 effects of retreating coastline, expanding wetlands, golf management & disturbance beyond constructed tees & greens of biopoverty lawns, & intensively mown fairways, & 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 during 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 supports Stonechats & insects including: https://butterfly-conservation.org/sites/default/files/habitat-bracken-for-butterflies.pdf.
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.
DPEA Hearing: Scottish Government - DPEA - Case Details (scotland.gov.uk)
Planning: https://wam.highland.gov.uk/wam/ ref. 23/00580/FUL
Not Coul:
https://notcoul.org/
https://www.youtube.com/watch?v=Bnm7krCGoGQ&t=4s
Coastal Erosion Crisis: https://www.youtube.com/watch?v=I_Zpr6c1elI&list=LL
Information: https://www.coullinksgolf.com/
Coul photos: https://twitter.com/VisitGroatbury/status/1636675680938217472
'Community' propaganda: https://www.communities4coul.scot/
The Screening Request was from a councillor on behalf of a defunct football club, but Scoping & Full application were adopted by an astroturfing & greenwashing stalking horse, Communities for Coul (C4C), purporting to represent local populace (see Updates ↓ of 16 June 2021 & 27 Aug 2023) but representing golf & tourism interests in coastal Sutherland, appointing same developer, applicant of 1st failed planning application, & intending to dissolve! The 2023 golf course plan is similar to the ‘environmentally friendly’ design of 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 https://you.38degrees.org.uk/petitions/conserve-coul-links-for-nature-not-golf-1 (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 https://littlesis.org/person/42895-Michael_Keiser & doesn’t have an impeccable conservation record in Oregon: https://oregoncoastalliance.org/bandon-dunesbiota-bulldoze-roads-and-dig-bore-holes-in-bandon-state-natural-area/. Cabot NS failed to obtain a lease to convert wild protected public dunes to a golf course: https://www.cbc.ca/news/canada/nova-scotia/west-mabou-beach-provincial-park-cabot-golf-tory-rushton-1.6817243.
The only substantial improvement to the previous course design is 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 effects of retreating coastline, expanding wetlands, golf management & disturbance beyond constructed tees & greens of biopoverty lawns, & intensively mown fairways, & 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 during 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 supports Stonechats & insects including: https://butterfly-conservation.org/sites/default/files/habitat-bracken-for-butterflies.pdf.
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.
DPEA Hearing: Scottish Government - DPEA - Case Details (scotland.gov.uk)
Planning: https://wam.highland.gov.uk/wam/ ref. 23/00580/FUL
Not Coul:
https://notcoul.org/
https://www.youtube.com/watch?v=Bnm7krCGoGQ&t=4s
Coastal Erosion Crisis: https://www.youtube.com/watch?v=I_Zpr6c1elI&list=LL
Information: https://www.coullinksgolf.com/
Coul photos: https://twitter.com/VisitGroatbury/status/1636675680938217472
'Community' propaganda: https://www.communities4coul.scot/
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 arguments, for and against, in a Hearing in November 2024 (see Updates ↓).
