Coul Links
Scottish Ministers have called-in the golf course development proposal at Coul Links, which threatens a protected sand dune habitat.
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Scottish Ministers have confirmed that the application for an 18-hole golf course on Coul Links must be referred to them for determination, meaning they have ‘called-in’ the proposal. This was after over 11,000 people took action to ask for the decision to be reviewed.
In December 2023, Highland Councillors voted by eight in favour, six against to grant the plans by developer C4C for a golf course at Coul Links, near Embo in East Sutherland. This decision to grant permission was against the advice of Highland Council’s own planning officers, and in the face of over 700 objections, including the objection from statutory consultee NatureScot, Scottish Government’s advisers on nature.
This Highland Committee decision was extremely disappointing and concerning. As NatureScot objected to the development due to the harm it would cause to protected sites for nature, the Council had to formally notify Scottish Ministers of their decision and give them an opportunity to call it in. Due to the national importance of this decision for nature, RSPB Scotland and our Conservation Coalition partners called on Scottish Ministers to step in to save Coul Links from development.
Background
Just over three years after planning permission was refused for a golf course at Coul Links in 2020, a new application for a golf course development on the same site was submitted to Highland Council in February 2023. The application can be viewed here.
After carefully considering the new application we objected strongly to it and encouraged others to do the same. You can view our obejction here and the annexes to it here (NB some sensitive information has been redacted by Highland Council). We've also summarised the reasons for our objection in this blog.
In 2019, over 13,000 people campaigned for the Scottish Government to 'call-in' a planning decision to grant a golf course on Coul Links, because of the harm it would cause to nature. The proposed golf course would have destroyed the unique collection of dune habitats and would have resulted in harmful disturbance to both wintering and breeding waders, waterfowl and other species, many of which are rare and/or declining in number.
The campaign was led by the Conservation Coalition, made up of seven environmental charities: Buglife, Butterfly Conservation Scotland, Plantlife Scotland, Marine Conservation Society, National Trust for Scotland, RSPB Scotland and Scottish Wildlife Trust
The Scottish Government called the application in, scrutinised the planning application through a Public Inquiry and in February 2020 they turned down the development plans for a luxury golf course on this highly protected site.
The decision by Scottish Ministers can be read here.
The Scottish Government decision letter in 2020 concluded that, ‘the local and regional socio-economic benefits of the development do not justify the adverse effects on the qualities of designation of the SSSI, SPA and Ramsar.’
This landmark decision was very welcome not only for Coul Links but in the context of the nature and climate emergency, and the commitment shown by the Scottish Government to protected areas.
This campaign success was brought about by a huge, collected effort the Conservation Coalition and many members of the public, including those in the local community, who supported the call-in campaign. We believe that the decision marked a watershed moment for planning decisions truly considering environmental needs and protection.
Sadly, despite this decision and NatureScot now working with the landowner to manage the protected sites on Coul Links, a new planning application for an 18-hole golf course has been submitted. We are once again working with our Conservation to ensure that this unique area is protected from inappropriate development.
Why is it worth fighting for?
Coul Links is a beautiful, natural coastal dune system, home to many species of wildlife. It is located immediately south of Loch Fleet in East Sutherland, Scotland. Coul Links is one of the last areas of undeveloped, species-rich dune habitat in Scotland. Together with Loch Fleet itself, Coul Links is a Site of Special Scientific Interest (SSSI) and an internationally designated Special Protection Area (SPA) and Ramsar site.
Coul Links is a mosaic of different dune habitats, each individually important and all increasingly rare. It is particularly special as a complete dune system with dynamic, shifting dunes, static older dunes, seasonally flooded dune slacks, and ancient sand dunes covered by heath.
The dune complex at Coul Links is home to a number of different birds, including ducks such Wigeon and Teal, which use the area as a safe haven during bad weather in the winter months. The shore next to Coul Links provides roosting and feeding habitat for wintering waders such as Dunlin and Oystercatcher. Many of the species are of Conservation Concern being either Red or Amber Listed.
The dunes also provide home to a colourful and rich variety of flowering plants and insects including some rare, specialist species.
Many of the animals, birds and insects present depend upon free movement between the different dune habitats at different stages of their life cycle.
How you can help
Please keep an eye on this page and a follow #SaveCoulLinks on social media for updates which you can like, share, and retweet.
Our position
We are very concerned about the new proposals and do not think the golf course plans can be accommodated on the designated sites (SSSI, SPA, and Ramsar) without unacceptable impacts to rare and valuable species and habitats at Coul Links.
We are working with our Conservation Coalition partners again: Buglife, Butterfly Conservation Scotland, Plantlife Scotland, the Marine Conservation Society, the National Trust for Scotland and the Scottish Wildlife Trust to ensure that this unique area is protected from inappropriate development. All of our partners have objected to the proposals
Prior to this, as a Coalition, we wrote to the developers, C4C at an early stage to express our deep concerns about the proposals. We understood that they proposed to make some changes, compared to previous application, but we were concerned whether it would be possible to address all the negative environmental impacts, when proposed on the same site. We urged that an alternative site be identified.
Once the planning application was submitted, we carefully reviewed it and all the associated documents. We have objected strongly to the application to Highland Council. You can read our objection here and the annexes to it here (NB some sensitive information has been redacted by Highland Council).
The Applicant submitted Additional Information in September 2023, including a Report on what they proposed as biodiversity enhancement. We carefully considered this information, but it did not address any of our concerns and raised new issues of concern. We maintained our objection along with other organisations and members of the public. Our comments on this additional information can be viewed here.
We will continue to work with our Conservation Coalition partners to help save Coul Links.
Timeline
- 08 February 2024
Scottish Ministers confirm the application is to be referred to them for determination. - 1 February 2024
RSPB Scotland write a letter to the Planning Minister, Joe FitzPatrick, asking for the application to be called in. - 31 January 2024
Scottish Ministers acknowledge the notification, and they have 28 days to make a decision. - 29 January 2024
The Highland Council notify Scottish Ministers of their decision to approve the application. - 6 December 2023
Highland Councillors narrowly vote to approve the application for a golf course and other associated development. - 27 November 2023
The Highland Council planning officers recommend refusal of the application and it’s announced that it will be considered by the planning committee on 06 December 2023. - October 2023
Coalition partners, Buglife and Butterfly Conservation Scotland submit objections to the Additional Information - 20 October 2023
RSPB Scotland responds to the Additional Information, maintaining our objection and
raising additional points - 19 September 2023
The Applicant submits a number of pieces of additional information relating to the development proposal - 16 May 2023
Highland Council’s Ecology Officer objects to the application. - 5 May 2023
NatureScot objects to the application. - 9 April 2023
The final day for comments to be submitted on the application to Highland Council, as advertised on Highland Council's website. - 6 April 2023
RSPB Scotland submits its obejection to the planning application to Highland Council. - 28 February 2023
The new planning application is validated and published on the Highland Council website. Opportunity for general public to submit comments on the application to Highland Council. - 30 August 2022
RSPB Scotland attended online event delivered by C4C presenting new proposals. - 23 August 2022
Conservation Coalition submitted questions and comments to C4C. - 27 July 2022
RSPB Scotland attended public consultation event in Embo, as representatives of the Conservation Coalition - 19 June 2022
Proposal of Application Notice (22/02800/PAN) is submitted to The Highland Council by C4C notifying of the intention to submit an application for a Major Development and setting out public consultation details. - 14 April 2022
RSPB Scotland submits comments on the scoping request proposal, raising concerns. - 21 March 2022
A request for a Scoping Opinion is submitted by C4C to The Highland Council asking what needs to be covered in an Environmental Impact Assessment for a golf course on the site. - 25 September 2020
The Highland Council issue a screening opinion confirming an Environmental Impact Assessment (EIA) would be needed for the proposal on the site. - 4 September 2020
A request for a Screening opinion (20/02820/SCRE) is submitted to The Highland Council under the name of 'Embo Junior football and Athletic Club, C/o Jim McGillivray' for an 18 hole golf course at Coul Links. This is to ask whether an Environmental Impact Assessment (EIA) would be needed with a planning application. - 21 February 2020
Scottish Ministers turned down the development plans for a luxury golf course on this highly protected area. See our response here. The decision by Scottish Ministers can be read here. - 27 November 2019
Planning Reporters pass their Inquiry Report to Scottish Ministers. - 8 April 2019
The Conservation Coalition lodged our Closing Submissions summarising our case. - 22 March 2019
End of the inquiry. - 26 February 2019
Public inquiry started in the Carnegie Hall, Clashmore, Dornoch, IV25 3RG. - 31 October 2018
Pre-examination meeting held at the Carnegie Hall, Clashmore, Dornoch, IV25 3RG. - 24 August 2018
Scottish Ministers 'call in' the planning application, as the proposal raises issues of national importance in relation to natural heritage issues and its compliance with Scottish Planning Policy which require further scrutiny at a national level. - 4 July 2018
The council notified Scottish Ministers of its intention to grant planning permission for the golf course proposal. - 20 June 2018
Decision to approve planning application taken by the Highland Council North Planning Applications Committee. - 5 June 2018
Highland Council’s North Planning Applications Committee decided to defer a decision on whether or not to grant permission. - March 2018
Further information is submitted by the developer, mainly outstanding documents and information in relation to hydrology and the proposed recreational access management plan. - February 2018
Additional information is submitted by the developer, mainly in relation to hydrology and the proposed recreational access management plan. - December 2017
Closing date for planning submissions - 22nd December. - October 2017
Planning application published on Highland Council website: opportunity for general public to submit comments on the application to Highland Council. - August 2017
Several press articles suggest that a planning application is expected in September 2017. - May 2017
The Conservation Coalition hosts a local event celebrating the special wildlife of Coul Links. - March 2017
Butterfly Conservation Scotland joins the Conservation Coalition speaking out against the proposals. - September 2016
Marine Conservation Society joins the Conservation Coalition speaking out against the proposals. - August 2016
RSPB Scotland forms partnership Conservation Coalition with Scottish Wildlife Trust, Buglife and Plantlife Scotland to campaign against the proposals. The Conservation Coalition writes to the developers expressing its concern regarding the proposals and lack of meaningful engagement, and urging the developers to think again. - August 2016
Second public consultation event held by developers. - August 2016
Highland Council issues a revised scoping opinion following consultation with Scottish Natural Heritage. - July 2016
Developers hold a local public consultation event on their emerging proposals. RSPB Scotland registers concern about the impacts of the proposals on the SSSI and SPA and the site’s importance for wildlife more generally - July 2016
Highland Council issues a scoping opinion, setting out matters that the environmental impact assessment will be required to cover. - May 2016
RSPB Scotland writes to developers’ EIA consultant offering to discuss the project. Consultant declines the offer. - January 2016
Highland Council confirms that the proposals would require an Environmental Impact Assessment (EIA). - December 2015
Developer requests opinion from Highland Council on whether the proposal will require an environmental impact assessment (EIA) and if so, what matters the EIA should cover.