Fighting Golf At Coul

This is an evidence-based campaign against a second proposal for golf on protected land at Coul Links. The struggle has lasted 6 years so far. The first application for a proposed world-class course was made in 2017. It was thoroughly considered at a Public Local Inquiry in 2019. The Scottish Government refused planning permission in February 2020.


A four-week 2019 Public Local Inquiry involved:

Many experts
Strong views on both sides
A mountain of documents

It examined the following case for golf at Coul:

A world-class course
Environmentally-friendly design
Biodiversity net gain
Nationally-important investment
Hundreds of jobs to be generated

The outcome was that NONE of these were established, ANYTHING BUT

Here are SOME of the key findings:

  • SIGNIFICANT ADVERSE EFFECTS on Dune Heath, Dune Slacks and the overall Dune Habitat System
  • MITIGATION via Site Management Plan inadequate, CANNOT OVERCOME DAMAGE
  • SIGNIFICANT ADVERSE EFFECT on Wintering Birds, even after mitigation
  • SIGNIFICANT ADVERSE EFFECT on Breeding Birds, even after mitigation
  • SIGNIFICANT ADVERSE EFFECT on Coul lnvertebrate (Insect) Assemblage
  • SIGNIFICANT ADVERSE EFFECT on Dune Juniper and Lichens
  • Integrity of SSSI, SPA and Ramsar site would be compromised
  • Not in accord with site, habitat and species protection policies of local plan
  • SCALE OF INVESTMENT and JOBS CREATED were of local and regional Importance, NOT NATIONALLY IMPORTANT.
  • Number of jobs to be created directly in golf was EXAGGERATED when compared to known national total.

NOT COUL had made all the above points in its submissions to The Highland Council and the Inquiry. It was the only opposing party at PLI to contest on socio-economic matters.

PLI Reporters (page 279, Coul PLI Report) stated:

“the proposal fails to protect natural heritage sites (and ‘world-class environmental assets’) ….. hence cannot be regarded as sustainable development”

Have a look at the documents

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Spot the difference

Yes, there are now TWO golf courses AND a luxury hotel (see Not Coul map)

This is more development, not less. It is being promoted as less.

It is being sold as environmentally-friendly. It is not.

It is being sold as the economic solution to all sorts of problems in SE Sutherland. It is not: it is simply not needed. It could even make youth emigration worse. Scotland has no need for this environmentally-damaging and community-dividing type of development in the 21st Century.

In short, these developments are egregious threats to the SSSI/SPA/Ramsar sites and other Nature at Coul.

Some simple points, comparing the 2017 and 2022 “WORLD-CLASS” courses

The 2022 changes compromise the 2017 design. The 2022 C4C golf course is not world-class.  So why even think of building it?

The latest SSSI golf footprint is 80% the same as the old. It could retain 80% of the shocking PLI findings from 2019.

The moved Hole 4 first fairway in the north is on dune wetland, the second fairway has lichen interest, so there would be new habitat destruction, as two examples.

Mowing will not avoid significant adverse effects. Instead, it will severely damage the dune habitat system. Keystone dune species will be killed. Unharmed, their role is to keep best-in-the-UK Coul ecosystems intact. SSSI integrity will be compromised. A poor golf playing surface, at best, will result.


This is now notably larger in the north. It will reduce connectivity and increase disturbance. There will be increased significant adverse effects on wintering and breeding birds as a result, as two examples.

This will increase, due to construction of the Embo Par 3 Course.

A plan is just a brochure.  No plan is capable of mitigating the significant adverse effects in the 2022 design. 

  • A signed HMP is already in place, finally agreed in December 2021. 
  • It is operational and fully-funded. 
  • It will return the Coul SSSI sector to favourable condition. 
  • There is no need for a golf course to wreck part of Coul Nature to pay for managing what remains.


A future PLI on the 2022 layout application will get the same result: planning permission refused.


Build a world-class golf course, outside all protected ground. There is plenty of land available.

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The developer timeline

The Start:

2016 projections to 2020 failure Todd Warnock and Mike Keiser

The first public details of a golf course at Coul Links came at meetings in 2016, under the banner of Bandon Dunes Golf Resort. Bandon is the Oregon HQ for Mike Keiser’s world-leading business in golf resort development and tourism. No hotel or residential development was an assurance given at consultations. The golf footprint proposed was, frankly, horrifying. There was little mention of Coul Links being triple-protected as a part of SSSI/SPA/Ramsar sites.
2017 - Planning Application
A proposed Coul golf planning application was submitted in September by Coul Links Ltd, with Todd Warnock and Mike Keiser as Directors. Minor equity holdings were stated for the Coul landowner Edward Abel Smith and the Embo Trust (Urras Euraboil), representing the community in the settlement of Embo immediately south of Coul Links. Councillor Jim McGillivray was Chairman of the Embo Trust.
2017 - The Developers
Todd Warnock is an American entrepreneur with businesses in Dornoch and investments in American healthcare. He has the controlling interest in Coul Links Ltd. Together with Mike Keiser and using big consultancies, Mr Warnock was leading a very powerful team in 2016 but the leading consultants were not retained to make the planning application in 2017.
2017 - 2018 Opposition
The 2017 planning application was approved by The Highland Council in 2018 after a delay due to inadequate information on hydrology. It had been opposed by a petition of >80,000 signatures and many written objections outweighing support by >3:1. An objection was maintained by Scottish Natural Heritage and this led later in 2018 to a successful campaign to call-in the planning application, for further review by the Scottish Government. Call-in was followed by the announcement of a Public Local Inquiry (PLI).
2019 - Not Coul Representation
Not Coul was represented at PLI by experts on coastal geomorphology, hydrology, ecology, lichens, golf economics and SE Sutherland community economics. In addition to Scottish Natural Heritage, other considerable opposition came from the Save Coul Links Conservation Coalition (Butterfly Conservation, Buglife, Marine Conservation Society, National Trust for Scotland, Plantlife, RSPB, and Scottish Wildlife Trust). Not Coul was the only party opposing on social-economic grounds.
2019 - Public Local Inquiry
The PLI took place over four weeks in February and March 2019, before two Reporters, David Liddell and Timothy Brian, both professional Planners, appointed by Scottish Ministers. Their report, more than 300 pages, took until late November 2019 to be delivered. The delay was due entirely to late delivery of the Coul developers' Closing Submission, as a mammoth document >700 pages. New rules were then issued by the Planning and Environmental Appeals Division (DPEA) on submissions timing and length, to apply now to all PLIs in Scotland. This was extraordinary.
2020 - Refusal
The November 2019 Report recommended refusal. Scottish Ministers agreed. The refusal was comprehensive and not at all marginal. It found multiple significant adverse impacts. It acknowledged in particular that Coul Links represented world-class environmental assets which, if developed, would not be protected by SSSI/SPA/Ramsar status. It therefore did not represent sustainable development.
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Developers 2020 Onwards

If at first you do not succeed – reshuffle the card deck, add a C4C joker and start again.


Immediately following planning refusal in February 2020, Cllr McGillivray expressed very strong opinions and demanded opposing groups (but not Not Coul) attend a discussion on a Coul Links Action Plan. No opposing group wanted to attend, given the angry local reception of the decision. There was little reference in local anger to the detailed reasons justifying the decision. 

A damaging wildfire occurred very close to Embo in March 2020, one month after the 2017 golf planning application was refused by government. Much thick gorse was removed by the fire. A bonfire had been set on wasteland during a southerly gale in tinder-dry conditions. The resulting wildfire spread north and northeast, including into SSSI land at Coul Links. This damage to 8.5 ha of ground was not reported locally. Not Coul mapped the fire extent the following day and sent the results to Scottish Natural Heritage (now NatureScot).

Chairman Embo Junior Football & Athletic Club (defunct)

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A detailed scheme seems to have been hatched following the anger in February 2020, for a sequence of steps to achieve a second application. In July 2020 Cllr McGillivray requested a screening opinion (20/02820/SCRE) for a development north of Embo made up of the 2017 golf course plus a 14 hole par-3 course near Embo. The survey for the 14 Hole course was probably made easier by the earlier fire. 

The request for screening was made using the name of a junior football/athletic club as the Applicant. It had no members at the time and is defunct. The Highland Council replied in September 2020 that a second application would require an EIA and would not be considered within two years of the first refusal.

The 2020 Screening application for golf courses states, if progressed, that it will be submitted by a consortium of community groups local to the East Sutherland region’.

N.B. C4C Communities for Coul (see below) is not a consortium of existing community groups. It is a private limited company. It emerged in January 2021 and later that year defined the East Sutherland region as only three postcodes, out of many. Each selected postcode has a large and locally powerful golf club. There are a lot of excluded communities in other local postcodes.

Councillor McGillivray was re-elected as a Highland Region Councillor in the May 2022 local government elections.

2021 – C4C: Communities for Coul

C4C is stated as the Applicant in a Scoping Report application to The Highland Council (22/01330/SCOP)

C4C was registered in January 2021, SC686157 (Scotland)

There were originally six directors, one has resigned, another is not local.Company details state that profits are principally for the benefit of the community‘. There are as yet no details of which ‘community’ will directly benefit from profits.

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C4C has claimed it has a mandate for making the planning application. That is based on a ballot of the electoral roll in three small postcodes. Each postcode has a powerful golf club. Together they host four courses in the world top 100.

Prior to the ballot all local households received a 4-page golf development advertisement paper. The local newspaper then carried a full-page advert. The ballot question was: “Do you support a community planning application for an environmentally sensitive world-class golf course to be built at Coul Links near Embo?”  Each ballot paper was accompanied by a one page propaganda sheet, designed to secure a mainly YES vote . ‘Turnout’ overall was only 44% in Dornoch, Golspie and Brora and the settlement of Embo  – all locations where most people play or support golf.

Many ballot recipients were incensed by the propaganda and binned their ballots, as an obviously biased process.

Complaints were registered with the balloting company and in the local press. Many people, elsewhere in East Sutherland area plus nearby East Ross-shire, felt disenfranchised.

Does everything now have a new leader?



The Abel Smith family has owned Coul since the 1940s. The family formerly owned the adjacent Cambusmore Estate. EAS does not live locally but is a regular visitor.

Earlier conservation management

Shortly after Loch Fleet SSSI was notified as an SSSI (1984), the Abel Smith family agreed to have their SSSI land at Coul managed for conservation by the Scottish Wildlife Trust. That agreement ran for 25 years but was not renewed in 2010. SWT removed expanding gorse and birch, as well as protecting rare dune juniper from cattle with fencing. That fence wiring went quickly into disrepair a decade ago.

Until very recently the Abel Smith family did not enter into another conservation management agreement for the Coul SSSI sector. Little other successful direct management has been carried out for more than a decade.

Juniper exclosure

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Why do nothing?

A 1975 conifer plantation was felled in 2012 and trunk timber removed. That left large volumes of timber brash to add nutrients to the soil and groundwater, as well as attracting invasive species (mainly birch, raspberry, blackberry). These invasives are only extensive around brash and close to Coul Farm where soil was churned up by felling vehicles and timber storage. 

Much of this felled area is well through regenerating naturally as dune heath and dune grassland on dry ground. There is also dune slack now in extensive areas which are flooded for up to 9 months per year. It is rarely visited due to the brash debris and so there is a welcome lack of disturbance by visitors and especially dog walkers. That has allowed large numbers of breeding birds and the highest regular sightings of multiple roe deer. The area might look untidy but is already biodiverse.

Much has been made of this unsightly area of brash to support “management” funded by golf. There have been regular claims that opponents of golf have done nothing about an area which has been declared as an eyesore. The claims come from people who have not ventured into this interesting area and are ignorant of its steady recovery by habitat succession. 

It is not true that nothing has been done about the brash and invasive species. An offer of FREE timber mulching clearance was made in 2021 to EAS. That would have quickly spread fragmented brash and removed all pine stumps and invasives in about three weeks, with little damage to developing dune habitats. That offer was by Coul Future Ltd, a company with Not Coul members as directors. All Not Coul member work was offered pro bono. Permission for access to do the work, via an application to Scotland’s Nature Restoration Fund, was refused by EAS.

Of course nothing has been done in this sector: the landowner and manager, a developer, wants nothing done. That is his right. It strengthens his hand in seeking to persuade NatureScot that, at Coul, conservation management funds will only be provided long-term via revenue generated by a golf course which must be spread through much of the SSSI land at Coul.

Not doing the right thing

A few cattle are grazed and winter-fed in the north. That imports nutrients into the SSSI as silage and straw, affecting the naturally-poor Coul soils. Lack of grazing and nutrients via cattle dung have allowed dune grasslands to thicken up, helped by a collapse in the rabbit population. 

Pollution around the feeding station in 2018 was so severe that it has been moved well away more recently. Present grazing of dune grasslands in winter is not sufficient to open up this habitat. The cattle breeds used do little to control gorse or birch. Over time they have also enriched the waters of some dune slacks.

Scottish Natural Heritage was involved in prolonged negotiations after 2010 to achieve proper management of the nationally and internationally important Coul dunes. Not Coul FOI returns from SNH showed major SNH effort which ran for several years, attempting to persuade the Abel Smith family. Nothing was signed. SNH evidence at the 2019 PLI showed a poor relationship, with one very expensive potential agreement left unsigned by the family.

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At last a satisfactory management agreement

Surprisingly, a first management agreement between EAS and NatureScot was signed in December 2021. NatureScot has guaranteed funding. It runs for two years and covers gorse and birch/willow control, plus some bracken removal and minor treatment of weed species.

These measures should be enough to bring the Coul sector of Loch Fleet SSSI into favourable condition. It shows that neglect over the past decade can be quickly reversed without requiring a golf course or golf course profits to pay for nature management.

In charge of everything?

EAS has now assumed a much higher profile compared to 2016-2020, when he was content to be in the background.

Indeed, EAS might be the force behind C4C. In video sessions in advance of the C4C local ballot in 2021, EAS stated that he was entirely separate from C4C. He is not listed as a C4C director. However, the Scoping Application (22/01330/SCOP) naming C4C as Applicant has EAS named (in PDF properties) as the author of the scoping document. The planning consultancy on the cover would be expected to be listed as author, supposedly acting only for C4C.

EAS is also behind a current luxury ecolodge hotel planning application (21/02644/FUL) to be located outside the SSSI at Coul. It would be adjacent to the proposed golf course and near the clubhouse. That application states that the hotel will not be developed unless planning permission is granted for the golf course.

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Uncertain and changed roles for 2016-2020 leaders

Todd Warnock – Local entrepreneur

Comments in the press in 2021 and 2022 have stated that Mr Warnock is now uninvolved in a Coul golf project.

That might be the case BUT one of Mr Warnock’s local businesses holds planning permission for a reservoir and CAR licence for water abstraction, on non-SSSI land at Coul – for use in watering the proposed golf course (17/04404/FUL)

Mr Warnock is still registered as a person of significant control of Coul Links Limited SC541313 (Scotland), the 2017 applicant.

Mike Keiser remains as the other Coul Links Ltd Director.

Since 2016 Mr Warnock has probably spent very heavily on what was clearly HIS Coul Project. He led from the front between 2016 and its failure in 2020.

Not Coul regards his role at present as possibly involved, not ‘uninvolved’.

Mike Keiser – World-leading golf resort developer

Mike Keiser was reported in the press in early 2020 to be abandoning development in Europe due to EU environmental legislation and nature protections. That followed the refusal of planning permission for golf at Coul in February 2020.

Mr Keiser re-emerged early in 2021, as part of the promotion of the C4C bid to prepare a planning application in 2022.

Mr Keiser will build the golf course at Coul if the C4C planning application receives permission.

The Coul Links logo here was used by the Warnock-Keiser Coul Links Ltd company in 2017-2020, upon their website.

Golf hats with the same design are currently being offered in return for donations to Communities for Coul 2022, on the C4C website

C4C includes the logo on some social media.