Planning Objection to Coul Links Golf Course Proposal

TDFClogo_noshadow
Tain & District Field Club

20th December 2017

The Head of Planning and Building Standards

ePlanning Centre

The Highland Council

Glenurquhart Road

Inverness

IV3 5NX

Tain & District Field Club (TDFC) wish to lodge an objection to the following development:

Planning Reference: 17/04601/FUL

Development of 18 hole golf course, erection of clubhouse, renovation of existing buildings for maintenance facility, pro-shop, caddy hut, workshop, administration building, information booth, formation of new private access from C1026

Land 1700M NW Of Embo Community Centre School Street Embo

TDFC is a natural history society established in 1980 and based in Tain.  It draws its membership mainly from East Ross and East Sutherland.  Several members of the Club have read various aspects of the developers’ submissions; our objections below are based on a summary of their observations.

  1. Coul Links has a number of national and international designations:it is part of the Dornoch and Loch Fleet RAMSAR site.
    it is part of the Dornoch and Loch Fleet Special Protected area.
    it is part of the Loch Fleet Site of Special Scientific Interest.

    Only the best sites in the UK and Europe are accorded such designations. This development is unnecessary within our coastline already dominated by existing golf courses.  Furthermore, the case presented in the Environmental Statement of ‘no harm’ to the interests of the SSSI is seriously flawed, as has been very cogently put by specialist commentators.

    Coul Links provides a mosaic of habitats:

    the beach.
    the mobile dunes.
    intertidal sands & gravels connecting to the dune slacks.
    grey dunes with dune heaths including juniper heaths.>

    Each of these provides it own complex of sub-habitats with characteristic plant and animal species.  Such a dynamic system with its patchwork of biological habitats is dependent on sand movement, hydrology and micro-climatic conditions and is therefore very vulnerable to changes in drainage, enrichments from fertilizers and diffusion of pesticides through the system.

  2. The proposed development would cover a considerable area of the protected land outlined in §1.  As Coul Links is a dynamic system it is impossible to alter one area without detrimental effects throughout the system.
  3. Biological surveysThe biological surveys are inadequate:
    1. inappropriate and ill-timed
      the major duck migration period (late August to early October) is not covered
    2. techniques are at best poorly described
      Breeding bird survey techniques are not fully described.
    3. inadequate
      1. bat surveys are inadequate
      2. while there is discussion of some lepidoptra and of Fonseca’s Seed Fly (Botanophila fonsecai), the vast majority of invertebrate groups are inadequately dealt with or totally ignored.
      3. non-vascular plants and fungi are largely ignored.  Many of the rarer plant species are even ‘scoped out’ because we are told they will not be affected by the course layout. This is prejudging the assessments.
  4. Mitigation procedures are inappropriate, two examples being:
    1. It is suggested that the mitigation procedure for the Fonseca’s Seed Fly depends on the funding of a PhD.  This implies retrospective “mitigation”.  Mitigation must take place before a development, rather than just monitoring the damage after it has taken place.
    2. The proposed “translocation” of dune heath.
      The present distribution of this habitat depends on dune mobility, hydrological and other habitat factors.  Moving turfs will translocate heather and some associated plants but cannot move a habitat with its terrestrial and hydrological conditions or its total assemblage of plants, vertebrates and invertebrates. Failure of this supposed mitigation is inevitable.
  5. Socio economic claims:The socio-economic case is optimistic in the extreme.   The business basis for such a seasonal activity seems flawed in the current climate of falling member numbers of golf clubs. The so-called benefits to other golf courses are speculative, and the claims of support, it suggested, not as wholehearted as claimed.There are other ways that the locality, and not just for Dornoch and Embo, can be made more attractive in order to draw in greater numbers of visitors to the area – and year round, not just in the summer.  The lure of a seasonal game of golf, is of very little interest to a large proportion of the local and visiting population.  Give us something we can all use – but not on a precious SSSI.

In summary: Tain & District Field Club members feel that Coul Links is a unique habitat which is too valuable to be destroyed for an unnecessary golf course which has unsubstantiated claims of employment and visitor numbers.  There is no evidence that any jobs created will go to local people.

The area attracts many visitors and its loss would have a detrimental effect on both local visitors and ecotourism in the Highlands and will probably have a detrimental effect on some of the 30+ golf courses already existing within a 30 mile radius.

An unnecessary golf development should not be permitted to destroy an area which is nationally and internationally significant.  Even more importantly the links provides locals and visitors with a peaceful environment to contemplate, study and relax in a truly wild environment in the Highlands all year round.  It’s a wonderful place to enjoy being outside and see some of the amazing birds, butterflies, amphibians and plants Scotland is home to.  It’s one of our club’s favourite places.  We are very worried about what impact the golf course would have here, not only with the loss of the Coul Links, but also how much disturbance would be created in adjacent areas once the golf course is up and running.

David W McAllister

(Chairman, Tain & District Field Club)

For TDFC Committee & Members

Original statement of objection to the Coul Links Golf Course Development

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