SCOTTISH Government officials have advised ministers to reject plans for a golf course on a protected dune system on a Highland beach, files have revealed.
Ministers in Edinburgh “called in” the application to build an 18-hole course, a practice area and associated facilities at Coul Links at Embo, north of Dornoch in Sutherland, after the plan was approved by Highland councillors in December 2023.
The Coul Links site is triple protected, forming part of the Loch Fleet Site of Special Scientific Interest (SSSI), the Dornoch Firth and Loch Fleet Special Protection Area (SPA), and the Dornoch Firth and Loch Fleet Ramsar site – meaning it is protected under the 1971 international Convention on Wetlands.
Following an inquiry and delays imposed by a Scottish Government policy change affecting the Ramsar site designation, officials submitted their final recommendations to ministers on August 29, 2025.
Those recommendations were kept secret, as is standard procedure.
However, a Freedom of Information release on April 28 this year has revealed that the reporter told government ministers they should reject the proposals.
An email sent on October 23, 2025, states: “Please find attached a submission on the above called in planning application inviting you to refuse planning permission, in line with the reporters’ recommendation.”
It adds: “Our advice to Ministers regarding this case should not be passed on to or discussed with anyone outside the Scottish Government, and any queries regarding this case should be referred to us in Planning, Architecture and Regeneration Directorate.”
On January 27, 2026, an email was sent which was “for official record and confirms a ministerial decision”. However, that decision was redacted.
Then, a letter to all parties related to the case, published on the government’s official planning portal on March 17, 2026, stated: “The Scottish Ministers consider that submission of further ecological information would assist in determining the application.”
Following the FOI's release, Ramblers Scotland welcomed the reporter's recommendation.
Ramblers Scotland director Brendan Paddy said: “We are pleased to learn that planning inspectors are advising Scottish Government ministers to refuse this damaging and inappropriate application.
“The golf development would permanently harm access, the landscape and the experience for walkers, with up to seven holes crossing the John o’ Groats Trail long-distance trail.
“Scotland’s new ministers now have a golden opportunity to get off to a positive start by saving Coul Links – one of the last remaining dune systems on the east coast – for all to enjoy for generations to come.”
Last year, the Scottish Government published an updated policy on Ramsar sites, which stepped up protections, including by mandating a Habitats Regulations Assessment (HRA) for any developments affecting one.
Government agency NatureScot previously stated that an HRA must show “beyond reasonable scientific doubt” that a project would not “adversely affect the integrity” of a Ramsar site, or it must not be allowed to go ahead.
NatureScot later conducted a “shadow HRA”, which it said concluded that the development would “undermine” conservation objectives at the site.
The report stated that, following a scientific appraisal, there is “likely significant effect and probable adverse effect on integrity”, adding: “Development management response type: outright objection.”
In 2020, the Scottish Government rejected initial plans to develop on Coul Links. They had been put in by an American billionaire Mike Keiser, who will step in to fund construction if the new application is approved.
However, Communities for Coul (C4C), the developers behind the proposal, have claimed that the revised golf course plans would be net-positive for the Ramsar site.
The developers have claimed the course would contribute between 270-400 full-time jobs and would generate between £8-12 million per year to the economy.
