NOT COUL COUL LINKS PROPOSED GOLF DEVELOPMENT: ENVIRONMENTAL STATEMENT A WORKING AUDIT OF ANNEX B: ECOLOGY. Dr Tom Dargie Chair, Not Coul

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1 NOT COUL COUL LINKS PROPOSED GOLF DEVELOPMENT: ENVIRONMENTAL STATEMENT A WORKING AUDIT OF ANNEX B: ECOLOGY Dr Tom Dargie Chair, Not Coul Version 1: 19 th October 2017 THE CASE FOR AUDIT 1. Key datasets and scoping assumptions are audited for accuracy. This ES information underpins the ecological assessment in that document. It also affects the ecological impacts arising from course design. If the datasets and assumptions are wrong, all ecological assessment is invalid. 2. The bar for accuracy is set high. Multi-designated sites require very sound data to provide an accurate measure of their habitat and species diversity. Course design relies upon mapping accuracy to minimise effects on sensitive habitats (especially wetlands), as well as reducing the scale of earthworks in course construction. 3. The National Vegetation Classification (NVC) GIS database has been tested for accuracy. Fieldwork in 2017 recorded NVC habitats along 12 randomly placed line transects, each running from the inner SSSI edge at Coul towards the sea, stopping at the end of vegetated ground. The lines were then overlain upon the 2016 NVC database to capture 2016 habitats under 2017 lines. 4. The audit work has been done by Dr Tom Dargie, Scotland s expert on dune habitats. He has personally mapped more than 95% of the Scottish dune and machair resource of 500 km 2. The results are published by Scottish Natural Heritage as the Sand Dune Vegetation Survey of Scotland, including a GIS (Geographical Information System) database. Coul was mapped in 1994 and that survey allows a baseline for use in assessing change to As part of Dr Dargie s work, he mapped the habitat of most Scottish links golf courses between 1994 and He has also published work for English Nature on the impacts of golf at Sandwich Bay in Kent (including two separate surveys over time at Royal St Georges, a British Open venue). Overall, he has dune mapping experience gained over 45 years and, in the UK, ranging from Unst to the Scilly Isles, and Heiskeir to Sandwich Bay. 6. Dr Dargie is experienced in work preparing for golf course construction. He acted as lead ecologist producing a baseline NVC survey for Menie Links on behalf of Trump International Golf Limited Scotland (TIGLS). He led the production of the ecology section for the Menie ES and defended his work at the subsequent Menie Public Inquiry. He was interrogated as an expert witness for more than 6 hours, the longest of any witness in that controversial inquiry. He emerged reputation intact. 1 P a g e

2 KEY AUDIT CONCLUSIONS TO DATE: HABITAT SURVEY AND IMPORTANT SPECIES MAPPING 1. The accuracy of the 2016 NVC survey is poor to very poor when measured using a sample line transect method. It nowhere reaches the highest standards required for work on an area rated as SSSI/SPA/Ramsar status. 2. Dr Dargie s 2017 work recorded 83 NVC types. The 2016 ES work under 2017 sample lines totals 43 NVC types. This is a large difference in totals and represents a major underestimate of habitat biodiversity in ES work. This suggests work by 2016 NVC surveyors who were inexperienced in dune habitat work, contrary to scoping stipulation. Vegetation types missing in 2016 included Moray Firth types established in the SDVSS. SNH had recommended attention to the SDVSS Moray Firth NVC survey in scoping advice but that was not heeded. It is not possible to check that conclusion using collected vegetation samples as evidence of vegetation type. That information is not presented. It normally forms part of a NVC report. This failure to include is deviation from good practice. 3. The overall accuracy, based on 20 NVC groupings, is only 55%. This means that 45% of all mapped ground in ES 2016 work is allocated to an incorrect NVC type. 4. Overall accuracy based on just two groupings, wet and dry dune habitats, suggest very serious errors in site mapping dry ground vegetation has an accuracy of 85%, fair but far short of a high-quality result wet ground only achieved an accuracy of 58% which is lamentable. This suggests that 42% of Coul wet ground has been mapped as dry habitat. 5. These results for accuracy have been tested on ground around Holes 13 and 16 in the Coul golf layout (Figure 1). Hole 16 has obviously been designed to avoid very wet ground immediately to the east and is located mainly within ground mapped in 2016 as dry grassland. 6. This is very wrong. A single mapped area, with a boundary enclosing wet slack habitat and a little wet woodland, covers about 40% of the Hole 13 fairway. All this ground should have been avoided. Instead, this habitat, qualifying as GWDTE (Groundwater-dependent Terrestrial Ecosystem), would be destroyed by imported sand to raise the playing surface above all significant seasonal waterlogging. 7. Bad habitat mapping detail around Hole 13 corroborates strongly the overall accuracy result for dune wet ground. Much has been mapped in error as dry ground. 8. These findings are sufficient to declare 2016 ES NVC survey as NOT FIT FOR PURPOSE. It would be impossible to use this dataset without creating major errors in course design and very serious environmental damage to sensitive habitats protected under international designations. 9. It is recommended that all ES work dependent on this dataset is regarded as unreliable. It must be discarded and a completely new NVC survey undertaken, with a further quality audit to check its validity for use in a golf context. All ES work reliant on the NVC survey must be rejected too and that includes producing a new course design. 10. The error levels likely to be present are so large that it is not worth continuing audit work on this dataset. It will only repeat the results already found. These results should be reported to SNH and SEPA, to assist in their evaluations of ES Ecology work. 11. The Phase 1 habitat survey has mainly used NVC results to allocate Phase 1 habitat sites. Given serious NVC errors, Phase 1 work should be disregarded too. 12. There are additional serious mapping errors or unintended destructive consequences for important plant species and a very rare wetland habitat. 2 P a g e

3 Figure 1 Mapping accuracy for NVC habitats and important plant species around Holes 13 and 16, Coul Links Proposed Golf Development 3 P a g e

4 13. Preparatory work in August 2017 prior to ES publication included a small Not Coul quadrat collection (20 samples) made by Dr Dargie and Mr Andrew Weston (a professional habitat surveyor with 25 years of experience). Two wet slack quadrats were found to contain Baltic rush Juncus balticus (locations: ; ). This is a nationally scarce species recorded in one location in the north of Coul as a 1995 record. 14. The two new occurrences of Baltic rush are very close indeed to the Hole 13 footprint. Both locations should be considered endangered at site level. There is no mention of Baltic rush in the ES or the Appendix B7 ecology report on NVC work. 15. Common juniper (Juniperus communis) is considered a receptor species in the ES Ecology report but no information is provided on numbers at Coul, or their sizes. Three locations are given in Table 3 of Appendix B2. This species is rated of Regional importance (ES Table B28, page 223), with a risk of population change of Medium before mitigation (translocation) which, with no discussion of translocation techniques or translocation survival risk, is reduced in magnitude to Low after translocation. 16. It must be stressed that juniper on dunes is very rare in Britain. It is confined to the Moray Firth with the bulk of occurrences at Morrich More, Ross-shire (part of the Dornoch Firth and Loch Fleet SPA/Ramsar). The population at Coul is probably the second-largest in Britain, based on records in the Sand Dune Vegetation Survey of Scotland. 17. Not Coul ecologists have recorded almost 200 individual juniper bushes at Coul, with accurate GPS records for each. An overlay of these records found a very large concentration on and immediately adjacent to the southern fairway of Hole 16 (Figure 1). 103 individuals are present above the outer band of thick rough. This represents over 50% of the Coul population and therefore the risk of magnitude of population change (loss) is Major, not Medium. 18. The concentrated population here is grid referenced in Table 3 (Appendix B2), the third of three. With such a large number, it is surprising that a count was not made, sufficient to make an accurate assessment of risk. Moreover, there appears to have been no communication of this population to the golf course designers, or it has been ignored. This ground surely should have been avoided by course planners. 19. It is unlikely that many juniper individuals will survive translocation. The root system has both shallow and deep roots and the largest bushes on Hole 16 are 5 metres in diameter. The Magnitude of Change after Mitigation should probably be reset to High. The resultant effect is therefore likely to be a significant residual effect (negative). This in all respects completely contradicts the superficial ES analysis. 20. The ES ecology work failed to find Seaside centaury Centaurium littorale or Rough horsetail Equisetum hyemale, other nationally scarce species in addition to Juncus balticus, which was completely overlooked. Seaside centaury is present on upper saltmarsh in the northeast of Coul, in SM16 and SM27 NVC saltmarsh vegetation. Neither type was recorded in the 2016 ES NVC survey, hence no centaury. Rough horsetail is locally abundant close to the foredune edge close to Embo and a grid reference was available in the SDVSS Moray Firth account for Coul. 21. ES ecology work on higher plants has been casual and for the key species, Common juniper, assessment is seriously wrong. Overall, higher plant assessment is NOT FIT FOR PURPOSE. 22. Not Coul work in 2017 found five locations with abundant Shoreweed Littorella uniflora within slack vegetation. It is in some of the wetter slacks and seems to occupy a winterflooded and part-summer submerged zone, above Common spikerush Eleocharis palustris 4 P a g e

5 (NVC S19). This differs from its common UK distribution in upland shallow waters of permanent water bodies. This is the first record for Coul and the Loch Fleet SSSI, although it also occurs at Morrich More in slacks carrying permanent water. 23. The Shoreweed occurrences at Coul represent a very rare habitat in the UK: a priority habitat under the Habitats Directive H3110 Oligotrophic waters containing very few minerals of sandy plains (Littorelletalia uniflorae). It is illustrated in Plate 1. Coul is the first location it has been found on the Scottish mainland (it also occurs at the rear of machair wetland in South Uist, in blackland habitat). 24. The habitat requires nutrient-poor groundwater and there is a high risk that golf-derived increased nutrients could damage or eradicate this habitat. The only mitigation would be to move fairways, greens and tees to lower levels, below the altitudes of Shoreweed. That would probably be impossible. 25. Given its Coul extent and distinctive structure, this habitat should have been found in 2016 ES survey. It deserves an Importance valuation of National given its rarity as a habitat. All locations lie close to proposed golf holes and in the case of Plate 1, it would be destroyed by Hole 13 construction. There is probably no effective mitigation and course construction would result in a significant residual effect (negative). 26. The failure to recognise this habitat and the mapping of this ground as dry dune grassland corroborates the poor mapping conclusion above, regarded as NOT FIT FOR PURPOSE. Plate 1 Habitats Directive Priority Habitat H3110 Oligotrophic waters containing very few minerals of sandy plains (Littorelletalia uniflorae) adjacent to wet woodland. All foreground and central areas are planned as fairway for Hole 13. The short turf is dominated by Shoreweed Littorella uniflora. 5 P a g e

6 RECENT SITE MANAGEMENT IN RELATION TO HABITAT AND CLIMATE CHANGE The next version of this audit will incorporate a comprehensive analysis of change in habitats since the 1994 baseline. It will consider in detail the ES evidence for poor management of the designated parts of the site. It will also include change which is driven by climate and this will be used to audit the minimal information provided in the ES. 6 P a g e

Chair, Cllr Maxine Smith, North Planning Applications Committee, The Highland Council Members, NPAC

18 th June 2018 Chair, Cllr Maxine Smith, North Planning Applications Committee, The Highland Council Members, NPAC Dear Chair/Members 17/04601/FUL and 17/04404/FUL Coul Links Not Coul respectfully makes