Stop Coul Links Golf Course


Save our SSSI​​

Mike Keiser and Todd Warnock

Beware of Bandon Dunes​​ Golf Resort

Mike Keiser has been feted in Dornoch and Embo as “one of the most environmentally sensitive golf developers in the world”, based on his Bandon Dunes Golf Resort. He works much of the time with Coore & Crenshaw Inc to deliver ‘natural’ golf courses in ‘off-the-beaten-path locations’ where ‘natural landscape and regional character are key draws’.  The quotes are from consultation posters and the Pre-Application Consultation Report submitted (late) as part of the planning application.

Check out that acclaim of environmental sensitivity and you find something very different. Instead, Mr Keiser’s wealth has been achieved by exploiting sensitive environments, damaging and destroying natural habitats, arresting the dynamics of his original dunes and preventing them from evolving in response to an ever-changing environment over time. Just look at Bandon Dunes.

A huge landscape change has been imposed on the famous Oregon dune coast, in the north-western USA. Mr Keiser purchased 1,200 acres of run-down coastal duneland in the late 1980s. This still had extensive natural habitat patches of mobile dune, native coastal scrub and coastal dune woodland, despite being partly disfigured by invasive species that plague the southern Oregon coast: gorse, Scotch broom and European beachgrass. Most is now a golf lawn. The coastal habitat-type patches between the fairways is highly fragmented, even where Bandon Dunes has replanted some native species. Gorse is the plague of the south coast, growing in impenetrable, thorny mats if left unchecked. All south coast landowners, Bandon Dunes included, must control gorse on their lands. European beachgrass, which is not native to North America, was introduced to the Bandon area in the late 19th century to stabilise sand that would otherwise become too mobile for golf management and urban development. Bandon Dunes continues to use European beach grass as a stabilizing plant. In Britain we call it Marram grass. It is regarded as invasive and unwanted in the local Coast Range Ecoregion. Control is very expensive.

The expansion of golf, the use of an invasive species and the eradication of natural habitats in the Bandon Dunes resort can be traced over time using Google Maps (Lat 43.2038, Long -124.3912). The neglected coastal area Keiser originally purchased could have been restored to healthy dune habitat, but this is impossible now. Worse yet, the Bandon Dunes golf courses have extended further along the coastline and into adjacent intact forest. Cranberry farms nearby have been abandoned, many purchased by Mr. Keiser. And this expansion continues, because six courses at the Bandon Dunes resort are not enough for Mr Keiser.

An environmental organization, Oregon Coast Alliance (ORCA), prevented development in 2013 of a further course several miles south of the Bandon Dunes resort. For this highly controversial proposal, Mr. Keiser’s company, Bandon Biota, proposed to buy 280 acres of Bandon State Natural Area (a nearly 1,000-acre State Park, roughly equivalent to a large SSSI) for what would at the time have been his sixth golf course. During negotiations, Keiser illegally sent contractors into the State Park – which he did not own, and without permission from the State - who brought in heavy equipment, dug deep bore holes, felled many trees in the forest, and bulldozed extensive roads through fragile dune and meadow habitats. In addition, this illegal entry introduced gorse to an area of the Park that had none.

Bandon Dunes was forced to pay half the costs of repairing the ecological damage and removing the invasive species, collaborating in the restoration under the watchful eye of the Parks Department, but they did not get the land. The deal fell through after the illegal vandalism became public knowledge.

Not Coul believes that the scale of habitat destruction at Bandon Dunes, the use of aggressive invasive species in golf course construction, use of extensive fertilizers and pesticides in a fragile dune area, and the illegal land entry and damage upon State ground is the clearest possible evidence for Mr Keiser’s attitude to the environment. For him, it is simply there to be exploited for his company’s profits, derived from elite golf. Mr. Keiser rarely stops at construction of just one golf course in a locality, as Bandon Dunes clearly shows. He has other dunes courses billed as sustainable at Barnbougle Dunes in Tasmania, Cabot Links at Cape Breton Nova Scotia, Canada, and at Sand Valley and Mammoth Dunes in Wisconsin in the Midwest.
For the campaign stopping the further Bandon course see

For illegal habitat damage see

For an account of the 90% loss and damage suffered by Oregon’s Coastal Dune habitat over the past 170 years see

For the severe marram grass threat to the dunes and dune wildlife of the western USA, and its costly control, see: A.J. Pickart (1997) Control of European Beachgrass (Ammophila arenaria) on the West Coast of the United States, pages 1-8 in Proceedings of the California Exotic Pest Plant Council Symposium Proceedings, Volume 3. Concord, California. Available here >>

Not Coul acknowledges the assistance of the Oregon Coast Alliance in preparing and checking this material.

We are somewhat confused about developers. Coul Links Ltd is the name behind the golf application, but Bandon Dunes Golf Resort was the main developer stated in 2016 and is still named as such in some application documents. Coul Links Ltd (registered July 2016) is mainly controlled by Coul Links Holding Company Llc, based in Wilmington, Delaware, USA. This we presume is where the bulk of the profits would go, offshore, to a low-tax regime. Two directors are listed as having the majority shareholding: Michael Keiser and Todd Evan Warnock, both named as resident in the USA. Mike Keiser is also the owner of Bandon Dunes Golf Resort, which is an Oregon-based company in the western USA specialising in elite golf and trading worldwide.

Together, Keiser and Warnock assembled a heavy hitting team of global corporates to pursue the development of the Coul Links Golf Course on one of Scotland's precious SSSIs, a location with international designations too. 

When Not Coul examined the Environmental Statement it found that, suddenly and unexpectedly, at some stage in 2017, the main developers dispensed with the services of Golder Associates (former lead consultants, special expertise in hydrology), Jones Lang LaSalle (former planning and consultation advisers), plus JMP Consultants (Transport and Access). The Sports Turf Research Institute (STRI) has since been appointed to produce the overall Environmental Statement. This Yorkshire-based playing surface consultancy is responsible for maintaining the ecological interest of UK Open Golf championship venues. It does not seem to have a track record in Scotland for leading planning applications for a major development, particularly one impinging on a heavily-designated nature conservation site.

Importantly, several consultancies are now stated as contributing to hydrology and hydrogeology in the Environmental Statement, with no clear overall lead.  Some materials on show at consultations in late October 2017 still bore the names of Golder Associates and Jones Lang LaSalle. One obvious result of these major changes is an Environmental Statement which has been put together too rapidly. There is missing material and key work, notably on hydrology, is incomplete. Linkage between ecology and hydrology is particularly weak, an area highlighted in the scoping phase of EIA to need special attention.

Four consultancies remain from the original seven: Optimised Environments (Landscape & Visual Amenity), Alba Ecology (Ecology & Ornithology), Biggar Economics (Socio-Economic Analysis) and Northlight Heritage (Cultural Heritage).

This late change in the developer’s consultancy team suggests frustration at the cost, time and care required in producing a sound Environmental Statement for a development affecting a triple-designated nature conservation site. An Environmental Statement we now know to be weak gives Not Coul great confidence that these wealthy developers can be challenged and prevented from securing planning permission using our passion, checking and in-depth analysis of the facts, plus close investigation of the economics of golf in the Highlands and Scotland.

Mike Keiser - Developer

Mr. Keiser is a self-made American billionaire and owner of the massive Bandon Dunes Golf Resort in Oregon, western USA with green fees up to $300. There are now six courses at the resort. He also owns similar courses in the USA, Canada and Australia, all of which have luxury hotels and resorts catering for elite golf. He now has his sights set on Scotland. He is widely reported as the main competitor of Donald Trump as they seek to outdo each other in the monied world of American golf. 

Todd Warnock - Developer

As well as owning Links House and the Carnegie Court House in Dornoch, he is leading the efforts to purchase the Royal Golf Hotel in Dornoch. In talking about a very fine dune system, he has been quoted as saying "If it were developed the essence would change". ​Unfortunately Mr. Warnock is talking about the dune system opposite his own home near Lake Michigan and NOT Coul Links. He obviously appreciates a good view of a dune wilderness untouched by development. He recently donated  $1.1M to save the nature reserve in the Lake Michigan dunes, to preserve the tranquility. READ THIS

Below is Warnock's profile from

Mr. Todd E. Warnock is a Senior Advisor at RoundTable Healthcare Management, LLC. He was a Founding Partner at the firm. He has been a Senior Advisor since July 2010 and was a Founding Partner and Transaction Partner from February 2001 to July 2010. From the inception of the firm in 2001 until his transition to Senior Advisor began in 2006, Mr. Warnock was responsible for leading the firm’s transaction team. Prior to this, Mr. Warnock was the Managing Director and Head of U.S. Health Care Investment Banking at Credit Suisse First Boston Corporation from 1999 till 2001. At the firm, he also served as the Managing Director of the Investment Banking Group from 1997 to 2001; as a Director of Investment Banking from 1995 till 1997; and various other positions from 1988 till 1995. Mr. Warnock worked at the firm for more than 12 years, the majority of which was spent in senior roles in sourcing and executing healthcare merger and acquisition and financing transactions. At the firm, he advised in excess of 90 completed transactions valued in excess of $75 billion. Mr. Warnock was also a Research Assistant at the Board of Governors of the Federal Reserve System, Washington D.C., 1983 to 1986. He serves on the Board of Sabex, Greater Chicago Food Depository, and Oxbow School of Art (School of the Art Institute of Chicago). Mr. Warnock has extensive strategic and financial experience in all aspects of mergers, acquisitions, spin-outs, carve-outs, and divestitures. He has substantial experience covering a wide spectrum of securities offerings including IPOs, secondary common, preferred stock, convertible preferred stock, convertible debt, high yield bonds, senior bonds, bridge loans, and bank credit facilities, as well as non-U.S. based financings. He has more than 13 years of mergers and acquisition and financing experience in the healthcare industry.

Edward Abel Smith – Landowner and The Embo Trust
These have been stated verbally as having a share interest in Coul Links Ltd but are not yet listed on any documentation readily available via the web. The landowner at Coul has stated that the golf course would lease his land. His family agreed a 25-year management agreement with the Scottish Wildlife Trust in 1985, shortly after the Coul area was designated part of Loch Fleet SSSI. For unknown reasons this agreement was not renewed when it ended in 2010. The SWT achieved much in that time, particularly fencing off and saving a large population of dune juniper that was being badly damaged by cattle. It is not known what attempts at further management agreement have been made by Scottish Natural Heritage. Local observation over three decades suggests that large parts of Coul Links have not been managed well, with too much winter stock grazing and feeding in the inner parts of the site. That imports nutrients into dune ecosystems which are naturally nutrient-poor. There has been a lack of grazing in outer paddocks. The landowner has overall responsibility in the long term for land management, including all management at the present time. He is responsible for any poor condition at Coul. The Embo Trust is a company run by local Embo people, led by Councillor Jim McGillivray. It has a quoted £5000 investment in Coul Links Ltd, with an offer from Mike Keiser of doubled match funding in share equity for each £1 of extra investment raised locally, with all equity entitled to a proportionate share of Coul Links Ltd profits.

Coore & Crenshaw - Golf Course Designers

There is no doubt that Coore & Crenshaw is a world class American golf course design and development business. They have completed almost fifty enormous projects to date. Although mostly in North America they have also worked in China, Japan, Indonesia and Australia.

Mike Keiser and Todd Warnock


The developers and their consultants