An expert found Yntegra's environmental case for Sampson Cay "wholly inadequate."

Over the coming weeks, Turtlegrass is publishing a series of expert witness reports on the Yntegra Group's proposed Rosewood Exuma resort on Sampson Cay. Each was prepared by a highly qualified specialist for the legal proceedings now before the courts. We are releasing summaries so the public can see what the evidence says. The second is by ecologist and expert in biodiversity assessments, Mark Gash of Turnstone Ecology Limited.

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Who is Mark Gash?

Gash is Director of Turnstone Ecology Limited and a Full Member of the Chartered Institute of Ecology and Environmental Management, a status he has held since 2006. He holds an honours degree in Ecology from the University of Leeds and specialises in ornithology and the assessment of international projects against Good International Industry Practice and the standards of international lending institutions. He has led biodiversity assessments and ecological reviews for developments in more than 25 countries across Europe, the Middle East, Africa, Asia and the Americas, working as lead ecologist, independent biodiversity specialist and Lenders Technical Advisor. In short, he assesses for a living whether environmental studies are good enough to be trusted.

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What was he asked to assess?

Gash was instructed to provide an independent review of the two documents at the centre of Yntegra's approvals: the Environmental Impact Assessment (EIA), which is required by the Department of Environmental Planning and Protection (DEPP) to explain how a project will affect the environment, and the Environmental Management Plan (EMP), which is meant to set out how those impacts will be minimised. He examined the adequacy of the ecological assessment as a whole, with particular focus on the bird surveys, and measured it against two internationally recognised benchmarks: IFC Performance Standard 6 and World Bank Environmental and Social Standard 6. Together these represent, in his words, "the prevailing benchmark for internationally accepted good practice in biodiversity risk management" (pg. 61). His report was delivered in June 2026 to assist the Courts and the Subdivision and Development Appeal Board in determining whether DEPP was given appropriate information before issuing environmental approvals.

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The central finding: Yntegra’s EIA and EMP are “wholly inadequate for a site of this ecological sensitivity”

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Gash found that Yntegra’s EIA submitted in support of its Rosewood Exuma project and the survey programme behind it, he writes, are "wholly inadequate for a site of this ecological sensitivity” (pg. 64). Sampson Cay sits within the Exuma Cays, a chain internationally recognised for its biodiversity, yet the surveys underpinning the approval were "single-season, unquantified, undated, conducted by a team of unknown composition and expertise, and cover only a fraction of the taxa (groups of organisms) and habitats that Good International Industry Practice (GIIP) requires to be assessed” (pg. 64). 

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All fieldwork in support of the EIA was carried out in a single winter season where a winter-only survey "is incapable of characterising the full bird assemblage" given that some birds that may occupy the island in other seasons would not be present. The Yntegra EIA itself acknowledged that summer surveys were needed but never commissioned them. As a result, species of high international conservation concern, including Bahamian endemics such as the Bahama Woodstar hummingbird and Bahama Mockingbird, the globally threatened Kirtland's Warbler and breeding seabirds, were "either missed entirely or inadequately assessed” (pg. 9). In sum, the bird surveys in the Yntegra EIA are inadequate by any internationally accepted standard and "no reasonable decision-maker properly directing itself on the material before it could conclude that this proposal is acceptable in ornithological terms" (pg. 10).

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Gash found the failures ran well beyond birds. The site, on the available evidence, is "highly likely to qualify as Critical Habitat under multiple IFC PS6 and ESS6 criteria (pg. 64) yet no Critical Habitat assessment was carried out at all. The EIA recorded a functioning microbial mat community in a hypersaline lake - communities Gash describes as "among the rarest and most ancient ecosystems on Earth" (pg. 29) - while the Yntegra EMP itself proposes the project would affect two such ponds. “The best-documented examples occur in Shark Bay, Western Australia (a UNESCO World Heritage Site), The Bahamas, the Yucatan Peninsula, and a small number of other hypersaline and marine environments. Within The Bahamas, the Exuma Cays have been recognised as supporting some of the finest examples of modern marine stromatolites and microbial mat communities anywhere in the world; those within the Exuma Cays Land and Sea Park are internationally significant. The presence of a functioning microbial mat community in the hypersaline lake of the project site has direct and material implications for Critical Habitat assessment…However, the reports offer no specialist assessment of them” (pg. 30).

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The Yntegra EIA reported that the reef appears free of Stony Coral Tissue Loss Disease (SCTLD). Another expert, marine ecologist and Executive Director of the Perry Institute for Marine Science, Craig Dahlgreen, instead found it had a below-average level of SCTLD. Gash says this “misrepresentation further undermines the reliability of its baseline“ while noting that a reef with low disease prevalence is still substantially more likely to support viable populations of important coral species “at densities meeting Critical Habitat thresholds” than more highly diseased coral. It is therefore “more sensitive to direct physical impacts from development and long-term operational pressures”, said Gash, noting however that the EIA does not reflect this elevated sensitivity in its impact assessment.

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Notably, proposed mitigation measures that are offered by Yntegra - including offering a freshwater wetland in place of natural forest and hypersaline lagoon, and “translocating mobile marine megafauna” like Whitespotted Eagle Rays - are offered with “no evidence base to support its feasibility or effectiveness” (pg. 65). 

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 “Major adverse impacts that cannot be mitigated or offset”

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Gash found that the approval for the Rosewood Exuma project was granted on an evidence base that does not meet international standards "in any material respect" (pg. 11). As Gash puts it, "the decision-maker was not provided with the ecological information necessary to make a properly informed decision, and some of the information that was provided was wrong" (pg. 65). Moreover, in his professional opinion, a properly conducted environmental assessment "would conclude major adverse impacts that cannot be mitigated or offset" if Yntegra were to go ahead with the Rosewood Exuma project as designed (pg. 12). 

Notably, he and Andrew Baker reviewed Yntegra's documents independently and reached the same conclusions.

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Stop the work so the real risks can be properly considered

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Like the Baker report, Gash’s expert review of Yntegra’s EIA and EMP confirms what we have said from the start: the project would do serious, lasting harm to an extraordinary place, without effective steps to offset this damage, and the approvals behind it were given without the information the law requires. 

Gash's report is the first of a series of expert reports on Yntegra’s Rosewood Exuma project that will be released in coming weeks. 

Last week, Turtlegrass released Andrew Baker’s report into Yntegra’s Environmental Impact Assessment and Environmental Management Plan, which he found “deeply flawed”. Read about that here.

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Read Gash’s full report for yourself, and watch out for the rest.

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