In practice, GBRMPA has inconsistently applied the public advertising

ANAO Report No.3 2015–16 Regulation of Great Barrier Reef Marine Park Permits and Approvals 51 Conclusion

2.29 GBRMPA has produced a range of guidance materials to underpin its

processing of permit applications. The materials that have been produced are, however, fragmented, ambiguous in parts and do not clearly address all relevant requirements. GBRMPA should revise and finalise its application processing guidance materials—much of which is currently in draft form or overdue for a review.

2.30 The arrangements established by GBRMPA to process permit

applications are generally sound. Notwithstanding the established arrangements, sufficient evidence has not been retained by GBRMPA to demonstrate that required assessment activities were satisfactorily undertaken on all occasions. Further, the checksheets established to evidence the completion of key assessment activities were also incomplete, which increases the risk that relevant information was not obtained to inform the delegate’s decision on whether to grant or refuse a permit. The subsequent certification of incomplete checksheets within the EAP Section reduces the assurance that they provide as a quality control measure. Recommendation No.1

2.31 To improve the processing of Marine Park permit applications, the

ANAO recommends that the Great Barrier Reef Marine Park Authority: a review and finalise standard operating procedures and administrative guidance for the permit application and assessment process; and b reinforce to staff the need to document whether permit application assessment requirements have been addressed. GBRMPA’s response: Agreed. ANAO Report No.3 2015–16 Regulation of Great Barrier Reef Marine Park Permits and Approvals 52

3. Permit Application Assessment

This chapter examines the Great Barrier Reef Marine Park Authority’s preparation of permit application assessment reports for the delegate’s consideration. Introduction

3.1 The GBRMP Regulations specify a number of mandatory considerations

that must form part of the permit application assessment, as well as a number of discretionary considerations. The information gathered from the assessment process is assessed by GBRMPA and presented in a report for the delegate’s consideration. The assessment reports also generally contain a recommendation to the delegate as to whether the application should be granted with conditions or refused.

3.2 To assist with the processing of routine or lower risk permit applications,

which comprise in excess of 90 per cent of all permit applications, GBRMPA has developed permit assessment templates that cover the most common permit types including in relation to vessel-based tourism, aircraft-based tourism, research and moorings. Within the context of each application type, the templates document GBRMPA’s broad assessment against the mandatory considerations and those discretionary considerations that GBRMPA considers are relevant to the assessment of the particular application type. Risk assessments many of which are also template-based are also attached to most permit application assessments. Where permit assessment templates are used 61 , cover sheets are attached that summarise GBRMPA’s consideration of each application, including additional matters relevant to mandatory or discretionary considerations not contained in the templates.

3.3 Permit assessment templates are not used for the assessment of permit

applications for major structures, works or facilities which comprise less than 10 per cent of all permit applications. In these cases, GBRMPA customises the permit application assessments to the requirements of the applications. 61 Multiple templates can form part of a single permit application assessment report where the applicant has applied for multiple permission types for example, vessel-based tourism and moorings.