Where templates are used as the basis for permit application

ANAO Report No.3 2015–16 Regulation of Great Barrier Reef Marine Park Permits and Approvals 60 permit applications assessments examined by the ANAO satisfactorily considered nine of the 11 discretionary considerations Regs.88Ra-h and k. However in relation to the remaining two discretionary considerations: • five assessments did not consider all relevant threat abatement plans, wildlife conservation plans and recovery plans made under the EPBC Act that applied to the Marine Park Reg.88Ri; and • three assessments did not satisfactorily consider the compliance history of the permit applicant and related entities Reg.88Rji-iii. 67 Risk assessments

3.17 A documented assessment of risks associated with each permit

application allows the delegate to consider the extent to which relevant risks to the Marine Park posed by the proposed activity can be effectively managed. The template-based assessments prepared by GBRMPA make reference to risk, particularly in relation to mandatory considerations Reg.88Q a and b from the GBRMP Regulations see Table 3.1 earlier. Use of risk assessments

3.18 As part of each permit assessment, GBRMPA commonly prepares a risk

assessment related to the permitted activity sought by the application. To inform its assessment of relevant risks, the GBRMPA has developed a suite of risk assessment templates for the most common types of permitted activities such as standard vessel-based tourism operations and research. These templates contain generic risks that can be relevant to the particular permitted activity, including pre-prepared inherent risk ratings and risk ratings after existing controls have been taken into account. 68

3.19 GBRMPA has not, however, developed risk assessment templates for all

permitted activity types and, in their absence, customised risk assessments are 67 Two assessments considered the applicant was a suitable person yet noted that the permit holder had ‘a poor record of effectively administering Marine Park permits’. In addition to the non-compliance documented as part of this assessment, other non-compliance was evident in other parts of the permit application assessments in relation to unpermitted facilitiesstructures identified during the replacement of past expiring permits. One assessment did not consider the compliance history of companies related to the permit applicant—unlike other application assessments for this permit holder. 68 The risk assessment templates were last updated in March 2012. ANAO Report No.3 2015–16 Regulation of Great Barrier Reef Marine Park Permits and Approvals 61 prepared for some high-risk non-routine applications. 69 Neither template-based nor customised risks assessments were prepared for other permitted activity types, including: moorings; commercial and coral harvest fisheries; crown-of-thorns starfish programs and education programs. These activities constitute more than 8.5 per cent of all permit applications assessed by GBRMPA during the two-year period from July 2012 to June 2014. As a consequence, the delegate’s decision to grant or refuse applications for these permitted activity types is not informed by a documented assessment of the risks that the activities pose to the Marine Park. Assessment of risks to the Marine Park

3.20 In those cases where a risk assessment is prepared, the assessments

generally indicated that most high and medium-rated inherent risks could be reduced to low or medium risks due to existing controls. The existing controls related to the establishment of permit conditions and for tourism operations, the use of better practice guidance. In relation to the 56 permit applications examined by the ANAO that contained a risk assessment, GBRMPA assigned a medium, high or extreme inherent risk rating to 212 risks. GBRMPA considered that all but two risks could be reduced to medium or low after taking into account existing controls. These two remaining high risks related to a non-routine application that was refused a permit. Consideration of relevant risks

3.21 As template-based risk assessments are not generally tailored by

GBRMPA assessors to address the risks posed by each permit application, the assessments have not addressed some relevant risk considerations while risks that are not relevant to some permits have been addressed. Relevant risk considerations that were not specifically addressed by GBRMPA in relation to the 77 risk assessments examined by the ANAO involving both template-based and customised risk assessments include: • 35 permit assessments 45.5 per cent that did not consider all aspects of the potential risk of damage to, or unauthorised interference with, coral or marine life from vessels including reef strike, anchor damage, 69 Customised risk assessments were prepared for the seven non-routine applications that were examined by the ANAO.