Overall, permit monitoring undertaken by GBRMPA has been

ANAO Report No.3 2015–16 Regulation of Great Barrier Reef Marine Park Permits and Approvals 23 these incidents were generally not documented in 89.5 per cent of cases and the prioritisation of, and planning for, investigations was not undertaken in accordance with established procedures. Further, while half of the 51 finalised investigations were completed within a relatively short time period 10 days or less, extended timeframes were required to finalise a significant proportion of investigations—many of which have been impacted by consistent, lengthy delays of months, and even years in obtaining timely information or action from other areas of GBRMPA outside of the FMCU.

38. In general, the documentation of enforcement decision-making in

relation to permit-rated non-compliance has been poor. In relation to the 51 finalised investigations: • the officer making the enforcement decision and the date when the decision was made was unclear in 21 cases 41 per cent and 18 cases 35 per cent, respectively; and • the FMCU retained documentation to sufficiently explain the reasons underpinning the enforcement decision in only seven cases, with partially complete documentation retained for a further 14 cases. 25

39. While enforcement actions have generally been executed as intended

by GBRMPA and the FMCU with advisory letters the most common action taken, there were a small number of cases related to the education of permit holders where the investigations were closed despite enforcement action not having been undertaken. GBRMPA should better document the reasons for key decisions taken during investigations and verify that enforcement action has been undertaken prior to the closure of investigations. Summary of entity response

40. GBRMPA’s summary response to the proposed report is provided

below, while the full response is provided at Appendix 1. The Great Barrier Reef Marine Park Authority the Authority agrees without qualifications with all five recommendations contained within the report. The Authority had already identified the need to strengthen its permissions system through commitments in the Great Barrier Reef Region Strategic Assessment 25 The type of enforcement action such as advisory letter or prosecution had little or no bearing on the extent to which reasons were documented.