As a consequence of the weaknesses in permit processing and

ANAO Report No.3 2015–16 Regulation of Great Barrier Reef Marine Park Permits and Approvals 20 for a high-risk activity in the Marine Park to dump capital dredge spoil off the coast of Abbot Point, contained four options to refuse to grant a permit or grant a permit under three separate scenarios with no recommendation from the assessment officer. The nature of this approval decision, including the high risk to the Marine Park and the absence of a recommendation to the delegate, increased the importance of the delegate thoroughly documenting the reasons for the decision at the time that it was made. 20

29. To inform its identification of the relevant conditions to attach to

Marine Park permits, GBRMPA has established a suite of templates for most permit types that can be tailored to meet the requirements of each permit. While most permit conditions have been satisfactorily designed to address many of the identified high and medium-rated risks to the Marine Park environment, some conditions do not sufficiently address identified risks for example, the risk of vessels anchoring without moorings damaging coral. To help ensure that significant risks are being effectively mitigated, GBRMPA should periodically review the design of standard permit conditions. Compliance Intelligence and Risk Assessment Chapter 5

30. The FMCU has established processes for collecting and analysing

compliance intelligence to inform the identification, assessment and treatment of a broad range of compliance risks that have the potential to impact on the health of the Marine Park. Given its contact with a large number of permit applicants each year and its compliance monitoring and permit maintenance activities for over 1300 current permit holders, there is scope for GBRMPA’s EAP Section to make a greater compliance intelligence contribution to the FMCU’s intelligence collection activities and products. Recent improvement in the coordination of the FMCU’s and EAP Section’s compliance activities has the potential to enhance permit-related intelligence and overall permit compliance management outcomes.

31. To further improve its monitoring and management of compliance

risks associated with permits and permitted activities, GBRMPA’s EAP Section is developing a permit compliance management plan. As part of this work, a 20 In this case, a more comprehensive explanation of the basis on which the delegate approved the permit was subsequently provided one and a half months later when GBRMPA prepared and published a statement of reasons in response to a number of requests for such a statement received after the decision was made.