Three of the 13 Marine Park activities assessed on a quarterly basis

ANAO Report No.3 2015–16 Regulation of Great Barrier Reef Marine Park Permits and Approvals 89 • participation in multi-agency audits involving Queensland Government agencies; • development of an annual permit compliance plan discussed in Chapter 6; and • development of permit compliance procedures for FMCUGBRMPA staff. Permit risk assessment

5.26 In September 2014, GBRMPA hosted a permit risk assessment workshop

as an initial step towards improving its monitoring and management of compliance risks associated with GBRMP permits. The workshop was attended by all EAP Section staff and selected representatives from the FMCU, other areas of GBRMPA, QPWS and the Department of the Environment.

5.27 The primary purpose of the workshop was to assess all permit categories

against a common risk—‘Failure to comply with the intent and conditions of the permit’. Workshop participants considered that a number of factors could give rise to this risk occurring, including: • lack of awareness of permit holder obligations; • unintentional non-compliance; • intentional non-compliance; and • errors in the permit terms.

5.28 While the permit risk assessment has provided useful insights into the

risk of permit non-compliance within the Marine Park, key elements of the assessment remain incomplete. While risk ratings and treatments where relevant were documented for all permit risk categories, the impact of risk and the residual risk that is, the risk rating after treatments was not documented for most permit risk categories 14 of 17, as was the acceptability of seven of the 17 risk ratings. GBRMPA informed the ANAO that the permit risk assessment will be completed in conjunction with the finalisation of the permit compliance management plan.

5.29 The permit risk assessment indicates that existing controls which

include permit conditions, deeds and bonds, intelligence gathering and analysis, patrols, and other monitoring activities are generally insufficient to effectively manage the risks posed by GBRMP permits and permitted activities in the Marine Park. After considering the effectiveness of existing controls, workshop ANAO Report No.3 2015–16 Regulation of Great Barrier Reef Marine Park Permits and Approvals 90 participants rated the risk of non-compliance for over half of the permit categories as ‘High to Very High’ or greater including in relation to: structures excluding moorings—operations; dredging and spoil disposal; aquaculture— disease, genetic changes, pests; take of a species that pose a threat shark; navigation of a shipbarge; net fishing; take of species that pose a threat crown-of-thorns starfish; and facilities—works.

5.30 The permit compliance management plan, to be introduced in 2015–16, is

expected to rate the potential risks to the Marine Park environment from permitted activities, taking into account the risks of non-compliance determined at the workshop, and identify a range of additional treatments to mitigate unacceptable risks. Potential additional treatments considered during the workshop included: increasing the rigour of permit application assessments; strengthening or refining permit conditions including a greater use of deeds and bonds; increased compliance monitoring including the use of enabling technology and stronger enforcement action. Conclusion

5.31 The FMCU has established processes for collecting, analysing and

disseminating 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. The compliance intelligence obtained from a variety of sources, including from partner agencies and members of the public, is consolidated into information reports that inform compliance activities. In addition to the preparation of information reports, the FMCU also produces a number of tailored documents to support its compliance activities, including targeting profiles and patrol briefs.

5.32 The FMCU has a well-established framework to identify, assess and

develop treatments for strategic risks facing the Marine Park, primarily based on the development of a strategic risk register. The risk register is monitored on a regular basis and is updated to reflect changes in the risk environment, for example to reflect compliance incidents and intelligence information. The preparation of quarterly threat and response analyses facilitates the timely adjustment to risk treatments.

5.33 To complement the strategic risk register, which generally addresses a

broader range of risks beyond those that specifically relate to permitted activities, GBRMPA has recently taken steps to strengthen its identification and management of permit-related risks. In late 2014, GBRMPA conducted a permit