As part of the audit, the ANAO sought comment from stakeholders on

ANAO Report No.3 2015–16 Regulation of Great Barrier Reef Marine Park Permits and Approvals 68 discretionary considerations and identified risks. However, there is scope to significantly improve the coverage and content of assessment and risk templates to better address mandatorydiscretionary considerations and risks, respectively, relevant to the assessment of all, or particular types of, permits. These improvements would minimise: the requirement for assessing officers to repetitively tailor assessments to address matters commonly relevant; and the likelihood of relevant considerations and risks being overlooked during assessments.

3.34 On most occasions, template-based permit application assessments are

not sufficiently tailored to address relevant regulatory requirements and risks that are not canvassed by the templates. Similarly, the customised permit assessments examined by the ANAO assessed non-routine applications involving structures, works or facilities against most, but not all, mandatory and discretionary regulatory requirements.

3.35 The development of risk assessment templates in early 2012 for common

types of permitted activities has assisted GBRMPA to efficiently assess the risks posed by these activities. The lack of templates for some permitted activity types has, however, necessitated the development of customised risk assessments. Further, in the case of some permitted activity types that constitute around 8.5 per cent of approvals such as moorings and crown-of-thorns starfish programs neither template-based nor customised risk assessments were prepared. Weaknesses in the identification of risks to the Marine Park posed by proposed activities makes it more difficult for GBRMPA to design appropriate conditions to attach to permits.

3.36 All permit application assessment reports prepared for the delegate’s

consideration that were examined by the ANAO included the assessments against mandatory and discretionary considerations and risk assessments prepared by the assessment officers. The reports also generally contained reference to, and the results of, other assessment activities undertaken in support of each permit assessment such as application referrals with GBRMPA and to QPWS, and native title notifications. However, permit assessment checksheets were not completed in full by the assessment officers for some 70 per cent of the assessments examined by the ANAO, and the subsequent certification of assessments as complete has diminished the effectiveness of checksheets as a quality control measure. ANAO Report No.3 2015–16 Regulation of Great Barrier Reef Marine Park Permits and Approvals 69 Recommendation No.2

3.37 To improve the rigour of permit application assessment and

decision-making processes, the ANAO recommends that the Great Barrier Reef Marine Park Authority: a prepare and revise permit application assessment templates and risk templates to better address assessment considerations and risks relevant to the various permit types; and b reinforce to staff the importance of preparing assessment reports for delegates that adequately address regulatory assessment requirements. GBRMPA’s response: Agreed.