In the absence of monitoring guidelines, the EAP Section has established

ANAO Report No.3 2015–16 Regulation of Great Barrier Reef Marine Park Permits and Approvals 104 risk-based program of site inspections, including a dedicated budget, or determined a target number of inspections to undertake each year. GBRMPA informed the ANAO that site inspections are conducted infrequently due to resourcing constraints. Further, the logistics involved in arranging suitable inspection dates with permit holders, GBRMPA staff and representatives from other agencies including QPWS and the Queensland Department of Environment and Heritage Protection adversely impacts on the number of inspections conducted.

6.29 While a co-ordinated risk-based program of inspections has not been

established by GBRMPA, a limited number of site visits, audits and inspections have been undertaken. A register maintained by GBRMPA indicates that, over the period from July 2012 to early January 2015, GBRMPA and FMCU partners conducted 34 site visits, audits and inspections including pre-works surveysfamiliarisation visits for permitted facilitiesworksstructures, such as dredging activities, jetties, pontoons, pipelines and sewage treatment plants.

6.30 To guide the conduct of the visits, audits and inspections, GBRMPA has

developed a comprehensive template covering the planning including consultation undertaken, past compliance history, and work, health and safety considerations and conduct of inspections, documentation of findings and post-inspection reporting. The ANAO examined the site inspection documentation for a sample of permits, supplemented by documentation associated with additional inspections of sewage outfall facilities in the Whitsunday Islands in 2013 five in total. The inspections template was satisfactorily completed in all cases. The completed reports clearly identified the extent of compliance and non-compliance with permit and EMP conditions and included photographic evidence and documented an approved course of action to address any non-compliance. The areas of non-compliance observed by GBRMPA included: a failure to develop, or comply with aspects of, the sites’ EMP; unauthorised waste discharge or waste discharge exceeding release limits; and the installation of unpermitted equipment. 118

6.31 Site inspections are an effective tool to identify aspects of permit

compliancenon-compliance that are not readily identifiable through other monitoring methods, such as vessel and aerial patrols. A co-ordinated, 118 Of the four site inspections that identified aspects of permit non-compliance, four aspects of non-compliance at two sites were not recorded as non-compliance incidents in CMIS.