Minimising the time taken to assess permit applications enables

ANAO Report No.3 2015–16 Regulation of Great Barrier Reef Marine Park Permits and Approvals 66

3.30 The ANAO examined eight routine applications and three non-routine

applications where the assessments required greater than 120 days and one year, respectively, for GBRMPA to complete. While the reasons for some assessment delays were well-documented, the reasons for other assessments delays was not evident from retained documentation. The ANAO found that: • routine applications—the assessment of three of the eight applications were delayed for reasons related to: the applicant being overseas for an extended period; the confirmation of permit details with QPWS and the applicant; and the application being considered in conjunction with the assessment of a separate permit application. Reasons for the delayed assessments for the remaining five applications were not evident from retained records; and • non-routine applications—the assessments for two of the three applications were delayed for reasons related to: the determination of a Commonwealth lease as a precursor to the issuing of the permit; and the extensive consultations involved during the permit assessment and the precursor consideration of the project as a controlled action under the EPBC Act. The assessment for the remaining application remained inactive for six months when the assessing officer was re-assigned to other duties and not replaced, and subsequently for a further three and a half months for reasons not evident from retained documentation. Stakeholder comments on permit application assessments

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

GBRMPA’s permit assessment practices. Comments received by the ANAO from permit holders and general stakeholders 75 including industry environmental peak bodies, government agencies and reef research stations consistently identified the lack of timeliness as a major issue—particularly for non-routine applications. By way of example, one permit holder indicated that GBRMPA required two and a half years to process its permit application, by 75 The ANAO received eight responses from permit holders from 152 requests and 17 responses from general stakeholders from 67 requests, as well as two unsolicited responses. ANAO Report No.3 2015–16 Regulation of Great Barrier Reef Marine Park Permits and Approvals 67 which time its application had been handled by four different GBRMPA assessing officers with differing views of assessment requirements.

3.32 While permit holders and other stakeholders expressed some positive or

neutral comments on GBRMPA’s permit assessment performance, most comments highlighted perceived shortcomings or areas for improvement. The issues raised by permit holders and general stakeholders in submissions provided to the ANAO—apart from the timeliness of application processing— include: • GBRMPA’s scientific skills and knowledge—permit holders and some general stakeholders acknowledged the high level of scientific marine knowledge within GBRMPA, while other general stakeholders considered that additional technical expertise in relation to ports, shipping and dredging would be beneficial; • communication—permit holders were generally satisfied with their communication with GBRMPA as their permit applications progressed though the assessment process. However, general stakeholders held mixed views, with some satisfied with their communication with GBRMPA while others were dissatisfied; • the basis for assessments—some general stakeholders expressed concern about ‘shifting goalposts’ in regards to the information GBRMPA required to assess non-routine applications and a need for GBRMPA to balance the science with ‘real-life’ operational practicalities; and • risk management—some general stakeholders considered that permit application assessments would benefit from a more rigorous consideration of risks to the Marine Park based on scientifically documented environmental threats. Conclusion

3.33 GBRMPA places a heavy reliance on the templates that it has developed

to assess mandatory and discretionary considerations and risks associated with the routine permit application assessments that comprise around 90 per cent of all Marine Park permit application assessments. The templates generally facilitated an appropriate assessment of the permitted activities most commonly requested by applicants for the various permit types such as vessel-based tourism and research against most mandatory considerations, some relevant