In undertaking the audit, the ANAO reviewed GBRMPA’s files and

ANAO Report No.3 2015–16 Regulation of Great Barrier Reef Marine Park Permits and Approvals 41

2. Processing of Permit Applications

This chapter examines the processing of Marine Park permit applications received by the Great Barrier Reef Marine Park Authority. Introduction

2.1 The regulatory framework applying to the Great Barrier Reef Marine

Park provides the basis for GBRMPA to grant permits, with conditions where appropriate, to applicants on the basis of an assessment that the risks posed by the permitted activitiesfacilities can be adequately managed. The ANAO examined GBRMPA’s processing of permit applications and its management of processing requirements. 45 Permit application assessment framework

2.2 The GBRMP Act prohibits the conduct of particular activities in the

Marine Park without a permit granted under the GBRMP Regulations. The Regulations establish administrative arrangements governing the granting and management of permits, for example in relation to: matters to be considered by GBRMPA during the assessment of permit applications; and the form, term and conditions of permits.

2.3 To guide its staff when processing permit applications, GBRMPA has

developed a range of administrative guidance materials to support its issuing of permits in accordance with the Regulations. These materials include: • policy documents and position statements—covering matters such as environmental impact management, tourism, dredge spoil and disposal, structures, scientific research, and aquaculture; • permit application assessment procedures—including in relation to environment assessment and management, processing routine and major project permit applications, a permit assessors’ reference guide and ancillary guidance such as native title notifications and applying the assessment criteria specified in the GBRMP Regulations; and 45 The preparation of assessment reports for the delegate’s consideration and the development of conditions attached to issued permits is examined in Chapters 3 and 4, respectively. ANAO Report No.3 2015–16 Regulation of Great Barrier Reef Marine Park Permits and Approvals 42 • templates categorised by permit type—covering most application forms, risk assessments, assessment reports and permitspermit conditions.

2.4 Overall, the guidance materials support the assessment of permit

applications by GBRMPA staff. However, permit application assessment procedures are contained in multiple documents that do not clearly address all relevant requirements and processes. In particular, procedural documents: • are in draft form or overdue for a reviewupdate 46 , with some documentation not subject to review for up to five years; • do not address all key relevant assessment considerations—including the incorporation of risk assessments into the assessment process; and • do not indicate how assessors are to developtailor assessment reportscoversheets and permit conditions relevant to the activity recommended for approval or refusal.

2.5 To better manage the risks associated with out-of-date, ambiguous or

incomplete guidance materials for permit processing, it would be prudent for GBRMPA to streamline and consolidate content, and to clarify and expand coverage. Processing permit applications

2.6 GBRMPA and QPWS have established a joint permitting system that

allows applicants to apply for permits under Commonwealth and Queensland marine park legislation through a joint permit application and assessment process. Once an application is approved, permit holders are issued with a single permit covering the conduct or operation of the activityfacility in both the Marine Park and coast Marine Park. Under current arrangements, GBRMPA assumes the lead role in the assessment of joint permits against Commonwealth and Queensland requirements 47 with the exception of camping and education permits that are assessed by QPWS, although delegates from each jurisdiction are required to approve the permits. 46 Most GBRMPA permit assessment procedural documentation nominates a date at which time the documents are expected to be reviewed for currency. 47 The audit examined GBRMPA’s assessment of permit applications against Commonwealth requirements only. Most recreational and commercial fishing activities in the Marine Park are subject to state permits and licenses issued by Fisheries Queensland outside of the joint permitting system.