The FMCU informed the ANAO that it has up to 10 problemtarget

ANAO Report No.3 2015–16 Regulation of Great Barrier Reef Marine Park Permits and Approvals 86 Park, of which seven related primarily to permitted activities and a further 1413 related to both permitted activities and activities not subject to permits see Table 5.1. 88 Table 5.1: Summary of strategic risk register risk ratings Risk Rating All Compliance Risks Risks Related to Both GBRMP Permitted Activities and Activities Not Subject to Permits Risks Related Primarily to GBRMP Permitted Activities 2013–14 2014–15 2013–14 2014–15 2013–14 2014–15 Extreme 1 2 - - 1 - Very High 13 10 2 1 - 1 High 14 14 7 6 3 4 Medium 10 12 5 6 3 2 Low 1 1 - - - - Total 39 39 14 13 7 7 Source: ANAO analysis of FMCU strategic risk registers.

5.17 Only a small proportion of the ‘Extreme’ and ‘Very High’ rated

compliance risks relate to GBRMP permitted activities—with most relating to commercial fishing, vessel groundings or the illegal take of protected species. The highest-rated compliance risk related to GBRMP permitted activities is ‘breach of a Marine Park permit to commercially net in the Princess Charlotte Bay Special Management Area’.

5.18 For each rated risk, the risk register identifies: the areas within the

Marine Park and the months of the year that the risk is at its greatest 89 ; the intended surveillancemonitoring treatments; and the agencies tasked involved in managing the risks. The FMCU has determined that most risks related to GBRMP permitted activities can be addressed exclusively through vessel and aerial patrols by FMCU and its partner agencies. However, some risks are also addressed through actions from other areas of GBRMPA, for example EAP Section audits of user charges and reports from state government agencies, commercial tourism operators and members of the public. 88 The remaining risks related primarily to illegal or state-regulated activities. 89 High risk periods often coincide with fishing seasonsexclusions or peak visitation times. ANAO Report No.3 2015–16 Regulation of Great Barrier Reef Marine Park Permits and Approvals 87

5.19 The FMCU strategic risk register includes ‘Breach of a Marine Parks

Permit’ as a generic risk for non-compliance related to permitted activities in the Marine Park. The FMCU acknowledges that this is a broad risk category, with consequence and likelihood ratings varying considerably depending on the types of permits. However, for the purposes of developing a single risk rating for permit breaches, the FMCU’s 2013–14 strategic risk register indicated that a risk rating of ‘High’ based a combination of a ‘Minor’ consequence rating and an ‘Almost Certain’ likelihood rating broadly reflects the relative consequence and likelihood of the types of permit breaches that are typically reported to the FMCU.

5.20 The 2014–15 strategic risk register continues to record and rate the

‘Breach of a Marine Parks Permit’ as a ‘High’ risk. The FMCU indicated that a permits risk management plan being developed by GBRMPA’s EAP Section which is discussed later in this chapter would provide more detailed analysis of the varying risks and risk ratings facing the Marine Park from GBRMP permitted activities. Quarterly forward threat and response analysis

5.21 At the conclusion of each quarter, the FMCU prepares a report on the

outcomes of its compliance activities and its re-assessment of compliance risks impacting the Marine Park—a forward threat and response analysis. In preparing the forward threat and response analysis, the FMCU considers whether planned responses to 13 Marine Park activities which encompass the risks from the strategic risk register in each of the four Marine Park management areas requires adjustment. 90

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

during the period July 2012 to June 2014 related to or related in part to GBRMP permitted activities—commercial netting, tourism operations, and other a 90 For administrative purposes, the GBRMP Zoning Plan divides the Marine Park into four discrete management areas: Far Northern; CairnsCooktown; TownsvilleWhitsunday and MackayCapricorn. The GBRMP management areas are taken into account in much of the FMCU’s risk planning management and patrol activities.