As template-based risk assessments are not generally tailored by

ANAO Report No.3 2015–16 Regulation of Great Barrier Reef Marine Park Permits and Approvals 63 • QPWS comments received including ‘nil’ returns in relation to 55 of the 58 assessments 94.8 per cent where applications were referred or QPWS provided unsolicited comments 70 ; • native title notifications sent and comments received if any on 66 assessments 83.5 per cent 71 ; • applicants having paid all outstanding environmental management charges as applicable; • reasonable use assessments having been undertaken for special tourism permits on all nine relevant occasions; and • QPWS having been provided with a copy of the draft permit assessment for endorsement prior to them being submitted to the delegate for approval on nine of the 12 occasions where endorsement was requested. 72 Management of permit assessments processing

3.24 The draft permit application assessment reports prepared by GBRMPA’s

assessment officers are to be reviewed within the EAP Section before the reports are submitted to the delegate for consideration. 73 Evidence of the review is to be documented on the permit processing checksheet. The ANAO examined evidence supporting GBRMPA’s oversight of the development of permit application assessment reports, as well as the timeliness of GBRMPA’s permit processing. 70 In relation to the remaining applications, two permit application assessment reports made no or partial reference to the comments received and one report incorrectly noted that the application had not been referred. 71 In relation to the remaining 13 assessment reports: 10 assessments did not refer to native title notifications having been sent or received nine of which related to non-class notifications; two assessments incorrectly indicated that class notifications were involved when non-class notifications had been sent; and one assessment did not reflect whether comments had been received. 72 On two of the nine occasions, the QPWS endorsement process resulted in the modification to permit details to: insert conditions unintentionally omitted from the expiring permit; and correct the Global Positioning System GPS location of moorings. Where QPWS was not afforded an opportunity to endorse the permit assessment as requested: one assessment report incorrectly indicated that endorsement had not been requested; another report confused QPWS’ referral comments with endorsement of the application; and while the remaining assessment had not been endorsed by QPWS, the assessment report had noted that endorsement was required. 73 All permit assessments with the exception of research applications are reviewed for completeness within the EAP Section two occasions. The first review was examined earlier in Chapter 2. ANAO Report No.3 2015–16 Regulation of Great Barrier Reef Marine Park Permits and Approvals 64 Review of draft permit application assessment reports

3.25 The review certifies the accuracy and completeness of draft permit

applications assessment reports after endorsements have been obtained from QPWS where requested and, from April 2013, that the applicants have paid any outstanding environmental management charges and the Reef Permits database has been updated. 74

3.26 As outlined earlier in Chapter 2, the checksheets, where prepared,

generally documented the review of permit application processing and assessment reports, but the significant gaps in the completeness of many of certified checksheets reduced the effectiveness of the reviews as a quality assurance measure. In relation to the 79 permit application assessments examined by the ANAO: • records supporting only one of the four non-routine permit assessments without completed checksheets provides a clear indication that the permit assessment process and the draft permit application assessment report were reviewed within the EAP Section before the assessment report was submitted to the delegate for decision; • the checksheets do not evidence that the reviews had been undertaken as required for four assessments 5.1 per cent; and • 48 of the 68 checksheets 70.6 per cent reviewed by managers were incomplete. Timeliness of permit application assessment processing

3.27 Minimising the time taken to assess permit applications enables

GBRMPA to: facilitate timely access to the Marine Park for new applicants to undertake their permitted activities or operations; and promptly reassess the risks posed by the permitted activities or operations of expiring permit holders who seek a new permit. GBRMPA’s permit processing procedures have established a target timeframe of 60 days to assess routine applications. Assessment timeframe targets have not been established for non-routine applications, which are generally more complex and, therefore, expected to take longer to assess. 74 Checksheet templates were updated in April 2013 to reflect a new requirement for assessment officers to record, and assessment managers to certify, that applicable environmental management charges had been paid and that the Reef Permits database had been updated.