In addition to the limited monitoring undertaken, shortcomings in the

ANAO Report No.3 2015–16 Regulation of Great Barrier Reef Marine Park Permits and Approvals 105 risk-based program of site inspections—as part of a permit compliance management plan—would allow GBRMPA to better demonstrate that it is: appropriately targeting those permits that pose the greatest risks; and efficiently allocating limited resources. Conclusion

6.32 GBRMPA generally grants and processes amendments to permit

conditions and associated nominations requested by permit holders after taking into account considerations relevant to the decisions. In those cases where amendments to permit conditions are initiated by GBRPMA, it has consulted with relevant permit holders as part of the approval process.

6.33 The permits approved by GBRMPA incorporate a range of standardised

conditions that generally provide a basis on which GBRMPA can monitor ongoing compliance. However, with the exception of the executionlodgement of deeds and bonds, GBRMPA does not effectively monitor the timely receipt, nor appropriately document its assessmentapproval of, most other post- approval reporting requirements that permit holders are required to submit under their permit conditions. There is scope for GBRMPA to strengthen its monitoring of post-approval reporting requirements, specifically by developing new, and enhancing existing, guidance material and support tools for its staff.

6.34 The FMCU and its partner agencies undertake compliance monitoring

within the Marine Park for both permitted activities and activities not subject to a permit through field compliance operations based on intelligence and an analysis of strategic and emerging risks. Nevertheless, GBRMPA’s monitoring of post-approval reporting requirements and the conduct of field compliance operations, in isolation, do not sufficiently address all aspects of potential permit non-compliance. The delivery of supplementary compliance monitoring activities, such as risk-based site inspections, provides additional assurance relating to certain types of permitted activities, including sub-surface infrastructure. The use of supplementary monitoring has, however, been limited, with weaknesses evident in the delivery and documentation of these monitoring activities. While the limited numbers of site inspections that have been conducted have provided insights into permit holders’ compliance, they have not been delivered as part of a co-ordinated, risk-based program.

6.35 Overall, permit monitoring undertaken by GBRMPA has been

insufficient to determine permit holders’ compliance with permit conditions. Improved monitoring of permit holders’ compliance with post-approval