While GBRMPA has produced a range of guidance materials to

ANAO Report No.3 2015–16 Regulation of Great Barrier Reef Marine Park Permits and Approvals 18 GBRMPA should revise and finalise its application processing guidance materials—much of which is currently in draft form or overdue for a review.

23. The arrangements established by GBRMPA to process permit

applications are generally sound, but the extent to which the requirements have been implemented has been variable. Permit processing activities such as the receipt and acknowledgement of permit applications and issuing native title notifications were generally undertaken satisfactorily 17 , but other required permit processing activities including responses to native title notifications, and referrals within GBRMPA andor to QPWS for comment were not. 18

24. GBRMPA officers are to complete checksheets for each permit

application assessment as a means of monitoring the satisfactory conduct of processing activities. However, over half of the assessment checksheets 56 per cent examined by the ANAO were incomplete. Notwithstanding the incomplete status of most checksheets, permit processing activities had been certified as complete by the EAP Section. The certification of incomplete checksheets reduces the assurance that they are intended to provide. Permit Application Assessment Chapter 3

25. The GBRMP Regulations specify a number of mandatory and

discretionary considerations as part of the permit application assessment process. GBRMPA has developed, and relies heavily upon, templates to assess routine permit applications 19 against relevant regulatory requirements. While the template-based assessments took into account many requirements, they were, in general, not sufficiently tailored to address all applicable requirements—particularly discretionary considerations. Similarly, the 17 For example, of the 76 permit applications examined by the ANAO, GBRMPA: acknowledged the receipt of permit applications within two weeks for 93.7 per cent of applications; and issued native title notifications as required for 96.2 per cent of applications. 18 For example, of the 76 permit applications examined by the ANAO, GBRMPA did not retain documentation to evidence: eight of the 25 responses 32 per cent received from native title notifications; the referral of applications within GBRMPA for 26 of the 40 applications 65 per cent that met referral thresholds; and the referral of applications to QPWS for 12 of the 70 applications 17.1 per cent that met referral thresholds. 19 Routine permit applications cover the most common permission types including vessel and aircraft-based tourism, research and moorings that GBRMPA has assessed as generally posing a lower risk to the Marine Park environment relative to other non-routine applications—most commonly major facilitiesworksstructures—that pose a greater risk. Routine permit applications comprise in excess of 90 per cent of all permit applications. ANAO Report No.3 2015–16 Regulation of Great Barrier Reef Marine Park Permits and Approvals 19 customised assessments prepared for non-routine applications also took into account most, but not all, mandatory and discretionary regulatory requirements such as the condition of some existing structures current at the time of permit assessment.

26. Risk assessments also template-based are to be prepared as part of

permit application assessments. However, 48 per cent of risk assessments in the sample of permits examined by the ANAO did not consider all relevant risks posed by the permitted activities, including the potential for damage tointerference with coral and marine life, and the impact on other Marine Park users. Further, risk assessments have not been prepared for approximately 8.5 per cent of permit assessments involving activities such as moorings undertaken by GBRMPA over the period from July 2012 to June 2014. Weaknesses in the identification of risks to the Marine Park posed by proposed activities makes it more difficult for GBRMPA to design appropriate conditions to attach to permits.

27. As a consequence of the weaknesses in permit processing and

assessment activities, the assessment reports prepared for delegates did not incorporate all relevant information to inform the delegate’s decision to issue or refuse a permit. In addition, the assessment of permit applications by GBRMPA has not been timely. Over the period from July 2012 to June 2014, GBRMPA achieved its 60-day target timeframe for assessing routine applications in 57 per cent of cases 413 of the 720 routine applications, with a further 81 applications taking between 120 days and around two years to complete. Over the same period, assessments of 22 of the 63 non-routine applications for which no target assessment timeframes have been established took between one year and nearly four years to complete. The comments provided to the ANAO by permit holders and general stakeholders identified assessment timeliness as an area of concern in relation to GBRMPA’s regulation of permits. Permit Decisions and Approval Conditions Chapter 4

28. The 786 permit assessment decisions during the period July 2012 to

June 2014 were made by an authorised GBRMPA delegate. In 78 of the 79 permit assessments examined by the ANAO, the assessment reports contained recommendations that were supported by the assessments prepared, with the delegate agreeing to all recommendations 76 of which were to grant a permit and two to refuse a permit. The remaining permit application assessment report