The permit assessment templates developed by GBRMPA incorporate

ANAO Report No.3 2015–16 Regulation of Great Barrier Reef Marine Park Permits and Approvals 59 contents andor permit assessment coversheets were rarely varied to take into account relevant discretionary considerations. 66 Nevertheless, the ANAO found that, of the 93 permit application assessments examined, none fully considered all of the relevant discretionary considerations—many of which are identified by a ‘No’ response in Table 3.3 above—including: • adherence to GBRMPA policies and guidelines primarily the ‘Managing Tourism Permission Policy’ in respect of the tourism-related assessments Reg.88Rd and whether the proposed conduct requires approval under Queensland law Reg.88Rf—both of which GBRMPA guidance indicates should form part of all permit application assessments; • Plans of Management established under Part VB of the GBRMP Act applying to particular areas of the Marine Park Reg.88Rh; • threat abatement plans, wildlife conservation plans and recovery plans made under the EPBC Act that apply to particular marine species prevalent in the Marine Park Reg.88Ri; and • applicants’ history of environmental compliance with respect to previous GBRMP permits in relation to tourism, harvest fishery and most other routine permit applications with the exception of moorings and some research Reg.88Rji-iii.

3.15 While acknowledging that discretionary considerations will not be

relevant to all application assessments, it would be prudent for the permit application assessments to document those discretionary considerations that permit assessing officers consider are not relevant, or do not add value, to the delegate’s consideration of an application. Customised permit application assessments

3.16 GBRMPA’s assessment of discretionary considerations for most

non-routine permit applications most of the Level 2 and all of the Level 3 and 4 applications are customised to the specific nature of the respective applications. As a consequence, most, if not all, discretionary considerations are substantively addressed in each application assessment. The seven customised 66 The exceptions were some GBRMPA policies and guidelines Reg.88Rd for most research applications and the applicants’ compliance history for applications to replace most expiring mooring and research permits Reg.88Rji-iii.