The ANAO examined GBRMPA’s assessment of Marine Park permit

ANAO Report No.3 2015–16 Regulation of Great Barrier Reef Marine Park Permits and Approvals 16

17. While GBRMPA has well-established arrangements for processing and

assessing permit applications, there were weaknesses in the quality and completeness of the assessments undertaken against regulatory requirements. The causes of these weaknesses included fragmented and incomplete guidance material for staff, incomplete records, insufficient consideration of relevant assessment requirements and limited assurance from quality control processes. As a consequence, the permit application assessment reports prepared for the delegate did not address all regulatory requirements on which decisions to issue or refuse permits were to be based. Delegates did, however, generally document their decisions to issue or refuse permits in an appropriate manner, including the reasons underpinning the decisions, after considering the permit application assessment reports and proposed conditions to be attached to issued permits. These conditions, which are the primary means by which GBRMPA mitigates the risks posed to the reef by proposed activities, generally addressed many of the high or medium-rated risks identified during the assessment process. GBRMPA should, however, periodically review the design of standard permit conditions that it applies to common permit types to help ensure that they effectively address significant risks to the Marine Park.

18. In general, permit monitoring undertaken collectively by GBRMPA and

its partner agencies has been insufficient to determine permit holders’ compliance with permit conditions. Specifically, GBRMPA was not effectively monitoring the timely receipt of most post-approval reporting documentation that permit holders were required to submit under their permit conditions, nor appropriately documenting its assessmentapproval of the post-approval reports submitted. While intelligence and risk-based field compliance operations primarily vessel, aerial and land-based patrols undertaken by GBRMPA and its partners agencies are effective in detecting some forms of permit-related non-compliance, they are not well-suited to detecting other forms of non-compliance such as the condition of sub-surface infrastructure. The limited additional monitoring of permit compliance that has been undertaken by GBRMPA to supplement existing patrols including site inspections, was not, however, informed by an appropriate risk-based approach. The failure to effectively monitor permit holder reporting requirements and to undertake sufficient risk-based supplementary monitoring activities reduces the effectiveness of permit conditions as a means of managing risks to the Marine Park from permitted activities.

19. Until recently, many instances of permit holder non-compliance mostly

related to the provision of required documentation were not identified by