The ANAO examined GBRMPA’s assessment processes and the

ANAO Report No.3 2015–16 Regulation of Great Barrier Reef Marine Park Permits and Approvals 55 assessment or comment on the significance to the assessment of not having done so 64 ; • one of the three assessments above recommended that GBRMPA approve an environmental management plan a key management document that only partially covered the operation of 18 of the 20 existing facilities so as to address the then unlawful operation of these facilities due to the expiry of the previous permit 65 ; • one assessment that justified the setting of the bond amount solely on the minimum bond amount for Level 4 projects provided as a guide in GBRMPA’s permit assessment policy—without reference to the likely costs to restore the environment and remove the facilities should the development fail or the proponent become insolvent; and • one assessment that did not specify the proposed permit conditions to be put in place to monitor, manage and mitigate potential impacts Reg.88Qb and to orderly and properly manage the Marine Park Reg.88Qf. In this case, the reasons for the decision documented by the delegate outlined the relevant permit conditions to varying degrees of specificity.

3.9 The evidence retained by GBRMPA to demonstrate that it has

appropriately assessed permit applications involving the take of protected species a specific mandatory consideration under Reg.88S has also been variable. Two of the five affected applications examined by the ANAO met all assessment requirements, while the remaining three were either partially assessed against requirements one or were not assessed against any of the requirements two. 64 Including one assessment report that mentioned that ‘several of the [maintenance] certificates state the facilities are fit for purpose subject to the completion of works’, but did not indicate that one of the facilities was found to be in such a poor state that it was closed to the public until remedial works were undertaken. The assessing officer did not obtain independent evidence to supplement the representations of the permit holder that the required remedial works had been completed. 65 Although the assessing officer also considered that the environmental management plan should be revised within six months of the approval, no permit condition was attached to the approval to make this a requirement, nor had GBRMPA requested the permit holder to update the plan in the seven months since the permit was approved.