The permissions and conditions included in permits issued to new

ANAO Report No.3 2015–16 Regulation of Great Barrier Reef Marine Park Permits and Approvals 78 outlined earlier, permit holders are more likely to comply with the conditions attached to their permits if obligations have been clearly communicated.

4.22 Comments received by the ANAO from permit holders and general

stakeholders in relation to the conditions generally imposed by GBRMPA on granted permits were mixed. Permit holders generally considered that the conditions imposed on their permits were appropriate and reasonable. However, general stakeholders questioned the appropriateness and consistency of conditions across granted permits—with some stakeholders indicating that similar conditions were imposed across permits without due consideration of their relevance to the circumstances, and others indicating that different conditions were included in permits for similar activities. Notification of permit decisions

4.23 After a decision on the permit application has been made by the

GBRMPA and QPWS delegates as applicable, the permit applicants are to be notified in writing of the decision and sent a copy of their permit where granted and any supporting material such as maps and information guides 85 . Evidence retained by GBRMPA indicates that all permits granted in the ANAO’s sample were provided to the permit holder. However, as noted earlier, GBRMPA did not generally draw the attention of permit holders to, and provide the rationale for: permissions granted that were not requested; and new or revised conditions imposed by GBRMPA to permits replacing an expiring permit. As such, there is scope for GBRMPA to better inform permit holders of the permissions granted and new or revised permit conditions in correspondence accompanying the issued permits.

4.24 The appropriateness of GBRMPA’s advice to permit holders was also

considered by the participants at the permit assessment workshop conducted in September 2014 which is discussed further in Chapter 5. The participants concluded that the provision of permits to holders may not be sufficient to effectively communicate permit requirements, particularly given that many permit holders—generally tourism operators and researchers—did not read andor understand their permits. GBRMPA informed the ANAO that it intends to brief each permit holder on the contents of their permit as they are issued. 85 Information guides contain generic information on permit maintenance and conditions relevant to particular types of permits. This information does not, however, explain the new or revised conditions imposed by GBRMPA in replacement permits discussed earlier. ANAO Report No.3 2015–16 Regulation of Great Barrier Reef Marine Park Permits and Approvals 79

4.25 In addition to the provision of permits to holders, a copy of the permit is

also to be provided to the relevant QPWS offices, with the hard-copy application files and the data in the Reef Permit System database to be updated and finalised. However, documentation retained by GBRMPA to evidence that these steps have been undertaken is incomplete. In relation to the permits examined by the ANAO, the assessment officers’ checksheets were not completed on 12 of 73 occasions 16.4 per cent to indicate that copies of permits had been sent to the relevant QPWS offices and that the GBRMPA filesdatabase had been updated and finalised. Conclusion

4.26 Overall, decisions to issue permits have been made by authorised

GBRMPA delegates and the basis on which delegates have decided to grant or refuse a permit have been appropriately documented, which in most cases 78 of 79 examined by the ANAO across all permit levels was in accordance with a recommendation outlined in the assessment report. In the remaining case where the assessment report was not accompanied by a recommendation, the basis on which the delegate decided to grant a permit for an activity posing high risks to the Marine Park was not fully documented until one and a half months after the initial decision had been made.

4.27 The conditions contained in issued permits, which are determined using

permit templates, are generally relevant to the permitted activities sought by applicants and the approval granted by GBRMPA. Most permit conditions have been satisfactorily designed to address many of the identified risks rated high or medium during the assessment process. Nevertheless, some conditions do not sufficiently address all aspects of risks relevant to a significant proportion of permitted activities. To help ensure that significant risks are being effectively mitigated, GBRMPA should periodically review the design of standard permit conditions. Further, issued permits contained newrevised conditions imposed by GBRMPA that related to permissions that were not requested by the applicants andor differed from conditions contained in an expiring permit. There would be benefit in GBRMPA improving the documentation of the rationale for, and better informing applicants of, newrevised conditions that have been imposed by GBRMPA.