In general, permit monitoring undertaken collectively by GBRMPA and

ANAO Report No.3 2015–16 Regulation of Great Barrier Reef Marine Park Permits and Approvals 17 GBRMPA staff and not recorded centrally for assessment and possible enforcement action. 16 These shortcomings in recording permit non-compliance have adversely impacted on GBRMPA’s ability to develop an informed view of the extent of permit non-compliance and address areas of non-compliance in a timely manner. The limited guidance for investigators when determining appropriate enforcement responses to non-compliance, when coupled with poorly documented reasons for enforcement actions, also makes it difficult for GBRMPA to demonstrate the basis for its enforcement decision-making.

20. GBRMPA has acknowledged weaknesses in its permit assessment and

compliance management processes and practices and has commenced work on a number of initiatives to strengthen existing arrangements. As part of this work, a high-level risk assessment of permitted activities in the Marine Park, which was prepared by GBRMPA in late 2014, indicated that existing controls primarily permit conditions, deeds and bonds, intelligence gathering and analysis, patrols, and other monitoring activities are generally insufficient to detect non-compliance with permit conditions. GBRMPA informed the ANAO that the permit compliance management plan, currently under development, will outline strategies to better address risks to the Marine Park environment from permitted activities and permit holders.

21. To improve GBRMPA’s regulation of Marine Park permits and to

inform the work being undertaken to enhance compliance management practices, the ANAO has made five recommendations to strengthen the: processing of permit applications; rigour of the permit application assessment and decision-making processes; effectiveness of permit conditions; effectiveness of permit compliance monitoring; and response to instances of non-compliance. Key findings by chapter Processing of Permit Applications Chapter 2

22. While GBRMPA has produced a range of guidance materials to

underpin its processing of permit applications, the materials are fragmented and unclear in parts and do not clearly address all relevant requirements. 16 GBRMPA informed the ANAO that it established and implemented new processes for 2014–15 to monitor the receipt of post-approval reporting documentation from permit holders and to record potential non-compliance with post-approval reporting requirements.