The effective management of issued permits requires GBRMPA’s

ANAO Report No.3 2015–16 Regulation of Great Barrier Reef Marine Park Permits and Approvals 103 conditions after permits have been issued. Of the 116 permit examined by the ANAO, the EAP Section had not initiated or conducted monitoring activities with the exception of the commencement of tourism permit operations discussed earlier, on a risk basis, in relation to 104 permits 89.7 per cent over the period from July 2012 to June 2014. 116 Documented monitoring activity undertaken by the EAP Section was limited to nine of the 27 facility worksstructure and mooring permits 117 and two tourism-related permits in relation to eco-tourism certification considerations.

6.27 In addition to the limited monitoring undertaken, shortcomings in the

quality and completeness of some of GBRMPA’s monitoring activities were noted during the ANAO’s examination of current permits and permit application assessments for permits replacing those about to expire. These include: • a failure to detect two unpermitted structures that were observed by FMCU or the EAP Section as early as 2009, but not identified as unpermitted until 2012 and 2013; • a lack of documentation supporting the follow-up of identified issues or GBRMPA’s satisfaction with the actions taken by permit holders to address identified issues; and • large periods of inactivity when managing issues—for example: a three-year delay in assessing a continuing permit application while awaiting requested documentation from the permit holder; and a 14-month delay between the revocation of a permit for an existing mooring and the EAP Section’s consideration of the need to order its removal from the Marine Park. Site inspections

6.28 In response to potential or emerging risks associated with particular

permit holders or classes of permits most notably, facilityworksstructure permits, GBRMPA’s EAP section can undertake site inspections of permit holders’ operations. GBRMPA has not, however, established a co-ordinated, 116 Monitoring activity had not been recorded in relation to all 19 research permits and 68 of 70 tourism-related permits 97.1 per cent examined by the ANAO. 117 Compliance monitoring for these permits involved: post-approval reporting requirements; site inspections; desk-based reviews of permit compliance status as part of an assessment of applications for permit replacementsplittransfer; andor following-up of alleged or identified non-compliance.