In relation to non-routine applications, GBRMPA required up to 90 days

ANAO Report No.3 2015–16 Regulation of Great Barrier Reef Marine Park Permits and Approvals 67 which time its application had been handled by four different GBRMPA assessing officers with differing views of assessment requirements.

3.32 While permit holders and other stakeholders expressed some positive or

neutral comments on GBRMPA’s permit assessment performance, most comments highlighted perceived shortcomings or areas for improvement. The issues raised by permit holders and general stakeholders in submissions provided to the ANAO—apart from the timeliness of application processing— include: • GBRMPA’s scientific skills and knowledge—permit holders and some general stakeholders acknowledged the high level of scientific marine knowledge within GBRMPA, while other general stakeholders considered that additional technical expertise in relation to ports, shipping and dredging would be beneficial; • communication—permit holders were generally satisfied with their communication with GBRMPA as their permit applications progressed though the assessment process. However, general stakeholders held mixed views, with some satisfied with their communication with GBRMPA while others were dissatisfied; • the basis for assessments—some general stakeholders expressed concern about ‘shifting goalposts’ in regards to the information GBRMPA required to assess non-routine applications and a need for GBRMPA to balance the science with ‘real-life’ operational practicalities; and • risk management—some general stakeholders considered that permit application assessments would benefit from a more rigorous consideration of risks to the Marine Park based on scientifically documented environmental threats. Conclusion

3.33 GBRMPA places a heavy reliance on the templates that it has developed

to assess mandatory and discretionary considerations and risks associated with the routine permit application assessments that comprise around 90 per cent of all Marine Park permit application assessments. The templates generally facilitated an appropriate assessment of the permitted activities most commonly requested by applicants for the various permit types such as vessel-based tourism and research against most mandatory considerations, some relevant ANAO Report No.3 2015–16 Regulation of Great Barrier Reef Marine Park Permits and Approvals 68 discretionary considerations and identified risks. However, there is scope to significantly improve the coverage and content of assessment and risk templates to better address mandatorydiscretionary considerations and risks, respectively, relevant to the assessment of all, or particular types of, permits. These improvements would minimise: the requirement for assessing officers to repetitively tailor assessments to address matters commonly relevant; and the likelihood of relevant considerations and risks being overlooked during assessments.

3.34 On most occasions, template-based permit application assessments are

not sufficiently tailored to address relevant regulatory requirements and risks that are not canvassed by the templates. Similarly, the customised permit assessments examined by the ANAO assessed non-routine applications involving structures, works or facilities against most, but not all, mandatory and discretionary regulatory requirements.

3.35 The development of risk assessment templates in early 2012 for common

types of permitted activities has assisted GBRMPA to efficiently assess the risks posed by these activities. The lack of templates for some permitted activity types has, however, necessitated the development of customised risk assessments. Further, in the case of some permitted activity types that constitute around 8.5 per cent of approvals such as moorings and crown-of-thorns starfish programs neither template-based nor customised risk assessments were prepared. Weaknesses in the identification of risks to the Marine Park posed by proposed activities makes it more difficult for GBRMPA to design appropriate conditions to attach to permits.

3.36 All permit application assessment reports prepared for the delegate’s

consideration that were examined by the ANAO included the assessments against mandatory and discretionary considerations and risk assessments prepared by the assessment officers. The reports also generally contained reference to, and the results of, other assessment activities undertaken in support of each permit assessment such as application referrals with GBRMPA and to QPWS, and native title notifications. However, permit assessment checksheets were not completed in full by the assessment officers for some 70 per cent of the assessments examined by the ANAO, and the subsequent certification of assessments as complete has diminished the effectiveness of checksheets as a quality control measure.