While these avenues are available to GBRMPA, in practice there has been

ANAO Report No.3 2015–16 Regulation of Great Barrier Reef Marine Park Permits and Approvals 104 risk-based program of site inspections, including a dedicated budget, or determined a target number of inspections to undertake each year. GBRMPA informed the ANAO that site inspections are conducted infrequently due to resourcing constraints. Further, the logistics involved in arranging suitable inspection dates with permit holders, GBRMPA staff and representatives from other agencies including QPWS and the Queensland Department of Environment and Heritage Protection adversely impacts on the number of inspections conducted.

6.29 While a co-ordinated risk-based program of inspections has not been

established by GBRMPA, a limited number of site visits, audits and inspections have been undertaken. A register maintained by GBRMPA indicates that, over the period from July 2012 to early January 2015, GBRMPA and FMCU partners conducted 34 site visits, audits and inspections including pre-works surveysfamiliarisation visits for permitted facilitiesworksstructures, such as dredging activities, jetties, pontoons, pipelines and sewage treatment plants.

6.30 To guide the conduct of the visits, audits and inspections, GBRMPA has

developed a comprehensive template covering the planning including consultation undertaken, past compliance history, and work, health and safety considerations and conduct of inspections, documentation of findings and post-inspection reporting. The ANAO examined the site inspection documentation for a sample of permits, supplemented by documentation associated with additional inspections of sewage outfall facilities in the Whitsunday Islands in 2013 five in total. The inspections template was satisfactorily completed in all cases. The completed reports clearly identified the extent of compliance and non-compliance with permit and EMP conditions and included photographic evidence and documented an approved course of action to address any non-compliance. The areas of non-compliance observed by GBRMPA included: a failure to develop, or comply with aspects of, the sites’ EMP; unauthorised waste discharge or waste discharge exceeding release limits; and the installation of unpermitted equipment. 118

6.31 Site inspections are an effective tool to identify aspects of permit

compliancenon-compliance that are not readily identifiable through other monitoring methods, such as vessel and aerial patrols. A co-ordinated, 118 Of the four site inspections that identified aspects of permit non-compliance, four aspects of non-compliance at two sites were not recorded as non-compliance incidents in CMIS. ANAO Report No.3 2015–16 Regulation of Great Barrier Reef Marine Park Permits and Approvals 105 risk-based program of site inspections—as part of a permit compliance management plan—would allow GBRMPA to better demonstrate that it is: appropriately targeting those permits that pose the greatest risks; and efficiently allocating limited resources. Conclusion

6.32 GBRMPA generally grants and processes amendments to permit

conditions and associated nominations requested by permit holders after taking into account considerations relevant to the decisions. In those cases where amendments to permit conditions are initiated by GBRPMA, it has consulted with relevant permit holders as part of the approval process.

6.33 The permits approved by GBRMPA incorporate a range of standardised

conditions that generally provide a basis on which GBRMPA can monitor ongoing compliance. However, with the exception of the executionlodgement of deeds and bonds, GBRMPA does not effectively monitor the timely receipt, nor appropriately document its assessmentapproval of, most other post- approval reporting requirements that permit holders are required to submit under their permit conditions. There is scope for GBRMPA to strengthen its monitoring of post-approval reporting requirements, specifically by developing new, and enhancing existing, guidance material and support tools for its staff.

6.34 The FMCU and its partner agencies undertake compliance monitoring

within the Marine Park for both permitted activities and activities not subject to a permit through field compliance operations based on intelligence and an analysis of strategic and emerging risks. Nevertheless, GBRMPA’s monitoring of post-approval reporting requirements and the conduct of field compliance operations, in isolation, do not sufficiently address all aspects of potential permit non-compliance. The delivery of supplementary compliance monitoring activities, such as risk-based site inspections, provides additional assurance relating to certain types of permitted activities, including sub-surface infrastructure. The use of supplementary monitoring has, however, been limited, with weaknesses evident in the delivery and documentation of these monitoring activities. While the limited numbers of site inspections that have been conducted have provided insights into permit holders’ compliance, they have not been delivered as part of a co-ordinated, risk-based program.

6.35 Overall, permit monitoring undertaken by GBRMPA has been

insufficient to determine permit holders’ compliance with permit conditions. Improved monitoring of permit holders’ compliance with post-approval