As part of its annual business planning cycle, the FMCU reviews, and

ANAO Report No.3 2015–16 Regulation of Great Barrier Reef Marine Park Permits and Approvals 87

5.19 The FMCU strategic risk register includes ‘Breach of a Marine Parks

Permit’ as a generic risk for non-compliance related to permitted activities in the Marine Park. The FMCU acknowledges that this is a broad risk category, with consequence and likelihood ratings varying considerably depending on the types of permits. However, for the purposes of developing a single risk rating for permit breaches, the FMCU’s 2013–14 strategic risk register indicated that a risk rating of ‘High’ based a combination of a ‘Minor’ consequence rating and an ‘Almost Certain’ likelihood rating broadly reflects the relative consequence and likelihood of the types of permit breaches that are typically reported to the FMCU.

5.20 The 2014–15 strategic risk register continues to record and rate the

‘Breach of a Marine Parks Permit’ as a ‘High’ risk. The FMCU indicated that a permits risk management plan being developed by GBRMPA’s EAP Section which is discussed later in this chapter would provide more detailed analysis of the varying risks and risk ratings facing the Marine Park from GBRMP permitted activities. Quarterly forward threat and response analysis

5.21 At the conclusion of each quarter, the FMCU prepares a report on the

outcomes of its compliance activities and its re-assessment of compliance risks impacting the Marine Park—a forward threat and response analysis. In preparing the forward threat and response analysis, the FMCU considers whether planned responses to 13 Marine Park activities which encompass the risks from the strategic risk register in each of the four Marine Park management areas requires adjustment. 90

5.22 Three of the 13 Marine Park activities assessed on a quarterly basis

during the period July 2012 to June 2014 related to or related in part to GBRMP permitted activities—commercial netting, tourism operations, and other a 90 For administrative purposes, the GBRMP Zoning Plan divides the Marine Park into four discrete management areas: Far Northern; CairnsCooktown; TownsvilleWhitsunday and MackayCapricorn. The GBRMP management areas are taken into account in much of the FMCU’s risk planning management and patrol activities. ANAO Report No.3 2015–16 Regulation of Great Barrier Reef Marine Park Permits and Approvals 88 generic category. The content of these quarterly analyses indicates that the threatresponse ratings were adjusted 91 on the basis of: • recent and historical incident reports and intelligence; • seasonal patterns and trends; • weather patterns; and • information from other relevant sources.

5.23 Responses proposed to address identified threats related primarily to

vessel, aerial and land-based patrols, supplemented by educational and media activities.

5.24 As outlined earlier, in July 2014, the FMCU and GBRMPA EAP Section

recognised the need to specifically assess permit compliance risks and develop a compliance plan specifically related to GBRMP permits which is discussed in Chapter 6. As part of the increased focus on permits compliance, a new Marine Park ‘activity’—Marine Park permit compliance—was included in the FMCU forward threat and response analysis for the July to September 2014 quarter which was rated ‘ModerateReview’ for all four Marine Park management areas.

5.25 FMCUEAP Section analysis undertaken to date indicates that some

types of permit breaches such as lack of maintenance of permitted facilities, failure to notify GBRMPA of works, and exceeding permit conditions are likely to have minor to major impacts on the Marine Park, depending on the circumstances. Common treatments identified to date include those listed in paragraph 5.23 in respect of commercial netting and tourism operations, with the addition of: • education of permit holders including development and publication of an information guide distributed to all permit holders in December 2014 92 ; 91 The forward threat and response analysis contain three threatresponse levels: LowMaintain— requiring no change treatments in the short-term; ModerateReview—threat and current response strategies warrant a review; or HighImmediate Response—significant likelihood of non-compliant behaviour and threat to the World Heritage Area requiring immediate attention. 92 The information guide contains generic information on permit maintenance, compliance and conditions relevant to particular types of permits.