To inform its identification of the relevant conditions to attach to

ANAO Report No.3 2015–16 Regulation of Great Barrier Reef Marine Park Permits and Approvals 21 high-level risk assessment of permitted activities in the Marine Park, which was prepared by GBRMPA in 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. The permit compliance management plan, to be introduced in 2015–16, is expected to rate the potential risks to the Marine Park environment from permitted activities, taking into account the risks of non-compliance, and identify a range of additional treatments to mitigate unacceptable risks. Managing Compliance Chapter 6

32. GBRMPA’s monitoring of permit holders’ compliance with

post-approval reporting requirements established for issued permits has been mixed. While GBRMPA effectively monitors the executionlodgement of deeds and bonds 21 , it has not generally monitored the receipt, nor effectively documented its assessmentapproval of, most other post-approval reporting documentation that permit holders are required to submit. For example, GBRMPA retained evidence of the receipt of 18 of 63 required documents relating to 27 permits, with evidence of assessmentapproval retained in relation to only eight documents.

33. A risk-based supplementary monitoring program is also an important

component of effective permit compliance arrangements, as patrols under the Joint Field Management Program are not well-suited to observe compliance or detect non-compliance with some permit conditions or for some permit types, including the condition of sub-surface infrastructure such as jetties, pontoons and pipelines. The conduct of supplementary monitoring has, however, been limited and not underpinned by an appropriate risk-based approach. While GBRMPA effectively monitors the commencement of permitted tourism operations and the impending expiry of permits 22 , it did not initiate or conduct monitoring activities, on a risk basis, for 104 permits 89.7 per cent examined 21 GBRMPA executed 40 of 42 deeds and oversaw the submission of all 15 bonds related to the permits examined by the ANAO. 22 GBRMPA examines its other data holdings to determine whether tourism permit holders commenced operations within the established timeframe usually two years unless an extension is granted. In advance of the expiry of permits, GBRMPA issues reminders to permit holders to submit another permit application if they wish to continue to conduct the permitted activities.