In general, GBRMPA has notified native title bodies of permit

ANAO Report No.3 2015–16 Regulation of Great Barrier Reef Marine Park Permits and Approvals 49 • 58 82.9 per cent were referred to one or more QPWS offices for comment although the only evidence of referral in four cases was references in the assessment reports; • GBRMPA decided not to refer seven applications for reasons that do not accord with referral exemptions guidance including four that were not referred as they related to ‘harvest fisheries’; and • evidence has not been retained to demonstrate that the remaining five applications that met referral thresholds had been referred for comment.

2.24 While QPWS did not make substantive comments in relation to most

referred permit applications, on 12 occasions it requested that a copy of the draft permit assessments be provided for endorsement before the assessments were submitted to the delegate for approval and this issue is discussed in Chapter 4. Public advertising

2.25 GBRMPA’s permit processing procedures indicate that public

advertising may be required for those applications that ‘may restrict the use of part of the Marine Park by the public’—with mooring applications provided as an example. 59 The comments received in response to permit applications that have been publicly advertised must be considered by GBRMPA as part of the permit assessment process.

2.26 In practice, GBRMPA has inconsistently applied the public advertising

requirements for permit applications. Of the permit applications examined by the ANAO, GBRMPA required only one—involving existing moorings—to be publicly advertised. However, GBRMPA did not require public advertising for 11 other permit applications examined by the ANAO that involved facilities, structures and moorings already in place. 60 GBRMPA’s rationale for not publicly advertising these applications was that the public’s use of the Marine Park would not be further restricted by the continuing existence of this infrastructure. The ANAO also found that one of the existing facilities subject to a permit application that was not advertised was an unpermitted structure and, as such, 59 GBRMPA, Corporate Procedures: Processing of Marine Park Permits Applications—Routine Permits, unpublished, February 2013, p. 5. 60 Public advertising was also undertaken for a project assessed as a controlled action under the EPBC Act that was later to become the subject of a permit application. Consequently, GBRMPA did not consider it necessary for this application to be publicly advertised. ANAO Report No.3 2015–16 Regulation of Great Barrier Reef Marine Park Permits and Approvals 50 may have illegally restricted the use of part of the Marine Park by the public. In relation to the only publicly advertised application, evidence has not been retained to indicate that GBRMPA complied with its guidelines to consult with its Communications Unit on the draft text of the proposed advertisement or publish a copy of the advertisement on its website. Management of permit application processing

2.27 To manage permit application processing requirements, GBRMPA has

developed checksheets to document the completion of key processing steps from the receipt of applications to the issuing of permits to approved applicants, and the follow-up of any post-approval requirements such as the execution of deeds and submission of bonds, where applicable. The checksheets are to be completed by permit assessment officers as the application progresses and provide a sound basis for monitoring whether all relevant steps in the permit assessment process have been undertaken. However, in practice, the checksheets were generally incomplete. Of the 79 permit application assessments examined by the ANAO: • permit processing checksheets were not preparedretained for four applications examined 5.1 per cent—all of which relate to non-routine applications that involve complex processing requirements; • 42 of the 75 checksheets 56 per cent contained gaps evidencing the satisfactory processing of the permit applications by assessment officers including in relation to comments from native title bodies, referrals tofrom QPWS, further information requests and the relevance addressing of certain requirements applying to particular applications.

2.28 With the exception of research applications, the work of assessment

officers is to be reviewed within the EAP Section once the permit application assessment process is completed and prior to the preparation of the permit application assessment report. Evidence of the review is to be documented on the permit processing checksheet. While checksheets generally record the review of permit application processing, the significant gaps in the completeness of many of the certified checksheets noted above reduces the effectiveness of this review as a quality assurance tool for GBRMPA’s permit processing.