6.1 Implications arising from significance
The Commonwealth statement of significance (see Section 5.1) demonstrates the Montague Island Lighthouse is a place of considerable heritage value due to its contribution to the establishment of New South Wales ‘highway of lights’, and its assistance to the east coast shipping at the turn of the twentieth century.
The implication arising from this assessment is that key aspects of the place should be conserved to retain this significance. The key features requiring conservation include:
- the continued use of the lighthouse as an AtoN
- the architectural quality of the building
- The interior spaces and features, which are notable for their design, details, and/or their original lighthouse function. These include:
- intermediate floors
- ground floor
- spiral staircase and weight tube
- lantern room
- entrance vestibule
- The external spaces and features, which are notable for their design, details, and/or their original lighthouse function. These include:
- lantern roof and glazing
- external catwalk and balcony, including fixtures
- lighthouse tower walls
- windows and doors
- walkway/walkway stairs
Referral and approvals of action
The EPBC Act (1999) requires approval from the Minister for Sustainability, Environment, Water, Population and Communities for all actions likely to have a significant impact on matters of National Environmental Significance (NES).
The Act provides that actions:
- Taken on Commonwealth land which are likely to have a significant impact on the environment will require the approval of the Minister.
- Taken outside Commonwealth land which are likely to have a significant impact on the environment on Commonwealth land, will require the approval by the Minister.
- Taken by the Australian Government or its agencies which are likely to have a significant impact on the environment anywhere will require approval by the Minister.
- The definition of ‘environment’ in the EPBC Act (1999) includes the cultural heritage values of places.
If an Australian Government agency owns or controls one or more places with Commonwealth heritage values, it must prepare a heritage strategy within two years from the first time they own or control a heritage place (section 341ZA).
A heritage strategy is a written document that integrates heritage conservation and management within an agency’s overall property planning and management framework. Its purpose is to help an agency manage and report on the steps taken to protect and conserve the Commonwealth heritage values of the properties under its ownership or control.
The heritage strategye for AMSA’s AtoN assets was completed and approved by the Minister in 2018.
6.2 Framework: sensitivity to change
A heritage asset condition report is a written document that details the heritage fabric of a site with an in-depth description of each architectural and structural element. The document includes: a brief history of the site, the Commonwealth Heritage statement of significance and value criteria, a heritage significance rating for each individual element, and a catalogue of artefacts on-site.
The document is also accompanied by up-to-date photos of each structural element.
This document operates as a tool for heritage monitoring, and is reviewed and updated biennially.
Due to the site’s desired intactness and aesthetic qualities, the Montague Island Lighthouse is of high significance. Therefore, work actioned by AMSA on the lighthouse’s fabric harnesses the potential to reduce or eradicate the significance of the site’s heritage values.
Conservation works, including restoration and reconstruction, or adaption works of the absolute minimum so as to continue the lighthouse’s usefulness as an AtoN are the only works that should be actioned by AMSA on Montague Island Lighthouse. Some exceptions are made for health and safety requirements, however any and all work carried out must be conducted in line with heritage considerations and requirements of the EPBC Act.
The table below demonstrates the level of sensitivity attributed to the various elements of the fabric register in the face of change. These are measured on a high-moderate-low spectrum depending on the action’s possible threat to the site’s heritage values (definitions listed below).
High sensitivity to change includes instances wherein a change would pose a major threat to the heritage value of a specific fabric, or the lightstation as a whole. A major threat is one that would lead to substantial or total loss of the heritage value.
Moderate sensitivity to change includes instances wherein a change would pose a moderate threat to the heritage value of a specific fabric, or would pose a threat to the heritage significance of a specific fabric in another part of the building. A moderate threat is one that would diminish the heritage value, or diminish the ability of an observer to appreciate the value.
Low sensitivity to change includes instances wherein a change would pose little to no threat to the heritage value of a specific fabric, and would pose little to no threat to heritage significance in another part of the building.
|Component||Level of sensitivity||Nature of change impacting heritage values|
|Montague Island Lighthouse structure||high||
Major changes to facade materials and design.
Reduction of the all-round visibility of the structure and its setting on Montague Island.
Repainting of structure (in like colours).
Removal of asbestos/lead paint and/or other toxic materials.
Minor repairs to apron paving.
|Ground floor, including entrance vestibule||high||
Changes to facade materials and design.
Removal of 1880 timber frames wind lock vestibule.
|low||Repainting of ground flooe (in like colours).|
|Stairs, and weight tube||high||
Removal of 1880 geometric stairs.
Removal of 1880 riveted iron weight tube.
Permanent removal of clock weights from within weight tube.
|low||Repainting of stairs and weight tube (in like colours).|
|Intermediate floors||moderate||Removal of 1880 windows.|
|low||Reapinting of intermediate floor levels (in like colours).|
|Balcony||high||Major changes to facade materials and design.|
|low||Repainting of balcony floor/balustrade (in like colours).|
|Optical apparatus and pedestal||low||
Alteration or replacement of the Vega VRB-25 Beacon.
Changing of the light’s character.
Alteration or replacement of aluminium post pedestal.
|Lantern room||high||Removal of 188- Chance Bros. part spherical dome.|
Replacement of glazing.
Re-sealing of glazing.
6.3 Statutory and legislative requirements
Below are listed the various Acts and Code that influence the management of the Montague Island Lighthouse in terms of heritage, navigation, and work health and safety.
|Act or code||Description|
|Environmental Protection and Biodiversity Conservation Act 1999||The Environment Protection & Biodiversity Conservation Act (EPBC Act) requires agencies to prepare management plans that satisfy the obligations included in Schedule 7A and 7B of the EPBC Regulations 2000.|
|Environment Protection and Biodiversity Conservation Regulations 2000 Schedule 7B||
The Commonwealth Department of the Environment and Energy has determined these principles as essential for guidance in managing heritage properties.
|AMSA Heritage Strategy 2018||
As the custodian of many iconic sites, AMSA has long recognised the importance of preserving their cultural heritage.
This Heritage Strategy is in response to section 341ZA of the EPBC Regulations which obliges AMSA to prepare and maintain a heritage strategy, along with obliging AMSA to:
The strategy derives from the AMSA Corporate Plan and achievements are reported through the AMSA Annual Report. The 2018-19 AMSA Annual report can be found online.f
|Navigation Act 2012||
Part 5 of the Act outlines AMSA’s power to establish, maintain and inspect marine aids to navigation (such as the Montague Island Lighthouse).
|Australian Heritage Council Act 2003||
This Act establishes the Australian Heritage Council, whose functions are:
To make assessments under Division 1A and 3A of Part 15 of the EPBC Act 1999;
|New South Wales Heritage Act 1977||This Act intends to:
|New South Wales Heritage Regulation 2012||
|National Parks and Wildlife Act 1974||
Part 4, Division 2, Section 30F: Historic Sites
|Building Code of Australia||
The Code is the definitive regulatory resource for building construction, providing a nationally accepted and uniform approach to technical requirements for the building industry. It specifies matters relating to building work in order to achieve a range of health and safety objectives, including fire safety.
As far as possible, Commonwealth agencies aim to achieve compliance with the Code, although this may not be entirely possible because of the nature of and constraints provided by existing circumstances, such as an existing building.
|Work Health and Safety Act 2011
The objectives of this Act include:
[Quoted from Division 2 of Act]
This has implications for the Montague Island Lighthouse of Australia as it is related to AMSA staff, contractors and visitors.
6.4 Operational requirements / occupier needs
As a working AtoN, the operational needs of the Montague Island Lighthouse are primarily concerned with navigational requirements.
Operational details and requirements
Below are the operational details and navigational requirements of the Montague Island light as outlined by AMSA.
Navigational requirement for AMSA AtoN site
An AtoN is required on Montague Island, 30 miles south of Batemans Bay, to warn of the island itself and that it lies 3.8 miles off of the coast.
This AtoN also warns of the unmarked Aughinish Rock which lies one mile to the south.
This AtoN is required as a navigation mark for vessels transiting north–south along the eastern Australian coast.
Ocean Data Acquisition System (ODAS) at depths of 15 metres are shown 3.1 miles north and 4.2 miles north east of the island.
Required type(s) of AtoN
A fixed structure is required to act as a day mark.
A distinctive light is required for use at night.
An AtoN at this site is important for the navigation of commercial ships.
Required measure of performance
IALA Availability Target Category 2 (99 per cent).
Primary and secondary means (if any) of identification
The day mark must be conspicuous. The existing 21 m high grey granite tower at an elevation of 80 m meets this requirement.
The light must comply with the requirements of rhythmic characters of light as per the IALA Navguide. The light must have distinct characteristics that are easy to recognise and identify. The present flashing white light every 15 seconds meets this requirement.
During daytime, the AtoN structure should be visible from at least 5 nautical miles.
At night, the white light must have a nominal range of at least 20 nautical miles.
As the island itself will provide a good radar echo, no additional radar enhancement is required for this site.
The existing licence between AMSA and the NPWS for tour operation within Montague Island Lighthouse includes additional operational requirements. Access is required by the licencee to conduct tours inside the lighthouse tower (in- keeping with AMSA work safety requirements). The tourism licencee must comply with any requirements, notices or orders any government agency having jurisdiction or authority in respect of the land or the use of the land.
Tourism licencees must have an adequate understanding of the site’s heritage values, and new staff must be educated in the site’s history and significance.
Under the Navigation Act 2012, AMSA is responsible for maintaining a network of marine AtoN around Australia’s coastline assisting mariners to make safe and efficient passages. AMSA’s present network of 500 marine aids to navigation include traditional lighthouses (like the Montague Island Lighthouse), beacons, buoys, racons, and automatic identification system stations, broadcasting tide gauges and a current meter.
Technological developments in the area of vessel traffic management have also contributed to increase the safety of navigation and helped promote marine environment protection. AMSA aims to meet international standards for the reliability of lighthouses set by the International Association of Marine Aids to Navigation and Lighthouse Authorities (IALA).
At the time of preparing this management plan, the major goal for the Montague Island Lighthouse primarily encompassed continuing its utilisation as an AtoN, while up-keeping the appropriate maintenance to conserve and preserve the heritage values of the lightstation.
Lighthouse performance standards
AMSA aims to meet international standards for the reliability of lighthouses set by IALA. The Montague Island light is designated as an IALA Availability Category 2 aid to navigation (within a scale of Category 1 to Category 3, Category 1 aids are most critical). Category 2 aids have an availability target of 99.0 per cent.
Access to the Lighthouse
One practical effect of this performance standard is that the operational equipment and structure of the light need to be kept in good repair by regular preventative maintenance and equipment that fails is repaired quickly. Routine maintenance and emergency repairs are carried out by AMSA’s maintenance contractor. The contractor needs reliable access to the site for this work, and AMSA officers also need access for occasional inspections of the site including for auditing of the contractor’s performance.
6.5 Proposals for change
Preventative maintenance works are carried out on the lightstation to maintain its status as a working marine AtoN and to assist in the site’s conservation.
A list of scheduled preventative maintenance work is identified within the 12/03/2020 AMSG maintenance inspection report.
The information provided below was taken from this report:
|Maintenance description||Expected maintenance date|
|Montague Island lantern room—paint||2022|
|Montague Island structure—paint||2023|
|Montague Island—reseal glazing||2023|
|Montague Island—lantern change||2024|
6.6 Potential pressures
A significant pressure that harnesses the potential to effect the Commonwealth heritage values of the place would be the obligation to remove or replace original fabric materials from the lightstation owing to unavoidable and irreversible deterioration.
Increasing tourism on Montague Island has potential to cause additional wear and tear to the precinct.
6.7 Process for decision-making
Processes for decision-making are required in the event of incidents that impact the heritage values of the site. The following incidents are included due to their likelihood of occurrence at the Montague Island Lighthouse.
|Damage to lighthouse’s fabric (heritage significance)||
|Damage to lighthouse’s fabric (no heritage significance)||
|Modification to lighthouse (e.g. adding of attachment)
|Unforeseen discovery of Indigenous artefacts on-site.
|Divestment of lighthouse from AMSA