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.

Heritage Strategy

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

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

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

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.
low

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.
moderate

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.
low

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.

  • The objective in managing Commonwealth heritage places is to  identify, protect, conserve, present and transmit, to all generations, their Commonwealth Heritage values.
  • The management of Commonwealth heritage places should use the best available knowledge, skills and standards for those places, and include ongoing technical and community input to decisions and actions that may have a significant impact on their Commonwealth Heritage values.
  • The management of Commonwealth heritage places should respect all heritage values of the place and seek to integrate, where appropriate, any Commonwealth, State, Territory and local government responsibilities for those places.
  • The management of Commonwealth heritage places should ensure that their use and presentation is consistent with the conservation of their Commonwealth Heritage values.
  • The management of Commonwealth heritage places should make timely and appropriate provision for community involvement, especially by people who: 
    • have a particular interest in, or associations with, the place
    • may be affected by the management of the place
  • Indigenous people are the primary source of information on the value of their heritage and that the active participation of indigenous people in identification, assessment and management is integral to the effective protection of indigenous heritage values.
  • The management of Commonwealth heritage places should provide for regular monitoring, review and reporting on the conservation of Commonwealth heritage values.
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: 

  • Assist in identification, assessment and monitoring of places of heritage value in its care.
  • Prepare and maintain a register of its places of heritage value.
  • Protect the heritage value of places when they are sold or leased.
  • Provide this heritage strategy, and any subsequent major updates, to the relevant minister.

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).

  1. AMSA may:
    1. Establish and maintain aids to navigation.
    2. Add to, alter or remove any aid to navigation that is owned or controlled by AMSA.
    3. Vary the character of any aid to navigation that is owned or controlled by AMSA.
  2.  AMSA, or person authorised in writing by AMSA may, at any reasonable time of the day or night: 
    1. Inspect any aid to navigation or any lamp or light which, in the opinion of AMSA or the authorised person, may affect the safety or convenience of navigation, whether the aid to navigation of the lamp or light is the property of: 
      1. A state or territory
      2. An agency of a State or Territory
      3. Any other person
    2. Enter any property, whether public or private, for the purposes of an inspection under paragraph (a)
    3. Transport, or cause to be transported, any good through any property, whether public or private, for any purpose in connection with: 
      1. The maintenance of an aid to navigation that is owned or controlled by AMSA.
      2. The establishment of any aid to navigation by AMSA.
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;

  • To advise the Minister on conserving and protecting places included, or being considered for inclusion, in the National Heritage List or Commonwealth Heritage List.
  • To nominate places for inclusion in the National Heritage List or Commonwealth Heritage List.
  • To promote the identification, assessment, conservation and monitoring of heritage.
  • To keep the Register of the National Estate.
  • To organise and engage in research and investigations necessary for the performance of its functions.
  • To provide advice directly to any person or body or agency either if its own initiative of at the request of the Minister.
  • To make reports as outlined in the Act.
New South Wales Heritage Act 1977 This Act intends to:
  • promote understanding and conservation of the state’s heritage.
  • provide for identifying and registering items of state heritage significance.
  • provide for the interim protection of items, pending an assessment of their state heritage significance.
  • encourage the adaptive reuse of items of state heritage significance.
  • help owners conserve items of state heritage significance.
New South Wales Heritage Regulation 2012

This Regulation:

  • Prescribes the forms to be used and fees applicable when making applications.
  • Prescribes the minimum standard of maintenance and repair of buildings, works and relics, ruins and moveable objects listed on the State Heritage Register or located in a precinct listed on the Register.
  • Prescribes classes of items that are required to be entered in a Heritage and Conservation Register.
National Parks and Wildlife Act 1974

Part 4, Division 2, Section 30F: Historic Sites

  1. The purpose of reserving land as a historic site is to identify, protect and conserve areas associated with a person, event or historical theme, or containing a building, place, feature or landscape of cultural significance so as to enable those areas to be managed in accordance with subsection (2).
  2. A historic site is to be managed in accordance with the following principles:
    1. The conservation of places, objects, features and landscapes of cultural value.
    2. The conservation of natural values.
    3. Provision for sustainable visitor or tourist use and enjoyment that is compatible with the conservation of the historic site’s natural and cultural values.
    4. Provision for the sustainable use (including adaptive reuse) of any buildings or structures or modified natural areas having regard to the conservation of the historic site’s natural and cultural values.
      1. Provision for the carrying out of development in any part of a special area in the historic site that is permitted under section 185A having regard to the conservation of the historic site’s natural and cultural values. 
  3. The promotion of public appreciation and understanding of the historic site’s natural and cultural values. 
  4. Provision for appropriate research and monitoring.
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:

  1. The main object of this Act is to provide for a balanced and nationally consistent framework to secure the health and safety of workers and workplaces by:
    1. Protecting workers and other persons against harm to their health, safety and welfare through the elimination or minimisation of risks arising from work.
    2. Providing for fair and effective workplace representation, consultation.
    3. Co-operation and issue resolution in relation to work health and safety.
    4. Encouraging unions and employer organisations to take a constructive role in promoting improvements in work health and safety practices, and assisting persons conducting businesses or undertakings and workers to achieve a healthier and safer working environment.
    5. Promoting the provision of advice, information, education and training in relation to work health and safety.
    6. Securing compliance with this Act through effective and appropriate compliance and enforcement measures.
    7. Ensuring appropriate scrutiny and review of actions taken by persons exercising powers and performing functions under this Act.
    8. Providing a framework for continuous improvement and progressively higher standards of work health and safety.
    9. Maintaining and strengthening the national harmonisation of laws relating to work health and safety and to facilitate a consistent national approach to work health and safety in this jurisdiction.
  2. In furthering subsection (1)(a), regard must be had to the principle that workers and other persons should be given the highest level of protection against harm to their health, safety and welfare from hazards and risks arising from work as is reasonably practicable.

[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

Objective/rationale

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.

Priority/significance

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.

Visual range

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.

Radar conspicuousness

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.

AMSA’s goals

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.

Incident Procedure
Damage to lighthouse’s fabric (heritage significance)
  • AMSA or selected contractor to assess extent of damage.
  • Seek heritage advice on restoration of heritage fabric impacted.
  • Identify possible loss of heritage value at both State and Commonwealth level.
  • Seek appropriate approvals for restoration of heritage fabric impacted.
  • Implement best practice management of restoration work in keeping with the original character of the place.
  • In the case of a loss of heritage value, prepare report for submission.
  • Update record-keeping of incident and make available to relevant personnel.
Damage to lighthouse’s fabric (no heritage significance)
  • AMSA or selected contractor to assess extent of damage.
  • Identify possible impact on heritage fabric in any work carried out to restore fabric.
  • Implement best practice management of restoration work.
  • Update record-keeping of incident and make available to relevant personnel.
Light upgrade
  • Assess possible loss of heritage value in the event of an upgrade.
  • Seek expert heritage advice on process of upgrade.
  • Seek heritage approvals for the upgrade of light.
  • Implement best practice management of light upgrade work.
  • Update record-keeping and make available to relevant personnel.
Modification to lighthouse (e.g. adding of attachment)
 
  • Assess possible obstruction to light.
  • Seek heritage approvals for attachment to tower.
  • Monitor attachment and update record-keeping.
Unforeseen discovery of Indigenous artefacts on-site.
 
  • Immediate stop-work.
  • Notify Land Council and NPWS.
  • Delay work on site until artefacts have been appropriately extracted and further investigations carried out in surrounding area.
  • Update record-keeping of unforeseen discovery and make available to relevant personnel.
Divestment of lighthouse from AMSA
 
  • Transfer ownership or control of heritage assets to the NSW State Government.
  • Terminate lease of Montague Island site with the NSW state government.
  • Transfer relevant records and historical information held by AMSA to the NSW State Government.