6.1 Implications arising from significance
The Commonwealth statement of significance demonstrates Mersey Bluff Lighthouse is a place of considerable heritage value due to its contribution to the development of Devonport and the Mersey District, and its significance as an important local landmark.
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:
- continued use of the lighthouse as an AtoN
- architectural quality of the building
- 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
- lantern room
- external spaces and features, which are notable for their design, details, and/or their original lighthouse function. These include:
- lantern roof
- balcony
- lighthouse walls and windows
Referrals and approvals of action
The EPBC Act requires approval from the Minister for the Environment 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 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.
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 it has taken to protect and conserve the commonwealth heritage values of the properties under its ownership or control.
The heritage strategy for AMSA’s AtoN assets was completed and approved by the Commonwealth Minister for the Environment in 2018 and is available online.16
Heritage asset condition reports
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.
Aboriginal heritage significance
Mersey Bluff as a whole is notable for its Aboriginal heritage significance. The potential remains for future works at the lighthouse to impact these values. In the event major works at the lighthouse are to be carried out, AMSA will seek to minimise impacts to the surrounding area by:
- Utilising specific access tracks to ensure no damage to surrounding vegetation,
- Ensuring project footprint is limited to the AMSA lease. In the unlikely instance work is required outside of this footprint, approvals will be sought from the appropriate stakeholders.
- Implementing an appropriate discovery plan in the instance Aboriginal cultural heritage is suspected and/or found.
6.2 Framework: sensitivity to change
Owing to the site’s historic relationship with the settlement of Devonport, and its aesthetic qualities, Mersey Bluff 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 Mersey Bluff 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 – Medium – Low spectrum depending on the action’s possible threat to the site’s heritage values.
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 lighthouse. 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 |
|---|---|---|
| Mersey Bluff Lighthouse structure | High |
|
| Low |
| |
| Ground floor | High |
|
| Low |
| |
| Intermediate floors | High |
|
| Low |
| |
| Stairs | High |
|
| Low |
| |
| Balcony | High |
|
| Medium |
| |
| Low |
| |
| Lens assembly, pedestal | Low |
|
| Windows, doors | High |
|
| Low |
|
6.3 Statutory and legislative requirements
The following table outlines the statutory and legislative requirements relevant to the conservation and management of Mersey Bluff Lighthouse.
| Act or code | Description |
|---|---|
| Environment Protection and Biodiversity Conservation Act 1999 (Cth) | The Environment Protection & Biodiversity Conservation Act 1999 (Cth) requires agencies to prepare management plans that satisfy the obligations included in Schedule 7A and 7B of the EPBC Regulations. |
Environment Protection and Biodiversity Conservation Regulations 2000 (Cth)
| The Commonwealth Department of Agriculture, Water and the Environment 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 2020-21 AMSA Annual report can be found online.17 |
| Navigation Act 2012 (Cth) | Part 5 of the Act outlines AMSA’s power to establish, maintain and inspect marine aids to navigation (such as Mersey Bluff Lighthouse).
|
| Australian Heritage Council Act 2003 (Cth) | This Act establishes the Australian Heritage Council, whose functions are:
|
TAS Historic Cultural Heritage Act 1995 (TAS)
| This Act establishes the Tasmanian Heritage Council. 7 General functions and powers of Heritage Council
|
Tasmanian Planning Scheme, as enacted by the Land Use Planning and Approvals Act 1993 (TAS)
| The purpose of the Local Historic Heritage Code of the Tasmanian Planning Scheme (pursuant to clause C6.1 of the Tasmanian Planning Scheme) is to: Recognise and protect:
|
| 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 (Cth) | The objectives of this Act include:
[Quoted from Division 2 of Act] This has implications for Mersey Bluff Lighthouse of Australia as it is related to AMSA staff, contractors and visitors. |
6.4 Operational requirements and occupier needs
As a working AtoN, the operational needs of Mersey Bluff Lighthouse are primarily concerned with navigational requirements. Below are the operational details and requirements of Mersey Bluff Lighthouse as outlined by AMSA.
| Navigational requirement for AMSA’s AtoN site | ||
1
| Objective/rationale
| An AtoN is required on Mersey Bluff to provide both a landfall mark for Devonport and a mark for coastal navigation. A sector light arrangement is required to the east and to west to mark over the shallows, rocks and reefs that lie on either side of the safe approach sector. |
2
| 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. |
3
| Priority/significance | An AtoN at this site is critical for the navigation of commercial ships. |
4
| Required measure of performance
| The service performance of the AtoN must comply with the IALA Availability Target Category 1 (99.8%). |
5
| Primary and secondary means (if any) of identification
| The day mark must be conspicuous. The existing 16 m white round brick tower with red vertical stripes 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 group (4) flashing white and red sector light every 20 seconds meets this requirement. |
6
| 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 15 nautical miles, and the red sector lights at least 10 nautical miles. |
7
| Radar conspicuousness | As the site provides a good radar echo, no additional radar enhancement is required. |
AMSA’s goals
AMSA is responsible, under the Navigation Act, for maintaining a network of marine AtoN around Australia’s coastline that assist mariners to make safe and efficient passages. AMSA’s present network of 500 marine AtoN includes traditional lighthouses such as Goose Island Lighthouse, beacons, buoys, racons, automatic identification system stations, metocean sensors including broadcasting tide gauges, current meter, directional wave rider buoys and a weather station.
Technological developments in the area of vessel traffic management have also contributed to increasing navigation safety 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 Mersey Bluff Lighthouse primarily encompasses its continued utilisation as an AtoN (for as long as necessary), while upkeeping the appropriate maintenance to conserve and preserve the heritage values of the lighthouse.
Lighthouse performance standards
AMSA aims to meet international standards for the reliability of lighthouses set by IALA. Mersey Bluff light is designated as an IALA Availability Category 1 AtoN (within a scale of Category 1 to Category 3, Category 1 aids are most critical). Category 1 aids have an availability target of 99.8 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 in service 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 need access for occasional inspection of the site including auditing the contractor’s performance.
6.5 Proposals for change
Preventative maintenance works are carried out on the lighthouse 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 latest available site inspection report. The information provided below was taken from this report:
| Maintenance description | Estimated maintenance date |
| Mersey Bluff reseal glazing | 2025 |
| Mersey Bluff lantern room paint | 2025 |
| Mersey Bluff structure paint | 2029 |
6.6 Potential pressures
In the case of Mersey Bluff Lighthouse, the obligation to remove/replace original fabric materials from the lighthouse owing to unavoidable and irreversible deterioration remains a potential pressure on the site and it’s identified heritage values. At this stage however, there is no plan to remove or replace original fabric materials.
In the event plans are made to modify or remove heritage fabric, work will be conducted in line with the heritage considerations and requirements of the EPBC Act.
6.7 Processes for decision-making
Processes for decision-making are required in the event of an incident that impacts the heritage values of the site. The following incidents are included due to their likelihood of occurrence at the Mersey Bluff Lighthouse.
| Incident | Procedure |
| Damage to lighthouse’s fabric (heritage significance) |
|
| Damage to lighthouse’s fabric (no heritage significance) |
|
| Light upgrade |
|
| Modification to lighthouse such as adding of attachment |
|
| Unforeseen discovery of Aboriginal artefacts on-site. |
|
| Divestment of lighthouse from AMSA |
|
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