6.1 Implications arising from significance
The Commonwealth statement of significance (section 5.1 above) demonstrates Cape St Albans Lighthouse is a place of considerable heritage value due to its contribution to navigational assistance as one of the earliest unattended lights established in South Australia.
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:
- architectural quality of the building
- interior spaces and features, which are notable for their design, details and/or their original lighthouse function. These include:
- lantern room
- lens assembly
- ground floor
- external spaces and features, which are notable for their design, details, and/or their original lighthouse function. These include:
- lantern roof and glazing
- external ladder
- apron paving
Referral 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 approval of the Minister.
- outside Commonwealth land, which are likely to have a significant impact on the environment on Commonwealth land, will require approval of the Minister.
- by the Australian Government or its agencies, which are likely to have a significant impact on the environment anywhere, will require approval of the Minister.
The definition of ‘environment’ in the EPBC Act 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.
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 latest heritage strategy for AMSA’s AtoN assets was completed and approved by the Commonwealth Minister for the Environment in 2022 and is available online.35
Heritage asset condition report
A heritage asset condition report is a written document that details the heritage 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 and natural values
The broader Cape St Alban landscape is notable for its heritage significance and natural values. Although these values lie outside of the Commonwealth heritage listing curtilage, the potential remains for future works at the lighthouse to impact these values. At the time this plan was written, no plans have been made for future works at Cape St Albans Lighthouse. 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 curtilage. In any instance that 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 desired intactness and aesthetic qualities, Cape St Albans 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 adaptation 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 Cape St Albans 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 from high to low, depending on the action’s possible threat to the site’s heritage values.
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 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 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, or to the heritage significance in another part of the building.
|Component||Level of sensitivity||Nature of change impacting heritage values|
|Cape St Albans Lighthouse structure||High||
6.3 Statutory and legislative requirements
The following table lists the Acts and codes relevant to the management of Cape St Albans 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 Climate Change, Energy, the Environment and Water has determined these principles as essential for guidance in managing heritage properties.
|AMSA Heritage Strategy 2022-2025||
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.36
|Navigation Act 2012 (Cth)||
Part 5 of the Act outlines AMSA’s power to establish, maintain and inspect marine aids to navigation (such as Cape St Albans Lighthouse).
|Australian Heritage Council Act 2003 (Cth)||
This Act establishes the Australian Heritage Council, whose functions are:
|South Australia Heritage Places Act 1993 (SA)||
Part 1 Preliminary
|Building Code of Australia/National Construction 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 Cape St Albans 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 Cape St Albans Lighthouse are primarily concerned with navigational requirements. Below are the operational details and requirements of the Cape St Albans light as outlined by AMSA.
Navigation requirement for AMSA’s AtoN site
The following table is taken from AMSA’s Asset Management Strategy for the Cape St Albans Lighthouse.
An AtoN is required at Cape St Albans to mark the cape itself and to provide a navigation mark for vessels transiting North West / South East through the Backstairs Passage between Cape St Albans and The Pages islands 8 miles to the East.
The AtoN also assists vessels keep clear of the Yatala Shoal 4 miles to its North East and The Scraper shoals up to a mile to its South East.
To the North West, the obscured sector assists vessels stay in deeper water in Antechamber Bay
|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 important 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 2 (99%).|
|5||Primary and secondary means (if any) of identification||
The day mark must be conspicuous. The existing nine-metre white masonry tower and lantern at an elevation of 48 metres 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 sector light every five seconds meets this requirement.
During daytime, the AtoN structure should be visible from at least five nautical miles.
At night, the white light must have a nominal range of at least 14 nautical miles.
|7||Radar conspicuousness||As the cape itself will provide a good radar echo, no additional radar enhancement is required for this site.|
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 around 500 marine AtoN includes traditional lighthouses such as Cape St Albans 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 Cape St Albans Lighthouse primarily encompassed continuing its 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. Cape St Albans’ light is designated as an IALA Availability Category 2 AtoN (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 maintenance. Routine maintenance and emergency repairs, where equipment fails in service, 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 inspections of the site including to audit 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.
|Mainteance||Estimated date of work|
|Lantern room paint||2024|
|Reseal lantern glazing||2024|
|LED array replacement||2030|
6.6 Potential pressures
A significant pressure that harnesses the potential to effect the Commonwealths heritage values of the place would be the obligation to remove or replace original fabric materials from the lighthouse owing to unavoidable and irreversible deterioration. At the time this plan was written, no current plans exist to remove or replace any original fabric materials from Cape St Albans Lighthouse. Any work proposed 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 Cape St Albans Lighthouse.
|Major project/maintenance works proposed||
|Damage to lighthouse’s fabric (heritage significance)||
|Damage to lighthouse’s fabric (no heritage significance)||
|Modification to lighthouse such as adding of attachment||
|Unforeseen discovery of Indigenous artefacts on-site.||
|Divestment of lighthouse from AMSA||