6.1 Implications arising from significance
The Commonwealth statement of significance (section 5.1 above) demonstrates Goods Island Lighthouse is a place of considerable heritage value due to its association with the maritime history of the Torres Strait, its standing as the only known lighthouse entirely constructed by the State Government, and for the retention of its 19th century Queensland lighthouse characteristics.
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
- the original lens assembly,
- interior features including:
- lantern room,
- ground floor,
- exterior feature including:
- lantern roof,
- balcony (including balustrades),
- tower walls,
- windows and doors,
- entry stairs
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 (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 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.45
Heritage asset condition report
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 and natural values
Goods Island is notable for its Aboriginal heritage significance and natural values. Although these values lie outside of the Commonwealth heritage listing curtilage and AMSA’s lease, 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 Goods Island Lighthouse. In the event major works at the lighthouse are required to be carried out, AMSA will seek to minimise impacts to the surrounding area by:
- Abiding by any relevant environment management plans for the marine park
- Consulting with Aboriginal stakeholders to ensure no significant sites are impacted
- Ensuring no damage is made to surrounding vegetation or animal habitats
- Ensuring project footprint is limited to the AMSA lease. 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 association with Queensland’s maritime history, its rarity as a lighthouse tower complete with residences built atop a coral reef, and its unique technical achievement due to the water tank at its base, Goods 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 Goods 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 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 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 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.
|Level of sensitivity
|Goods Island Lighthouse structure
|Ground floor (including ladder)
|Balcony and balustrades
|Lens assembly and light source
6.3 Statutory and legislative requirements
The following table lists the Acts and codes relevant to the management of Goods Island Lighthouse.
|Act or code
|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.
(a) have a particular interest in, or associations with, the place; and
(b) may be affected by the management of the place;
|AMSA Heritage Strategy 2018
As the custodian of many iconic sites, AMSA has long recognised the importance of preserving their cultural heritage.
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.46
|Navigation Act 2012 (Cth)
Part 5 of the Act outlines AMSA’s power to establish, maintain and inspect marine aids to navigation (such as Goods Island Lighthouse).
(1) AMSA may:
(a) establish and maintain aids to navigation; and
(b) add to, alter or remove any aid to navigation that is owned or controlled by AMSA; and
(c) 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:
(a) 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:
(i) a state or territory; or
(b) enter any property, whether public or private, for the purposes of an inspection under paragraph (a); and
(c) transport, or cause to be transported, any good through any property, whether public or private, for any purpose in connection with:
(i) the maintenance of an aid to navigation that is owned or controlled by AMSA; or
|Australian Heritage Council Act 2003 (Cth)
This Act establishes the Australian Heritage Council, whose functions are:
|Building Code of Australia/National Construction Code
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:
(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:
a) protecting workers and other persons against harm to their health, safety and welfare through the elimination or minimisation of risks arising from work; and
b) providing for fair and effective workplace representation, consultation, co operation and issue resolution in relation to work health and safety; and
c) 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; and
d) promoting the provision of advice, information, education and training in relation to work health and safety; and
e) securing compliance with this Act through effective and appropriate compliance and enforcement measures; and
f) ensuring appropriate scrutiny and review of actions taken by persons exercising powers and performing functions under this Act; and
g) providing a framework for continuous improvement and progressively higher standards of work health and safety; and
h) 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 Goods Island 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 Goods Island Lighthouse are primarily concerned with navigational requirements. Below are the operational details and requirementsof the Goods Island light as outlined by AMSA.
Navigational requirement of AMSA’s AtoN site
The following table is taken from AMSA’s Asset Management Strategy for the Goods Island light.
|An AtoN is required on Goods Island to assist ships in the pilotage waters of the Torres Strait.
To the West, the limit of the lit sector assists vessels to remain in the two-way route and to find the pilot station 4.7 miles to the west.
It then warns of the island and the course alteration 1.6 miles to the west.
To the North, it provides the rear transit light for vessels to check their compasses and a position line to check progress along track.
To the South East it provides a light sector warning of West Wai Weer Reef.
It also warns of offshore reefs and navigation hazards such as Harrison Rock to the north-west at 1.7 miles, Sunk Reefs to the north at 1.5 miles and Ipili Reef to the north-east at 1.5 miles.
|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
|The service performance of the AtoN must comply with the IALA Availability Target Category 1 (99.8%).
|Primary and secondary means (if any) of identification
|The day mark must be conspicuous. The existing 5 m high white round tower with a red cupola at an elevation of 105 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 2.5 seconds, synchronized with Goods Islands Front Lead, 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 14 nautical miles.
|As the Island 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 480 marine AtoN includes traditional lighthouses such as Goods Island, 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 primary goal for Goods Island Lighthouse is to continue 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. Goods Island 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 must be kept in good repair by regular maintenance. Routine maintenance and emergency repairs, when 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 20.08.2020 site inspection report. The information provided below was taken from this report.
Estimated maintenance date
Solar panel changeout
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 lighthouse owing to unavoidable and irreversible deterioration. At the time of preparing this management plan, no plans have been made to remove original fabric material. In the event plans are made to modify or remove original 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 Goods Island Lighthouse.
|Major project/maintenance works proposed
|Damage to lighthouse’s fabric (heritage significance)
|Damage to lighthouse’s fabric (no heritage significance)
|Minor modification to lighthouse (such as adding of attachment)
|Unforeseen discovery of Aboriginal artefacts on-site
|Divestment of lighthouse from AMSA