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,
    • pedestal, 
    • ladder,
    • porch
  • 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.

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 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 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 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, or to the heritage significance in another part of the building.

 

Component Level of sensitivity  
Goods Island Lighthouse structure High
  • Reduction of visibility of structure and its setting on Goods Island.
  • Major alterations to the colour scheme of the tower.
  • Major design changes to lighthouse tower.
Low
  • Removal of asbestos, lead paint and other toxic materials.
  • Implementation of health and safety hazard markings.
  • Repainting of structure in like-colours.
Ground floor (including ladder) High
  • Major alterations to concrete slab floor and cast iron base ring. 
Low
  • Repainting of ground floor in like colours. 
  • Removal/replacement of battery equipment from ground floor. 
Ladder High
  • Major alterations to or removal of original timber ladder.
Low
  • Repainting of ladder in like colours.
  • Minor reparations to rotten timber with like-materials. 
Lantern base High
  • Major alterations to 1886 timber frame base or iron plates.
  • Major alterations to curved iron door. 
  • Major alterations to 1886 timber floor.
Low
  • Repainting of lantern base and floor in like-colours.
  • Corrosion reparations to lantern base walls and door.
  • Reparations to rotten timber with like-materials.
Balcony and balustrades High
  • Major alterations to original balcony floor.
Medium
  • Major alterations to balcony balustrades.
Low
  • Replacement/reparations to wrought iron stanchion balustrades with like materials. 
  • Reparations to rotten timber with like-materials. 
  • Repainting of balcony floor and balustrades in like-colours. 
Lantern glazing  High
  • Major alterations to original astragals.
Low
  • Replacement of broken glazing panes. 
  • Resealing of glazing. 
  • Repainting of astragals and glazing strips. 
Lantern roof High
  • Major alterations to original dome, including ribs, ventilator, gutter and drip tray. 
Low
  • Repainting of lantern roof in like-colours.
  • Corrosion reparations to lantern roof. 
Lens assembly and light source  High
  • Removal or replacement of 1886 Chance Brothers 250mm fixed lens. 
Pedestal High
  • Major alterations to original cast iron pedestal.
Low
  • Repainting of pedestal in like-colours.
Tower walls High
  • Major alterations to original timber frames.  
  • Major alterations to original conical form of tower.
Low
  • Reparations to corroded iron sheeting with like-materials.
  • Reparations to rotten timber frame.
  • Repainting of timber frames and iron sheeting in like-colours.
Windows  High
  • Major alterations to original window openings.
Low
  • Repainting of sashes and frames in like-colours. 
  • Replacement of rotten timber frames with like-materials. 
  • Replacement of broken window panes. 
Door High
  • Major alterations to original door opening. 
Low
  • Repainting of door in like-colours. 
  • Reparations to rotten timber doors and frame.
Porch  High
  • Major alterations to porch design (including barrel-vaulted roof).
Low
  • Repainting of timber frame and corrugated iron sheeting in like-colours. 
  • Reparations to rotten timber frames with like-materials.
  • Corrosion reparations to iron sheeting. 
  • Replacement of 2006 roof and wall cladding with like-materials.  
Entry stair High
  • Removal of or major alteration to entry stair.
Low
  • Replacement or removal of recent aluminium features. 
  • Repainting of stairs and ramp.

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 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)
Schedule 7B

The Commonwealth Department of Agriculture, Water and the Environment 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:

(a) have a particular interest in, or associations with, the place; and

(b) 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.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
(ii) an agency of a state or territory; or
(iii) any other person; and

(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
(ii) the establishment of any aid to navigation by AMSA. 

 

Australian Heritage Council Act 2003 (Cth)

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; and
  • to make reports as outlined in the Act.
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.

1 Objective/rationale  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. 
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 1 (99.8%). 
5 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. 
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 14 nautical miles. 
7 Radar conspicuousness  As the Island itself will provide a good radar echo, no additional radar enhancement is required for this site. 

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 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.

Maintenance

Estimated maintenance date

Solar panel changeout

2027

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.

Incident Procedure
Major project/maintenance works proposed 
  • Prepare Heritage Impact Statement on proposed modifications. 
  • Submit scope of works and Heritage Impact Statement to the Department of Agriculture, Water and the Environment for review.
Damage to lighthouse’s fabric (heritage significance)
  • AMSA or selected contractors assess extent of damage. 
  • Seek heritage advice on restoration of impacted heritage fabric.
  • Identify possible loss of heritage value (at both state and Commonwealth level).
  • Seek the 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 contractors to assess extent of damage.
  • Identify possible impact on heritage fabric in any work carried out to restore non-significant 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.
  • If necessary, seek expert heritage advice on process of upgrade.
  • If necessary, 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. 
Minor modification to lighthouse (such as adding of attachment)
  • Assess possible obstruction to light.
  • Seek heritage approvals for attachment to tower.
  • Monitor attachment and update record-keeping.
Unforeseen discovery of Aboriginal artefacts on-site
  • Immediate stop-work.
  • Notify appropriate Kurareg and QLD State Government. 
  • Delay work on site until artefacts have been appropriately assessed and/or 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  State of Queensland.
  • Terminate lease of site.
  • Transfer relevant records and historical information held by AMSA to the State of Queensland.

 Footnotes

45 Australian Maritime Safety Authority, AMSA Heritage Strategy (Australian Maritime Safety Authority, 2018)

46 Australian Maritime Safety Authority, Annual Report 2020-21 (Australian Maritime Safety Authority, 2021)