Opportunities and constraints

6.1 Implications arising from significance

The Commonwealth Statement of Significance (section 5.1 above) demonstrates Swan Island Lighthouse is a place of considerable heritage value due to its contribution to the development of mid-nineteenth century shipping within Bass Strait, its original fabric, rarity, aesthetic, its standing as the oldest lighthouse in Bass Strait, and its unique design.

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 landings (including original landing markers)
- ground floor
- 1845 lantern base
- lantern room
- 1893 staircase
External spaces and features, which are notable for their design, details, and/or their original lighthouse function. These include:
- lantern roof
- glazing openings
- balcony
- walls
- window and door openings
- oil store
- building remnant

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 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 (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.³⁶

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 Values

Swan Island as a whole is notable for its Aboriginal heritage significance. Although known heritage and cultural sites lie outside of the Commonwealth heritage listing curtilage and AMSA’s lease, the potential remains for future works at the lighthouse to impact Aboriginal heritage values. At the time this plan was written, no plans have been made for future works at Swan Island 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:

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,
Consulting with the Department of Primary Industries, Parks, Water and Environment (Aboriginal Heritage Tasmania), the Cape Barren Aboriginal Association, the Aboriginal Land Council of Tasmania, and other relevant stakeholders in the event heritage artefacts/sites are uncovered or suspected during works.

6.2 Framework: sensitivity to change

Owing to the site’s historic value, rarity, aesthetic qualities, technical achievement, and association with significant people, Swan 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 Swan 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.

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
Swan Island Lighthouse structure	High	Changes to façade materials and design. Reduction of all-round visibility of the structure and its setting on Swan Island.
Swan Island Lighthouse structure	Low	Repainting of structure in like colours. Removal of asbestos and lead paint or other toxic materials. Repairs to apron paving.
Ground floor	High	Changes to façade materials and design.
Ground floor	Low	Repainting of ground floor in like colours. Removal, movement or replacement of battery cabinets.
1893 staircase and intermediate floors	High	Removal of original intermediate landing markers. Removal of remaining two intermediate landings. Removal of 1893 staircase.
1893 staircase and intermediate floors	Low	Repainting of the intermediate landings in like colours. Repainting of staircase in like colours. Corrosion repairs to stairs and landings.
Balcony	High	Changes to façade materials and design.
Balcony	Low	Replacement of recent balustrade railings. Repainting of balcony floor in like colours.
1845 lantern base	High	Removal of the original external catwalk markers. Alteration to original vent openings.
	Moderate	Removal of remaining original vent regulator.
	Low	Removal or replacement of recent vent regulators.
Lantern room and roof	High	Removal of original cast metal ribs and top ring.
	Medium	Removal of hand holds. Significant alteration to early lantern room door.
	Low	Removal or replacement of cast cowl ventilators. Repainting of lantern room, astragals and glazing strips in like colours. Replacement of blanking panels. Replacement of lantern glazing panes. Alteration to access hole opening. Corrosion repairs to lantern floor
Lens assembly and pedestal	Low	Replacement of Vega VRB-25 beacon. Changing of light’s character. Replacement of pedestal.
Door and windows	High	Alteration to original door and window openings.
	Moderate	Alteration to, or replacement of, timber framed and sheeted door and timber door frame.
	Low	Alteration to, or replacement of, metal window frames and sashes. Replacement of window panes. Repainting of door in like colours.
Oil store	High	Changes to original façade materials or design.
Oil store	Low	Alteration to or replacement of 2012 CFC sheets. Alteration to or replacement of 2012 stainless steel corrugated roofing sheets, gutters and downpipes. Repainting of oil store in like colours.
Building remnant	High	Removal of slab.
Building remnant	Low	Repairs to cracks in concrete.

6.3 Statutory and legislative requirements

The following table outlines legislation relevant to Swan Island Lighthouse and its heritage.

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. 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; and 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 2020-21 AMSA Annual report can be found online.³⁷
Navigation Act 2012 (Cth)	Part 5 of the Act outlines AMSA’s power to establish, maintain and inspect marine aids to navigation (such as Swan Island Lighthouse). 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. 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.
TAS Historic Cultural Heritage Act 1995 (Tas)	This Act establishes the Tasmanian Heritage Council. 7 General functions and powers of Heritage Council The functions of the Heritage council are – to advise the Minister on matters relating to Tasmania's historic cultural heritage and the measures necessary to conserve that heritage for the benefit of the present community and future generations; and to work within the planning system to achieve the proper protection of Tasmania's historic cultural heritage; and to co-operate and collaborate with Federal, State and local authorities in the conservation of places of historic cultural heritage significance; and to encourage and assist in the proper management of places of historic cultural heritage significance; and to encourage public interest in, and understanding of, issues relevant to the conservation of Tasmania's historic cultural heritage; and to encourage and provide public education in respect of Tasmania's historic cultural heritage; and to assist in the promotion of tourism in respect of places of historic cultural heritage significance; and to keep proper records, and encourage others to keep proper records, of places of historic cultural heritage significance; and to perform any other function the Minister determines. The Heritage Council may do anything necessary or convenient to perform its functions.
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: 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: protecting workers and other persons against harm to their health, safety and welfare through the elimination or minimisation of risks arising from work; and providing for fair and effective workplace representation, consultation, co‑operation and issue resolution in relation to work health and safety; and 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 promoting the provision of advice, information, education and training in relation to work health and safety; and securing compliance with this Act through effective and appropriate compliance and enforcement measures; and ensuring appropriate scrutiny and review of actions taken by persons exercising powers and performing functions under this Act; and providing a framework for continuous improvement and progressively higher standards of work health and safety; and 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. 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 Swan Island Lighthouse of Australia as it is related to AMSA staff, contractors and visitors.

6.4 Operational requirements

As a working AtoN, the operational needs of Swan Island Lighthouse are primarily concerned with navigational requirements. Below are the operational details and requirements of the Swan Island light as outlined by AMSA.

Navigational requirement for AMSA’s AtoN site

The following table is taken from AMSA’s Asset Management Strategy for the Swan Island Light.

1	Objective/rationale	An AtoN is required at the north-east end of Swan Island to mark the island and to warn of the nearby dangers including several rocks, shallows, wreck and other islets to the north-west and south. The AtoN is required as a mark for coastal navigation for ships transiting north-west / south-east through the eight mile wide Banks Strait between Tasmania and the Furneaux Group of islands.
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 (99.0%).
5	Primary and secondary means (if any) of identification	The day mark must be conspicuous. The existing 27m white masonry tower and lantern at an elevation of 30m 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 7.5 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 19 nautical miles.
7	Radar conspicuousness	As the island on which the AtoN is located provides a good radar echo, no further radar enhancement is required.

6.5 Occupier needs

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 Swan 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 Swan Island 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 lightstation.

Lighthouse performance standards

AMSA aims to meet international standards for the reliability of lighthouses set by IALA. The Swan Island 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 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 inspections of the site including auditing the contractor’s performance.

6.6 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
Annual service	2022
Lantern change	2024
Reseal lantern room glazing	2026
Solar panels changeout	2030
Structure paint	2030

6.7 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.

6.8 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 Swan Island Lighthouse.

Incident	Procedure
Damage to lighthouse’s fabric (heritage significance)	AMSA or selected contractors 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 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 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.
Significant modification to lighthouse heritage fabric	Prepare Heritage Impact Statement on proposed modifications Submit scope of works and Heritage Impact Statement to the Department of Agriculture, Water and the Environment, the Tasmanian Heritage Council, and TAS PWS for review.
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. Create temporary 'buffer' zone and allow no entry in zone until artefacts have been assessed by appropriate personnel. Notify Aboriginal Land Council of Tasmania, Cape Barren Aboriginal Association, and Aboriginal Heritage Tasmania as soon as possible. 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 Minister administering the Crown Lands Act (TAS). Terminate lease of Swan Island site with the Minister administering the Crown Lands Act (TAS). Transfer relevant records and historical information held by AMSA to the Minister administering the Crown Lands Act (TAS).

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Footnotes

³⁶AMSA, AMSA Heritage strategy, (2018) PDF4.79 MB
³⁷ AMSA, Annual Report 2020-21

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