6.1 Implications arising from significance
The Commonwealth statement of significance (section 5.1 above) demonstrates Sugarloaf Point Lighthouse is a place of considerable heritage value due to its contribution to the ‘highway of lights’ designed by the colony authorities to illuminate the coast of New South Wales throughout the mid to late 19th century
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:
- lantern room
- original lens assembly and pedestal
- internal catwalk
- lantern floor
- auxiliary light
- intermediate floors
- stairs and weight tube
- 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 catwalk
- lantern base
- balcony and balustrades
- walls
- windows and doors
- external stairs
- apron and wall
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.
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 2022 and is available online.40
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 and Natural values
Sugarloaf Point and the Myall National Park as a whole is notable for its Aboriginal heritage 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 Sugarloaf Point 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,
- Consulting with NSW NPWS to ensure work does not impact areas of environmental concern,
- 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 historic importance, rare features, aesthetic qualities, and technical, social and associative prominence, Sugarloaf Point 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 Sugarloaf Point 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 | Nature of change impacting heritage values |
---|---|---|
Sugarloaf Point Lighthouse structure | High |
|
Low |
|
|
Ground floor | High |
|
Low |
|
|
Intermediate floor | High |
|
Medium |
|
|
Low |
|
|
Stairs and weight tube | High |
|
Low |
|
|
Lantern room | High |
|
Medium |
|
|
Low |
|
|
Balcony and balustrades | High |
|
Low |
|
|
Lantern glazing | High |
|
Low |
|
|
Lantern roof | High |
|
Low |
|
|
Lens assembly and light source | High |
|
Low |
|
|
Pedestal | High |
|
Medium |
|
|
Low |
|
|
Walls | High |
|
Low |
|
|
Windows | High |
|
Low |
|
|
Doors | High |
|
Low |
|
|
Auxiliary light | High |
|
Low |
|
|
External stairs | High |
|
Low |
|
|
Apron, path and wall | High |
|
Low |
|
|
Generator building | Medium |
|
Low |
|
6.3 Statutory and legislative requirements
The following table lists the Acts and codes relevant to the management of Sugarloaf Point 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 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.
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.41 |
Navigation Act 2012 (Cth) |
Part 5 of the Act outlines AMSA’s power to establish, maintain and inspect marine aids to navigation (such as Sugarloaf Point Lighthouse).
|
Australian Heritage Council Act 2003 (Cth) |
This Act establishes the Australian Heritage Council, whose functions are:
|
New South Wales Heritage Act 1977 (NSW) |
The objects of this Act include: (a) to promote an understanding of the State’s heritage; |
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: (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 Sugarloaf Point 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 Sugarloaf Point Lighthouse are primarily concerned with navigational requirements. Below are the operational details and requirements of the Sugarloaf Point light as outlined by AMSA.
1 | Objective/rationale | An AtoN is required on Sugarloaf Point to mark the point itself and to provide a landfall mark on this south-east point of Australia. The AtoN is required to provide a mark for coastal navigation and to assist ships in keeping clear of several shoals that lie within close proximity both north and south of it. An auxiliary fixed red light is required to guard over the Seal Rocks that lie 2.5 nm to the south. |
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 15m white round masonry tower and lantern at an elevation of 79m 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 25 nautical miles and the red sector light must have a nominal range of at least 13 nautical miles |
7 | Radar conspicuousness | As the Sugarloaf Point itself provides 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 500 marine AtoN includes traditional lighthouses such as Sugarloaf Point, 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 Sugarloaf Point 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 lightstation.
Lighthouse performance standards
AMSA aims to meet international standards for the reliability of lighthouses set by IALA. Sugarloaf Point 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 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 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 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.
Maintenance | Estimated date of work |
---|---|
Structure paint | 2022 |
LED Array replacement | 2024 |
Reseal lantern glazing | 2025 |
Lantern room paint | 2026 |
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 lightstation 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 Sugarloaf Point Lighthouse. 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 Sugarloaf Point Lighthouse.
Incident | Procedure |
---|---|
Major project/maintenance works proposed |
|
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 Indigenous artefacts on-site. |
|
Divestment of lighthouse from AMSA |
|
Footnotes
40 Australian Maritime Safety Authority, AMSA Heritage Strategy (Australian Maritime Safety Authority, 2022)
41 Australian Maritime Safety Authority, Annual Report 2020-21 (Australian Maritime Safety Authority, 2021)