7. Conservation management principles and policies

Policies 

Note: The management of sensitive information is not relevant to AMSA’s heritage strategy and therefore bears no relevance in this management plan. 

Fabric and setting

Policy 1 – Protect and conserve the significant external and internal fabric of the lighthouse, including existing buildings, layout and setting.

AMSA’s main purpose is to facilitate the ongoing operation of the site as a marine AtoN while preserving the site’s heritage values. As part of a heritage monitoring program, Heritage Asset Condition Reports are produced for each site every two years to evaluate the condition of the heritage fabric and values. Routine servicing is also carried out by maintenance contractors. Regular written reports from these visits will be sent to AMSA Asset Management and Preparedness for review and any work requirements identified will be scheduled accordingly. Should for some unforeseen reason the site no longer be viable as a marine AtoN, ownership will be passed to an appropriate state or federal authority to ensure preservation of the heritage assets.  

Implementation strategy:

• AtoN Maintenance Contractor will continue scheduled periodic maintenance of the lighthouse and marine aids to navigation every 12 months to ensure condition is monitored for early warning of deterioration. Schedule must be approved by AMSA Asset Management and Preparedness.
• AMSA Asset Management and Preparedness to arrange for maintenance to be carried out on the lighthouse as required while continuing to operate as an AMSA marine AtoN.
• AMSA Asset Management and Preparedness to continue the scheduled heritage monitoring visits to Sugarloaf Point Lighthouse and review of the Heritage Asset Condition Reports every two years. 
• AMSA Asset Management and Preparedness to arrange for the replacement and upgrading of marine AtoN equipment in the lighthouse as required to meet AMSA’s service commitment, in a manner that preserves the original fabric of the lighthouse. 
• AMSA Asset Management and Preparedness to maintain information on the heritage fabric of the lighthouse including any and all actions, treatments and inspection outcomes within the heritage fabric register. See ‘Section 4.1 for Fabric register’. 
• AMSA Asset Management and Preparedness to conserve all the fabric elements identified as significant in the Heritage Asset Condition Report. 
• AMSA Asset Management and Preparedness to seek expert materials conservation advice when considering repair, restoration and reconstruction of historic fabric. The relevant local, state and Commonwealth heritage approvals must be sought prior to repair, restoration and reconstruction. 
• AMSA AtoN Heritage Coordinator to conserve the distinctive character of the lightstation by collecting photographic evidence and historical documentation of the original fabric.

Uses

Policy 2 – Install and operate equipment in the lighthouse, so it continues to function as an effective marine AtoN, in such a way as to impose the least possible harm to the significant fabric.

Sugarloaf Point Lighthouse’s use as a working marine AtoN is of high priority. Carrying out maintenance, including upgrades to navigational equipment, is necessary to its function and continued marine safety along the NSW coast. In the event of the installation or upgrade to AtoN equipment, proper precaution will be taken to ensure the least possible harm is done to significant fabric.

Implementation strategy:

• AtoN Maintenance Contractor to monitor Sugarloaf Point’s AtoN equipment every 12 months and propose maintenance in the instance of necessary installation or removal. Proposed maintenance is to be approved by AMSA Asset Management and Preparedness.
• AMSA Asset Management and Preparedness to outline all possible risks to significant fabric (external and internal) associated with the installation, removal and operation of navigational equipment.
• AMSA Asset Management and Preparedness to ensure works carried out are those that ensure the least possible harm to significant fabric.
• AMSA Asset Management and Preparedness to seek expert heritage conservation advice on best practice management of the site during installation, removal and operation of AtoN equipment.   

Policy 3 – Monitor possible impacts to the site resulting from tourism and control appropriate access to the lighthouse for contractors and visitors.

Sugarloaf Point Lighthouse is not currently open as a tourist site and access inside the lighthouse is restricted to authorised personnel, such as contractors and AMSA employees. In the event Sugarloaf Point Lighthouse were to be opened to tour groups, AMSA personnel and contractors would require easy access inside the lighthouse precinct and tower for periodical site visits to carry out inspections and routine maintenance.

Implementation strategy:

• AtoN Maintenance Contractor to ensure control of access to all buildings within the precinct is maintained by periodically inspecting restricted access areas every 12 months.
• AtoN Maintenance Contractor to inspect lighthouse for signs of wear and tear attributed to visitor intake during yearly maintenance visit, and note changes in Heritage Asset Condition Report. 
• The maintenance of the light holds priority over official tours conducted inside the lighthouse. 
• AMSA Asset Management and Preparedness to ensure access to the lighthouse complies with workplace health and safety measures. 
• AMSA Asset Management and Preparedness to notify NSW NPWS of any special events that require access to the lightstation. 
• AMSA Asset Management and Preparedness to ensure access to site is available for Aboriginal people to maintain cultural traditions. 

Interpretation

Policy 4 – Accurate and relevant interpretation of the history and significance of the place should be made available to site users/visitors and for offsite external research.

AMSA will continue to make information available through the maintenance of site interpretive signage and its website.

Implementation strategy:

• All relevant information concerning the history and significance of the place will be checked for accuracy and updated appropriately.
• Information will be primarily presented in online resource files accessible to both relevant personnel and the general public. On-site interpretative signage will be utilised where appropriate.
• This information will be maintained and updated in accordance with changes to the history and significance of the place.

Management

Policy 5 – AMSA will continue to conserve the lighthouse in accordance with Commonwealth and NSW State heritage listing requirements.

For works requiring heritage approval, AMSA will obtain permission from any relevant state or federal authorities. Continuous and as-needed conservation works will be undertaken as required.

Implementation strategy: 

• AMSA Asset Management and Preparedness to liaise with the relevant Commonwealth and State heritage agencies when proposing work on the site.
• AMSA Asset Management and Preparedness to consult with NSW NPWS when proposing work on site.
• Approval in writing from the relevant Commonwealth and State heritage authorities must be granted for any proposals for development.

Policy 6 – The cultural significance of the lightstation will be the basis for deciding how to manage it.

The heritage values or cultural significance of the place must be conserved. This heritage management plan includes relevant background information to support this policy (see ‘Section 3 History’).

Implementation strategy: 

• Conserve the lightstation to protect its heritage values (cultural significance). 
• When possible, strive to maintain the original fabric of the lightstation.
• Use the Burra Charter as the primary guide for treatment of fabric. 
• Engage appropriately qualified heritage consultants when making decisions regarding impact on heritage values.
• Assess impacts on the heritage values of the place when considering proposed alterations or adaptations.

Policy 7 – Monitor, review and report the Commonwealth heritage values of the lighthouse every five years or sooner if major changes to the lightstation occur.

The Commonwealth heritage values of the lighthouse are to be monitored and reported on a regular basis. A Heritage Asset Condition Report is updated for Sugarloaf Point Lighthouse every two years. The report records historical information, condition, and maintenance requirements for fabric within the lighthouse to ensure a gain and/or loss of heritage value is identified.

Implementation strategy:

• AMSA Asset Management and Preparedness to regularly monitor the lighthouse for possible impacts on the identified Commonwealth heritage values.
• AMSA AtoN Maintenance Contractor to update the Heritage Asset Condition Report every two years, and AMSA AtoN Heritage Coordinator to review the reports. 
• AMSA Asset Management and Preparedness to review the current Commonwealth heritage values at least once every five years and assess any gain/loss of values.
• This review must be undertaken in the event of any major alterations to the lightstation.
• AMSA Asset Management and Preparedness to report any changes to the Commonwealth heritage values of the lightstation to the Department of Climate Change, Energy, the Environment and Water (Heritage Branch).
• AMSA Asset Management and Preparedness to update AMSA’s Heritage Strategy and this plan to reflect any changes identified.

Policy 8 – Maintain historical, management and maintenance records within AMSA and make available these records.  

As part of the proper process for managing change in significant places, the Burra Charter points out the importance of making records before any change, and advocates placing records in a permanent archive and making them available where this is appropriate. AMSA’s collection of records, which include documents pertaining to heritage intervention, management and maintenance, are subject to this process. Heritage Asset Condition Reports are routinely generated for each heritage lighthouse and stored in AMSA’s record-keeping system. AMSA will continue to practice such processes via their records management systems. 

Implementation strategy:

• AMSA AtoN Asset Management and Preparedness to maintain, review and update records through existing AMSA record management system. 
• AMSA AtoN Asset Management and Preparedness to ensure records are made available to the relevant personnel and parties.

Policy 9 – Develop and provide appropriate training and resources to all relevant AMSA staff, contractors and licensees.

In order to ensure best practice management of AMSA-operated lighthouses, all staff, contractors and licensees are required to have access to the appropriate training and resources in order to provide best practice conservation of the site.    

Implementation strategy:

• AMSA Asset Management and Preparedness to provide staff, contractors and licensees access to up-to-date versions of the AMSA Heritage Strategy, heritage management plans and fabric registers.
• When funds are made available, AMSA Asset Management and Preparedness staff will undertake the appropriate training to ensure comprehension of the Commonwealth heritage and EPBC Act statutory requirements.
• Contractors engaged with heritage sites will undertake appropriate training to ensure comprehension of the Commonwealth heritage and EPBC Act statutory requirements.
• AMSA representatives will attend Commonwealth-run heritage workshops, programs and conferences for up-to-date information on statutory requirements and best-practice management of sites of national and state heritage significance.
• All current and incoming tour guides operating within AMSA lighthouses will be required to take the lighthouse tour guide safety induction e-learning module once every two years to stay informed on heritage values, visitor safety and lighthouse duty-of-care.

Policy 10 – Use contractors and service providers with appropriate experience.

AMSA is to ensure parties carrying out work have appropriate knowledge and use effective methods to ensure conservation of the lighthouse.

Implementation strategy:

• AMSA Asset Management and Preparedness to engage staff and contractors with the relevant experience and expertise concerning conservation of the lighthouse.
• Develop and provide the appropriate training on heritage conservation matters for AMSA staff and other relevant parties who hold responsibility for heritage management.

Policy 11 – Seek heritage advice and apply best heritage practice.

AMSA will continue to use in-house heritage expertise, external consultancy, or a combination of both as required in order to successfully apply best heritage practice. Should in-house heritage expertise be limited in responding to a requirement, external heritage expertise will be engaged to address the issue.  

Implementation strategy: 

• Apply in-house heritage expertise when required. 
• Use tools such as the Burra Charter and Working Together: Managing Commonwealth Heritage Places42 to measure the likely impact of proposals.
• Seek external heritage expertise in the event of limited in-house capability.

Policy 12 – Appropriate protocol in the event of unforeseen discoveries or disturbances of Aboriginal heritage within the AMSA site.

AMSA’s scope of work rarely involves excavation. Should such work need be undertaken, AMSA will implement a suitable discovery plan and seek advice from suitably qualified personnel as required. In the event of any unforeseen discovery or disturbance of Aboriginal heritage items on the AMSA site, notification to the appropriate organisation will occur in accordance with the conditions of the discovery plan. This plan will also be updated accordingly.  

Note: In most cases, AMSA’s leases are limited to the immediate vicinity of the lighthouse and therefore this scenario is not anticipated as a likely occurrence.

Implementation strategy:

• AMSA Asset Management and Preparedness to notify NSW Heritage and the lessor the instance an unforeseen discovery is made/suspected.
• AMSA Asset Management and Preparedness to seek appropriate heritage advice and apply best practice in the event of unforeseen discoveries/disturbances.

Policy 13 – Make this heritage management plan available to all persons involved in decision-making on the management of the lighthouse and its setting.   

The plan will be made available to all personnel intrinsic to management of the lighthouse and its setting, for example AMSA maintenance contractors, staff and other relevant parties.

Implementation strategy:

• Provide links to this plan via the AMSA publicly accessible website.
• Provide copies to all relevant personnel and parties.

Future developments

Policy 14 – Adaptation of the place using methods or processes that minimise impact on heritage values and significance in accordance with the Burra Charter principles.

It is likely that over time the lighthouse will house new equipment as technology changes and improves. The Burra Charter principles will be used as the basis for decision-making. 

Implementation strategy:

• AMSA Asset Management and Preparedness to assess the likely impacts of changes on the heritage values and significance of the place.
• AMSA Asset Management and Preparedness to preserve the original fabric of the place and do only what is necessary for the continued use and care of the place.
• AMSA Asset Management and Preparedness engage expert heritage advice and use the Burra Charter in adapting the place.  

Policy 15 – When required, engage with adjacent landowners to maintain an appropriate setting for the lighthouse in its visual and natural context.

Any changes to the surrounding land, or AMSA leased area, requires careful consideration. AMSA will liaise with NSW NPWS and all adjacent landowners in the event of any proposed changes that may affect the setting and attempt to influence a positive outcome.

Implementation strategy:

• AMSA Asset Management and Preparedness to engage with NSW NPWS and adjacent landowners through consultation when changes are proposed regarding the wider visual and natural context.

Policy 16 – In the event of adaptive re-use or divestment (an instance(s) which would no longer place the lighthouse under AMSA control), AMSA will strive to ensure the Commonwealth and NSW State heritage values of the site are recognised and preserved. 

In the event Sugarloaf Point Lighthouse is no longer identified as a working AtoN, AMSA will withdraw its standing as lessee and hand over all authority to the lessor. This process must be conducted in line with s 341ZE of the EPBC Act.

Implementation strategy: 

• AMSA will negotiate with lessor to have site lease terminated.
• All available heritage information within AMSA’s collection, including this heritage management plan, will be shared with the relevant parties to ensure the Commonwealth and NSW State heritage values of the site are recognised and preserved.  

Community Involvement

Policy 17 – Consult with Traditional Stakeholders and the wider community in the preparation of the management plan.

AMSA will give the community and Traditional Stakeholders, as well as the general public, an opportunity to review and comment on this management plan through a public consultation process.

Implementation strategy: 

• AMSA to undertake community consultation when preparing the heritage management plan in accordance with EPBC Regulations.
• AMSA to seek advice from all relevant Aboriginal communities and refer to Engage Early—Guidance for proponents on best practice Indigenous engagement for environmental assessments under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act).43 to guide consultations.  

Review

Policy 18 – Review this plan within five years of its adoption or sooner if major changes are needed.

This plan will be reviewed every five years. This review should:

• assess the content of the plan. 
• determine its effectiveness in protecting the identified heritage values.
• provide any necessary recommendations for updating or re-writing of the plan. If major changes occur at the site in the interim, this plan will be reviewed and updated earlier than the specified five years.

Implementation strategy:

• AMSA Asset Management and Preparedness to review this heritage management plan at least five years after its adoption.
• AMSA Asset Management and Preparedness to review and update this heritage management plan in the event of a major change to the lightstation.
• AMSA Asset Management and Preparedness to submit revised plan for approval.

Footnotes

⁴² Commonwealth of Australia, Working Together Managing Commonwealth Heritage Places: a guide for Commonwealth agencies (2019).

⁴³ Commonwealth of Australia, Engage Early—Guidance for proponents on best practice Indigenous engagement for environmental assessments under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) (2016).