Bushfire Management Plan

Transcription

1 Bushfire Management Plan Wentworth West Estate Bartram Road, Success LUSH FIRE & PLANNING PO Box 114 Woodanilling WA ABN Ref Ver D May 2018

2 Site Address / Plan Reference: Lot 9503 P Bartram Road Suburb: Success State: WA P/code: 6164 Local government area: Cockburn Description of the planning proposal: Residential subdivision BMP Plan / Reference Number: Version: D Date of Issue: 10/05/2018 Client / Business Name: Richard Noble & Co Reason for referral to DFES Yes No Has the BAL been calculated by a method other than method 1 as outlined in AS3959 (tick no if AS3959 method 1 has been used to calculate the BAL)? Have any of the bushfire protection criteria elements been addressed through the use of a performance principle (tick no if only acceptable solutions have been used to address all of the BPC elements)? Is the proposal any of the following special development types (see SPP 3.7 for definitions)? Unavoidable development (in BAL-40 or BAL-FZ) Strategic planning proposal (including rezoning applications) Minor development (in BAL-40 or BAL-FZ) High risk land-use Vulnerable land-use If the development is a special development as listed above, explain why the proposal is considered to be one of the above listed classifications (E.g. considered vulnerable land-use as the development is for accommodation of the elderly, etc.)? Note: The decision maker (e.g. the local government or the WAPC) should only refer the proposal to DFES for comment if one (or more) of the above answers are ticked Yes. BPAD Accredited Practitioner Details and Declaration Name Accreditation Level Accreditation No. Accreditation Expiry Geoffrey Lush Level 2 BPAD /02/2019 Company Contact No. Lush Fire & Planning I declare that the information provided in this bushfire management plan is to the best of my knowledge true and correct. Signature of Practitioner Date 10/05/2018

3 Executive Summary This bushfire management plan is prepared for the proposed subdivision and development of the Wentworth West Estate. The subject land is Lot 9503 Bartram Road Success and it is located approximately 1.5 kilometres south of Cockburn Central. The subdivision was previously approved by the WAPC (Ref No ) in June 2014 and this reflects the Twin Bartram Local Structure Plan (LSP) endorsed by the WAPC in The development is subject to an approved bushfire management plan prepared by TME Town Planning Management Engineering Pty Ltd (1) which was specifically referenced in the subdivision approval. The subject land is the undeveloped portion of Lot 9503 which has an area of hectares and is comprised of three separate portions of land being: a) Land north of Steiner Avenue being ha; b) Western portion being ha; and c) Eastern portion being ha. It is noted that Lots have already been created under the existing subdivision approval (WAPC Ref No ). Hanbury Loop, Renshaw Road and the POS area to the north east have also been constructed. The adjoining Lot 9501 is currently constructing a residential subdivision. A BAL Contour Map has been prepared and the ratings calculated for all the individual lots. This confirms that all of the proposed lots will have a BAL-19 or lower rating. The aim of this Report is to reduce the threat to the residents in the proposed subdivision in the event of a bushfire within or adjacent to the development. It demonstrates: How the hazard level will be reduced and maintained for the life of the development. That compliance with the Bushfire Protection Criteria in the Guidelines can be achieved. The bushfire hazard issue relates to interface between the development and the wetland area. The secondary concern relates to the transmission line easement and the balance of Lot The proposed subdivision complies with the objectives of State Planning Policy 3.7 as: 1. It avoids any increase in the threat of bushfire to people, property and infrastructure. Development with a maximum BAL-29 rating it does not increase the threat of bushfire. The proposed subdivision design does not increase the bushfire threat as it complies with the Bushfire Protection Criteria and provides for the management of vegetation hazards, suitable road access and appropriate separation distances with all proposed lots having a BAL-29 rating or lower. 2. It reduces vulnerability to bushfire through the identification and consideration of bushfire risks in the design of the development and the decision-making process. The bushfire hazard and risks have been identified and assessed in this report. 3. The design of the subdivision and the development takes into account bushfire protection requirements and includes specific bushfire protection measures. The proposed development complies with the Bushfire Protection Criteria. 1 TME Town Planning Management Engineering Pty Ltd (G Lush) Lots 9014 & 9015 Bartram Road Fire Management Plan Version L June 2015 (i)

4 Executive Summary 4. Achieves an appropriate balance between bushfire risk management measures and biodiversity, conservation values, and environmental protection. The vegetation on the site which is to be cleared for any development does not have any significant conservation value. The wetland foreshore has already been rehabilitated and provision for this has been included in the design and assessment. The recommendations in this report should not be construed to assure total bush fire protection and do not guarantee that a building will not be damaged in a bush fire. The severity of a bush fire will depend upon the vegetation fuel loadings; the prevailing weather conditions and the implementation of appropriate fire management measures. (ii)

5 Document Reference Property Details Street No Lot No s Plan Street Name Bartram Road Locality Success State WA Postcode 6164 Local Government Area Description of the building or works Cockburn Residential subdivision Revision Date Job No A 08/03/2018 Preliminary B 14/03/2018 Final Report Details C 05/05/2018 Revised vegetation and BAL Contours D 10/05/2108 Revised vegetation and BAL Contours Practitioner Details BPAD Level 2 Practitioner Accreditation No Disclaimer The measures contained in this report do not guarantee that a building will not be damaged in a bushfire. The ultimate level of protection will be dependent upon the design and construction of the dwelling and the level of fire preparedness and maintenance under taken by the landowner. The severity of a bushfire will depend upon the vegetation fuel loadings; the prevailing weather conditions and the implementation of appropriate fire management measures. Geoffrey Lush 10 May 2018 geoffrey@lushfire.com.au

6 CONTENTS 1.0 Proposal Details Introduction Existing Conditions Bushfire Prone Land Fire Control Order Proposed Development Environmental Considerations Native Vegetation Modification and Clearing Re-vegetation / Landscape Plans Bushfire Assessment Results Assessment Inputs Existing Vegetation Classifications Assessment Outputs BAL Contour Map Identification of Bushfire Hazard Issues Assessment Against the Bushfire Protection Criteria Compliance Table Additional Management Strategies Purchaser Advice Responsibilities for Implementation and Management of the Bushfire Measures FIGURES Figure 1 Location and Context... 2 Figure 2 Existing Conditions... 3 Figure 3 Bushfire Prone Land... 5 Figure 4 Proposed Subdivision... 6 Figure 5 Vegetation Classifications Figure 6 Modified Vegetation Figure 7 BAL Contour Map Figure 8 Spatial Mitigation Measures TABLES Table 1 Existing Vegetation Classifications... 9 Table 2 Revised Vegetation Plots Table 3 Lot BAL Classifications Table 4 Bushfire Protection Criteria Table 5 Implementation... 25

7 1.0 PROPOSAL DETAILS 1.1 Introduction This bushfire management plan is prepared for the proposed subdivision and development of the Wentworth West Estate. The subject land is Lot 9503 Bartram Road Success. The site is located approximately 1.5 kilometres south of Cockburn Central as shown in Figure 1. The subdivision was previously approved by the WAPC (Ref No ) in June 2014 and this reflects the Twin Bartram Local Structure Plan (LSP) endorsed by the WAPC in The development is subject to an approved bushfire management plan prepared by TME Town Planning Management Engineering Pty Ltd (2) which was specifically referenced in the subdivision approval. The aim of this Report is to reduce the likelihood and consequences of a bushfire within the proposed development. The Report also demonstrates: 1) How the hazard level will be reduced and maintained for the life of the development. This will enable the decision-maker to ensure that appropriate bushfire risk management measures are in place to achieve and maintain a low or moderate hazard level. 2) That compliance with the Bushfire Protection Criteria in the Guidelines can be achieved. 1.2 Existing Conditions The subject land is the undeveloped portion of Lot 9503 which has an area of hectares and is comprised of three separate portions of land as shown in Figure 2 and being: d) Land north of Steiner Avenue being ha; e) Western portion being ha; and f) Eastern portion being ha. The subject land is vacant and the two most significant features of the site are: The Bartram swamp to the north of the site; and The Western Power transmission line over the western portion of the site. To the east of the site is Lot 9501 is a semi rural unsubdivided lot with an existing dwelling. This land is presently being developed for residential purposes with a subdivision under construction. To the west and north of the site is existing residential development which forms part of the Thomson s Lake Estate. To the south are additional residential development and a Water Corporation water treatment site. 2 TME Town Planning Management Engineering Pty Ltd (G Lush) Lots 9014 & 9015 Bartram Road Fire Management Plan Version L June

8 Figure 1 Location and Context 2

9 Figure 2 Existing Conditions 3

10 1.3 Bushfire Prone Land The southern portions of the subject land are shown on the Map of Bush Fire Prone Areas (Figure 3) as being bushfire prone. Bushfire prone areas are comprised of (3): Bushfire prone vegetation; and A 100m wide bushfire prone buffer. The designation of bushfire prone areas triggers: The application of Australian Standard AS3959 Construction of Buildings in Bushfire Prone Areas under the Building Code of Australia; The provisions of the Planning and Development (Local Planning Schemes) Amendment Regulations 2015; and The application of SPP3.7 Planning in Bushfire Prone Areas. 1.4 Fire Control Order The City s Fire Control Order stipulates that: Properties over 2032m³ must have a 3 metre wide boundary firebreak with a 4 metre vertical clearance; and Properties less than 2032m³ must have all flammable materials such as long dry grass and weeds slashed, mown or trimmed down to a maximum height of 50mm across the entire property and all dead vegetation must be removed. The above measures must be installed by the1 November each year and maintained to 15 April. 1.5 Proposed Development The proposed subdivision / development plan is shown in Figure 4 and the development area site is primarily located within Hanbury Loop. A total 31 lots will be created and these will have areas of between 360 to 590sqm. It is noted that Lots have already been created under the existing subdivision approval (WAPC Ref No ). Hanbury Loop, Renshaw Road and the POS area to the north east have all been constructed as shown in the following photographs. A 17m wide limestone accessway / low fuel zone will also be created adjacent to the western boundary of lots 64 to DFES (2015) Mapping Standard for Bush Fore Prone Areas. 4

11 Figure 3 Bushfire Prone Land 5

12 Figure 4 Proposed Subdivision 6

13 Developed POS and drainage basin on the north side of Hanbury Loop. Overlooking the proposed development site. Looking south over Lots which have already been constructed. 7

14 2.0 ENVIRONMENTAL CONSIDERATIONS 2.1 Native Vegetation Modification and Clearing There is no clearing associated with the proposal. However, Lot 9501 to the east of the site is presently being developed as a residential subdivision. 2.2 Re-vegetation / Landscape Plans The originally proposed landscaping and revegetation of the wetland foreshore and POS areas has already been completed. It is also noted that the western portion of Lot 9503, under the transmission lines, has been subject to some re-vegetation of scrub like plants which are documented in Section 3.1. This area will be further modified by: Development of an eight (8) metre wide access limestone track and associated treatment extending for a distance of 17m from the rear boundary of the existing lots along Hanbury Loop; and Sand excavation under the middle section of the transmission lines. Once completed this will be treated with hydro mulch but for the purposes of the BAL Contour Map it will be assumed to be grassland. The modified vegetation is shown in Figure 6 (Section 3.2) as it has been used to determine the BAL Contours. 8

15 3.0 BUSHFIRE ASSESSMENT RESULTS 3.1 Assessment Inputs Existing Vegetation Classifications The classification of the vegetation adjacent to the site is shown in Figure 6 and the photographs on the following pages. The classification is based upon AS3959 and also takes into account The Visual Guide for Bushfire Risk Assessment in Western Australia (WAPC 2016). The details of the vegetation plots are summarised in Table 2. Table 1 Existing Vegetation Classifications Plot No Applied Vegetation Classification 1 Class A Forest - Low open forest A-04 2 Class C Shrubland - Low shrubland C-12 Effective Slope Under Vegetation Flat as it is predominantly located in the wetland. Flat although marginally higher than Plot 1 due to the fire service access route 3 Class D Scrub - Closed scrub D-13 Flat Section on the development side of the fire service access route might have a very slight rise but is barely 20m wide whereas the majority of the Plot is situated on the wetland side. 4 Class D Scrub - Open scrub D deg 5 Class G Grassland Tussock grassland G-22 6 Excludable (f) Low Threat Vegetation 5-8 deg Short embankment 3 deg 7 Note 1 Class G Grassland Tussock grassland G-22 3 deg 8 Class B Woodland - Woodland B Class G Grassland Tussock grassland G deg 0-5 deg Notes 1. Classified as Class B Open Woodland (09) and in accordance with Table 2.3 of AS3959 the classification is then based upon the understorey vegetation. 9

16 Figure 5 Vegetation Classifications 10

17 Photo No 1 Plot No 1 Vegetation Classification Class A Forest - Low open forest A- 04 Description Melaleuca vegetation to 10m height in the swamp area. It is technically closed as the foliage coverage is 90% but this does not comply with Class 18. Very heavy fuel loads. Vegetation situated on the northern and north eastern side of the fire service access route. Photo No 2 Plot No 2 Vegetation Classification Class C Shrubland - Low shrubland C-12 Description Revegetation between the fire service access route and POS area. Consists of grass trees with other ground covers. Moderate to heavy fuel loads. Photo No 3 Plot No 3 Vegetation Classification Class D Scrub - Closed scrub D-13 Description Vegetation primarily being Acacias to 4m in height situated between the fire service access route. Note the shrubs in the foreground which form part of Plot 2. 11

18 Photo No 4 Plot No 3 Vegetation Classification Class D Scrub - Closed scrub D-13 Description View looing north showing the fire service access route with scrub vegetation on both sides. The vegetation changes on the north eastern side of the FSAR as it transitions into the wetland. Photo No 5 Plot No 3 Vegetation Classification Class D Scrub - Closed scrub D-13 Description Different scrub vegetation on the north eastern side of the FSAR to 2m in height with dense understorey. Photo No 6 Plot No 3 Vegetation Classification Class D Scrub - Open scrub D-14 Description Scrub vegetation extending along the northern boundary of Lot 9501 along the edge of the wetland. Transitions from Acacia to Melaleuca. 12

19 Photo No 7 Plot No 4 Vegetation Classification Class D Scrub - Open scrub D-14 Description Revegetation under the transmission line easement. Species not known but the plants in the photo are approximately 1m high and assumed will develop into scrub over time. Photo No 8 Plot No 4 Vegetation Classification Class D Scrub - Open scrub D-14 Description Revegetation under the transmission line easement. Species not known but the plants in the photo are approximately 1m high and assumed will develop into scrub over time. Photo No 9 Plot No 5 Vegetation Classification Class G Grassland Tussock grassland G-22 Description Unmanaged grassland and bare ground on the embankment between the transmission line and the existing lots. Bare ground classified as grassland as it is expected to regenerate over time. 13

20 Photo No 10 Plot No 5 Vegetation Classification Class G Grassland Tussock grassland G-22 Description Unmanaged grassland and bare ground on the embankment between the transmission line and the existing lots. Bare ground classified as grassland as it is expected to regenerate over time. Photo No 11 Plot No 6 Vegetation Classification Excludable (e) Non Vegetated Areas Description Constructed lots on the western side of Hanbury Loop but not within the subject land. Photo No 12 Plot No 6 Vegetation Classification Excludable (e) Non Vegetated Areas Description Residential development on previous stage of the Estate. 14

21 Photo No 13 Plot No 7 Vegetation Classification Class B Woodland - Open woodland B-06 Description Open woodland area within Lot 9501 with less than 10% canopy coverage. Therefore, it is classified as Grassland in accordance with Table 2.3 Notes. Photo No 14 Plot No 7 Vegetation Classification Class B Woodland - Open woodland B-06 Description Open woodland area within Lot 9501 with less than 10% canopy coverage. Therefore, it is classified as Grassland in accordance with Table 2.3 Notes. Photo No 15 Plot No 8 Vegetation Classification Class B Woodland - Woodland B-05 Description Banksia woodland to 12m with other Eucalypts and some introduced species. degraded understorey and moderate fuel loads. 15

22 3.2 Assessment Outputs BAL Contour Map The modified vegetation classifications for the developed site are shown in Figure 6 and referenced in Table 2. Table 2 Revised Vegetation Plots Plot No Applied Vegetation Classification Comment & Effective Slope Under Vegetation A Class A Forest - Low open forest A-04 Flat as it is predominantly located in the wetland. B Class C Shrubland - Low shrubland C-12 Flat although marginally higher than Plot 1 due to the fire service access route C Class D Scrub - Closed scrub D-13 Flat Section on the development side of the fire service access route might have a very slight rise but is barely 20m wide whereas the majority of the Plot is situated on the wetland side. D Class D Scrub - Open scrub D deg E F G H Class G Grassland Tussock grassland G-22 Excludable (f) Low Threat Vegetation Excludable (f) Low Threat Vegetation Excludable (f) Low Threat Vegetation 0-5 deg Excavation area with potential for grassland following completion of works. 17m wide crushed limestone pathway and low hazard area adjacent to the rear of the existing lots in Hanbury Loop. 3 deg Existing residential lots and proposed development site. 3 deg Residential development being constructed in the adjacent Lot

23 Figure 6 Modified Vegetation 17

24 A BAL Contour Map is shown in Figure 7 and this is a plan of the subject lot/s illustrating the potential radiant heat impacts and associated indicative BAL ratings in reference to any classified vegetation remaining within 100 metres of the assessment area after the development is completed. The BAL Contour Map is based on the following assumption: That the vegetation modifications outlined in Section 2.0 occur being; sand extraction; construction of a 17m wide limestone pathway and clearing of vegetation in Lot 9501 to the east of the subject land; That any vacant undeveloped lots within the subject land will be maintained as low threat vegetation; and That the existing vacant lots in the previous stages of the estate and in particular Lots 71 to 82 will be maintained as low threat vegetation in accordance with Council s Fire Control Order. The BAL ratings for the individual lots are documented in Table 3. These ratings have been measured from the nearest point of the lot to the hazard vegetation and the BAL rating for the actual site of any future dwelling may differ from this. Figure 7 and Table 3 confirms that all lots have a BAL-29 or lower rating. 18

25 Table 3 Lot BAL Classifications Lot Number Vegetation Plot (1) Vegetation Classification Effective Slope Separation Distance (2) BAL Rating 32 C C Shrubland Flat 73m BAL C C Shrubland Flat 60m BAL C C Shrubland Flat 70m BAL C C Shrubland Flat 75m BAL C C Shrubland Flat 82m BAL C C Shrubland Flat 88m BAL C C Shrubland Flat >100m BAL-Low 39 C C Shrubland Flat >100m BAL-Low 40 D D Scrub Flat 84m BAL D D Scrub Flat 80m BAL C C Shrubland Flat 84m BAL C C Shrubland Flat 74m BAL C C Shrubland Flat 62m BAL C C Shrubland Flat 50m BAL C C Shrubland Flat 42m BAL C C Shrubland Flat 37m BAL C C Shrubland Flat 35m BAL C C Shrubland Flat 24m BAL C C Shrubland Flat 19m BAL C C Shrubland Flat 19m BAL C C Shrubland Flat 22m BAL C C Shrubland Flat 32m BAL C C Shrubland Flat 43m BAL C C Shrubland Flat 54m BAL C C Shrubland Flat 64m BAL C C Shrubland Flat 72m BAL C C Shrubland Flat 85m BAL D D Scrub Flat >100m BAL-Low 63 D D Scrub Flat 99m BAL D D Scrub Flat >100m BAL-Low 106 C C Shrubland Flat 94m BAL-Low Notes (1) (2) The selected vegetation plot is the plot with the highest BAL rating. The separation distance is measured to the nearest point on the lot boundary. 19

26 Figure 7 BAL Contour Map 20

27 4.0 IDENTIFICATION OF BUSHFIRE HAZARD ISSUES Figure 1 shows the existing conditions for the locality around the subject land. The most significant bushfire hazards are: The vegetation in the Bartram Swamp; and The vegetation to the south of Bartram Road around the Water Corporation treatment plant. The primary concern relates to interface between the development and the wetland area. While the predominant wind is from the east and the south west (sea breeze) northerly winds are often associated with hotter temperatures and more severe fire weather conditions. The secondary concern relates to the transmission line easement. This applies to the proposed lots on the eastern side of the easement and the existing lots on the western side i.e. in Marav Crt; and Mersey Close. The existing development on the northern side of Steiner Avenue is within 100m of the hazard vegetation and could be impacted by ember attack. None of the existing dwellings north of Steiner Ave and to the west of the site are part of this fire management plan. Fire construction standards cannot be applied retrospectively to these dwellings. 21

28 5.0 ASSESSMENT AGAINST THE BUSHFIRE PROTECTION CRITERIA 5.1 Compliance Table In formulating the proposed mitigation measures regard has been given to the objectives, general principles, guidance statements and performance criteria contained in the Guidelines for Planning in Bushfire Prone Areas and specifically the Bushfire Protection Criteria. The requirements in the Bushfire Protection Criteria and the proposed mitigation strategies are summarised in Table 3 and shown spatially in Figure 7. Table 4 Bushfire Protection Criteria Bushfire protection criteria Element 1: Location Method of Compliance Compliance Proposed bushfire management strategies Acceptable solutions / Performance based solution A1.1 Development location Yes The proposed lots will have a BAL-29 or lower rating. Element 2: Siting and design A2.1 Asset protection zone (APZ) Yes The lots are not large enough to contain the APZ within their own boundaries. Generally, for the first row of dwellings adjacent to the hazard areas the APZ will be provided within the development setback from the front boundary combined with the perimeter road reserve. Element 3: Vehicular access A3.1 Two access routes Yes Hanbury Loop provides two access routes to Bartram Road which itself has east - west access connecting into the district road network. A3.2 Public road Yes The subdivision roads will be constructed in accordance with the Local Government Guidelines (4) for Subdivisional Development which meet required specifications for bushfire access. A3.3 Cul-de-sac (including a dead-endroad) N/A There are no cul-de-sacs in the development. A3.4 Battle-axe N/A There are no battle axe lots. A3.5 Private driveway longer than 50m is to meet detailed requirements contained within the Guidelines. N/A There are no lots more than 50m deep. 4 Department of Planning Lands and Heritage (2017) Local Government Guidelines for Subdivisional Development 22

29 Bushfire protection criteria Method of Compliance Compliance Proposed bushfire management strategies Acceptable solutions / Performance based solution A3.6 Emergency access way (EAW) Yes There is no proposed EAW. A3.7 Fire service access N/A There are no proposed FSARs routes (FSAR) A3.8 Firebreak width Yes All proposed residential lots are less than 0.5ha in size. The balance portions of Lot 9503 are larger than 0.5 hectares and require a 3m wide boundary firebreak. Element 4: Water A4.1 Reticulated areas Yes The subdivision will be serviced with fire hydrants in accordance with the required specification. A plan of the hydrants will be submitted to Council and DFES as part of the subdivision clearance. A4.2 Non-reticulated N/A Not applicable areas A4.3 Individual lots within non-reticulated areas. N/A Not applicable 5.2 Additional Management Strategies Purchaser Advice All prospective purchasers must be made aware of the fire management issues, measures and responsibilities associated with the subdivision. This can be a notification placed upon the Certificate of Title of all lots pursuant to Section 70A of the Transfer of Land Act advising landowners of this Bushfire Management Plan and BAL requirements. 23

30 Figure 8 Spatial Mitigation Measures 24

31 6.0 RESPONSIBILITIES FOR IMPLEMENTATION AND MANAGEMENT OF THE BUSHFIRE MEASURES The management of the risk posed by bushfires is a shared responsibility between landowners, government and industry. These responsibilities are summarised in Table 4. Table 5 Implementation No MANAGEMENT ACTION TIMING 1.0 Developer Prior to Issue of Titles 1.1 Construction of subdivision roads to standards outlined in the BMP to ensure safe access and egress. 1.2 A plan demonstrating the location and capacity of fire the fire hydrants shall be submitted to the City of Cockburn and DFES 1.3 Preparing a notification be included on the certificate of titles for the lots as having a BAL-12.5 rating or higher as shown on Figures 7 and 8 advising that the land is subject to a Bushfire Management Plan. 2.0 Developer Prior to Sale Subdivision Subdivision Subdivision 2.1 Providing prospective residents with a summary of this BMP Purchase 3.0 Landowner Prior to Occupancy 3.1 Ensuring that any application for a building permit for a dwelling is to include an individual BAL assessment to confirm that sufficient land has been cleared to provide for BAL-29 setbacks. 4.0 Landowners Ongoing 4.1 Undertaking regular maintenance of their property in preparation for the annual fire season. 4.2 Ensuring that all fire mitigation measures shall be completed by the date prescribed in Council s Fire Control Order 5.0 Local Government Ongoing Management Development Ongoing Ongoing 5.1 Ensuring Building Permit Applications and Development Applications are Ongoing compliant with the building and land use planning provisions 5.2 Maintenance of the designated areas of Local Open Space as low threat Ongoing vegetation in accordance with the approved management plans. 5.3 Enforce compliance with its annual Fire Control Order. Ongoing 25