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240628FBPaper2FireByelaw

For decision

Title: Fire Man­age­ment Byelaws Paper 2 Form­al Board 28 June 2024 Page 1 of 7 Pre­pared by: Grant Moir, CEO

Stra­tegic context

  1. The Nation­al Park Part­ner­ship Plan has two rel­ev­ant sec­tions provid­ing stra­tegic con­text for this work. a) A7 — Fire Man­age­ment: Devel­op and agree a Nation­al Park approach to camp­fires and bar­be­cues. b) Policy C4 (d) – Redu­cing fire risk by lim­it­ing or exclud­ing bar­be­cues and open fires in key areas of the Nation­al Park, such as in areas of wood­land and peatland.

  2. The con­sulta­tion paper set out a range of inform­a­tion to help people think about the issues around fire man­age­ment, the stra­tegic policy con­text and spe­cific­ally wheth­er a byelaw would be an appro­pri­ate way for­ward to help reduce fire risk and the poten­tial for igni­tion in the Nation­al Park. This built on the board papers dis­cussed by mem­bers in Septem­ber and Novem­ber 2023.

  3. The Park Author­ity has already com­mit­ted in the Nation­al Park Part­ner­ship Plan (NPPP) to estab­lish an Integ­rated Wild­fire Man­age­ment Plan (IWMP) for the Park. An update on this plan is provided as paper three.

Pur­pose

  1. Fol­low­ing the board decision on 24 Novem­ber 2024 the Park Author­ity have car­ried out an extens­ive con­sulta­tion on poten­tial fire man­age­ment byelaws for the Cairngorms Nation­al Park the res­ults of which gives the Park Author­ity a man­date for change.

  2. Mem­bers are now invited to agree the Park Author­ity pos­i­tion. If the Board agrees to pro­ceed with a byelaw then the spe­cif­ic word­ing of the byelaw will be agreed at the board meet­ing in Septem­ber and then sub­ject to a form­al 12 week con­sulta­tion in the Autumn before being final­ised and sub­mit­ted to Scot­tish Min­is­ters for approval.

Paper 2 Form­al Board 28 June 2024 Page 2 of 7

Recom­mend­a­tions

The Board is asked to: a) Agree that the Park Author­ity devel­op a sea­son­al fire man­age­ment byelaw from 1 April to 30 Septem­ber each year for form­al con­sulta­tion this Autumn. b) Agree that the fire man­age­ment byelaw does not cov­er muir­burn as indi­vidu­al muir­burn licence con­di­tions will cov­er muir­burn dur­ing peri­ods of high fire risk. c) Agree that the Park Author­ity con­tin­ue to work with the Scot­tish Gov­ern­ment to ensure that fixed pen­alty notices can be issued for byelaw offences.

Stake­hold­er engagement

  1. The Park Author­ity launched a con­sulta­tion on fire man­age­ment, includ­ing the poten­tial intro­duc­tion of fire byelaws on Thursday 8 Feb­ru­ary 2024, with the con­sulta­tion run­ning for 10 weeks until Wed­nes­day 17 April 2024. The cam­paign was sup­por­ted by a ded­ic­ated post­card sent to every address in the Nation­al Park, an art­icle in Cairn magazine, mul­tiple press columns and inter­views, video con­tent and ded­ic­ated social media activity.

  2. The con­sulta­tion doc­u­ment out­lined three poten­tial ways for­ward, ran­ging from a no byelaw option to a year round byelaw. The Park Author­ity did not express a pre­ferred option as part of this pro­cess but instead, sought feed­back from a range of dif­fer­ent per­spect­ives to inform its long term plans.

  3. The online sur­vey received a total of 1,664 online responses and 18 writ­ten responses. The detailed break­down of the con­sulta­tion is con­tained in Annex 1.

  4. The head­line over­view of the con­sulta­tion was as fol­lows: a) Main types of respond­ents were loc­al res­id­ents (58%), vis­it­ors (31%) busi­nesses (11%) and land man­agers / work­ers (10%). b) 79% of all respond­ents sup­por­ted the intro­duc­tion of a byelaw, 16% were against and 5% were unsure. c) Respond­ents were asked which (if any) of three options they preferred:

     i. 17% preferred option 1 no byelaw / enhanced education.
     ii. 34% preferred option 2 – a high fire risk byelaw.
     iii. 49% preferred option 3 – year round byelaw.
    

    d) Respond­ents were asked wheth­er they wished to see pre­scribed burn­ing included in a byelaw with 45% in favour, 35% against and 20% don’t know.

Paper 2 Form­al Board 28 June 2024 Page 3 of 7

Stra­tegic policy consideration

  1. The con­sulta­tion responses give the Park Author­ity a strong man­date for change and for the devel­op­ment of a fire man­age­ment byelaw. There were a lot of dif­fer­ent views about what that byelaw should look like and should cover.

  2. This sec­tion sets out the think­ing behind the recom­mend­a­tions from staff based on the inform­a­tion gathered through the con­sulta­tion and fur­ther con­sid­er­a­tion about the most effect­ive approach going forward.

  3. There were three cri­ter­ia that staff used to con­sider the dif­fer­ent options. a) Ease of com­mu­nic­a­tion and under­stand­ing by the pub­lic b) Ease of enforce­ment c) Like­li­hood of redu­cing wild­fire risk and risk of ignition

High fire risk fire man­age­ment byelaw

  1. The high fire risk byelaw option whilst the most focussed at stop­ping fires dur­ing peri­ods of high risk is not easy to com­mu­nic­ate. This was borne out by com­ments in the con­sulta­tion. Vis­it­ors com­ing to the Nation­al Park would need to know wheth­er there was a high fire risk in place. They would also need to know when it would be over. This is likely to be dif­fi­cult to com­mu­nic­ate to the circa two mil­lion vis­it­ors and sig­nage would have to be deployed across the Nation­al Park and taken down again, mak­ing it dif­fi­cult to resource. High fire risk may also only affect part of the Nation­al Park at any giv­en date, mak­ing it dif­fi­cult to com­mu­nic­ate. This in turn would make enforce­ment dif­fi­cult as people could be unaware of the cur­rent fire risk with­in the Nation­al Park.
Cri­ter­ia
Ease of com­mu­nic­a­tion and understandingRed
Ease of enforcementRed
Like­li­hood of redu­cing wild­fire risk and risk of ignitionAmber

Year round fire man­age­ment byelaw

  1. The year round fire man­age­ment byelaw is easy to com­mu­nic­ate with a simple year round mes­sage. It could have issues around enforce­ment, with people see­ing it as heavy handed e.g. enfor­cing when there is little or no risk of igni­tion. This was

Paper 2 Form­al Board 28 June 2024 Page 4 of 7

some­thing that a num­ber of respond­ents to the con­sulta­tion raised in their feed­back. The year round approach would, how­ever, reduce the risk of wild­fire and poten­tial points of igni­tion if there was a high rate of compliance.

Cri­ter­ia
Ease of com­mu­nic­a­tion and understandingGreen
Ease of enforcementAmber
Like­li­hood of redu­cing wild­fire risk and risk of ignitionGreen

Sea­son­al fire man­age­ment byelaw

  1. As part of the con­sulta­tion, 291 con­sul­tees sug­ges­ted an altern­at­ive option should be con­sidered. A sea­son­al byelaw was one of the spe­cif­ic options that 21 respond­ents spe­cific­ally men­tioned. It was con­sidered rel­at­ively simple to com­mu­nic­ate it would not apply dur­ing the colder and gen­er­ally wet­ter months when there is rel­at­ively low risk from recre­ation­al fires and thus would not be seen as heavy handed.

  2. In look­ing at recre­ation­al fire trends in the Nation­al Park, it is clear that from Octo­ber the amount of act­ive fires decrease due to weath­er and that few­er people are camp­ing. The data only starts in April so there is no data for March 2023.

Act­ive Fires – CNPA Ranger Ser­vice 2023

Month 2023AprilMayJuneJulyAugustSeptOct
Act­ive Fires2020825520214
  1. Wild­fire Danger Assess­ments when the over­all fire danger assess­ment was very high or extreme were issued for all or part of the Cairngorms Nation­al Park from 10 to 11 March 2023, 17 April to 22 April 2023, 26 May to 10 June 2023 and 14 June to 17 June 2023.

Paper 2 Form­al Board 28 June 2024 Page 5 of 7

Cri­ter­ia
Ease of com­mu­nic­a­tion and understandingGreen
Ease of enforcementGreen
Like­li­hood of redu­cing wild­fire risk and risk of ignitionAmber

Recom­mend­a­tion 1 – Of those that wanted a byelaw, the dif­fer­ence in pref­er­ence was rel­at­ively small between the options, with 59% in favour of a year round byelaw and 41% in favour of a high fire risk byelaw. Con­sid­er­a­tion has been giv­en by the Park Author­ity to see if there is a way that an option can be formed that com­bines the best from these options whilst respond­ing to con­cerns raised about each. This means try­ing to find an approach that is still easy to com­mu­nic­ate and is not per­ceived as heavy handed but also cov­ers the peri­ods with the greatest risk. It is thus recom­men­ded that the Park Author­ity devel­op a sea­son­al fire man­age­ment byelaw from 1 April to 30 Septem­ber each year for form­al con­sulta­tion this Autumn.

Pre­scribed burning

  1. The inclu­sion of pre­scribed burn­ing in the con­sulta­tion was around the need for con­sist­ency dur­ing peri­ods of high fire risk, i.e. there should be times of the years when nobody is light­ing a fire due to a high fire risk being in place.

  2. Land man­agers in the Nation­al Park (see Annex 1) gen­er­ally felt that muir­burn should not be included in the byelaws as it was poten­tially duplic­at­ing oth­er legis­la­tion and there was the poten­tial for double penalties.

  3. On 24 March, in the middle of the con­sulta­tion peri­od, the Wild­life Man­age­ment and Muir­burn Bill passed in the Scot­tish Par­lia­ment. In dis­cus­sions with NatureScot and oth­ers since, it has been agreed that restric­tions on under­tak­ing muir­burn dur­ing a peri­od of high fire risk (with exemp­tions for con­trolling a wild­fire etc) will be con­di­tioned in Muir­burn Licences. This is in line with best prac­tice. This approach was what was poten­tially being pro­posed with­in the byelaw con­sulta­tion but, with this now being covered by the Muir­burn Licence, this means that the byelaws can focus solely on recre­ation­al fires.

Recom­mend­a­tion 2 – It is recom­men­ded that the fire man­age­ment byelaw does not cov­er muir­burn as indi­vidu­al muir­burn licence con­di­tions will cov­er muir­burn dur­ing peri­ods of high fire risk.

Paper 2 Form­al Board 28 June 2024 Page 6 of 7

Enforce­ment

  1. Enforce­ment is a last resort, with the main focus being on inform­a­tion, edu­ca­tion and com­mu­nic­a­tion. It is, how­ever, abso­lutely vital that the Park Author­ity is able to issue fixed pen­alty notices. This will need a change in legis­la­tion but is a key part of imple­ment­a­tion for the byelaws. The Park Author­ity has been in dis­cus­sions with Scot­tish Gov­ern­ment around this. There will also need to be a sig­ni­fic­ant train­ing pro­gramme for the Park Author­ity rangers and ongo­ing enforce­ment dis­cus­sions with Police Scotland.

Recom­mend­a­tion 3 – The Park Author­ity con­tin­ue to work with the Scot­tish Gov­ern­ment to ensure that fixed pen­alty notices can be issued for byelaw offences.

Times­cale and next steps

  1. If the Board approve the recom­mend­a­tions, a paper will be taken to the Septem­ber board with pro­posed byelaw word­ing for the form­al con­sulta­tion. This will include the details of exemp­tions from the byelaw, exactly what the byelaw will cov­er, flex­ib­il­ity around dates for the sea­son­al byelaw if, for example, the Park Author­ity needs to respond to sus­tained changes in the pat­tern of future wild­fire risk or recre­ation pat­terns etc. If approved by the Board in Septem­ber, it will go out to form­al con­sulta­tion for 12 weeks.

  2. Fol­low­ing the form­al con­sulta­tion, the Board will con­sider the feed­back and agree the final byelaw word­ing to be sub­mit­ted to Scot­tish Ministers.

  3. In advance of any imple­ment­a­tion date there will need to be three major pieces of work car­ried out: a) Train­ing for all Park Author­ity Rangers and rel­ev­ant man­agers on the pro­cess for enfor­cing the byelaws. Liais­on with Police Scot­land and oth­ers on imple­ment­a­tion sup­port. b) Com­mu­nic­a­tions and engage­ment cam­paign in advance of any imple­ment­a­tion date to ensure that res­id­ents and vis­it­ors are aware of any restric­tions. c) Devel­op­ment and install­a­tion of sig­nage at key entry points and des­tin­a­tions in the Nation­al Park.

Paper 2 Form­al Board 28 June 2024 Page 7 of 7

Implic­a­tions

  1. There is still a sig­ni­fic­ant amount of con­sulta­tion to under­take and a rel­at­ively long times­cale until any byelaw is imple­men­ted. The Park Author­ity will con­tin­ue to work with part­ners on redu­cing wild­fire risk and con­sid­er­ing the resources needed to imple­ment the Integ­rated Wild­fire Man­age­ment Plan.

Suc­cess measures

  1. The key suc­cess meas­ures for the fire man­age­ment byelaws are: a) Reduc­tion in num­ber of recre­ation­al fires being lit dur­ing oper­a­tion of the byelaw. b) Reduc­tion in num­ber of wild­fire incid­ents in the Nation­al Park caused by recre­ation­al fires.

Annex 1, Paper 2 Form­al Board 28 June 2024 Page 1 of 8 Annex 1

Con­sulta­tion overview

Back­ground

The Park Author­ity launched a con­sulta­tion on fire man­age­ment, includ­ing the poten­tial intro­duc­tion of fire byelaws on Thursday 8 Feb­ru­ary 2024 with the con­sulta­tion run­ning for 10 weeks until Wed­nes­day 17 April 2024. A con­sulta­tion doc­u­ment out­lined three poten­tial ways for­ward, ran­ging from a no byelaw option to a year round byelaw. The Park Author­ity did not express a pre­ferred option as part of this pro­cess but instead, sought feed­back from a range of dif­fer­ent per­spect­ives to inform its long-term plans.

The con­sulta­tion was largely car­ried out online, with respond­ents asked ques­tions on dif­fer­ent options and the reas­ons for their responses via an online sur­vey. Some anonymised data was also gathered on the type of respond­ent so ana­lys­is could be under­taken of any dif­fer­ences in views from dif­fer­ent groups e.g. res­id­ents or vis­it­ors. Writ­ten responses were also wel­comed, and a num­ber received, largely from part­ner organ­isa­tions although some of these also com­pleted the online survey.

Level of response

The online sur­vey received a total of 1,664 responses. 1,617 people respon­ded to the ques­tion of respond­ent type with a break­down as shown in the table below. Note that people could select mul­tiple options e.g. Loc­al res­id­ent and Land man­ager or work­er, so responses do not total 100%.

What is your con­nec­tion with the Cairngorms Nation­al Park?
Respond­ent typeNo.%
Busi­ness own­er or employee17811.0%
Part­ner organisation412.5%
Com­munity group member885.4%
Staff/​board mem­ber or Park Author­ity volunteer181.1%
Land man­ager or worker16610.3%
Vis­it­or50731.4%
Loc­al resident94358.3%
Prefer not to say241.5%
Oth­er734.5%

Annex 1, Paper 2 Form­al Board 28 June 2024 Page 2 of 8

Level of sup­port for a byelaw

1,571 respond­ents indic­ated their level of sup­port for, or oppos­i­tion to a byelaw with responses as follows.

Do you think a fire man­age­ment byelaw is part of the solu­tion for the Cairngorms Nation­al Park Author­ity to tackle wild­fire risk?
Answer choicesNo.%
Yes1,24579.2%
No25216.0%
Don’t know744.7%

Level of sup­port for the dif­fer­ent options presen­ted in the con­sulta­tion document

1,469 respond­ents expressed a pref­er­ence for one of the options detailed with responses as below. 105 respond­ents indic­ated that they pre­ferred anoth­er option not described.

Annex 1, Paper 2 Form­al Board 28 June 2024 Page 3 of 8

Which of the three options do you think the Park Author­ity should take forward
Answer choicesNo.%
Option 1 — no byelaw, enhanced com­mu­nic­a­tion and edu­ca­tion approach22517.1%
Option 2 — high fire risk byelaw44533.9%
Option 3 – year-round byelaw64449.0%

Vari­ations in response by group

When responses are broken down by the respond­ent group (loc­al res­id­ent, vis­it­or etc.) some vari­ations in views were evid­ent although most groups responses were with­in a few per­cent­age points of the all respond­ents” aver­age. Not­able excep­tions were:

a) Sig­ni­fic­antly more com­munity group mem­ber respond­ents favoured no byelaw when com­pared with the aver­age (30% v an 18% average)

b) Sig­ni­fic­antly more Land man­ager or work­er respond­ents and Part­ner Organ­isa­tions favoured a high fire risk byelaw when com­pared with the aver­age (48% & 52% respect­ively v a 34% average)

c) Sig­ni­fic­antly more vis­it­ors favoured an all year byelaw when com­pared with the aver­age (55% v a 46% average)

Annex 1, Paper 2 Form­al Board 28 June 2024 Page 4 of 8

d) Sig­ni­fic­antly few­er land man­ager or work­er and com­munity group mem­ber respond­ents as well as part­ner organ­isa­tions favoured an all year byelaw when com­pared with the aver­age (31%,37% and 30% respect­ively v a 46% average)

Full details with the most sig­ni­fic­ant vari­ations circled in red are shown in the table below.

All responsesLoc­al res­id­entVis­it­orLand man­ager or work­erStaff/​board or Park Author­ity volun­teerCom­munity group mem­berPart­ner organ­isa­tionBusi­ness own­er or employee
Option 1 — no byelaw18%135 (16%)77 (18%)27 (21%)2 (14%)22 (30%)6 (18%)40 (26%)
Option 2 — high fire risk byelaw34%284 (33%)120 (28%)63 (48%)5 (36%)24 (33%)17 (52%)54 (35%)
Option 3 — year round byelaw46%432 (51%)236 (55%)41 (31%)7 (50%)27 (37%)10 (30%)60 (39%)

Pre­scribed burning

1,515 people respon­ded as to wheth­er they wished to see pre­scribed burn­ing included in a byelaw with responses as follows.

Do you think that pre­scribed burn­ing should be included in a byelaw?Responses
Answer choices
Yes678 (44.8%)
No528 (34.9%)
Don’t know309 (20.4%)

When responses are broken down by the respond­ent group some vari­ations in views were evid­ent as indic­ated below. There was a wider range of responses between

Annex 1, Paper 2 Form­al Board 28 June 2024 Page 5 of 8

dif­fer­ent groups than with the pre­vi­ous ques­tions with one par­tic­u­larly not­able vari­ance (circled in red) being the views of Land man­agers and work­ers. A sig­ni­fic­antly high­er num­ber (64% v a 35% aver­age) were against the inclu­sion of pre­scribed burn­ing with con­sequently few­er being supportive.

All responsesLoc­al res­id­entVis­it­orLand man­ager or work­erStaff/​board or Park Author­ity volun­teerCom­munity group mem­berPart­ner organ­isa­tionBusi­ness own­er or employee
Do you think that pre­scribed burn­ing should be included in a byelaw?
Yes45%412 (47%)228 (51%)41 (27%)11 (61%)35 (43%)14 (39%)55 (34%)
No35%304 (34%)113 (25%)98 (64%)6 (33%)25 (31%)14 (39%)76 (47%)
Don’t know20%170 (19%)109 (24%)13 (9%)1 (5%)21 (26%)8 (22%)32 (20%)

Respond­ent profile

1,505 respond­ents also com­pleted a series of ques­tions that allowed a pro­file of respond­ents to be gathered that helps identi­fy wheth­er there was a spread of char­ac­ter­ist­ics such as age, employ­ment status and gender. The three tables below give an indic­a­tion of the spread of char­ac­ter­ist­ics from those respond­ents with not­ably great­er num­bers of responses from men and from older age groups being evident.

Annex 1, Paper 2 Form­al Board 28 June 2024 Page 6 of 8

Annex 1, Paper 2 Form­al Board 28 June 2024 Page 7 of 8

Reas­ons for responses

In addi­tion to ques­tions gath­er­ing quant­it­at­ive data, respond­ents were also asked to give reas­ons as to why they sup­por­ted the option they did. This allows the Park Author­ity to con­sider not just abso­lute num­bers sup­port­ing an option but also some qual­it­at­ive data that could sup­port or oppose any of the poten­tial options. As these responses were provided in a free text” format it is not pos­sible to provide all the detail here but an ana­lys­is of all the responses did identi­fy some com­monly occur­ring themes. It is also worth not­ing that many com­ments indic­ated that respond­ents recog­nised that there were nuanced pos­it­ives and neg­at­ives to all the options presen­ted and so a defin­it­ive response could con­sequently be difficult.

a) Increas­ing risk — respond­ents com­monly men­tioned the risk of fire to either prop­erty or the envir­on­ment with some also feel­ing the level of risk was increas­ing with cli­mate change. Many people also com­men­ted on the risk to wild­life / hab­it­ats / biod­iversity. Man­aging risk through redu­cing fuel load through burn­ing, firebreaks etc was also mentioned.

b) Clar­ity — respond­ents com­men­ted on what they saw as a lack of clar­ity around fires in the Scot­tish Out­door Access Code and in related mes­saging. Amongst those sup­port­ing one of the byelaw options there was a view that this would provide a less ambigu­ous and / or stronger message.

c) Enforce­ment some respond­ents sup­por­ted great­er oppor­tun­it­ies for enforce­ment in par­tic­u­lar when com­pared to cur­rent options which are seen to be quite lim­it­ing. Many also com­men­ted on the fact that the abil­ity to enforce would in itself encour­age great­er com­pli­ance with any byelaw.

d) Edu­ca­tion / Advice — sig­ni­fic­ant num­bers of respond­ents sup­por­ted the con­tinu­ation of efforts to edu­cate or advise people about fires. Many of those opposed to a byelaw felt this approach was adequate, while many sup­port­ing a byelaw com­men­ted on the num­bers ignor­ing such advice and stated that edu­ca­tion is inef­fect­ive. There was broad sup­port for con­tin­ued edu­ca­tion / advice from respond­ents favour­ing all three of the options presen­ted. Some respond­ents high­lighted that any restric­tion would need to be sup­por­ted by advice on alternatives.

e) Respons­ible beha­viour – par­tic­u­larly amongst those opposed to a byelaw there was a feel­ing that intro­du­cing a byelaw would also pen­al­ise respons­ible people. Related to this, a num­ber of respond­ents com­men­ted on the need to allow prac­tic­al edu­ca­tion around fires such as bush­craft” courses.

f) Muir­burn – many respond­ents com­men­ted both for and against the inclu­sion of muir­burn with those against com­monly sug­gest­ing this be covered via licencing.

Annex 1, Paper 2 Form­al Board 28 June 2024 Page 8 of 8

g) A Nation­al issue a num­ber of respond­ents com­men­ted on the fact that this is not an issue unique to the Cairngorms and as such a solu­tion should be developed nationally.

Altern­at­ive approaches

291 respond­ents sug­ges­ted that an altern­at­ive approach to tack­ling wild­fire risk should be con­sidered. A sea­son­al byelaw was an option that 21 respond­ents spe­cific­ally men­tioned with the sug­ges­tion that set dates were easi­er to com­mu­nic­ate. Oth­er options sug­ges­ted by mul­tiple respond­ents were increased man­age­ment of fuel loads, pro­vi­sion of altern­at­ive fire areas or ded­ic­ated fire / barbe­que sites and per­mit or licens­ing systems.

Writ­ten Responses

In addi­tion to the online responses, 17 writ­ten responses were received – although some were from respond­ents who also com­pleted the online sur­vey. Most of the writ­ten responses provided sim­il­ar obser­va­tions to those described in the pre­vi­ous two sec­tions but some addi­tion­al points were raised which are giv­en below.

a) A byelaw that applies only at times of high fire risk could make mat­ters worse as it could imply there isn’t a risk at oth­er times.

b) Allow­ing fires with­in private prop­er­ties (gar­dens) would present an incon­sist­ency in approach could risk los­ing the con­fid­ence of vis­it­ors affected by a byelaw.

c) No case has been presen­ted as to why pre­scribed burn­ing with­in the Nation­al Park should be treated dif­fer­ently to that out with and as described in the Part­ner­ship Plan, this should be done via the new licens­ing sys­tem for muir­burn. Oth­ers have made asso­ci­ated com­ments that the term pre­scribed burn­ing” is not recog­nised by primary legis­la­tion but muir­burn” is.

d) It is not appro­pri­ate to use the same reg­u­lat­ory frame­work to reg­u­late both the recre­ation­al and pro­fes­sion­al applic­a­tion of fire. Respond­ents com­monly poin­ted to pre­scribed burn­ing being under­taken by trained staff with the expert­ise and equip­ment to pre­vent spread.

e) The Park Author­ity should con­sider impos­ing byelaws at the loc­al author­ity scale as opposed to park wide.

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