b'Section 95 of the Local Government Act 2003 enables the relevant Minister (by regulation) to authorise relevant authorities to undertake commercial activities in relation to their ordinary functions. The legislation requires the establishment of a company to do so. Under the Local Authorities (Best Value Authorities) (Power to Trade) (England) Order 2009 the authority must also approve a business case before it sets up the company and must not provide subsidy to the trading company. Under section 5A of the 2004 Act (as inserted by the Localism Act 2011), a relevant fire authority may do: (a)anything it considers appropriate for the purposes of the carrying-out of any of its functions;(b)anything it considers appropriate for purposes incidental to its functions; (c)anything it considers appropriate for purposes indirectly incidental to its functions through any number of removes; (d)anything it considers to be connected with any of its functions, or anything it may do under paragraph (a), (b) or (c); and (e)for a commercial purpose anything which it may do under any of paragraphs (a) to (d) otherwise than for a commercial purpose. As with section 95, if this power is exercised for a commercial purpose, the Fire Authority must do so through a company. Relevant fire and rescue authority means a fire and rescue authority in England that is: a metropolitan county fire and rescue authority; the London Fire and Emergency Planning Authority; constituted under a scheme under the 2004 Act. Therefore, each type of Fire Authority has, in principle, the power to establish a company.Once formed, the boundary of the activity of the company is constrained only by the statutory purpose for setting up the company in the first place, the Companies Act and its articles of association. This is a fundamental principle and a major reason for local authorities and Fire Authorities are using the vehicle of a company to undertake trading activities. Standalone fire and rescue authorities: general power 6.10 The general power of competence takes the starting position of what an individual can do, limited by legislation. This is not an appropriate provision for a single-purpose body which is defined by its functions. This is because standalone FRAs are constituted specifically to focus on a core set of functions limited by their governing statutory code. Instead, following the enactment of the 2011 Act, standalone FRAs now benefit from a different general power to the general power of competence. These powers enable standalone FRAs to: 73'