State government authorities create By-laws as a type of "statutory rule" under an empowering Act, and are made by the State governor.[3] Local government by-laws are the most prevalent type of by-law in Australia, and control things from Parking and Alcohol in parks to fire regulations and zoning controls. In New South Wales these by-laws are called ordinances and Zoning Controls are called Environmental Planning Instruments created under the Environmental Planning and Assessment Act.[4] Numerous specific institutions, including universities, are also empowered to make by-laws by their establishing legislation. By-laws of a company or society are created as a contract among members, and must be formally adopted and/or amended.[5] Strata Title was developed in Australia and by-laws of body corporate are also empowered by state legislation.[6] These are the main type of by-law most people come into contact with on a regular basis as they control what people in Strata title housing can do in their own homes.[7] The most well known of these is the "no pets in flats" rule.[8][9]