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I'm not really sure what'd count as being fortified for a 3+ save. I was thinking bunkers, but then they have their own separate rules as buildings. Like, walls, or sandbags, or gun pits or whatever are a 4+, so I dunno what'd be 3+.
Intact structures originally built for military purpose. Being inside a true trench system, not just a line of sandbags. Bunker-like structures that are too big to use the transport style building rules. Gun emplacements on a Marine Fortress Monastery. That sort of thing.