Question 5. Do you think we have identified the right cross-boundary issues and initiatives that affect ourselves and neighbouring areas?
Cam Conservators support the cross-boundary issues identified in the document. It is in the Cam Conservator’s particular interest that wildlife habitats and green infrastructure are dealt with as a cross boundary issue as well as water, including supply, quality, waste water and flood risk. This is particularly important with regards to the river and as part of their mission to manage the river in a manner sensitive to environmental interests. The existing allocation for residential moorings along the river adjacent to Fen Road spans both Councils’ administrative boundaries, therefore it is imperative that all parties and stakeholders work together to ensure that the allocation can be delivered along with the proposed residential development.
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3.1. Savills (UK) Ltd are instructed by Mr and Mrs Wilkinson to make representations to the Greater Cambridge Issues and Options Local Plan (January 2020) (The First Conversation) in respect of their land interests to the east of the A505 Royston. 3.2. We particularly welcome the identification of housing and transport as key cross boundary issues, but it is also important that economic growth both within and outside Greater Cambridge is considered and discussed as this could have implications for the direction of the plan. 3.3. In considering cross-boundary issues, it is important the authorities look beyond Cambridge as the centre for growth, and consider the role neighbouring authorities play in supporting communities within Greater Cambridge. 3.4. The town of Royston, located in neighbouring North Hertfordshire, in particular plays an important role in servicing communities in south west Greater Cambridge. The A505 which encloses the town to the north, east and west, forms the boundary between South Cambridgeshire and North Hertfordshire. Our client’s land, to the east of the A505, is within South Cambridgeshire but new development in this location would largely be serviced by the town. 3.5. Large areas of North Hertfordshire are covered by the Metropolitan Green Belt, and Royston is the only major settlement within the District which is not constrained by it. Development to the south west of the town is constrained by Therfield Heath which is a rare chalk grassland habitat, SSSI and Local Nature Reserve. Consequently, in order to continue to support the economic and social growth of the town, development opportunities beyond the A505 in South Cambridgeshire should be considered and our clients land to the east of the A505 provides such an opportunity.
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46. Any strategy which progresses must adequately respond to the needs of both Cambridge City Council (CCC) and South Cambridgeshire District Council (SCDC) and provide a sufficient supply and mix of sites to deliver growth needs across both areas. 47. Therefore, reliance on a single growth strategy such as Edge of Cambridge or new settlements must be avoided, and a mixed and flexible approach should be adopted to ensure housing demand is met in all locations across the Plan area including established settlements and villages. 48. Allocating a range of types and locations for development will ensure there is a robust supply which will enable a sufficient amount and variety of land can come forward where it is needed as encouraged by the NPPF (paragraph 59). 49. This means there needs to be a step away from the existing preference for locating development, as set out in adopted Plans for SCC and CCC. At present, the priority is to deliver new housing on the edge of Cambridge, followed by within new settlements and lastly in the rural area at Rural Centres.
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Where to build? The current approach requires significant adjustment as it is too heavily geared towards long term and complex development projects involving the various new planned settlements. This approach is leaving the Councils unable to deliver sufficient housing numbers in the short to medium terms, and is therefore prejudicing their ability to meet their rolling five year housing land supply requirements and objectively assessed housing needs. It is also too Cambridge Centre/Cambridge Edge focused to the detriment of the villages in the District, including Guilden Morden. Without encouraging more allocations within the villages, their needs will effectively be ignored and the new Joint Local Plan strategy will miss out on valuable Section 106 opportunities to deliver community benefits and secure improvements to local infrastructure. A more dispersed and proportionate strategy would be more appropriate so that the distribution of development can be spread more evenly across the district to embrace an appropriate level of development and investment within the villages. Learning from the recent Local Plan Examination experiences of other nearby rural districts, such as Uttlesford District Council, adopting such a strategy would go a long way to ensuring that the Councils’ joint approach to the new Plan can ultimately be found to be ‘sound’ by the Inspector. Sites such as the one being promoted at ‘Land south of New Road, Guilden Morden’, adjoining the existing settlement, provide an excellent opportunity to deliver sustainable development solutions and much needed housing (including new affordable homes) to meet local needs in the short term. Our ‘Call for Sites’ report (December 2019) is attached for your ease of reference. This can be considered as a very logical ‘extension’ to the existing settlement boundary. This could form part of a wider comprehensive review exercise to identify similar opportunities for sustainable development within the villages across Cambridgeshire, which cumulatively would help the Councils to deliver the required number of dwellings to demonstrate a five year housing supply and ensure that development is more proportionately distributed across the district to meet objectively assessed needs. As referenced earlier, the absence of new housing allocations means that potential Section 106 opportunities to enhance local village facilities and infrastructure will not be realised. Moreover, there will be no injection of new residents, including younger people and families, with the associated increased expenditure to the local catchment area that such an injection would bring, thereby helping to underpin the long-term sustainability of villages, and ensuring mixed and balanced communities. For these reasons, we urge the Council to adjust its current approach so that it is not over reliant on Cambridge and the new planned settlements, with the associated skewed housing delivery focused on the longer term that it creates. Rather, we recommend that the Council adopts a dispersed and proportionate approach to development across the district, including site allocations throughout the villages, based on the principles of achieving sustainable development and capable of early delivery. This should specifically include the allocation of the land to the South of New Road, in Guilden Morden.
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Southern & Regional development (Cottenham) identifies that it is essential for a Local Plan to demonstrate that it has discharged its statutory Duty to Co-Operate with neighbouring authorities and other relevant organisations to ensure that it is sound. Without due consideration of cross-boundary issues, including housing requirements and economic functions, a Plan will not have demonstrated its requirements as contained within the Duty to Co-Operate. Although the Greater Cambridge Local Plan is at an early stage of its preparation, it is vital that is able to demonstrate that it has taken into appropriate consideration cross-boundary issues. These issues will influence the strategies of the new Plan, including the approach in achieving residential and other types of development across the Local Plan area. Those issues which have been identified within the Issues and Options document address significant considerations which will inform the trajectory of the Plan during the preparation process. It is considered that those areas of concern relating to cross-boundary factors are appropriate. Although it is recognised that the Cambridge HMA is relatively self-contained, with a travel to work area similar in size and pattern to the housing market area itself, this should not result in a Plan which reduces the significance in cross-boundary impacts on the ability of the Planning Authorities in delivering their housing needs. For instance, given that the neighbouring Authorities are generally unconstrained, with no Green Belt, it is likely that they will be able to meet their own needs within their own jurisdiction. As such, there may be lesser need for Greater Cambridge to assist in accommodating cross-boundary housing numbers. However, it is considered that the emerging Local Plan must take into account the impacts that a rapidly growing local economy will have on these cross-boundary issues. This includes the influence of strategic infrastructure projects, such as East-West Rail and the Oxford-Cambridge Expressway which will open the housing market up further to additional influxes of people commuting to the expanding job market within Cambridge. This in turn will have a material impact on strategic residential need as a result of increasing demand and exacerbate housing costs. A careful approach to cross-boundary considerations is therefore required, to ensure that the new Plan remains responsive to these issues given that they arise from outside the Local Plan area and are beyond the control of the Local Authorities. Summary of Comments: The list of cross-boundary considerations is appropriate, however the Local Plan should acknowledge the degree of importance and significance to each.
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We welcome the inclusion of Green Infrastructure as a cross boundary issue and would expect to see the Wicken Fen Vision Area referenced in that context. In terms of the wider geography, we note that the Ox-Cam Arc is referenced elsewhere but the potential cross boundary opportunities should be clearly articulated; the Local Natural Capital Plan will be key to achieving the GI vision and will go beyond neighbouring local authorities. See also our response to Questions 12 and 13.
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CambridgePPF disagrees: • London is the elephant in the room. Although the London Plan sets out that housing needs can be met, in reality high land values, house prices, and rental rates mean that a substantial number of new London workers will commute from outside. Cambridge already has a significant number of London workers and has been identified as providing opportunities for outward migration from the London area. This situation will be exacerbated by the opening of Cambridge South Station and new development close to Cambridge North Station. In London there is no political appetite to build on the Green Belt in order to address this situation. To what extent should Cambridge provide housing for London commuters, especially if this means building on Cambridge’s Green Belt? It would seem unacceptable to us if Cambridge were to sacrifice its Green Belt because London refused to build on its own. This is an issue that we feel should be given much greater prominence in the Local Plan and discussed with local communities. • Anecdotally, we are aware that many people moving into housing around Cambridge which was previously green belt, such as Nine Wells and Great Kneighton, are London workers. If the Councils have not already commissioned research into the scale of London workers occupying new Cambridge developments then we suggest that this should be done as part of the evidence-base for the Local Plan as it has a critical bearing on who we are providing housing for. • Cambridge now has a very large commute-to-work area, which extends beyond the neighbouring Cambridgeshire districts. We believe that the commute-to-work area should form the basis of cross-boundary engagement. As an example, one of our employees commutes from a new development in Norfolk. • The Local Plan must identify where there are cross-boundary planning issues and incorporate the tools and mechanisms within the Plan to deal with them if they arise during the Plan period. This will avoid a repeat of the situation which has emerged in the A1301 corridor where the planning authority has been largely powerless to manage large-scale piecemeal development (Agritech at Hinxton Grange, Wellcome Trust expansion, Great Chesterford Business Park, and the Uttlesford ‘Garden Village’). The Local Plan should also have the flexibility to require Area Action Plans/Masterplans/Supplemental Planning Documents when unplanned cross-boundary issues arise. This could be achieved through policy wording to that effect.
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Agree Other issues to consider are: assessing economic development needs, infrastructure and landscape character. West Suffolk Council shares: travel to work, housing market and functional economic areas. Approaches to growth should consider landscape characteristics, which span administrative boundaries. Consideration of cross-boundary transport issues should include both the strategic (A14) and major road networks (A1307) that cross the county boundary and the Ipswich to Cambridge rail line where the East West Rail Eastern Section Group is actively working to increase passenger rail frequencies.
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Strongly Agree. For nature to recover it is critical that local authority boundaries do not create a barrier to wildlife moving throughout the nature network. If we are to achieve our ‘doubling nature’ target in Cambridgeshire, the Greater Cambridge plan authorities need to work closely with neighbouring authorities to deliver ambitious and strategic habitat creation projects and a coherent green infrastructure network that is joined up across authority boundaries.
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Steeple Morden borders North Hertfordshire District Council and the A505. The layout of road junction at Odsey is of serious concern and should be the subject of a priority upgrade by the Transport Authority, Hertfordshire County Council.
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We broadly agree with your paper and welcome the acknowledgement of the new railway and its role in 3.6.1. As set out in Figure 1 above, there are proposals for new stations in the Cambourne and Sandy to St. Neots areas (located either in the broad area around Tempsford or to the South of St Neots). These locations potentially cover areas in South Cambridgeshire, Bedford, Central Bedfordshire and Huntingdonshire. EWR would welcome the opportunity to work with all relevant authorities to consider the implications of the new stations and the potential opportunities for associated housing and economic development. Recommendation We would like to work with the combined and neighbouring authorities to progress effective cross boundary working in relation to the EWR project.
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No - Fenland will flood before SCDC. We have not allowed for migration, nor the loss of farmland. The current emphasis on the information and knowledge sectors jobs being created and the cost of housing affect working, commuting and living across into neighbouring areas. With current policies, Greater Cambridge will be dependent on the adjacent areas to allow it to continue to be successful. In order to minimise this potentially carbon rich living style, we would expect the Local Plan to make more effort to improve the life chances of those born and educated here so that there are suitable jobs and housing locally for all abilities.
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No. Section 3.6.5 refers to ‘Working with our Neighbouring Local Authorities’. ECC supports reference to Uttlesford and Braintree District Councils, however there is no mention of ECC as the upper tier authority. The GCA will need to ensure engagement takes place in accordance with the duty to cooperate in our role as the strategic transport and highways authority, Local Education Authority (including Early Years and Childcare), Lead Local Flood Authority, Minerals and Waste Planning Authority, a provider and commissioner for adult social care, and lead advisors on public health. It is considered that the Local Plan may be strengthened by demonstrating greater collaborative working with wider organisations on major infrastructure improvements and proposals such as ECC and Highways England. It is also recommended that that Local Plan appreciates the wider relationships outside of Cambridgeshire and into Essex, London and other surrounding areas. ECC notes that figure 7 highlights the key economic corridors. ECC supports reference to the UK Innovation Corridor (London-Stansted-Cambridge). However, it is recommended that the Joint Local Plan contains further reference to the Corridor and how the objectives may influence the emerging strategy. The London Stansted Cambridge Consortium (LSCC) was formed in June 2013 as a strategic partnership of public and private organisations. The role of the LSCC is to organise and promote the UK’s Innovation Corridor. The corridor stretches from the Royal Docks in London, into Tech City, the City Fringe, Kings Cross and the Olympic Park, up through the Lee Valley, the M11, A1 and A10, the East Coast and West Anglia Mainline rail routes to Stevenage, Harlow and London Stansted through to Cambridge and Peterborough. ECC further recommends that figure 7 includes reference to key neighbouring economic locations including Harlow and Gilston Garden Town; the ports of Felixstowe (Suffolk), Harwich and Tilbury (Essex) given their international significance; and London Southend airport. ECC welcomes that the GCA have identified transportation and flood risk as matters where cross-boundary collaboration and joint working will be required. Depending on the chosen spatial development strategy adopted by the GCA and the neighbouring Essex authorities with emerging local plans, consideration should be given to cross boundary matters in relation to education and Early Years and Child Care. ECC notes that paragraph 3.4.1 entitled Gathering the Evidence outlines where the GCA are seeking to gather evidence. ECC supports the evidence list. Given there is no glossary of terms at this stage, ECC encourages the GCA to ensure that consideration is given to Early Years and Child Care and education comprising primary, secondary, Post 16 and further education as part of the ‘infrastructure’ category. ECC recommends that consideration is given to the emerging Cambridge and Peterborough Minerals and Waste Local Plan, as it forms part of the statutory Development Plan for the GCA. Elements of the Minerals and Waste Plan, particularly the approach to safeguarding unexcavated mineral resources and minerals and waste infrastructure, relies on effective partnership working at both the site allocation and planning application stages. As an adjoining County Council, the Essex Minerals and Waste Planning Authority has an interest in ensuring that Cambridgeshire and Peterborough use mineral and waste infrastructure and resources sustainably.
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It is essential not just for the prosperity of those living in the area, but also for the wider region within the Oxford-Cambridge Arc and the UK in general, that Greater Cambridge plays its part in delivering economic growth. MGH endorses the approach to consultation with wider partnerships, and places particular emphasis on the need to deliver the growth associated with the Oxford Cambridge Arc. This will require coordination with the combined Cambridgeshire and Peterborough Authority together with the County Council, neighbouring authorities and others in the Arc. A number of key issues are set out in the issues and Options report in relation to the aspirations of each local authority (p18). This includes the need to help businesses to grow. The report also recognises the need for an evidence base relating to employment and the duty to co-operate in relation to the Oxford Cambridge Arc. We endorse that emphasis, with Savills recent research document emphasising both the existing strength of the local economy and the ability for that to continue to growth and diversify in the future* *.’The Oxford-Cambridge Innovation Arc’, Savills, 2019
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Agree Thakeham agree with the Councils’ approach to collaborate with neighbouring authorities, especially in relation to assessing housing need. Whilst Section 4.6.3, details the Councils’ objectively assessed housing need, there appears to be no allowance for any shortfall in delivery that has been identified in neighbouring Local Authorities. Thakeham would like to raise concern that the Greater Cambridge Local Plan consultation document has not mentioned the wider housing market area and how this unmet need by neighbouring Authorities, impacts Greater Cambridgeshire’s housing need. Given the affordability issues in Cambridgeshire, it is highly likely the housing market area for Cambridge City and South Cambridgeshire is shared with neighbouring authorities. In accordance with the NPPF, the Council has a duty to co-operate on housing issues crossing administrative boundaries. Local Plans are required to meet their “full objectively assessed need for market and affordable housing in the housing market area, as far as consistent with the policies set out in this Framework” (NPPF, paragraph 47). Whilst it is pleasing that the Councils’ appear to be looking to meet their housing needs in full it is important to consider whether any unmet needs from other authorities in the housing market area can be met within the Greater Cambridge Local Plan.
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Q5 Agree
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Agreed Also, where business parks, employment areas or centres of liesure are identified that might impact neighbouring areas, i.e. traffic, housing, etc.
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Southern & Regionsal (swavesey) consider that a Local Plan must demonstrate that it has discharged its statutory Duty to Co-Operate with neighbouring authorities and other relevant organisations to ensure that it is sound. Without due consideration of cross-boundary issues, including housing requirements and economic functions, a Plan will not have demonstrated its requirements as contained within the Duty to Co-Operate. Although the Greater Cambridge Local Plan is at an early stage of its preparation, it is vital that is able to demonstrate that it has engaged and taken into appropriate consideration of cross-boundary issues. These issues should influence the strategies of the new Plan, including the approach in achieving residential and other types of development across the Local Plan area. Those issues which have been identified within the Issues and Options document address significant considerations that will inform the trajectory of the Plan during the preparation process. It is considered that the areas of concern relating to cross-boundary factors are appropriate. However, engagement with housing need and the cross-boundary influences that impact on this need should be strongly considered as a central component of the spatial strategy prepared as part of the new Greater Cambridge Local Plan. Although it is recognised that the Cambridge HMA is relatively self-contained, with a travel to work area similar in size and pattern to the housing market area itself, this should not result in a Plan which reduces the significance in cross-boundary impacts on the ability of the Planning Authorities in delivering their housing needs. For instance, given that the neighbouring Authorities are generally unconstrained, with no Green Belt, it is likely that they will be able to meet their own needs within their own jurisdiction. As such, there may be lesser need for Greater Cambridge to assist in accommodating cross-boundary housing numbers. However, it is considered that the emerging Local Plan must take into account the impacts that a rapidly growing local economy will have on these cross-boundary issues. This includes the result of strategic infrastructure projects, such as East-West Rail and the Oxford-Cambridge Expressway which will open the housing market up further to additional influxes of people commuting to the expanding job market within Cambridge. This in turn will have a material impact on strategic residential need as a result of increase demand and exacerbation of housing costs. A careful approach to cross-boundary considerations is therefore required, to ensure that the new Plan remains responsive to these issues given that they arise from outside the Local Plan area and are beyond the control of the Local Authorities. Summary of Comments: The list of cross-boundary considerations is appropriate, however the Local Plan should acknowledge the degree of importance and significance to each.
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4.20 In addition to the cross-boundary issues identified, which we considered are of regional and national importance, the role and opportunities linkages to Felixstowe play within this economic corridor should not be underestimated. 4.21 The site’s location along the newly improved A14 provides a unique opportunity to address a long-standing need for a site capable of meeting the needs of national employment and logistic operators in close proximity to Cambridge.
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When considering proposed development close to the boundaries of the Local Plan area, it is important to consider impacts on the areas beyond the planning boundaries. For example, in relation to heritage assets, the impact of development upon heritage assets and their settings across the Local Plan boundary should be considered. Regarding the North Uttlesford Garden Community you will now be aware of the Inspector’s letter to the Uttlesford District Council dated 10th January which places the future of the NUGC into question.
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Failure to take up the important opportunity to consider the historic city of Cambridge in conjunction with its full landscape and cultural setting.
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No. The most important cross-boundary issues have been omitted completely. Firstly, the presumption of ‘growth’ and the growth corridors of Ox-Cam and London-Stansted-Cambridge have been accepted without question. Secondly, there has been no consideration as to how this major investment of national funds in the relatively well-off south-east will further reduce or limit investment in the North of the UK. Cambridgeshire hosts a significant proportion of this country’s best and most versatile farm land. By the end of this century it is probable that climate change will have caused significant loss of the Fens which currently grow 24% of UK food supply. Therefore it is imperative that the remaining farm land is not built on but preserved for food supply. This is a national issue. There are currently 1 million empty homes in the North and Midlands which could be brought back into use and space for a further 1 million homes on brownfield sites in the North and Midlands. Investment in these would preserve Cambridgeshire’s precious farm land for food supply. Furthermore, climate change and other environmental issues are caused by untrammeled economic growth. Therefore, this Plan should be addressing how to reduce growth whilst maintaining adequate standards of living in our Region. CPRE is very concerned by the complex structure of authorities across local government within Cambridgeshire. Including the GCP and the Combined Authority with County, District and Parish/Town councils there are now four levels of planning authority on some issues and five levels of local government on many others. This brings severe communication challenges and the practicalities associated with the duty to co-operate. Overlapping authorities and bodies cause confusion to the public and make decision making and accountability difficult to understand. For example on transport there has been intense public argument between the Combined Authority and other bodies.
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Q1 and Q5 Stakeholder engagement and cross-boundary issues We support the Councils’ approach to stakeholder engagement and consideration of cross boundary projects including Oxford-Cambridge Arc, the Combined Authority Strategies, Greater Cambridge Partnership, County strategies and neighbouring Local Authorities. Natural England is satisfied that the Councils’ approach meets the relevant duty to cooperate requirements. We agree with the key cross-boundary issues identified including wildlife and green infrastructure, transport and water including supply, quality, waste water and flood risk. The Local Plan will need to take a strategic approach to these issues to ensure that the proposed scale of development is sustainable and will not adversely impact the natural environment. In particular the Local Plan should promote the delivery of a strategic green infrastructure network that is resilient to the scale of development proposed, capable of protecting designated sites and supporting habitat, and delivering the wider range of environmental services to meet development needs. This will require the delivery of a strategic GI network that contributes towards and complements the enhancement objectives of cross-boundary projects such as the Ox-Cam Arc Local Natural Capital Plan and landscape-scale priority areas such as the West Cambridgeshire Hundreds, Cambridgeshire Fens, the Chalk & Chilterns and the National Trust’s Wicken Fen Vision Area.
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- We suggest that, since your reports state that 22% of resident ‘workers’ work outside the GC area and 38% come into the GC area to work, there is a complex relationship between developing employment and housing within the GC area and likely changes to commuting patterns. - We suggest that these figures are updated and the LDP contains a clear statement as to what proportions of inward and outward commuting have been prediucted.
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We agree with the identified cross boundary issues. In terms of priority, strategic transport solutions could be key to achieving the other objectives of carbon-reduction and creating a properly connected green infrastructure strategy.
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In response to Question 5, FDC is content that section 3.6.5 identifies the broad areas for consideration in relation to cross boundary issues.
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Both the Over and Willingham Internal Drainage Board and Swavesey Internal Drainage Board are pleased to be involved in the emerging Water Cycle Study (WCS) and Strategic Flood Risk Assessment (SFRA) and note that reference is made to the County Council in its role as the Lead Local Flood Authority (LLFA) but given that most surface, ground and treated foul effluent water discharges through higher level watercourses that cross the lower lying fen to the north of the District they are most disappointed that little reference is made in the consultation document to "water related" issues including water level and flood risk management, water resources, treated foul effluent water disposal etc. It is appreciated that the constraints created by flooding and the extents of the floodplain are not as great as those experienced by other councils within Cambridgeshire but adequate consideration must be given to these matters particularly where flooding is an issue, for example, Swavesey, Bar Hill, Girton, Addenbrookes Hospital etc. The current South Cambridgeshire Development Control Policies are some of the best and most relevant "water related" policies within the County. It would be most disappointing if this position was lost. See also the additional relevant items discussed elsewhere in this response. The inclusion of a relevant flooding section within the recently adopted Swavesey Village Design Guide document should be taken as an example of what should be included within other similar relevant documents.
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No response proposed.
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Agree Thakeham agree with the Councils’ approach to collaborate with neighbouring authorities, especially in relation to assessing housing need. Whilst Section 4.6.3, details the Councils’ objectively assessed housing need, there appears to be no allowance for any shortfall in delivery that has been identified in neighbouring Local Authorities. Thakeham would like to raise concern that the Greater Cambridge Local Plan consultation document has not mentioned the wider housing market area and how this unmet need by neighbouring Authorities, impacts Greater Cambridgeshire’s housing need. Given the affordability issues in Cambridgeshire, it is highly likely the housing market area for Cambridge City and South Cambridgeshire is shared with neighbouring authorities. In accordance with the NPPF, the Councils' have a duty to co-operate on housing issues crossing administrative boundaries. Local Plans are required to meet their “full objectively assessed need for market and affordable housing in the housing market area, as far as consistent with the policies set out in this Framework” (NPPF, paragraph 47). Whilst it is pleasing that the Councils’ appear to be looking to meet their housing needs in full it is important to consider whether any unmet needs from other authorities in the housing market area can be met within the Greater Cambridge Local Plan. Please refer to the appended Vision Document titled 'Land east of Long Road, Comberton' produced by Thakeham.
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Whilst we agree, it imperative that the discussions with neighbouring authorities “on strategic matters that cross administrative boundaries” (National Planning Policy Framework (‘NPPF’) paragraph 24) are evidenced which confirm strategic policy-making authorities have collaborated “to identify the relevant strategic matters which they need to address in their plans” (NPPF, paragraph 25). The importance of this cannot be underestimated given a number of Local Plans have recently been found unsound owing to a lack of evidence in relation to the Duty to Cooperate (‘DtC’) on cross boundary strategic matters such as housing. We therefore suggest sufficient flexibility is incorporated into the spatial strategy that allows for inter alia, having to absorb neighbouring authorities unmet housing need, if required.
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