The National Planning Policy Framework (NPPF) Paragraph 24 identifies that, “Local planning authorities
and county councils (in two-tier areas) are under a duty to cooperate with each other, and with other
prescribed bodies, on strategic matters that cross administrative boundaries”

Pg.43 of the supporting text of the GCLP identifies that:
“In preparing our evidence informing the preferred strategy we have engaged with relevant organisations
under the legal duty to cooperate on plan making, to ensure we have fully considered strategic crossboundary
matters. The engagement we’ve completed to consider these strategic issues is set out in our Duty
to Cooperate Statement of Compliance, and our current position on each substantive issue is set out in our
draft Statement of Common Ground. The water supply challenge addressed above is a serious issue to be
resolved. Apart from this, we are not currently aware of any unresolved strategic cross-boundary matters
that would prevent the preferred strategy from being delivered. However, should it be proven that we
cannot deliver our strategy because of any reason later in the plan process, then we will need to talk with
our neighbours. We will continue to engage with all relevant organisations as we take the plan forward.”
Having reviewed the Duty to Cooperate Statement in detail, we identify that there is reference to the
potential implications of unmet employment needs under the Strategy ‘Strategic Topic’ (Appendix 4, pg.138
of the Statement) and the Councils’ discussion on 16th September 2020 as reported within the Statement. Of
note, during that discussion as a key point was reported the “need to explore the implications of emerging
Greater Cambridge economic evidence in relation to the CPIER”. At the same meeting, under the Transport
‘Strategic Topic’, it was also reported that “Employment land, linking to ideas about distribution hubs…” and
the need for this to be discussed at the next meeting.

Although it appears that the issue of accommodating unmet employment needs across the area was raised
within the context of this meeting, there is no further reference to this matter following that discussion. In
contrast, the First Proposals Statement of Common Ground states (at pg.7) that: “ Sufficient development
commitments and new sites exist to accommodate these growth levels within Greater Cambridge without
the need to request that one or more neighbouring authorities should assist under the duty to cooperate.”

As we discuss further below, in our view, at that stage the appropriate evidence on employment land needs
was not available in order to inform any meaningful discussion between Greater Cambridge Councils and
surrounding authorities in relation to meeting strategic employment needs.

We do expect that the Councils will need to update their evidence and undertake a further round of
discussions with the adjoining authorities to identify the appropriate levels of employment land across the
Plan period as part of Local Plan Regulations 19. Lack of a clear and agreed evidential basis in terms of both
informing and fulfilling the requirements of the Duty to Cooperate could represent a fundamental failing of
the emerging Local Plan. Accordingly, it is paramount that these issues be properly addressed at Local Plan
Regulation 19 Stage.