3.1 LPAs are bound by the statutory duty to co-operate under section 33A of the Planning and Compulsory Purchase Act 2004. This places a legal duty on LPAs to engage constructively, actively and on an ongoing basis during the preparation of plans. This engagement is required throughout the plan-making process and cannot be undertaken retrospectively.

3.2 To fulfil the duty to co-operate, the NPPF and the PPG require that a Statement of Common Ground is prepared identifying progress on addressing strategic cross-boundary matters throughout the plan-making process. This is acknowledged in paragraph 1.24 of the LPR.

3.3 However, no such Statement of Common Ground appears to have been prepared in support of the LPR and there is no evidence of any co-operation between relevant bodies. Accordingly, the LPR has not been prepared in accordance with the NPPF, the PPG or the Act.

3.4 It will therefore be necessary to engage with the appropriate bodies under the duty to co-operate and take this into account prior to drafting policies. This engagement cannot be undertaken now and retrospectively applied to the current draft policies as identified in the PPG (61-031). This is a significant issue for the LPR.