This chapter focuses on the particular issue of the relationship between strategic planning and statutory planning, and sets this within wider consideration of the nature of strategic planning and how strategic planning deals with uncertainty in a multi-level governance situation. It uses two case studies from Australia to develop several propositions about the relationship between spatial strategic planning and statutory authority. While strategic planning is conceptually distinct from statutory planning (see Chapter 1, this volume), in practice the two can overlap, as in one of the case studies here. Comparison of that case study with another involving a more typical non-statutory strategic plan allows for a more nuanced analysis of the statutory-strategic planning relationship.