Keele neighbourhood plan proposal documents
Keele neighbourhood plan consultation statement (part 2 - responses to representations)
Responses to representations
This part of the statement summarises the representations made in response to the Regulation 14 consultations, together with the parish council’s response.
National and statutory bodies
Network Rail
Reference (policy or page): not applicable
Representation
Network Rail Ltd comments on neighbourhood plans.
Network Rail is a statutory consultee for any planning applications within 10 metres of relevant railway land (as the Rail Infrastructure Managers for the railway, set out in Article 16 of the Development Management Procedure Order) and for any development likely to result in a material increase in the volume or a material change in the character of traffic using a level crossing over a railway (as the Rail Network Operators, set out in Schedule 4 (J) of the Development Management Procedure Order).
Network Rail is also a statutory undertaker responsible for maintaining and operating the railway infrastructure and associated estate. It owns, operates and develops the main rail network. Network Rail aims to protect and enhance the railway infrastructure, therefore any proposed development which is in close proximity to the railway line or could potentially affect Network Rail’s specific land interests will need to be carefully considered.
Network Rail – railway specific advice notice to LPAs/Developers Please note that whilst Network Rail (NR) is submitting responses via the planning application process, it should be born in mind by the LPA/developer that the operational railway presents risks/issues that are different/unique to the risks posed by works taking place adjacent to non-railway undertaker land. Works on this site therefore must be undertaken with the supervision of NR via the ASPRO (asset protection) team to ensure that the works on site do not impact the safe operation, stability, integrity of the railway & its boundary. The LPA/developer are advised that unauthorised works adjacent to the railway boundary could impact the operation of nationally significant infrastructure & the applicant would be liable for any and all damages & costs caused by any works undertaken in this scenario. Therefore, the developer is requested to ensure that the development meets with NR requirements for works/developments adjacent to the railway boundary which include planning material considerations as well as obligations specific to the railway undertaker. The interface is via a NR BAPA (basic asset protection agreement) – the developer is advised that the works must not commence on site (even if planning permission is granted) until agreed with NR. The applicant will be liable for all costs incurred by NR in facilitating, reviewing this proposal.
Asset protection comments:
Developments in the policy area should be notified to Network Rail to ensure that:
(a) Access points / rights of way belonging to Network Rail are not impacted by developments within the area.
(b) That any proposal does not impact upon the railway infrastructure / Network Rail land e.g.
- drainage works/water features
- encroachment of land or air-space
- excavation works
- siting of structures/buildings less than 2m from the Network Rail boundary/Party Wall Act issues
- lighting impacting upon train drivers’ ability to perceive signals
- landscaping that could impact upon overhead lines or Network Rail boundary treatments
- any piling works
- any scaffolding works
- any public open spaces and proposals where minors and young children may be likely to use a site which could result in trespass upon the railway (which we would remind the council is a criminal offence under s55 British Transport Commission Act 1949)
- any use of crane or plant
- any fencing works
- any demolition works
- any hard standing areas
For any proposal adjacent to the railway, Network Rail would request that a developer constructs (at their own expense) a suitable steel palisade trespass proof fence of at least 1.8m in height.
All initial proposals and plans should be flagged up to the Network Rail Town Planning at the following address:
Email: TownPlanningNWC@networkrail.co.uk
Railway station - Consideration should be given in transport assessments to the potential for increased footfall at railway stations as a result of proposals for residential development/employment areas within the neighbourhood area. Location of the proposal, accessibility and density of the development, trip generation data should be considered in relation to the station. Where proposals are likely to increase footfall and the need for car parking, the council should include developer contributions (either via CIL, S106) to provide funding for enhancements as part of planning decisions.
Level crossings - Developments within the neighbourhood area should be accompanied by a TS/TA which includes consideration of the impact of proposals upon any level crossings with mitigation implemented as required. We would encourage the council to adopt specific policy wording to ensure that the impact of proposed new development (including cumulative impact) on the risk at existing level crossings is assessed by the developer(s), and suitable mitigation incorporated within the development proposals and funded by the developer(s). TS/TAs should be undertaken in conjunction with the local highways authority with advice from Network Rail. Contributions will be sought where proposals impact on level crossings to mitigate the impacts of those developments. Where level crossing closure is the only option, the applicant is advised that closure would be via s257 of the T&CPA, and that closure would be required before the occupation of any dwellings.
Network Rail - railway specific advice notice to LPAs/Developers. Please note that whilst Network Rail (NR) is submitting responses via the planning application process, it should be born in mind by the LPA/developer that the operational railway presents risks/issues that are different/unique to the risks posed by works taking place adjacent to non-railway undertaker land. Works on this site therefore must be undertaken with the supervision of NR via the ASPRO (asset protection) team to ensure that the works on site do not impact the safe operation, stability, integrity of the railway & its boundary. The LPA/developer are advised that unauthorised works adjacent to the railway boundary could impact the operation of nationally significant infrastructure & the applicant would be liable for any and all damages & costs caused by any works undertaken in this scenario. Therefore, the developer is requested to ensure that the development meets with NR requirements for works/developments adjacent to the railway boundary which include planning material considerations as well as obligations specific to the railway undertaker. The interface is via a NR BAPA (basic asset protection agreement) – the developer is advised that the works must not commence on site (even if planning permission is granted) until agreed with NR. The applicant will be liable for all costs incurred by NR in facilitating, reviewing this proposal.
Response
Comment noted. Whilst there are no active railways in the parish, redundant assets e.g. railway tunnels are of relevance.
No reference is made to redundant assets in the representation but we are aware that development close to or above the site of old tunnels remains a matter which requires Network Rail to be notified.
Action: Issue brought to the attention of Newcastle-under-Lyme Borough Council
Historic England
Reference (policy or page): KNP-5, KNP-6, KNP-7
Representation
The area covered by your neighbourhood plan includes a number of important designated heritage assets. In line with national planning policy, it will be important that the strategy for this area safeguards those elements which contribute to the significance of these assets so that they can be enjoyed by future generations of the area.
If you have not already done so, we would recommend that you speak to the planning and conservation team at your local planning authority together with the staff at the county council archaeological advisory service who look after the historic environment record. They should be able to provide details of the designated heritage assets in the area together with locally-important buildings, archaeological remains and landscapes. Some historic environment records may also be available on-line via the Heritage Gateway. It may also be useful to involve local voluntary groups such as the local Civic Society or local historic groups in the production of your neighbourhood plan.
Historic England has produced advice which your community might find helpful in helping to identify what it is about your area which makes it distinctive and how you might go about ensuring that the character of the area is retained.
You may also find the advice in “Planning for the Environment at the Neighbourhood Level” useful. This has been produced by Historic England, Natural England, the Environment Agency and the Forestry Commission. As well as giving ideas on how you might improve your local environment, it also contains some useful further sources of information. This can be downloaded from the national archives:
Response
This appears to be generic guidance for those embarking on neighbourhood plans rather than a response to the specific policies of this neighbourhood plan.
A heritage and character assessment formed part of the evidence base for developing policies.
No change necessary.
Environment Agency
Reference (policy or page): KNP3 and to a limited degree KNP 2 and 12
Representation
Newcastle Under Lyme Level 2 Strategic Flood Risk Assessment (SFRA), March 2025, provides assessment of potential site allocations within the Newcastle-under-Lyme. Some of those sites fall within the NP boundary. Additionally, it is important that the NP within the area offers a robust confirmation that development is not impacted by flooding and that there is sufficient wastewater infrastructure in place to accommodate growth for the duration of the plan period.
We refer you to the Water Cycle Study Phase 2 July 2024 report undertaken as evidence to support the local plan.
We note the site falls across three Water Framework Directive (WFD) catchments. One of these includes the Checkley Brook - Upper Water Body which is currently afforded ‘good’ ecological status. The second area includes Park Brook Catchment (tributary of Trent) Water Body which is currently afforded ‘moderate’ ecological status. The third catchment is Meece Brook from Source to Chatcull Brook Water Body which is classed at ‘poor’ ecological status.
Local WFD catchment data can be obtained from: River Basin Catchment Data Explore Site Allocation: There are no strategic site allocations for housing in the NP. However, there is a strategic site allocation relating to Keele University and Science Park (allocation E8 employment development). The NP includes Policy: E8 employment development. It is not clear on the exact boundaries, but we assume this is site 1 as shown in Figure 2: Key Employment Sites. Based on our Flood Map for Planning, the site is entirely within Flood Zone 1, the low-risk zone.
We note there is an unnamed ordinary watercourse to the southeast of the site (site 1 on Figure 2) which flows to that direction and it falls outside of the development boundary. This ordinary watercourse is un-modelled based on the scale and nature of the stream and receiving catchment (less than 3km2). It should be noted that the Flood Map provides an indication of ‘fluvial’ flood risk only. You are advised to discuss matters relating to surface water (pluvial) flooding with the Councils drainage team as the Lead Local Flood Authority (LLFA). It is noted that pluvial flooding has been considered within the draft ND plan although there is no reference to fluvial flood risk matters.
Based on our records, there are three radioactive substance regulation points within the E8 employment development site. They could be material in the ground, or it could be storage as part of the university science park. Any planning application should assess such material or similar material within the ground. You are advised to utilise the Environment Agency guidance (attached) which should assist you moving forward with your plan.
We would not offer detailed bespoke advice on policy but advise that you ensure conformity with the adopted core strategy and, in consideration of the emerging Newcastle-under-Lyme local plan, during plan reviews.
Response
Comment noted.
Sentence on flood risk added to evidence chapter. Policy ‘KNP-5 Sustainable design and character’ amended to make reference to impacts of surface water run-off.
Reference also added in the evidence section of the plan in a new section ‘Other factors’.
Policy updated to remove risk of unintended consequences and incompatibility with green belt policy.
This would be a matter for NuLBC as part of the development management process.
The basic conditions have been amended.
The Coal Authority
Reference (policy or page): not applicable
Representation
Re: Keele parish neighbourhood plan
Thank you for your notification of 13 February 2026 seeking the views of the Coal Authority on the above.
The Coal Authority is a non-departmental public body sponsored by the Department for Energy Security and Net Zero. As a statutory consultee, the Coal Authority has a duty to respond to planning applications and development plans in order to protect the public and the environment in mining areas.
Our records indicate that within the Keele Parish neighbourhood plan area there are recorded coal mining features present at surface and shallow depth including: mine entries, coal workings and reported surface hazards. These features may pose a potential risk to surface stability and public safety.
It does not appear that the neighbourhood plan proposes to allocate any new sites for development and on this basis we have no specific comments to make.
Response
Comments noted.
Reference added to coal mining features in the neighbourhood area in the evidence section of the plan in a new section ‘Other factors’.
Sport England
Reference (policy or page): KNP 10
Representation
Government planning policy, within the National Planning Policy Framework (NPPF), identifies how the planning system can play an important role in facilitating social interaction and creating healthy, inclusive communities. Encouraging communities to become more physically active through walking, cycling, informal recreation and formal sport plays an important part in this process. Providing enough sports facilities of the right quality and type in the right places is vital to achieving this aim. This means that positive planning for sport, protection from the unnecessary loss of sports facilities, along with an integrated approach to providing new housing and employment land with community facilities is important.
Therefore, it is essential that the neighbourhood plan reflects and complies with national planning policy for sport as set out in the NPPF with particular reference to Pars 103 and 104. It is also important to be aware of Sport England’s statutory consultee role in protecting playing fields and the presumption against the loss of playing field land. Sport England’s playing fields policy is set out in our playing fields policy and guidance page.
Sport England provides guidance on developing planning policy for sport and further information can be found via the link below. Vital to the development and implementation of planning policy is the evidence base on which it is founded.
Sport England works with local authorities to ensure their local plan is underpinned by robust and up to date evidence. In line with Par 104 of the NPPF, this takes the form of assessments of need and strategies for indoor and outdoor sports facilities. A neighbourhood planning body should look to see if the relevant local authority has prepared a playing pitch strategy or other indoor/outdoor sports facility strategy. If it has then this could provide useful evidence for the neighbourhood plan and save the neighbourhood planning body time and resources gathering their own evidence. It is important that a neighbourhood plan reflects the recommendations and actions set out in any such strategies, including those which may specifically relate to the neighbourhood area, and that any local investment opportunities, such as the Community Infrastructure Levy, are utilised to support their delivery.
Where such evidence does not already exist then relevant planning policies in a neighbourhood plan should be based on a proportionate assessment of the need for sporting provision in its area. Developed in consultation with the local sporting and wider community any assessment should be used to provide key recommendations and deliverable actions. These should set out what provision is required to ensure the current and future needs of the community for sport can be met and, in turn, be able to support the development and implementation of planning policies. Sport England’s guidance on assessing needs may help with such work.
http://www.sportengland.org/planningtoolsandguidance
If new or improved sports facilities are proposed Sport England recommend you ensure they are fit for purpose and designed in accordance with our design guidance notes.
Any new housing developments will generate additional demand for sport. If existing sports facilities do not have the capacity to absorb the additional demand, then planning policies should look to ensure that new sports facilities, or improvements to existing sports facilities, are secured and delivered. Proposed actions to meet the demand should accord with any approved local plan or neighbourhood plan policy for social infrastructure, along with priorities resulting from any assessment of need, or set out in any playing pitch or other indoor and/or outdoor sports facility strategy that the local authority has in place.
In line with the government’s NPPF (including section 8) and its planning practice guidance (health and wellbeing section), consideration should also be given to how any new development, especially for new housing, will provide opportunities for people to lead healthy lifestyles and create healthy communities. Sport England’s active design guidance can be used to help with this when developing planning policies and developing or assessing individual proposals.
Active design, which includes a model planning policy, provides ten principles to help ensure the design and layout of development encourages and promotes participation in sport and physical activity. The guidance, and its accompanying checklist, could also be used at the evidence gathering stage of developing a neighbourhood plan to help undertake an assessment of how the design and layout of the area currently enables people to lead active lifestyles and what could be improved.
PPG Health and wellbeing section
Sport England’s active design guidance
Please note: this response relates to Sport England’s planning function only. It is not associated with our funding role or any grant application/award that may relate to the site.
If you need any further advice, please do not hesitate to contact Sport England.
Response
This appears to be generic guidance for those embarking on neighbourhood plans rather than a response to the specific policies of this neighbourhood plan.
The area of the neighbourhood plan benefits from extensive sporting facilities on the University campus, which are available to the public. Policy KNP4 deals with community facilities including sporting facilities. The interpretation to this policy has been amended to make reference to sports facilities on the Keele University campus.
Policy KNP10 designates local green space and policies KNP5 and KNP11 support active travel.
Staffordshire County Council (SCC)
Reference (policy or page): General comments KNP 8
Representation
Archaeology/historic environment
The positive approach outlined with regards to preserving and enhancing Keele’s heritage/historic environment in the draft neighbourhood plan is certainly welcome. The production of the draft has been informed by a detailed heritage and character assessment, which albeit was produced over eight years ago, provides a strong baseline for the development of robust heritage-related policies. Indeed, an appreciation of the parish’s historic environment, its significance and potential, is woven like a thread through the draft plan. This reflects the recognition of the importance of the role of the parish’s historic environment to the local community during the community and stakeholder engagement activities. The inclusion of heritage-specific/adjacent policies, such as KNP-5. 6, 7, 8 & 9 are welcome, as is the approach to highlighting in many of the other policies that support would be provided for developments that did not have significant adverse impacts on the historic or rural character of the area. There is necessarily, given their landscape scale and national significance, a heavy weighting in the draft plan policies towards the conservation areas and registered park and garden (KNP6 & 7), whilst KNP8 acknowledges the important role that historic field patterns and traditional stone walls play in contributing to the character of the parish. However, whilst historic farmsteads are mentioned in the design and heritage section of the draft (Page 13) there is no specific consideration of these, or indeed other heritage assets in the area, such as below ground archaeology (e.g. the Staffordshire Historic Environment Record shows that plan area includes a possible Roman road, the earthwork remains of medieval field systems, and historic mineral railway remains) in any of the policies. It is suggested that this could be remedied by mentioning and considering these in KNP-8 and its associated interpretation. For reference, some useful inspiration for including non-designated heritage assets, historic farmsteads and archaeology, can be found in the Whittington and Fisherwick neighbourhood plan.
SCC’s Historic Environment Team would be more than happy to discuss our comments further with the parish council in due course. We assume that they have also consulted Historic England and NuLBC’s Conservation Officer on the draft plan too. If not, it is recommended that they do so.
Staffordshire County Council adopted a new local transport plan (LTP) in January 2026 which is supported by the Bus service improvement plan (BSIP) and local cycling and walking infrastructure plan (LCWIP).
Suggest that the definition of active travel is expanded to include wheeling - walking, wheeling and cycling.
Policy wording for the following allocations in Newcastle’s emerging local plan provides details of the transport improvements needed: SP11, KL13, KL15 and TB19.
It is noted that section 5.1 contains a list of infrastructure priorities. S106 contributions can only be sought from development where they meet the tests set out in Regulation 122 of the CIL regulations. Maintenance and repair of existing issues would generally not meet these tests. S106 contributions can also only be collected for matters directly related to the development under consideration.
Response
Comments noted.
Policy KNP8 amended through the addition of a historic farmstead clause.
Below ground archaeology is already dealt with in national policy and guidance and local plan policy, so it is unnecessary to repeat this. Reference added to below ground archaeology and listed features in the representation to the heritage section of the evidence chapter to the plan.
Reference to SCC's plans added to the evidence chapter of the plan.
Active travel definition expanded to include ‘wheeling’.
Wording updated to read ‘planning infrastructure monies’.
Reference to public access or footpaths moved to Policy KNP11 and has been expanded.
Reference to Active Travel Infrastructure should be designed according to Local Transport Note LTN1/20 added to interpretation.
Policy KNP8, clause 2 already refers to woodlands in general not just ancient woodlands.
Interpretation amended to make reference to the interactive DEFRA Magic Map for latest information on landscape designations.
Policy KNP11 clause1 amended to include reference to transport improvements to mitigate their impact.
National Gas Transmission
Reference (policy or page): General comments
Representation
National Gas Transmission has appointed Avison Young to review and respond to neighbourhood plan consultations on its behalf. We are instructed by our client to submit the following representation with regard to the current consultation on the document.
About National Gas Transmission: National Gas Transmission owns and operates the high-pressure gas transmission system across the UK. In the UK, gas leaves the transmission system and enters the UK’s four gas distribution networks where pressure is reduced for public use.
Proposed sites crossed or in close proximity to National Gas Transmission assets: An assessment has been carried out with respect to National Gas Transmission’s assets which include high-pressure gas pipelines and other infrastructure.
National Gas Transmission has identified that it has no record of such assets within the neighbourhood plan area.
National Gas Transmission provides information in relation to its assets on our website.
Please also see attached information outlining guidance on development close to National Gas Transmission infrastructure.
Distribution networks: Information regarding the gas distribution network is available by contacting: plantprotection@cadentgas.com
Further advice: Please remember to consult National Gas Transmission on any neighbourhood plan documents or site-specific proposals that could affect our assets.
Response
Comments noted.
Natural England
Reference (policy or page): KNP 8
Representation
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development. Natural England is a statutory consultee in neighbourhood planning and must be consulted on draft neighbourhood development plans by the parish/town councils or neighbourhood forums where they consider our interests would be affected by the proposals made.
Natural England does not have any specific comments on this draft neighbourhood plan.
However, we refer you to the attached annex which covers the issues and opportunities that should be considered when preparing a neighbourhood plan and to the following information.
Natural England does not hold information on the location of significant populations of protected species, so is unable to advise whether this plan is likely to affect protected species to such an extent as to require a strategic environmental assessment. Further information on protected species and development is included in Natural England's standing advice on protected species.
Furthermore, Natural England does not routinely maintain locally specific data on all environmental assets. The plan may have environmental impacts on priority species and/or habitats, local wildlife sites, soils and best and most versatile agricultural land, or on local landscape character that may be sufficient to warrant a strategic environmental assessment. Information on ancient woodland, ancient and veteran trees is set out in Natural England/Forestry Commission standing advice.
We therefore recommend that advice is sought from your ecological, landscape and soils advisers, local record centre, recording society or wildlife body on the local soils, best and most versatile agricultural land, landscape, geodiversity and biodiversity receptors that may be affected by the plan before determining whether a strategic environmental assessment is necessary.
Natural England reserves the right to provide further advice on the environmental assessment of the plan. This includes any third party appeal against any screening decision you may make. If a strategic environmental assessment is required, Natural England must be consulted at the scoping and environmental report stages.
Response
Comment noted.
National Highways
Reference (policy or page): KNP 11
Representation
Thank you for providing National Highways with the opportunity to consult on the draft neighbourhood plan for Keele Parish Council.
National Highways (formally Highways England) has been appointed by the Secretary of State for Transport as a strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the Strategic Road Network (SRN). It is our role to maintain the safe and efficient operation of the SRN whilst acting as a delivery partner to national economic growth.
In responding to development plan consultations, we have regard to DfT Circular 01/2022: The Strategic Road Network and the Delivery of Sustainable Development (‘the Circular’). This sets out how interactions with the Strategic Road Network should be considered in the making of plans and development management considerations. In addition to the Circular, the response set out below is also in accordance with the National Planning Policy Framework (NPPF) and other relevant policies.
The SRN closest to the NDP area is the M6 Motorway.
We have considered the contents of the draft neighbourhood plan and as the plan does not introduce any new development sites or transport related policies that are likely to impact upon our network, we consider that the contents of the plan are for local determination, and we have no other comments to make.
Response
Comment noted.
Keele University
Keele University comprises a single campus site, close to Newcastle under Lyme. The campus offers a unique working, living and learning environment from which it delivers world class education and research, as well as supporting a range of commercial businesses within the Innovation Park.
However, the University is operating in an increasing competitive environment where learning buildings, student experience facilities and public ream play a key role in recruitment and retention. The university must continue to evolve to maintain credibility, improve the environmental performance of the estate, and ensure that the large areas of open space and numerous heritage assets of which the university are custodians, are maintained.
Keele University’s strategic vision ‘Our Future’ aims for the university to continue to grow as a research-led institution recognised for excellence in education, research and enterprise. The campus is a key asset for the university and a fundamental reason why staff, students and commercial business choose the University.
The university is developing a capital investment plan (CIP) to provide a fit for purpose, environmentally and financially sustainable campus in the long term. It is important that the emerging Newcastle Under Lyme local plan and this draft neighbourhood plan supports the objectives of the CIP, to achieve the borough’s wider economic, social and environmental objectives.
Current planning policy context
The saved policies of the Newcastle Under Lyme Local Plan 2011 and associated Policy Map identify a large area of the campus as an ‘inset area’, outside of the designated Green Belt, though not benefitting from any specific allocation or associated policies.
The adopted plan did identify land to the east of the campus under policy E8 (Keele University and Keele Science Park) including specific reference to education-related academic, employment and student housing uses considered to be acceptable in that area.
These designations and associated policies are expected to be superseded in the coming months by the adoption of the emerging Newcastle Under Lyme local plan, which is currently in the latter stages of examination in public.
The draft policy map accompanying the emerging local plan, identifies both Keele village and developed areas of the Keele University Campus, as areas outside of the surrounding green belt. Additionally, site allocation KL13 replaces former local plan area E8, and KL15 to the east is introduced to form new mixed use areas of the wider University campus.
The neighbourhood plan should reflect the emerging designations and support the associated policies to ensure conformity with the final version of the local plan in accordance with the basic conditions as set out in paragraph 8(2) of schedule 4B of the Town and Country Planning Act 1990.
KNP 1/2: In order for a neighbourhood plan to be made, it must meet a set of basic conditions. The basic conditions are set out in paragraph 8(2) of Schedule 4B to the Town and Country Planning Act 1990 as applied to neighbourhood plans by section 38A of the Planning and Compulsory Purchase Act 2004. The basic conditions are:
a) having regard to national policies and advice contained in guidance issued by the Secretary of State, it is appropriate to make the order (or neighbourhood plan).
b) having special regard to the desirability of preserving any listed building or its setting or any features of special architectural or historic interest that it possesses, it is appropriate to make the order. This applies only to orders.
c) having special regard to the desirability of preserving or enhancing the character or appearance of any conservation area, it is appropriate to make the order. This applies only to orders.
d) the making of the order (or neighbourhood plan) contributes to the achievement of sustainable development.
e) the making of the order (or neighbourhood plan) is in general conformity with the strategic policies contained in the development plan for the area of the authority (or any part of that area).
f) the making of the order (or neighbourhood plan) does not breach and is otherwise compatible with EU obligations.
g) prescribed conditions are met in relation to the Order (or plan) and prescribed matters have been complied with in connection with the proposal for the order (or neighbourhood plan).
The following detailed representations respond to the Regulation 14 neighbourhood plan consultation within the context of the above conditions.
The strategic objectives
The university is broadly supportive of the objectives and ambitions of the neighbourhood plan, particularly where these seek to protect the character of Keele, enhance green infrastructure and environmental quality, and support sustainable development.
The university is committed to working collaboratively with local stakeholders to deliver these shared objectives alongside its own long-term investment strategy.
The draft neighbourhood plan at page 11 (first paragraph) currently states that there are no strategic housing allocations within the area.
This position is now out of date and it is recommended that the plan be amended to reflect the emerging Newcastle-under-Lyme local plan, which is progressing through examination in public and identifies Site allocation KL13, and KL15, which includes an element of housing associated with the university.
A significant proportion of the evidence base referenced within the neighbourhood plan dates from 2017 or earlier. Given the scale of change in planning policy, environmental requirements and local development pressures since that time, it is essential that the evidence base is reviewed and updated.
It is recommended that the neighbourhood plan should also be updated to ensure that all policies are consistent with the development plan, in order to ensure conformity in line with the basic conditions and to ensure that the plan remain effective in the medium to long term.
KNP 8: The university supports the overarching aims of policy KNP8 in enhancing biodiversity and environmental quality.
However, as currently drafted, the policy is overly prescriptive and does not adequately reflect the guidance within the NPPF and the policies within the emerging local plan.
In particular, point 4 of KNP8 appears to require a level of biodiversity net gain (BNG) provision that exceeds the provision required through national policy and the local plan. The required provision of 20% BNG has not been tested from a viability perspective and risks making proposals unviable.
Other elements of the draft policy risk duplicating or conflicting with environmental legislation, which is outside of the planning system.
It is recommended that policy KNP8 is amended to align with national BNG requirements, avoid unnecessary duplication of legislative controls; and ensure flexibility in delivery.
The emerging local plan identifies the delivery of a new link road between the KL13 allocation and TB19 as a strategic piece of infrastructure intended to support planned growth, improve network resilience and address existing and future traffic pressures. The principle of the link road is to provide a north to south route, from Keele Road towards the A53 to support traffic and enhance public transport flows through this part of the district.
This infrastructure is of strategic importance and will deliver a range of benefits, including improved connectivity, enhanced public transport accessibility to Keele Village, and wider sustainability benefits in reducing congestion and supporting modal shift. Thus, supporting the objectives of the neighbourhood plan.
It is necessary to update the neighbourhood plan to reflect this aspiration and ensure the delivery of the link road does not conflict with the plan. It is therefore recommended that figure 5 of the draft plan, and other elements of the plan where relevant should be updated to reflect the aspirations for a new strategic link road through the Keele University campus and land to the south adjacent to the A53. This will support the sustainable infrastructure aspirations of both the neighbourhood plan and emerging local plan.
KNP 9: The university supports the overarching intention of policy KNP9 to protect and enhance landscape character. However, it is considered that part 2 of the policy must be supported by robust and proportionate landscape evidence to justify the approach to limiting development in these areas.
Furthermore, the policy should incorporate a clear and proportionate mechanism through which development proposals can be supported where justified, having regard to site-specific circumstances and wider sustainability considerations.
In its current form, the policy risks being overly restrictive and may not fully align with the presumption in favour of sustainable development set out in the National Planning Policy Framework.
It is recommended that policy KNP9 is revised to ensure it is evidence-based, sufficiently flexible, and consistent with national policy, enabling appropriate development where justified.
KNP 10: The status and intended function of proposed green space designations should be clarified, to ensure consistency and clarity in line with similar designations in the emerging local plan. The current policy wording suggests that the designation is “similar to green belt but not the same”, which introduces ambiguity and risks confusion in interpretation and application.
This terminology is also inconsistent with established national policy definitions and may lead to uncertainty in decision-making.
We recommend that reference to the designation being “similar to green belt” is removed, and that the policy is amended to provide clear and consistent terminology aligned with national policy, ensuring clarity and effectiveness.
KNP 12: The university strongly supports the positive aspirations of the policy relating to the campus and its recognition within the neighbourhood plan.
However, it is essential that the policy clearly supports the implementation of the university’s estates masterplan and facilitates the continued evolution and investment in the campus. In this regard and in order to ensure consistency between key documents, we recommend that references to the ‘University Masterplan’ should be updated to the ‘most recent masterplan document’, reflecting its iterative and evolving nature.
In addition, supporting text indicating that the policy “does not encourage stylistic imitation” should be removed, as it is unnecessarily prescriptive and may constrain high-quality and innovative design responses.
This is to ensure that the policy should provide a clear, flexible, and unambiguous framework that supports growth and investment consistent with the University’s strategic role.
Figure 8: As per similar comments above, we recommend that Figure 8 be updated to accurately reflect local plan allocations KL13 and KL15 and to confirm correct site boundaries.
This is necessary to ensure consistency with the emerging development plan and to provide clarity for decision-makers and applicants.
Section 4 green guidance note: The draft neighbourhood plan contains a section entitled ‘green guidance note’. Beyond the broadly understood aspiration principles, which are understood, it is unclear what the intended status or application of the guidance is intended to be.
We recommend that an introductory paragraph is added to provide context to this guidance and that this guidance, if it remains in the documents is cross-referenced to specific policies within the neighbourhood plan.
This will assist in clarifying the weight to be applied to this guidance in decision-making and ensure that the plan is effective in practice.
The content should also be reviewed to ensure alignment with the National Planning Policy Framework and the emerging local plan.
Furthermore, we recommend that the reference to “small wind turbines” is clearly defined within the plan.
Without a clear definition, there is potential for ambiguity and inconsistent interpretation in decision-making.
Section 5.1 Infrastructure projects: Similarly to section 4 above, the status of this guidance section is unclear.
Specifically, the list of infrastructure projects should be clearly justified and should be fairly and reasonably related to development, in accordance with relevant policy and legal tests for planning obligations.
The plan should also recognise the importance of continued investment in the Keele University campus, including its role as a major local employer and its contribution to the wider community.
It is recommended that Section 5.1 is reviewed to ensure that infrastructure requirements are appropriately justified, proportionate, and reflective of the strategic role of the university within the area.
Conclusions: This representation has been prepared by nineteen47 on behalf of Keele University in response to Keele neighbourhood plan (Regulation 14) consultation.
Keele University is a key stakeholder in Newcastle-under-Lyme and the wider region. The university is committed to working proactively with the neighbourhood plan group to establish a comprehensive approach to the university’s estate strategy.
Subject to the recommended amendments, it is considered that the neighbourhood plan can provide a sound and effective part of the development plan for guiding development in Keele.
The university remains committed to ongoing engagement with the parish council and other stakeholders as the plan progresses.
The comments set out in this representation are intended to:
- ensure alignment with the emerging local plan
- improve clarity and effectiveness of policies and
- support the continued growth and investment of the university
Response
Comments noted. The map that accompanies Policy KNP12 is taken from the Keele University’s published masterplan. Throughout the process, the parish council has contacted Keele University and asked if there are more up to date versions of the map.
The representation indicates a lack of awareness that there was extensive liaison with Keele University Estates Team in developing the policy wording.
KNP 1/2: Parish Council is aware of the legal requirements for neighbourhood plans, including the recent changes to the basic conditions.
Keele University did work closely with the Parish Council, especially the at earlier stages.
This emerging local plan is still at examination stage, so the strategic site allocations cannot be assumed. However, the section on the emerging local plan (2.4) already makes reference to strategic site allocations and has been updated and could be updated again at the examination stage if necessary.
KNP 8: Comments noted.
The biodiversity clause has been carefully worded and has taken account of national policy and guidance. Similar clauses in other neighbourhood plans have been accepted at the examination stage.
The policy has had regard to national policy and guidance and deals with material planning considerations only.
If the emerging local plan is adopted before the examination, changes can be made to the policies and evidence chapters where necessary.
NuLBC could amend the maps at the examination stage, depending on the progress of the emerging local plan.
KNP 9: Policy KNP9, clause 1 amended to refer to significant adverse impacts. The policy has taken account of national policy and guidance and is evidence-based including the AECOM heritage and Character assessment, which was provided by the national programme.
KNP 10: Interpretation to policy wording amended for clarity.
KNP 12: Comments noted. The map that accompanies policy KNP12 is taken from the Keele University’s published masterplan. Throughout the process, the parish council has contacted Keele University and asked if there are more up to date versions of the map.
The wording is the exact opposite of what is being suggested here. Interpretation to policy amended to refer to innovation.
Figure 8: Comments noted. Throughout the process, the parish council has contacted Keele University and asked if there are more up to date versions of the map.
Action: Asked Keele University for latest version of the map to be replaced in the plan. No response received.
Section 4 green guidance note: Purpose added to the ‘green guidance note’, for clarity and headings amended.
Section 5.1 Infrastructure projects: Wording amended to refer to planning infrastructure monies.
Conclusions: Comments noted. The parish council has worked closely with Keele University and continues to do so.