Keele neighbourhood plan representations

Date: 28 September 2026

Dear Sir / Madam

Introduction

United Utilities Water Limited (UUW) welcomes the opportunity to comment on the Submission Version of the Keele Neighbourhood Plan.

UUW is the not the statutory water and wastewater undertaker for all of the area. As such, consultation should take place with other water and wastewater undertakers. As a statutory undertaker, UUW has an interest in ensuring that growth is planned and delivered in a sustainable manner, supported by appropriate infrastructure and effective water management.

UUW previously submitted representations at the Regulation 14 stage and welcomes the positive engagement that has taken place through preparation of the Neighbourhood Plan.

Overall, UUW supports the objectives of the plan and considers that the Submission Version has responded positively to many of the matters raised through our earlier consultation response.

General Comments

UUW welcomes the stronger emphasis placed upon sustainable development, green infrastructure, climate resilience and sustainable water management in the plan. In particular, UUW welcomes:

• the integration of sustainable surface water management within landscape design

• references to sustainable drainage and rainwater reuse within the Green Guidance Note

• greater recognition of utility infrastructure constraints and

• clarification that policy provisions relating to the landscape setting of Keele are not intended to prevent necessary works associated with the existing wastewater pumping station

These amendments represent a positive response to issues raised by UUW during the Regulation 14 consultation.

Design Code

UUW notes that the Regulation 14 consultation was accompanied by a Design Code document on which detailed comments were submitted. No updated Design Code appears to accompany the Regulation 16 consultation material. It is therefore unclear whether the Design Code has been withdrawn, superseded, incorporated within the Neighbourhood Plan itself or is intended to be progressed separately.

If a Design Code is intended to form part of the final planning framework for the parish, UUW would welcome the opportunity to review any subsequent version to ensure that matters relating to utility infrastructure and sustainable water management continue to be appropriately reflected.

Policy KNP-5: Design Principles

UUW supports the revised policy approach and in particular welcomes the requirement for landscape design and green infrastructure to be integrated with sustainable surface water management. This reflects good placemaking practice and helps ensure that drainage infrastructure can contribute towards wider environmental and landscape objectives. To further support this approach, UUW recommends that consideration is given to including a simple reference to the National Standards for Sustainable Drainage Systems (or any successor standards).

Our recommended wording is:

Sustainable drainage features should be incorporated within development proposals where appropriate and designed in accordance with the National Standards for Sustainable Drainage Systems (or any successor standards), ensuring integration with landscape design and green infrastructure.

UUW considers that this modest amendment would reinforce the delivery of high-quality sustainable drainage whilst avoiding duplication of national and local planning policy requirements.

Green Guidance Note

UUW welcomes the inclusion of guidance relating to:

• rainwater capture and reuse

• permeable materials

• sustainable drainage measures and

• integration of drainage and landscape design

These measures support climate resilience and sustainable water management objectives and are supported by UUW.

Policy KNP-9: Landscape Setting and Prevention of Coalescence

UUW welcomes the clarification that the policy is not intended to prevent works associated with the existing wastewater pumping station. This amendment appropriately recognises the need for maintenance, improvement and upgrading of essential utility infrastructure and addresses a matter raised by UUW at Regulation 14 stage. UUW therefore supports the revised policy approach.

Utility Infrastructure

UUW welcomes the improved recognition of utility infrastructure considerations within the supporting text. Early engagement with infrastructure providers remains an important part of the development process and assists in ensuring that proposals are deliverable and that site layouts appropriately account for existing infrastructure constraints. UUW therefore encourages continued engagement with statutory undertakers where development proposals may affect existing utility assets.

Conclusion

UUW supports the overall objectives of the Keele Neighbourhood Plan and welcomes the positive amendments made since the Regulation 14 consultation. The Submission Version has addressed many of the matters previously raised by UUW, particularly in relation to:

• sustainable water management

• integration of drainage and landscape design

• recognition of utility infrastructure constraints and

• flexibility for future works associated with existing wastewater infrastructure

UUW's remaining comments are limited and relate principally to:

• clarification regarding the status of the Design Code and

• inclusion of a simple reference to the National Standards for Sustainable Drainage Systems within Policy KNP-5

Subject to these minor amendments and clarifications, UUW supports the Submission Version of the Keele Neighbourhood Plan.

If you have any queries or would like to discuss this representation, please do not hesitate to contact me.

Yours faithfully

Andrew Leyssens MRTPI

Asset Management

United Utilities Water Limited