Keele neighbourhood plan representations

From:    Hannah Barter

Date:    10 September 2026

Hello All,

The supplementary note should be considered as a Keele Parish Council representation to the Regulation-16 consultation to support the examiner in any suggested modifications and for clarity.

Hopefully this will cover any matters relating to the Basic Conditions changes. Hope everyone is well.

Speak soon Han

Hi Noel

Thanks for confirming safe receipt of the supplementary note. I have known issues with regard to your proposals for the protocol regarding the note. I have copied Hannah Barter into this reply in case she has anything to add.

We do not wish to revisit our Neighbourhood Plan based on the new national policy proposals as it is our understanding that there is no statutory need to do so.

Many thanks for all your hard work on reg 16, it has been a pleasure working with you and Alan.

Regards

Changes to the Basic Conditions and other legal requirements Supplementary Note

Introduction

The Keele Neighbourhood Plan submission was accompanied by a Basic Conditions Statement, which referred to changes being made to the Basic Conditions and other legal requirements for neighbourhood plans.

These changes have occurred, so this note describes how the Keele Neighbourhood Plan meets the new requirements.

The basic conditions that neighbourhood plans must now meet are summarised as follows (new requirements in bold):

• must contribute to the achievement of sustainable development

• must have regard to national policy and guidance

• must not deliver less housing development

• must be comparable with EU obligations

Regulations specify an additional basic condition that a plan does not breach the requirements of Chapter 8 of Part 6 of the Conservation of Habitats and Species Regulations 2017, which set out the habitat regulation assessment process for land use plans, including consideration of the effect on habitat sites.

In addition, the plan:

• must meet requirements of human rights law

• address climate change and Mitigation

• take account of any Local Nature Recovery Strategy

The Basic Condition relating to general conformity with strategic local policies no longer applies.

Housing

In terms of housing delivery, the polices would have the following implications.

The Keele Neighbourhood Plan enables housing development and would not lead to any reduction in housing delivery.

Local Nature Recovery Strategy

The Staffordshire and Stoke-On-Trent Local Nature Recovery Strategy applies to Keele. This was subject to consultation in Summer 2026. It should be adopted shortly.

Although not yet adopted, there is already a high level of correlation between the draft Local Nature Recovery Strategy and the policies of the Neighbourhood Plan.

Reference to the LNRS could be added to the rationales in 2.5 of the Neighbourhood Plan. Reference could also be made in the interpretation to Policy KNP8. This policy already addresses biodiversity and habitats. A requirement to have regard to the Local Nature Recovery Strategy could be added into the policy.

Climate Change and Mitigation

The submitted Neighbourhood Plan already addresses climate change in multiple ways. Planning aim one in 2.3 already refers to climate change. In addition, various policies have implications for climate change.

Reference to the Plan addressing climate change and Mitigation could be added to the rationales in 2.5 and to the introductory paragraph of the Green Guidance Note.