Keele neighbourhood plan representations

General Comments

The Council recognises that in accordance with Appendix A (specifically paragraph 6) of the latest version of the National Planning Policy Framework (NPPF), owing to Keele’s neighbourhood plan invoking these transitional arrangements having been submitted under Regulation 15 of the  Neighbourhood Planning (General) Regulations 2012 on or before the August 2026 publication date of the NPPF, it should be prepared in accordance with the NPPF published in December 2024.

Appendix A also states: ‘For neighbourhood plans that have already been submitted, the qualifying body may choose to withdraw the plan and update it to take account of this Framework’. The Council on 19 August asked the qualifying body via e-mail if they would wish to pursue this course of action. This opportunity was declined (10 September) with the qualifying body wishing to progress to Examination based on the neighbourhood plan submitted on 12 June 2026.

Considering the comments above re: transitional arrangements, it is important to highlight that in its representation at the Reg. 14 consultation stage, the Council stated that the absence of formal residential allocations (to contribute to meeting the identified requirements) in Keele’s neighbourhood plan, then NPPF paragraph 14 could reduce the weight that could be afforded to the neighbourhood plan in decision-taking, once made.

The following comments should also be viewed through the prism of the wider changes to the planning system and legislation that have recently emerged, such as provisions of the Levelling Up and Regeneration Bill and the changes in basic conditions which came into force on 25 March 2026.

Accordingly, question marks were raised by the Council as to the assertion made in the submitted Basic Conditions statement – Section 2.3 – that suggested these changes would apply from January 2027. Constructive comments on this issue were provided to the appointed consultants working on behalf of the qualifying body, whose stance (18 June 2026) remained that they considered that the amended basic conditions had been addressed. Moreover, during the Reg 16 consultation (Friday 4 September) an addendum (representation KE26) was also provided by the qualifying body to the Basic Conditions statement which sought to further set out how the neighbourhood plan addresses the extant basic conditions and legal requirements.

It is also noteworthy that the Newcastle under Lyme Local Plan was adopted 8 July 2026, with significant allocations (KL13 & KL15) within the Parish established to facilitate the expansion of Keele University. As part of the Local Plan’s evidence base, a Green Belt Village Study was undertaken and in line with the conclusions reached Keele village has been inset from the green belt (having previously been washed over), with this change reflected in the adopted Local Plan’s Policies Map.

It is as well important to recognise that several of the points raised in the following were highlighted to the qualifying body at the Reg.14 stage.

For ease of future reference, the Council continue to advocate the use of paragraph numbers in modifying the format of the document.

The specific comments raised below are presented under the relevant Chapter/Section headings of the Neighbourhood Plan.

Introduction

Section 1.2 Status of the Plan

An explanation should be provided of the rationale behind the circa 10/9- year horizon (2025/Made date - 2035) being determined as most appropriate, noting that the adopted Local Plan is 2020-2040.

Section 1.3 Implementation, Monitoring and Review

The role of the Borough Council in the development management process should be highlighted in the second paragraph of this section.

The mechanisms and indicators for monitoring policy should be detailed & included as part of an appendix to the neighbourhood plan.

More detail could be provided on the steps taken to date in the neighbourhood plan’s production and the necessary stages still to be addressed before the neighbourhood plan can become made. This could be done either in succinct written form or a diagram.

Background

Section 2.2.1 Community Engagement Activities

Many of these events and engagements took place several years ago (predating the base date - 2025 - of the Neighbourhood Plan) and this may potentially bring into question their continued contemporary relevance. There’s also question marks as to some of the dates that are specified - for instance, the points in which the Regulation 14 consultation actually took place, with a six-week duration of 17 February 2026 to 31 March 2026 being understood by the Council, whereas reference is made to February to March 2021 in the bullet points. Nor does the submitted Consultation Statement make it clear.

Section 2.2.3 Issues Raised

The statement that ‘…since the initial questionnaire and consultation…’ further justifies the point made above at 2.2.1 in the prospective value in more up to date engagement in shaping the issues raised.

Could more explanation be provided as to how these issues raised have directly influenced the policy framework established in the neighbourhood plan?

Section 2.3 National Policy Context

Please see earlier comments re: the 2026 NPPF and the interpretation of Annex A: Implementation (specifically para 6), for the purposes of Keele’s neighbourhood plan examination.

Section 2.4 Local Policy Context

Whilst we recognised (as stated in our representation at the Reg.14 stage) that the neighbourhood plan was being prepared during a period in which a Borough-wide Local Plan was advancing (as at that stage in early 2026, post Examination hearings), but not yet adopted, the Council still strongly consider the interactions/correlations between both documents should be more clearly expressed. The Local Plan is now adopted which makes this more important.

The retention of references – the entirety of Section 2.4.1 – to the 2009 Core Strategy is now no longer relevant, as the 2009 Core Strategy has now been replaced by the Borough Local Plan (2020-2040).

A factual issue should be corrected as the vast majority of site SP11(2) Golf Course is not within the Parish of Keele (instead being in Silverdale Parish), so this reference within 2.4.2 should be removed or caveated accordingly.

On the now adopted Local Plan, allocations KL13 & KL15 relating to Keele University should be more fully explained in setting the context for their development and including them on the respective maps in the document.

Section 2.5: Evidence and Planning Rationale

Housing

Question marks are raised as to whether the August 2017 Housing Needs Assessment remains contemporary owing, for instance, to 2021 census data subsequently being available and changes in market conditions (for reasons such as tax & regulation changes) impacting on the private rented sector.

For commitments and completions, it would be useful to clarify the component sites (i.e. KL13 and KL15) in addressing the housing need balance (from 800). The disparities between the neighbourhood plan 2025-2035 and local plan 2020-40 time-horizon is significant in this context also, as the 800 figure relates to the 20-year period of the Local Plan, with the extant permissions and built homes figure - 588 - calculated from the Local Plan base date of 1 April 2020.

The sentence re: figures provided by NuLBC should be deleted and instead a source footnote provided to the two subsequent tables that follow.

Approved Applications

It should be made clear that the 1706 figure represents a gross figure (net 953), with a 1:2.5 ratio for student household occupancy equating to 406 in terms of its contribution to the 5-year housing land supply position.

Local Employment and Community Facilities

A definition should be provided as to what is meant by community facilities (or maybe refer to KNP-4 as detailing this), and the value afforded by the Parish’s connections and proximity to Newcastle-under-Lyme town centre.

Design and Heritage

The Government has published an updated Design Guide and this alongside other relevant and up to date documents should be referenced (with direct web-links and dates of publication) accordingly.

Cross referencing within the neighbourhood plan to other sections & policies, including the green guidance note – as mentioned in the third paragraph - is felt worthwhile as well.

Given its age, absolute confidence in the 2017 Heritage and Character Assessment should also be reached by the Examiner in determining the continued value today (all or in part) of its applicability to the neighbourhood plan (noting that production within the last two years is the typical benchmark for up-to-date evidence for Local Plans).

In the final paragraph, an overview of the national and local plan policies which relate to archaeology should be added.

Countryside and Environment

It is recommended that the Defra Magic Map is linked as a footnote to allow any interested parties to access this directly.

Keele University

The Council will defer to consultation comments received from the University (representation KE13) and how this is represented in the neighbourhood plan, including the appropriate referencing of the Estate Strategy and Masterplan. Nonetheless, how the neighbourhood plan accords with the Strategy and Masterplan is not apparent, with points raised previously (e.g. at Section 2.4) re: Local Plan allocations KL13 and KL15 relevant here also.

Other Factors

Flood zone 1 represents a low probability of flooding, so is the point that this is a positive for Keele Parish? As drafted, it is not clear of the text’s intent, with a need for further explanation on any flood-risks and their source e.g. surface water.

Are the issues of mining legacy and United Utilities approach to water and sewage infrastructure especially significant for Keele Parish, beyond that for other areas of the Borough? What do such constraints mean in spatial terms and the capacity for development to take place – this is not clear and should be clarified.

Neighbourhood Plan Aims and Policies

Section 3.1 Planning Aims

KNP-1 Residential Development

Does this suggest/is the policy’s intent that brownfield sites irrespective of them being infill would be supported in existing built areas – may the addition of ‘and/’ prior to ‘or’ address this? If further/amended text could also be added to the interpretation section to clarify this aspect that would be useful.

KNP-2 Residential Mix and Affordable Housing

No explanation is provided as to why the three or more dwelling threshold chosen and how it is justified?

How does the dwellings designed for people with limited mobility reference in point 1 align with and add value to the provisions of Local Plan policy HOU3: Housing Standards?

Within the Interpretation text, the comment that ‘…one or two bedroom units should form the largest part of the mix’ does not tally with para 6.17 of the Local Plan. Regard should also be had to para 6.19 of the Local Plan in modifying this text as appropriate.

The Council considers that the perceived risk of ‘…inferior specification’, is adequately mitigated within Local Plan policy, including HOU3, and nationally set building regulations. Also, the terminology used – ‘inferior’ – in the Interpretation is different to that for part 2 of KNP-2 - ‘similar’., which if retained as is would bring challenges in the policy’s implementation.

Significantly, due regard should be had to para 6.5 of the Local Plan which addresses the issue of on and off-site affordable housing contributions and the exceptional circumstances in which the latter approach would be advocated. Policy HOU1 also states the 10 dwelling/0.5ha threshold for affordable housing which is at variance to the three dwelling figure stated in KNP-2.

KNP-3 Employment

To avoid any unintended consequences that may prejudice the existing operations – listed in Point 1 of KNP-3 - clarity should be provided on their existing uses (in use class terms) and if any change of use permission would likely be required to realise Use Class E development in these locations.

Notwithstanding this, the Council would wish to safeguard these existing businesses and to provide assurance that the neighbourhood plan is not intended in any way to hasten their redevelopment unless the businesses themselves decide to pursue this course of action. Should this policy extend therefore to the preservation of the existing uses in these localities and where potentially in time to come for reasons of no longer being suitable or viable, other uses may be appropriate?

The nature and operation of the University is quite distinct from those other locations listed, so it is considered appropriate that its reference here be removed and deferred to KNP-12.

The statement in the Interpretation re: green belt is a given and is already stated in Part 3 of the Policy, so it could be deleted.

For ease of cross-referencing, those other policies on design and transport within the neighbourhood plan should be specified.

KNP-4 Community Facilities

It is not stated what type of diversification would be appropriate – this could only be supported if ancillary to its principal use.

The loss of community facilities (part 2 of KNP-4) echoes the provisions of policy IN5 of the Local Plan, which perhaps negates the value of this being in essence reaffirmed in the neighbourhood plan.

There is no distance or time attached to what would constitute ‘…easy walking distance’ in the Interpretation section - 800m/10minutes? Could this potentially extend to areas outside of the Parish if it meant enhanced provision close by?

Weblinks to the Natural England assessment and other relevant evidence base (e.g. that used as part of the Local Plan for assessing landscape character) should be provided.

KNP-5 Sustainable Design and Character

PSD7 of the Local Plan covers this issue in significant detail, but how this (if at all) has influenced the policy approach in KNP-5 is less clear. Whilst the broad expectations are understood and the local emphasis is welcomed in relation to, for example, St John’s Church Spire, terms such as ‘good standard of finish’ and ‘local materials’ in point 8 require further explanation in the Keele context.

Sustainable surface water management – point 3 – is assumed to mean SuDS (which itself is referred to in point 12) and again the Local Plan (policy SE4 & its supporting information) addresses this issue.

Blue infrastructure, whilst referred to in the Interpretation section, does not form part of the policy framework of KNP-5 and a modification to address this will be required.

The wording of the para beginning ‘The requirement for landscaping…’ is confusing and could be merged with the following paragraph to form a more coherent framing of policy intent.

Typo ‘blank’ building elevations and a rewording of the text re: rear gardens and street frontages would help clarify its purpose.

KNP-6 Keele Village Conservation Area

For Point 2, is the historic palate meant to relate to that of the Parish? If so, this should be made clear.

What is the relevance of the comment made regarding the Hawthorn’s Estate in the Interpretation text? Is this based solely on the qualifying body’s opinion and/or informed by technical heritage analysis?

Difficulties in applying the standard housing estates etc test could ensue, as it’s open to challenge what this may translate to in decision making terms.

The Conservation Area appraisal should include a web link.

KNP-7 Keele Hall Conservation Area and Historic Park and Garden

Policies SE9: Historic Environment, SE10 Landscape and CRE2: Renewable Energy (of the Local Plan) cover issues including local character and setting as well as impacts on heritage assets which would be integral to the determination of proposals for schemes such as renewable energy. ‘Carefully sited and designed’ is not a strong enough expression to reflect the magnitude of the assessment required to form a judgement as to such a proposal’s harm, and the Interpretation text should be bolstered to manifest this.

KNP-8 Rural and Natural Environment

Point 1 of the policy should be amended to ‘…preserve and enhance’ with the text reframed as to adverse impact and mitigation measures.

How is the 20% figure for Biodiversity Net Gain justified - point 4? - this does not align with Local Plan Policy SE7: Biodiversity Net Gain, which whilst albeit states at least a 10% measurable net gain, this represents a key benchmark figure. Local need and viability are integral to any variance from this & it will need to be fully reasoned as to why 20% is considered appropriate in Keele.

It is unclear as to where these historic farmsteads are within the Parish and due regard should also be had to Appendix 5 of the Local Plan which presents a design code for this type of redevelopment. Para 10.61 of the Local Plan is also worth reviewing in this context.

A weblink to the DEFRA Magic Map should be provided for ease of reference.

KNP-9 Landscape Setting and Coalescence

Point 1 and Figure 6 Green Gaps - It’s unclear as to the justification for their inclusion, especially given the extent of Green Belt. There is also no detailed argument presented that there is a substantive heightened risk from development to coalescence, along with any consequent erosion of distinctive character and landscape setting within the areas where the Gaps are highlighted.

Whilst there might be value in retaining these for information and contextual purposes within the Neighbourhood Plan, it perhaps should not be assumed that they would provide any additional layer of protection beyond what the statutory designations (such as Green Belt) provide at present.

It is also important to acknowledge that work to accompany the new style Local Plan may also reveal areas of grey belt across the Borough and this will play a part in determining the relative merits of sites for allocation.

See also the comment made re: the insetting of Keele Village under the General Comments section above, as well as Local Plan policy SE10: Landscape.

KNP-10 Local Green Space

With reference to paragraph 107 of the (2024) NPPF any designations need to be demonstrably special, and it is important that in each circumstance for LGS1 and LGS2 the Examiner is confident that the additional designation is necessary and would serve a useful purpose.

If the Examiner is minded to retain these local green spaces, the distinction to the five purposes of green belt should be explained further in the Interpretation text.

KNP-11 Sustainable Transport

For the Interpretation text, the word ‘additional’ should be included before ‘…generation of journeys’ and an assumed typo/error rectified of referencing KHD-1.

Again, the links to policies of the adopted Local Plan should be explored, with regard to IN2: Transport and Accessibility; IN3 Access and Parking; IN4 Cycleways, Bridleways and Public Rights of Ways; Appendix 3 Parking Standards.

KNP-12 Keele University Estate

Restating the comments made under Section 2.4 above, specific mention should be made to Local Plan allocations KL13 & KL15, including the role the former plays in establishing a safeguarded route (illustrated on the Policies Map) to facilitate the future provision of a transport link between the A525 and A53.

Stating details of the date of publication of the university’s masterplan is also advised to set the benchmark year.

It is argued that any freed up surfaced car parks – point 4 - would also be suitable as brownfield redevelopment opportunities for university associated facilities rather than limitations being set to landscape and recreational use.

In the Interpretation text, the other neighbourhood plan policies that KNP-12 is felt to augment should be highlighted. A typo is also found in this paragraph ‘understands’ with the ‘s’ needing to be deleted.

The final paragraph refers to ‘harmful alterations’ – ‘unsympathetic alterations’ would be a more appropriate phrase to align with that used in point 5 of the policy.

Green Guidance Note

Section 4.1 Purpose of this Green Guidance Note: For decision making purposes does the note being badged as ‘informal’ mean it would not be afforded the statutory weight attached to the main policy body of the neighbourhood plan itself. The cross-referencing from specific policies (e.g. point 9 of KNP-5) to this note, will also need to be considered by the Examiner in this context.

Infrastructure Priorities

Whilst the infrastructure expenditure priorities are noted, it is important to reaffirm that any contributions yielded via S106 would need to have satisfied the requisite legal tests to ensure the planning obligations are necessary to make the respective development(s) acceptable in planning terms.

For the avoidance of doubt, there is no CIL in place currently within the Borough, nor is there any intent to establish one.