Circular 01/2022 and access onto the strategic road network

A new access onto a motorway or trunk road is the hardest highway argument in English planning, and the starting assumption of strategic road network access policy is that you will not get one. Department for Transport Circular 01/2022 sets out how National Highways approaches development affecting the network it operates, and its preference is plain: access should be taken from the local road network wherever that is possible, and the strategic network should keep doing the job it was built for, which is long distance movement of people and freight.

That does not make development next to a trunk road undevelopable. It changes what you have to prove and who you have to persuade, and it puts an organisation with the power to stop a permission in the middle of your programme.

Which roads the network covers

The strategic road network in England means the motorways and the trunk A roads for which National Highways is the highway authority. Everything else, including most A roads, is the responsibility of the local highway authority, which is usually the county council or the unitary authority.

The distinction matters because the two bodies behave differently, respond on different timescales, and apply different design standards. A trunk A road through a small town looks like an ordinary high street and is not treated like one.

Check the status of the road before doing anything else. Applicants regularly consult the wrong authority, lose three weeks, and then discover that the junction they proposed sits on a network with its own design manual and its own approvals process for departures from standard.

The policy position on new accesses

Circular 01/2022 frames the question around the safe and efficient operation of the network. It asks whether a proposal would have an unacceptable impact on safety, or a severe residual cumulative impact on the operation of the network, which lines up with the test in national planning policy for refusing development on transport grounds.

Three propositions follow from it in practice.

• Direct access to a motorway is effectively unobtainable for ordinary development, since motorway access is provided only at grade separated junctions
• New direct access to an all-purpose trunk road is resisted, and the case has to show that no reasonable alternative exists and that the access can be designed to current standards
• Intensification of an existing access is treated as a new access question once the trip generation changes materially, so relying on an old field gate does not avoid the argument

The circular also supports development that reduces reliance on the network, which gives you something to work with. Schemes that locate trips on the local network, that provide walking and cycling connections, and that come with a credible Travel Plan are treated more sympathetically than those that simply add vehicles to a trunk road.

Directions and what they mean in practice

National Highways is consulted on applications affecting the network, and its response carries a power that other consultees do not have. Through the Development Management Procedure Order 2015, directions can be given to a local planning authority which prevent it from granting permission, either for a period while the case is considered, or in terms that require refusal or the imposition of specified conditions.

A holding direction is the one applicants meet most often. The authority is minded to approve, the committee has resolved to grant, and the decision notice cannot be issued because a direction is in place. Officers cannot override it and the applicant cannot appeal against it, because there is no refusal to appeal.

The practical consequences are these. A direction stops the clock on any expectation of a decision, it removes the authority's ability to negotiate, and it is lifted only when the network operator is satisfied. Anyone budgeting a programme on a trunk road site should treat the possibility as a real risk rather than a footnote.

Evidence that answers a capacity objection

Objections from the network operator are almost always about junction capacity, safety record, or the adequacy of the assessment itself. The third is the most common and the easiest to avoid.

A Transport Assessment on a strategic network site needs the following to be agreed rather than asserted:

1. The study area and the junctions to be modelled, agreed in writing before any modelling starts.
2. The base year survey data and its validity, which is where the note on traffic survey timing and neutral months earns its place, because a count taken in August will be rejected.
3. The growth assumptions and the committed development list, taken from published national traffic forecasting datasets and the authority's own consent records.
4. Trip rates and their source, with the selected sites and filters disclosed so the operator can reproduce the query.
5. The junction modelling package and the parameters used, including saturation flows and whether queues have been modelled over the peak periods rather than a single hour.
6. The safety review, built from the collision record, which means using the data properly as set out in the note on requesting and using STATS19 collision data.

Modelling that shows a junction operating over capacity in the future year without the development is a stronger position than many applicants realise, because the test is the impact of your development, not the underlying condition of the network.

Mitigation the network operator will accept

The order of preference is consistent. Physical works that resolve the identified problem come first, delivered by the developer under a highway agreement with the operator and secured by planning condition. Demand management measures come next, and unsupported financial contributions come a distant last.

Land availability decides more of these than engineering does. A junction improvement that needs a metre of frontage owned by a neighbour is not deliverable, and a Grampian condition tied to land you cannot acquire is a refusal with extra steps.

When to engage, and with whom

Engage before you submit, through the network operator's own spatial planning route rather than through the council. Two conversations are worth having early: one to agree the scope of the transport work, and one to establish whether the access principle is arguable at all.

Ask directly whether the operator would object to the principle of access in this location. A clear answer at that stage is worth more than a favourable model six months later. And where the answer is a firm no, that is useful information, because it points the layout towards a local road access before the masterplan is fixed.

Allow for the response timetable. Statutory consultees have a defined period to respond and routinely ask for extensions on complex cases, and an extension of time agreed with the council is usually better than a refusal issued to beat the clock.

When a local access removes the problem

The cleanest solution on many sites is to give up on the trunk road frontage. An access taken from an adjoining local road, even at the cost of a less efficient internal layout or a ransom payment to a neighbour, moves the application from a national consultee with direction powers to a local highway authority with none.

That trade is often worth making. Compare the cost of the local access, including any land acquisition, against the cost of a delayed decision, a junction improvement designed to strategic standards and the risk of a holding direction. On the schemes I have seen, the local access wins more often than the frontage.

To see which transport and highways documents your site is likely to need, browse the planning report types and start a draft.

This is general guidance, not legal advice. Check the position with National Highways, your local highway authority or a qualified professional before relying on it. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.