Trunk road accesses and when National Highways objects
On a site fronting a trunk road, National Highways can require refusal, require conditions or hold the application. Here is what it assesses and how to manage the response.
A National Highways objection to an access does not merely add a consultee comment to the file. It can stop the council granting permission at all, because directions made by the Secretary of State allow the company to require refusal, to require conditions, or to hold the application for a period while it considers the case. On a site fronting a trunk road, that power is the single biggest planning risk and it should be tested before exchange rather than after validation.
The strategic road network is motorways and trunk roads in England. Everything else is the local highway authority's, and the two bodies apply different tests.
What the company is responsible for
National Highways operates, maintains and improves the strategic road network, and it is consulted on planning applications likely to affect it. Its remit is the safe and efficient operation of that network, which is narrower than a local highway authority's interest in the wider street network.
That narrowness cuts both ways. The company will not comment on residential parking standards or on the design of an estate road. It will comment, firmly, on anything that changes the number, pattern or safety of movements at a junction with the network, including development some distance away that routes traffic through an affected junction.
Establish early whether the network is engaged at all. A site that takes access from a local road may still generate trips through a trunk road roundabout two junctions away, and that is enough to bring the company in.
The policy position on new accesses
Department for Transport Circular 01/2022 sets the policy for the strategic road network and the delivery of sustainable development. Its starting point on direct accesses is restrictive. New direct accesses onto motorways are not entertained, and new or intensified accesses onto all purpose trunk roads are resisted where they would create or worsen a safety or capacity problem.
The practical reading is that a proposal relying on a new private access onto a high speed single carriageway trunk road starts a long way behind. Intensification of an existing access is easier to argue, though the company will look at the existing access geometry, visibility and accident record, and an existing access that falls short of current standards is not a licence to add traffic to it.
The Circular also expects development to reduce reliance on the network through sustainable travel measures, which is why a credible Travel Plan carries more weight in these cases than in ordinary local highway negotiations.
What the assessment has to cover
The company expects assessment proportionate to the effect, and on anything beyond a very small scheme that means a full Transport Assessment rather than a statement. The thresholds that trigger the heavier document are discussed in our note on transport assessment thresholds and trip generation.
Expect the following to be examined line by line:
- Trip generation and its source, with the database, the land use category and the site selection criteria stated rather than summarised.
- Distribution and assignment onto the network, with the method for deriving the routeing.
- Junction capacity modelling for each affected junction, in the assessment years agreed with the company, including committed development.
- Safety analysis using collision data for a defined period and a defined extent, with the source and the date range.
- Access geometry checked against the Design Manual for Roads and Bridges, with any departure from standard identified as such.
- Mitigation proposals, with a feasibility drawing showing the works fit within highway land or within land the applicant controls.
Two points cause more rejected assessments than anything else. Modelling scenarios agreed informally and then changed. And mitigation drawn on a plan that quietly encroaches on third party land.
Directions that restrict the grant of permission
Where the company is not satisfied, it can ask the local planning authority to hold the application while matters are resolved. A holding direction prevents the authority granting permission for a stated period, and it can be renewed. The company can also direct that permission be refused, or that it be granted subject to specified conditions.
Check the current direction on gov.uk for the exact powers and periods, because the instrument has been reissued and the version in a consultant's old report may be out of date. Two practical consequences hold in any version. The authority cannot simply overrule the direction. And a holding direction stops the clock on your determination period in practice, whatever the statutory period says, so an appeal against non-determination is rarely the answer.
| Outcome | Effect on the application | What usually resolves it |
|---|---|---|
| No objection | Application proceeds | Nothing further |
| No objection subject to conditions | Conditions attached to the permission | Agreeing wording before committee |
| Holding direction | Authority cannot grant for a stated period | Revised modelling, revised access design, agreed mitigation |
| Direction to refuse | Authority must refuse | Redesign and resubmission, or a different access strategy |
Mitigation, funding and technical approval
Works to the network are delivered under an agreement with National Highways and paid for by the developer, including the company's own costs for checking and supervising the design. Budget for the technical approval process as well as the construction, because the design must be developed to the company's standards and signed off through a defined procedure.
Where a departure from standard is needed, it has to be applied for and approved, and approval is not a formality. Build the departure process into the programme and get an in principle view at pre-application stage rather than assuming it at design stage.
A road safety audit is normally required at defined design stages. It is an independent exercise carried out by auditors with the relevant experience, and the designer responds formally to each recommendation. That audit is a specialist appointment outside the standard planning document set.
Illustrative example: a 140 unit scheme taking access from a local distributor that met a trunk road roundabout 600 metres away. The company's initial position was a holding direction, on the basis that the roundabout was already at capacity in the evening peak. Revised modelling with an agreed committed development list, a signal controlled improvement to one approach funded by the applicant, and a monitored travel plan resolved it over five months.
Managing the response period
The company responds within the statutory consultee period and will ask for extensions where the material is incomplete. Three habits shorten the process. Approach the company directly at pre-application stage and agree the scope of assessment in writing, including the assessment years and the junctions to be modelled. Submit the model files as well as the outputs. And copy the company's case officer when you respond to the local authority, so the two threads stay aligned.
Where a holding direction is in place, ask the company what specific evidence would allow it to be lifted, and get the answer in writing. Vague requests for further information consume months.
When a site should not proceed
Some access arrangements cannot be made acceptable. A new direct access onto a motorway is one. An access onto a high speed trunk road where visibility cannot be achieved within land the applicant controls is another. A junction already operating over capacity, where the only feasible mitigation is a scheme the company has no programme for, is a third.
The honest answer on those sites is to change the access strategy or change the site. The full policy background is set out in our piece on strategic road network access and Circular 01/2022.
This is general guidance, not legal advice; check the position with your local planning authority, National Highways or a qualified professional before relying on it.
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Frequently asked questions
Can National Highways stop a council granting permission?
Effectively yes. Directions made by the Secretary of State allow the company to require that permission be refused, that it be granted subject to specified conditions, or that it not be granted for a stated period. The local planning authority cannot overrule a direction, so the position has to be resolved with the company itself.
Is a new direct access onto a trunk road ever acceptable?
New direct accesses onto motorways are not entertained. On all purpose trunk roads, new or intensified accesses are resisted where they would create or worsen a safety or capacity problem. Intensifying an existing access is easier to argue, though existing geometry, visibility and collision record will all be examined against current standards.
Does the strategic road network matter if my site fronts a local road?
It can. The test is whether development is likely to affect the network, and traffic routed through a trunk road junction some distance away is enough to bring National Highways into the consultation. Check the likely assignment of trips before assuming the network is not engaged.
Who pays for mitigation on the network?
The developer, under an agreement with National Highways, and the cost includes the company's own charges for checking and supervising the design through its technical approval procedure. Departures from the Design Manual for Roads and Bridges must be applied for and approved separately, which takes time and is not a formality.
How do I get a holding direction lifted?
Ask the company, in writing, what specific evidence would allow it to be withdrawn, and deal with every item in one submission. Typically it is revised junction modelling on an agreed committed development list, a revised access design, or a funded mitigation scheme. Vague further information requests are what consume months.
Sources and further reading
This article is general guidance about the planning system in England and, where stated, the rest of the UK. It is not legal or professional advice. Check your local planning authority’s validation requirements and take professional advice for your specific site.