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Local plan scoping consultation
Transport and infrastructure
Representation ID: 6346
Received: 05/10/2026
Respondent: National Highways
National Highways’ response emphasises that Cheshire East’s new Local Plan must be supported by a robust transport evidence base demonstrating that planned growth can be accommodated without harming the safety, capacity or resilience of the Strategic Road Network (SRN), including the M6, M56 and A556. It advocates a vision-led approach that aligns development with sustainable transport, active travel and accessible locations rather than reliance on private cars. National Highways stresses the need to assess cumulative and cross-boundary traffic impacts, freight movements and infrastructure requirements early in the plan-making process. It seeks ongoing engagement to ensure appropriate modelling, mitigation and transport investment accompany future development.
National Highways has been appointed by the Secretary of State for Transport as a strategic highway company under the provisions of the Infrastructure Act 2015. We are responsible for operating, maintaining and improving the Strategic Road Network (SRN) in England, in accordance with the Licence issued by the Secretary of State for Transport (April 2015) and Government policies and objectives.
Our response to this consultation on the Cheshire East Local Plan (Scoping Consultation) is written in the context of statutory responsibilities as set out in National Highways’ Licence, and in the light of Government policy and regulation, including the:
•
National Planning Policy Framework (NPPF);
•
Town and Country Planning Development Management (Procedure) Order (England) 2015 (DMPO); and
•
DfT Circular 01/2022 The Strategic Road Network and the delivery of sustainable development (‘the Circular’).
Within the planning system, National Highways has a role at both plan-making and decision-taking stages. At Local Plan stage, the role is strategic and evidence-led, ensuring that growth options, site allocations and supporting transport evidence take appropriate account of the safe and efficient operation of the SRN. This requires early engagement with local planning authorities so that cumulative impacts, cross-boundary movements, infrastructure requirements and any necessary mitigation are considered before spatial strategies and site allocations are fixed.
This role is guided principally by DfT Circular 01/2022, which expects Local Plans to support sustainable development without undermining the operation, safety or resilience of the SRN. Site allocations should not be promoted primarily on the basis of access to the SRN, except where there is a clear functional need for such access,
such as roadside facilities or other uses that are demonstrably dependent on the SRN. Local Plan evidence should therefore consider how growth can be supported by sustainable transport choices and whether any residual impacts on the SRN need to be mitigated.
Where potential SRN impacts are identified, the evidence base should establish the scale, timing and deliverability of any required mitigation or infrastructure interventions, including how these would be secured through policy, infrastructure delivery planning, developer contributions or other mechanisms. This provides a clear framework for subsequent decision-taking on planning applications.
Planning applications then allow National Highways to review the detailed proposal, including access, phasing, trip generation, distribution, cumulative effects and proposed mitigation. Where a site has been allocated without specific SRN mitigation, National Highways may still seek further assessment, conditions, obligations or proportionate mitigation if the application evidence demonstrates a need.
However, application-stage mitigation should be grounded in clear evidence and should not generally be relied upon as a substitute for resolving strategic matters that could reasonably have been addressed through the Local Plan evidence base.
National Highways’ engagement in the planning system is not limited to its statutory consultation function. Through early and constructive involvement in plan-making, National Highways can help local planning authorities identify potential SRN matters at an early stage, support the development of proportionate evidence, and ensure that planned growth is supported by appropriate transport interventions where required. This is consistent with National Highways’ licence, which includes a requirement to “Support local and national economic growth and regeneration.”
Vision-Led Planning in Local Plans
National Highways aims to be a proactive partner in the planning system and has adopted vision-led planning within its policies. A vision-led approach to Local Plan preparation starts by defining the type of place the authority is seeking to create and the outcomes the Plan is intended to deliver. From the outset, this should include consideration of the role of roads and the SRN in supporting sustainable growth, particularly where existing or emerging capacity, safety or resilience issues may influence the location, scale or sequencing of development. In line with the Working with National Highways to deliver a vison-led approach for Local Plans guidance document, National Highways should therefore be consulted as the vision and spatial strategy are developed, so that SRN matters are considered alongside wider place-making, sustainability and growth objectives.
Transport planning should then be shaped around those outcomes, rather than being treated solely as a response to forecast traffic growth. In practice, this means planning development in locations and forms that reduce reliance on private car use, while maximising opportunities for walking, wheeling, cycling and public transport. Transport and land-use should therefore be planned in an integrated way, recognising that the location, density, mix and design of development strongly influence how people travel and whether everyday journeys can be made conveniently by active and sustainable modes.
Local Plans should prioritise well-connected, mixed-use developments and align site allocations with wider transport strategies and investment programmes, including Local Transport Plans (LTPs), Local Cycling and Walking Infrastructure Plans (LCWIPs), Rights of Way Improvement Plans (ROWIPs) and Bus Service Improvement Plans (BSIPs). This alignment will be important in demonstrating that any assumed shift away from car travel is credible, deliverable and supported by the right infrastructure.
Where the Plan seeks to reduce reliance on car travel, National Highways will need confidence that this is supported by credible and deliverable active travel and public transport infrastructure. This will help ensure that mode shift assumptions are realistic and that planned growth does not place unmitigated pressure on the SRN.
Preparation of a Local Transport Evidence Base
When producing the Local Plan, it is key to National Highways that any future development will not negatively impact the functionality and safety of the SRN, and that the transport evidence base ensures this. This is set out in Paragraph 26 of the DfT Circular:
In relation to the preparation of local plans and spatial development strategies, the government expects that the relevant authorities will engage with the company from the outset of this process, to understand the interaction between land use designations and the impacts on road safety and future performance of the SRN. The involvement of the company will ensure that the strategic transport evidence base will provide a robust assessment of any positive and negative impacts on the SRN and inform a transport strategy and the Strategic Environmental Assessment (SEA) for the study area that aligns with the safe operation and long-term integrity of the SRN.
It is important that the Local Plan is based on proportionate transport evidence which demonstrates that suitable schemes and mitigation have been considered, and will be implemented, that will shift demand into less carbon-intensive forms of travel. This is set out in Paragraph 33:
A robust evidence base will be required, including demand forecasting models, which inform analysis of alternatives by accounting for the effects of possible mitigation scenarios that shift demand into less carbon-intensive forms of travel.
The Local Plan should be produced in line with the Circular, paying due cognisance to its position as National Highways’ policy.
We expect the beginning stages of plan-making to be supported by baseline evidence for the highway networks across Cheshire East, with our focus being on the SRN.
This needs to set out current and future baseline information on the performance of junctions across the highway networks (end of plan period plus extant permissions). This could be informed by a strategic transport model. Baseline information on the current and expected performance of junctions across the highway networks (without the emerging Local Plan) is relevant to the selecting of sites for development and needs to be produced early in the process.
We are happy to be engaged with the scoping, calibration, and validation of this work, along with colleagues who manage and maintain the local highway network.
The Strategic Road Network in Cheshire East
Paragraph 4.4 of the scoping consultation page states that Cheshire East is a large unitary authority in north-west England, covering 1,166 km² with a population of around 421,300 (mid-2024). It has a lower population density than the national average and borders multiple neighbouring authorities, including Cheshire West and Chester, Warrington, Greater Manchester authorities, High Peak, Newcastle-under-Lyme, Stoke-on-Trent and Shropshire. Part of the borough lies within the Peak District National Park, where planning responsibilities rest with the National Park Authority.
In terms of connectivity, paragraph 4.5 of the page states:
“Cheshire East benefits from strong transport connections, with the M6 and M56 providing access to major regional and national destinations. Rail connectivity is centred on Crewe, a key national rail hub with direct services to many major UK cities, while Macclesfield and Wilmslow also have direct links to London. Manchester Airport, located on the edge of the borough, further enhances the area’s connectivity.”
Within Cheshire East, the Strategic Road Network (SRN) includes the following sections:
•
M6 motorway (from junction 16 to junction 20 Lymm Interchange)
•
M56 motorway (from junction 9 Lymm Interchange to Ringway, between junctions 6 & 7)
•
A556 from M6 Junction 19 Tabley Interchange to M56 Junction 7 Bowdon Interchange
These routes are of high strategic importance, with the M6 being one of the principal north-south strategic routes in the country, the M56 providing access to Greater Manchester and Manchester Airport, and the A556 providing a direct link between these two motorways.
National Highways’ Route Strategies set out National Highways’ plan for the SRN. They are a key research element underpinning the Road Investment Strategy (RIS), which informs the process of future road investment. The M6 motorway is included within the Route Strategy for ‘London to Scotland West (North)’. The M56 and A556 are included within the Route Strategy for ‘South Pennines (West)’. The respective Initial Overview Reports for the routes present analysis of current and future issues & opportunities, along with feedback received from customers and stakeholders.
Future growth within Cheshire East may therefore influence SRN demand through cumulative and cross-boundary travel movements. National Highways’ interest in the new Local Plan will focus on ensuring that the transport evidence base identifies whether planned housing and employment growth could affect the safe and efficient operation of relevant SRN junctions and corridors, including locations outside the CEC administrative boundary.
At this Scoping Consultation stage, National Highways would not expect the detailed assessment of potential SRN impacts to have been completed. The key requirement is instead to establish the principle that the emerging transport evidence base will need to be capable of assessing these matters as the Local Plan progresses, before spatial options and site allocations are fixed. This should include identifying the need to consider trip generation, distribution and assignment, existing network constraints, future traffic demand, cumulative impacts from multiple development sites, opportunities to reduce reliance on private car travel, and whether proportionate modelling, mitigation, infrastructure interventions or policy wording may be required at later stages.
Early engagement between CEC and National Highways will be important as the evidence base develops, with involvement from adjoining authorities where relevant to cumulative or cross-boundary impacts. This will help ensure that any SRN issues are identified at an early stage and can be addressed through the Local Plan, rather than deferred to individual planning applications.
Comments on Scoping Consultation
National Highways has reviewed the information published by CEC as part of the scoping consultation for the new Local Plan. Further transport evidence will be required as the Local Plan progresses.
At this stage, National Highways’ principal comments are:
•
National Highways is in the process of reviewing a number of Local Plan scoping consultations, as many Local Authorities are commencing the preparation of new Local Plans under the new system. It is noted that the level of detail provided in the CEC scoping consultation is lower than has been seen in other equivalent consultations, where more detail has been provided on the Local Plan matters, key issues and challenges, including analysis of Strengths Weaknesses Opportunities and Threats (SWOT). Whilst it is recognised that this is an early-stage scoping document, future stages of plan preparation should include a robust transport evidence base.
•
The spatial strategy should seek to align future growth with accessible locations and sustainable transport objectives, whilst ensuring that strategic connectivity is maintained and supported.
•
The Local Plan scoping consultation webpage states that the preparation of the Local Plan will be informed by a range of evidence, including the Local Transport Plan and the Manchester Airport Sustainable Development Plan. It also states that various new evidence documents are in production or are planned. This includes ‘Highways Network Modelling’. From National Highways’ perspective, the evidence base should demonstrate how planned growth can be accommodated whilst maintaining the safe, efficient and resilient operation of the transport network and SRN, including the M6, M56 and A556 corridors. Consideration should be given to cumulative and cross-boundary impacts, and freight movements.
•
National Highways should be involved in the development of the transport evidence base from an early stage, including through agreement of the scope, methodology, assumptions, assessment scenarios and modelling requirements.
•
The Local Plan scoping consultation webpage states that the Local Plan will need to encourage active travel both in new developments and existing areas. Where the Plan seeks to reduce reliance on car travel, National Highways will need confidence that this is supported by credible and deliverable active travel and public transport infrastructure. This will help ensure that any mode shift assumptions are realistic and that planned growth does not place unmitigated pressure on the SRN.
•
Where transport evidence is being prepared or updated for neighbouring authorities over a similar timeframe, there may be opportunities to align assumptions, assessment scenarios, modelling approaches and engagement arrangements across the local geographies. This would help ensure that evidence prepared for CEC can be integrated with future cross-boundary assessment and avoids duplication or inconsistent assumptions across overlapping Local Plan processes.
Future Engagement
We welcome further engagement with Cheshire East as you progress your Local Plan.
We would also like to share with you our Planning for the future – A guide to working with National Highways on planning matters, which is available from our website. This planning guide describes the approach we take to engaging with the planning system and the issues we look at when considering draft planning documents such as Local Plans.
We have also prepared a short explainer video outlining how we engage with planning, available on our website at https://nationalhighways.co.uk/roads-and-travel/road-projects/planning-and-the-strategic-road-network-in-england/.
Comment
Local plan scoping consultation
4 Baseline information and spatial portrait
Representation ID: 6347
Received: 05/10/2026
Respondent: National Highways
National Highways’ response emphasises that Cheshire East’s new Local Plan must be supported by a robust transport evidence base demonstrating that planned growth can be accommodated without harming the safety, capacity or resilience of the Strategic Road Network (SRN), including the M6, M56 and A556. It advocates a vision-led approach that aligns development with sustainable transport, active travel and accessible locations rather than reliance on private cars. National Highways stresses the need to assess cumulative and cross-boundary traffic impacts, freight movements and infrastructure requirements early in the plan-making process. It seeks ongoing engagement to ensure appropriate modelling, mitigation and transport investment accompany future development.
National Highways has been appointed by the Secretary of State for Transport as a strategic highway company under the provisions of the Infrastructure Act 2015. We are responsible for operating, maintaining and improving the Strategic Road Network (SRN) in England, in accordance with the Licence issued by the Secretary of State for Transport (April 2015) and Government policies and objectives.
Our response to this consultation on the Cheshire East Local Plan (Scoping Consultation) is written in the context of statutory responsibilities as set out in National Highways’ Licence, and in the light of Government policy and regulation, including the:
•
National Planning Policy Framework (NPPF);
•
Town and Country Planning Development Management (Procedure) Order (England) 2015 (DMPO); and
•
DfT Circular 01/2022 The Strategic Road Network and the delivery of sustainable development (‘the Circular’).
Within the planning system, National Highways has a role at both plan-making and decision-taking stages. At Local Plan stage, the role is strategic and evidence-led, ensuring that growth options, site allocations and supporting transport evidence take appropriate account of the safe and efficient operation of the SRN. This requires early engagement with local planning authorities so that cumulative impacts, cross-boundary movements, infrastructure requirements and any necessary mitigation are considered before spatial strategies and site allocations are fixed.
This role is guided principally by DfT Circular 01/2022, which expects Local Plans to support sustainable development without undermining the operation, safety or resilience of the SRN. Site allocations should not be promoted primarily on the basis of access to the SRN, except where there is a clear functional need for such access,
such as roadside facilities or other uses that are demonstrably dependent on the SRN. Local Plan evidence should therefore consider how growth can be supported by sustainable transport choices and whether any residual impacts on the SRN need to be mitigated.
Where potential SRN impacts are identified, the evidence base should establish the scale, timing and deliverability of any required mitigation or infrastructure interventions, including how these would be secured through policy, infrastructure delivery planning, developer contributions or other mechanisms. This provides a clear framework for subsequent decision-taking on planning applications.
Planning applications then allow National Highways to review the detailed proposal, including access, phasing, trip generation, distribution, cumulative effects and proposed mitigation. Where a site has been allocated without specific SRN mitigation, National Highways may still seek further assessment, conditions, obligations or proportionate mitigation if the application evidence demonstrates a need.
However, application-stage mitigation should be grounded in clear evidence and should not generally be relied upon as a substitute for resolving strategic matters that could reasonably have been addressed through the Local Plan evidence base.
National Highways’ engagement in the planning system is not limited to its statutory consultation function. Through early and constructive involvement in plan-making, National Highways can help local planning authorities identify potential SRN matters at an early stage, support the development of proportionate evidence, and ensure that planned growth is supported by appropriate transport interventions where required. This is consistent with National Highways’ licence, which includes a requirement to “Support local and national economic growth and regeneration.”
Vision-Led Planning in Local Plans
National Highways aims to be a proactive partner in the planning system and has adopted vision-led planning within its policies. A vision-led approach to Local Plan preparation starts by defining the type of place the authority is seeking to create and the outcomes the Plan is intended to deliver. From the outset, this should include consideration of the role of roads and the SRN in supporting sustainable growth, particularly where existing or emerging capacity, safety or resilience issues may influence the location, scale or sequencing of development. In line with the Working with National Highways to deliver a vison-led approach for Local Plans guidance document, National Highways should therefore be consulted as the vision and spatial strategy are developed, so that SRN matters are considered alongside wider place-making, sustainability and growth objectives.
Transport planning should then be shaped around those outcomes, rather than being treated solely as a response to forecast traffic growth. In practice, this means planning development in locations and forms that reduce reliance on private car use, while maximising opportunities for walking, wheeling, cycling and public transport. Transport and land-use should therefore be planned in an integrated way, recognising that the location, density, mix and design of development strongly influence how people travel and whether everyday journeys can be made conveniently by active and sustainable modes.
Local Plans should prioritise well-connected, mixed-use developments and align site allocations with wider transport strategies and investment programmes, including Local Transport Plans (LTPs), Local Cycling and Walking Infrastructure Plans (LCWIPs), Rights of Way Improvement Plans (ROWIPs) and Bus Service Improvement Plans (BSIPs). This alignment will be important in demonstrating that any assumed shift away from car travel is credible, deliverable and supported by the right infrastructure.
Where the Plan seeks to reduce reliance on car travel, National Highways will need confidence that this is supported by credible and deliverable active travel and public transport infrastructure. This will help ensure that mode shift assumptions are realistic and that planned growth does not place unmitigated pressure on the SRN.
Preparation of a Local Transport Evidence Base
When producing the Local Plan, it is key to National Highways that any future development will not negatively impact the functionality and safety of the SRN, and that the transport evidence base ensures this. This is set out in Paragraph 26 of the DfT Circular:
In relation to the preparation of local plans and spatial development strategies, the government expects that the relevant authorities will engage with the company from the outset of this process, to understand the interaction between land use designations and the impacts on road safety and future performance of the SRN. The involvement of the company will ensure that the strategic transport evidence base will provide a robust assessment of any positive and negative impacts on the SRN and inform a transport strategy and the Strategic Environmental Assessment (SEA) for the study area that aligns with the safe operation and long-term integrity of the SRN.
It is important that the Local Plan is based on proportionate transport evidence which demonstrates that suitable schemes and mitigation have been considered, and will be implemented, that will shift demand into less carbon-intensive forms of travel. This is set out in Paragraph 33:
A robust evidence base will be required, including demand forecasting models, which inform analysis of alternatives by accounting for the effects of possible mitigation scenarios that shift demand into less carbon-intensive forms of travel.
The Local Plan should be produced in line with the Circular, paying due cognisance to its position as National Highways’ policy.
We expect the beginning stages of plan-making to be supported by baseline evidence for the highway networks across Cheshire East, with our focus being on the SRN.
This needs to set out current and future baseline information on the performance of junctions across the highway networks (end of plan period plus extant permissions). This could be informed by a strategic transport model. Baseline information on the current and expected performance of junctions across the highway networks (without the emerging Local Plan) is relevant to the selecting of sites for development and needs to be produced early in the process.
We are happy to be engaged with the scoping, calibration, and validation of this work, along with colleagues who manage and maintain the local highway network.
The Strategic Road Network in Cheshire East
Paragraph 4.4 of the scoping consultation page states that Cheshire East is a large unitary authority in north-west England, covering 1,166 km² with a population of around 421,300 (mid-2024). It has a lower population density than the national average and borders multiple neighbouring authorities, including Cheshire West and Chester, Warrington, Greater Manchester authorities, High Peak, Newcastle-under-Lyme, Stoke-on-Trent and Shropshire. Part of the borough lies within the Peak District National Park, where planning responsibilities rest with the National Park Authority.
In terms of connectivity, paragraph 4.5 of the page states:
“Cheshire East benefits from strong transport connections, with the M6 and M56 providing access to major regional and national destinations. Rail connectivity is centred on Crewe, a key national rail hub with direct services to many major UK cities, while Macclesfield and Wilmslow also have direct links to London. Manchester Airport, located on the edge of the borough, further enhances the area’s connectivity.”
Within Cheshire East, the Strategic Road Network (SRN) includes the following sections:
•
M6 motorway (from junction 16 to junction 20 Lymm Interchange)
•
M56 motorway (from junction 9 Lymm Interchange to Ringway, between junctions 6 & 7)
•
A556 from M6 Junction 19 Tabley Interchange to M56 Junction 7 Bowdon Interchange
These routes are of high strategic importance, with the M6 being one of the principal north-south strategic routes in the country, the M56 providing access to Greater Manchester and Manchester Airport, and the A556 providing a direct link between these two motorways.
National Highways’ Route Strategies set out National Highways’ plan for the SRN. They are a key research element underpinning the Road Investment Strategy (RIS), which informs the process of future road investment. The M6 motorway is included within the Route Strategy for ‘London to Scotland West (North)’. The M56 and A556 are included within the Route Strategy for ‘South Pennines (West)’. The respective Initial Overview Reports for the routes present analysis of current and future issues & opportunities, along with feedback received from customers and stakeholders.
Future growth within Cheshire East may therefore influence SRN demand through cumulative and cross-boundary travel movements. National Highways’ interest in the new Local Plan will focus on ensuring that the transport evidence base identifies whether planned housing and employment growth could affect the safe and efficient operation of relevant SRN junctions and corridors, including locations outside the CEC administrative boundary.
At this Scoping Consultation stage, National Highways would not expect the detailed assessment of potential SRN impacts to have been completed. The key requirement is instead to establish the principle that the emerging transport evidence base will need to be capable of assessing these matters as the Local Plan progresses, before spatial options and site allocations are fixed. This should include identifying the need to consider trip generation, distribution and assignment, existing network constraints, future traffic demand, cumulative impacts from multiple development sites, opportunities to reduce reliance on private car travel, and whether proportionate modelling, mitigation, infrastructure interventions or policy wording may be required at later stages.
Early engagement between CEC and National Highways will be important as the evidence base develops, with involvement from adjoining authorities where relevant to cumulative or cross-boundary impacts. This will help ensure that any SRN issues are identified at an early stage and can be addressed through the Local Plan, rather than deferred to individual planning applications.
Comments on Scoping Consultation
National Highways has reviewed the information published by CEC as part of the scoping consultation for the new Local Plan. Further transport evidence will be required as the Local Plan progresses.
At this stage, National Highways’ principal comments are:
•
National Highways is in the process of reviewing a number of Local Plan scoping consultations, as many Local Authorities are commencing the preparation of new Local Plans under the new system. It is noted that the level of detail provided in the CEC scoping consultation is lower than has been seen in other equivalent consultations, where more detail has been provided on the Local Plan matters, key issues and challenges, including analysis of Strengths Weaknesses Opportunities and Threats (SWOT). Whilst it is recognised that this is an early-stage scoping document, future stages of plan preparation should include a robust transport evidence base.
•
The spatial strategy should seek to align future growth with accessible locations and sustainable transport objectives, whilst ensuring that strategic connectivity is maintained and supported.
•
The Local Plan scoping consultation webpage states that the preparation of the Local Plan will be informed by a range of evidence, including the Local Transport Plan and the Manchester Airport Sustainable Development Plan. It also states that various new evidence documents are in production or are planned. This includes ‘Highways Network Modelling’. From National Highways’ perspective, the evidence base should demonstrate how planned growth can be accommodated whilst maintaining the safe, efficient and resilient operation of the transport network and SRN, including the M6, M56 and A556 corridors. Consideration should be given to cumulative and cross-boundary impacts, and freight movements.
•
National Highways should be involved in the development of the transport evidence base from an early stage, including through agreement of the scope, methodology, assumptions, assessment scenarios and modelling requirements.
•
The Local Plan scoping consultation webpage states that the Local Plan will need to encourage active travel both in new developments and existing areas. Where the Plan seeks to reduce reliance on car travel, National Highways will need confidence that this is supported by credible and deliverable active travel and public transport infrastructure. This will help ensure that any mode shift assumptions are realistic and that planned growth does not place unmitigated pressure on the SRN.
•
Where transport evidence is being prepared or updated for neighbouring authorities over a similar timeframe, there may be opportunities to align assumptions, assessment scenarios, modelling approaches and engagement arrangements across the local geographies. This would help ensure that evidence prepared for CEC can be integrated with future cross-boundary assessment and avoids duplication or inconsistent assumptions across overlapping Local Plan processes.
Future Engagement
We welcome further engagement with Cheshire East as you progress your Local Plan.
We would also like to share with you our Planning for the future – A guide to working with National Highways on planning matters, which is available from our website. This planning guide describes the approach we take to engaging with the planning system and the issues we look at when considering draft planning documents such as Local Plans.
We have also prepared a short explainer video outlining how we engage with planning, available on our website at https://nationalhighways.co.uk/roads-and-travel/road-projects/planning-and-the-strategic-road-network-in-england/.
Comment
Local plan scoping consultation
Spatial distribution
Representation ID: 6348
Received: 05/10/2026
Respondent: National Highways
National Highways’ response emphasises that Cheshire East’s new Local Plan must be supported by a robust transport evidence base demonstrating that planned growth can be accommodated without harming the safety, capacity or resilience of the Strategic Road Network (SRN), including the M6, M56 and A556. It advocates a vision-led approach that aligns development with sustainable transport, active travel and accessible locations rather than reliance on private cars. National Highways stresses the need to assess cumulative and cross-boundary traffic impacts, freight movements and infrastructure requirements early in the plan-making process. It seeks ongoing engagement to ensure appropriate modelling, mitigation and transport investment accompany future development.
National Highways has been appointed by the Secretary of State for Transport as a strategic highway company under the provisions of the Infrastructure Act 2015. We are responsible for operating, maintaining and improving the Strategic Road Network (SRN) in England, in accordance with the Licence issued by the Secretary of State for Transport (April 2015) and Government policies and objectives.
Our response to this consultation on the Cheshire East Local Plan (Scoping Consultation) is written in the context of statutory responsibilities as set out in National Highways’ Licence, and in the light of Government policy and regulation, including the:
•
National Planning Policy Framework (NPPF);
•
Town and Country Planning Development Management (Procedure) Order (England) 2015 (DMPO); and
•
DfT Circular 01/2022 The Strategic Road Network and the delivery of sustainable development (‘the Circular’).
Within the planning system, National Highways has a role at both plan-making and decision-taking stages. At Local Plan stage, the role is strategic and evidence-led, ensuring that growth options, site allocations and supporting transport evidence take appropriate account of the safe and efficient operation of the SRN. This requires early engagement with local planning authorities so that cumulative impacts, cross-boundary movements, infrastructure requirements and any necessary mitigation are considered before spatial strategies and site allocations are fixed.
This role is guided principally by DfT Circular 01/2022, which expects Local Plans to support sustainable development without undermining the operation, safety or resilience of the SRN. Site allocations should not be promoted primarily on the basis of access to the SRN, except where there is a clear functional need for such access,
such as roadside facilities or other uses that are demonstrably dependent on the SRN. Local Plan evidence should therefore consider how growth can be supported by sustainable transport choices and whether any residual impacts on the SRN need to be mitigated.
Where potential SRN impacts are identified, the evidence base should establish the scale, timing and deliverability of any required mitigation or infrastructure interventions, including how these would be secured through policy, infrastructure delivery planning, developer contributions or other mechanisms. This provides a clear framework for subsequent decision-taking on planning applications.
Planning applications then allow National Highways to review the detailed proposal, including access, phasing, trip generation, distribution, cumulative effects and proposed mitigation. Where a site has been allocated without specific SRN mitigation, National Highways may still seek further assessment, conditions, obligations or proportionate mitigation if the application evidence demonstrates a need.
However, application-stage mitigation should be grounded in clear evidence and should not generally be relied upon as a substitute for resolving strategic matters that could reasonably have been addressed through the Local Plan evidence base.
National Highways’ engagement in the planning system is not limited to its statutory consultation function. Through early and constructive involvement in plan-making, National Highways can help local planning authorities identify potential SRN matters at an early stage, support the development of proportionate evidence, and ensure that planned growth is supported by appropriate transport interventions where required. This is consistent with National Highways’ licence, which includes a requirement to “Support local and national economic growth and regeneration.”
Vision-Led Planning in Local Plans
National Highways aims to be a proactive partner in the planning system and has adopted vision-led planning within its policies. A vision-led approach to Local Plan preparation starts by defining the type of place the authority is seeking to create and the outcomes the Plan is intended to deliver. From the outset, this should include consideration of the role of roads and the SRN in supporting sustainable growth, particularly where existing or emerging capacity, safety or resilience issues may influence the location, scale or sequencing of development. In line with the Working with National Highways to deliver a vison-led approach for Local Plans guidance document, National Highways should therefore be consulted as the vision and spatial strategy are developed, so that SRN matters are considered alongside wider place-making, sustainability and growth objectives.
Transport planning should then be shaped around those outcomes, rather than being treated solely as a response to forecast traffic growth. In practice, this means planning development in locations and forms that reduce reliance on private car use, while maximising opportunities for walking, wheeling, cycling and public transport. Transport and land-use should therefore be planned in an integrated way, recognising that the location, density, mix and design of development strongly influence how people travel and whether everyday journeys can be made conveniently by active and sustainable modes.
Local Plans should prioritise well-connected, mixed-use developments and align site allocations with wider transport strategies and investment programmes, including Local Transport Plans (LTPs), Local Cycling and Walking Infrastructure Plans (LCWIPs), Rights of Way Improvement Plans (ROWIPs) and Bus Service Improvement Plans (BSIPs). This alignment will be important in demonstrating that any assumed shift away from car travel is credible, deliverable and supported by the right infrastructure.
Where the Plan seeks to reduce reliance on car travel, National Highways will need confidence that this is supported by credible and deliverable active travel and public transport infrastructure. This will help ensure that mode shift assumptions are realistic and that planned growth does not place unmitigated pressure on the SRN.
Preparation of a Local Transport Evidence Base
When producing the Local Plan, it is key to National Highways that any future development will not negatively impact the functionality and safety of the SRN, and that the transport evidence base ensures this. This is set out in Paragraph 26 of the DfT Circular:
In relation to the preparation of local plans and spatial development strategies, the government expects that the relevant authorities will engage with the company from the outset of this process, to understand the interaction between land use designations and the impacts on road safety and future performance of the SRN. The involvement of the company will ensure that the strategic transport evidence base will provide a robust assessment of any positive and negative impacts on the SRN and inform a transport strategy and the Strategic Environmental Assessment (SEA) for the study area that aligns with the safe operation and long-term integrity of the SRN.
It is important that the Local Plan is based on proportionate transport evidence which demonstrates that suitable schemes and mitigation have been considered, and will be implemented, that will shift demand into less carbon-intensive forms of travel. This is set out in Paragraph 33:
A robust evidence base will be required, including demand forecasting models, which inform analysis of alternatives by accounting for the effects of possible mitigation scenarios that shift demand into less carbon-intensive forms of travel.
The Local Plan should be produced in line with the Circular, paying due cognisance to its position as National Highways’ policy.
We expect the beginning stages of plan-making to be supported by baseline evidence for the highway networks across Cheshire East, with our focus being on the SRN.
This needs to set out current and future baseline information on the performance of junctions across the highway networks (end of plan period plus extant permissions). This could be informed by a strategic transport model. Baseline information on the current and expected performance of junctions across the highway networks (without the emerging Local Plan) is relevant to the selecting of sites for development and needs to be produced early in the process.
We are happy to be engaged with the scoping, calibration, and validation of this work, along with colleagues who manage and maintain the local highway network.
The Strategic Road Network in Cheshire East
Paragraph 4.4 of the scoping consultation page states that Cheshire East is a large unitary authority in north-west England, covering 1,166 km² with a population of around 421,300 (mid-2024). It has a lower population density than the national average and borders multiple neighbouring authorities, including Cheshire West and Chester, Warrington, Greater Manchester authorities, High Peak, Newcastle-under-Lyme, Stoke-on-Trent and Shropshire. Part of the borough lies within the Peak District National Park, where planning responsibilities rest with the National Park Authority.
In terms of connectivity, paragraph 4.5 of the page states:
“Cheshire East benefits from strong transport connections, with the M6 and M56 providing access to major regional and national destinations. Rail connectivity is centred on Crewe, a key national rail hub with direct services to many major UK cities, while Macclesfield and Wilmslow also have direct links to London. Manchester Airport, located on the edge of the borough, further enhances the area’s connectivity.”
Within Cheshire East, the Strategic Road Network (SRN) includes the following sections:
•
M6 motorway (from junction 16 to junction 20 Lymm Interchange)
•
M56 motorway (from junction 9 Lymm Interchange to Ringway, between junctions 6 & 7)
•
A556 from M6 Junction 19 Tabley Interchange to M56 Junction 7 Bowdon Interchange
These routes are of high strategic importance, with the M6 being one of the principal north-south strategic routes in the country, the M56 providing access to Greater Manchester and Manchester Airport, and the A556 providing a direct link between these two motorways.
National Highways’ Route Strategies set out National Highways’ plan for the SRN. They are a key research element underpinning the Road Investment Strategy (RIS), which informs the process of future road investment. The M6 motorway is included within the Route Strategy for ‘London to Scotland West (North)’. The M56 and A556 are included within the Route Strategy for ‘South Pennines (West)’. The respective Initial Overview Reports for the routes present analysis of current and future issues & opportunities, along with feedback received from customers and stakeholders.
Future growth within Cheshire East may therefore influence SRN demand through cumulative and cross-boundary travel movements. National Highways’ interest in the new Local Plan will focus on ensuring that the transport evidence base identifies whether planned housing and employment growth could affect the safe and efficient operation of relevant SRN junctions and corridors, including locations outside the CEC administrative boundary.
At this Scoping Consultation stage, National Highways would not expect the detailed assessment of potential SRN impacts to have been completed. The key requirement is instead to establish the principle that the emerging transport evidence base will need to be capable of assessing these matters as the Local Plan progresses, before spatial options and site allocations are fixed. This should include identifying the need to consider trip generation, distribution and assignment, existing network constraints, future traffic demand, cumulative impacts from multiple development sites, opportunities to reduce reliance on private car travel, and whether proportionate modelling, mitigation, infrastructure interventions or policy wording may be required at later stages.
Early engagement between CEC and National Highways will be important as the evidence base develops, with involvement from adjoining authorities where relevant to cumulative or cross-boundary impacts. This will help ensure that any SRN issues are identified at an early stage and can be addressed through the Local Plan, rather than deferred to individual planning applications.
Comments on Scoping Consultation
National Highways has reviewed the information published by CEC as part of the scoping consultation for the new Local Plan. Further transport evidence will be required as the Local Plan progresses.
At this stage, National Highways’ principal comments are:
•
National Highways is in the process of reviewing a number of Local Plan scoping consultations, as many Local Authorities are commencing the preparation of new Local Plans under the new system. It is noted that the level of detail provided in the CEC scoping consultation is lower than has been seen in other equivalent consultations, where more detail has been provided on the Local Plan matters, key issues and challenges, including analysis of Strengths Weaknesses Opportunities and Threats (SWOT). Whilst it is recognised that this is an early-stage scoping document, future stages of plan preparation should include a robust transport evidence base.
•
The spatial strategy should seek to align future growth with accessible locations and sustainable transport objectives, whilst ensuring that strategic connectivity is maintained and supported.
•
The Local Plan scoping consultation webpage states that the preparation of the Local Plan will be informed by a range of evidence, including the Local Transport Plan and the Manchester Airport Sustainable Development Plan. It also states that various new evidence documents are in production or are planned. This includes ‘Highways Network Modelling’. From National Highways’ perspective, the evidence base should demonstrate how planned growth can be accommodated whilst maintaining the safe, efficient and resilient operation of the transport network and SRN, including the M6, M56 and A556 corridors. Consideration should be given to cumulative and cross-boundary impacts, and freight movements.
•
National Highways should be involved in the development of the transport evidence base from an early stage, including through agreement of the scope, methodology, assumptions, assessment scenarios and modelling requirements.
•
The Local Plan scoping consultation webpage states that the Local Plan will need to encourage active travel both in new developments and existing areas. Where the Plan seeks to reduce reliance on car travel, National Highways will need confidence that this is supported by credible and deliverable active travel and public transport infrastructure. This will help ensure that any mode shift assumptions are realistic and that planned growth does not place unmitigated pressure on the SRN.
•
Where transport evidence is being prepared or updated for neighbouring authorities over a similar timeframe, there may be opportunities to align assumptions, assessment scenarios, modelling approaches and engagement arrangements across the local geographies. This would help ensure that evidence prepared for CEC can be integrated with future cross-boundary assessment and avoids duplication or inconsistent assumptions across overlapping Local Plan processes.
Future Engagement
We welcome further engagement with Cheshire East as you progress your Local Plan.
We would also like to share with you our Planning for the future – A guide to working with National Highways on planning matters, which is available from our website. This planning guide describes the approach we take to engaging with the planning system and the issues we look at when considering draft planning documents such as Local Plans.
We have also prepared a short explainer video outlining how we engage with planning, available on our website at https://nationalhighways.co.uk/roads-and-travel/road-projects/planning-and-the-strategic-road-network-in-england/.
Comment
Local plan scoping consultation
New evidence
Representation ID: 6349
Received: 05/10/2026
Respondent: National Highways
National Highways’ response emphasises that Cheshire East’s new Local Plan must be supported by a robust transport evidence base demonstrating that planned growth can be accommodated without harming the safety, capacity or resilience of the Strategic Road Network (SRN), including the M6, M56 and A556. It advocates a vision-led approach that aligns development with sustainable transport, active travel and accessible locations rather than reliance on private cars. National Highways stresses the need to assess cumulative and cross-boundary traffic impacts, freight movements and infrastructure requirements early in the plan-making process. It seeks ongoing engagement to ensure appropriate modelling, mitigation and transport investment accompany future development.
National Highways has been appointed by the Secretary of State for Transport as a strategic highway company under the provisions of the Infrastructure Act 2015. We are responsible for operating, maintaining and improving the Strategic Road Network (SRN) in England, in accordance with the Licence issued by the Secretary of State for Transport (April 2015) and Government policies and objectives.
Our response to this consultation on the Cheshire East Local Plan (Scoping Consultation) is written in the context of statutory responsibilities as set out in National Highways’ Licence, and in the light of Government policy and regulation, including the:
•
National Planning Policy Framework (NPPF);
•
Town and Country Planning Development Management (Procedure) Order (England) 2015 (DMPO); and
•
DfT Circular 01/2022 The Strategic Road Network and the delivery of sustainable development (‘the Circular’).
Within the planning system, National Highways has a role at both plan-making and decision-taking stages. At Local Plan stage, the role is strategic and evidence-led, ensuring that growth options, site allocations and supporting transport evidence take appropriate account of the safe and efficient operation of the SRN. This requires early engagement with local planning authorities so that cumulative impacts, cross-boundary movements, infrastructure requirements and any necessary mitigation are considered before spatial strategies and site allocations are fixed.
This role is guided principally by DfT Circular 01/2022, which expects Local Plans to support sustainable development without undermining the operation, safety or resilience of the SRN. Site allocations should not be promoted primarily on the basis of access to the SRN, except where there is a clear functional need for such access,
such as roadside facilities or other uses that are demonstrably dependent on the SRN. Local Plan evidence should therefore consider how growth can be supported by sustainable transport choices and whether any residual impacts on the SRN need to be mitigated.
Where potential SRN impacts are identified, the evidence base should establish the scale, timing and deliverability of any required mitigation or infrastructure interventions, including how these would be secured through policy, infrastructure delivery planning, developer contributions or other mechanisms. This provides a clear framework for subsequent decision-taking on planning applications.
Planning applications then allow National Highways to review the detailed proposal, including access, phasing, trip generation, distribution, cumulative effects and proposed mitigation. Where a site has been allocated without specific SRN mitigation, National Highways may still seek further assessment, conditions, obligations or proportionate mitigation if the application evidence demonstrates a need.
However, application-stage mitigation should be grounded in clear evidence and should not generally be relied upon as a substitute for resolving strategic matters that could reasonably have been addressed through the Local Plan evidence base.
National Highways’ engagement in the planning system is not limited to its statutory consultation function. Through early and constructive involvement in plan-making, National Highways can help local planning authorities identify potential SRN matters at an early stage, support the development of proportionate evidence, and ensure that planned growth is supported by appropriate transport interventions where required. This is consistent with National Highways’ licence, which includes a requirement to “Support local and national economic growth and regeneration.”
Vision-Led Planning in Local Plans
National Highways aims to be a proactive partner in the planning system and has adopted vision-led planning within its policies. A vision-led approach to Local Plan preparation starts by defining the type of place the authority is seeking to create and the outcomes the Plan is intended to deliver. From the outset, this should include consideration of the role of roads and the SRN in supporting sustainable growth, particularly where existing or emerging capacity, safety or resilience issues may influence the location, scale or sequencing of development. In line with the Working with National Highways to deliver a vison-led approach for Local Plans guidance document, National Highways should therefore be consulted as the vision and spatial strategy are developed, so that SRN matters are considered alongside wider place-making, sustainability and growth objectives.
Transport planning should then be shaped around those outcomes, rather than being treated solely as a response to forecast traffic growth. In practice, this means planning development in locations and forms that reduce reliance on private car use, while maximising opportunities for walking, wheeling, cycling and public transport. Transport and land-use should therefore be planned in an integrated way, recognising that the location, density, mix and design of development strongly influence how people travel and whether everyday journeys can be made conveniently by active and sustainable modes.
Local Plans should prioritise well-connected, mixed-use developments and align site allocations with wider transport strategies and investment programmes, including Local Transport Plans (LTPs), Local Cycling and Walking Infrastructure Plans (LCWIPs), Rights of Way Improvement Plans (ROWIPs) and Bus Service Improvement Plans (BSIPs). This alignment will be important in demonstrating that any assumed shift away from car travel is credible, deliverable and supported by the right infrastructure.
Where the Plan seeks to reduce reliance on car travel, National Highways will need confidence that this is supported by credible and deliverable active travel and public transport infrastructure. This will help ensure that mode shift assumptions are realistic and that planned growth does not place unmitigated pressure on the SRN.
Preparation of a Local Transport Evidence Base
When producing the Local Plan, it is key to National Highways that any future development will not negatively impact the functionality and safety of the SRN, and that the transport evidence base ensures this. This is set out in Paragraph 26 of the DfT Circular:
In relation to the preparation of local plans and spatial development strategies, the government expects that the relevant authorities will engage with the company from the outset of this process, to understand the interaction between land use designations and the impacts on road safety and future performance of the SRN. The involvement of the company will ensure that the strategic transport evidence base will provide a robust assessment of any positive and negative impacts on the SRN and inform a transport strategy and the Strategic Environmental Assessment (SEA) for the study area that aligns with the safe operation and long-term integrity of the SRN.
It is important that the Local Plan is based on proportionate transport evidence which demonstrates that suitable schemes and mitigation have been considered, and will be implemented, that will shift demand into less carbon-intensive forms of travel. This is set out in Paragraph 33:
A robust evidence base will be required, including demand forecasting models, which inform analysis of alternatives by accounting for the effects of possible mitigation scenarios that shift demand into less carbon-intensive forms of travel.
The Local Plan should be produced in line with the Circular, paying due cognisance to its position as National Highways’ policy.
We expect the beginning stages of plan-making to be supported by baseline evidence for the highway networks across Cheshire East, with our focus being on the SRN.
This needs to set out current and future baseline information on the performance of junctions across the highway networks (end of plan period plus extant permissions). This could be informed by a strategic transport model. Baseline information on the current and expected performance of junctions across the highway networks (without the emerging Local Plan) is relevant to the selecting of sites for development and needs to be produced early in the process.
We are happy to be engaged with the scoping, calibration, and validation of this work, along with colleagues who manage and maintain the local highway network.
The Strategic Road Network in Cheshire East
Paragraph 4.4 of the scoping consultation page states that Cheshire East is a large unitary authority in north-west England, covering 1,166 km² with a population of around 421,300 (mid-2024). It has a lower population density than the national average and borders multiple neighbouring authorities, including Cheshire West and Chester, Warrington, Greater Manchester authorities, High Peak, Newcastle-under-Lyme, Stoke-on-Trent and Shropshire. Part of the borough lies within the Peak District National Park, where planning responsibilities rest with the National Park Authority.
In terms of connectivity, paragraph 4.5 of the page states:
“Cheshire East benefits from strong transport connections, with the M6 and M56 providing access to major regional and national destinations. Rail connectivity is centred on Crewe, a key national rail hub with direct services to many major UK cities, while Macclesfield and Wilmslow also have direct links to London. Manchester Airport, located on the edge of the borough, further enhances the area’s connectivity.”
Within Cheshire East, the Strategic Road Network (SRN) includes the following sections:
•
M6 motorway (from junction 16 to junction 20 Lymm Interchange)
•
M56 motorway (from junction 9 Lymm Interchange to Ringway, between junctions 6 & 7)
•
A556 from M6 Junction 19 Tabley Interchange to M56 Junction 7 Bowdon Interchange
These routes are of high strategic importance, with the M6 being one of the principal north-south strategic routes in the country, the M56 providing access to Greater Manchester and Manchester Airport, and the A556 providing a direct link between these two motorways.
National Highways’ Route Strategies set out National Highways’ plan for the SRN. They are a key research element underpinning the Road Investment Strategy (RIS), which informs the process of future road investment. The M6 motorway is included within the Route Strategy for ‘London to Scotland West (North)’. The M56 and A556 are included within the Route Strategy for ‘South Pennines (West)’. The respective Initial Overview Reports for the routes present analysis of current and future issues & opportunities, along with feedback received from customers and stakeholders.
Future growth within Cheshire East may therefore influence SRN demand through cumulative and cross-boundary travel movements. National Highways’ interest in the new Local Plan will focus on ensuring that the transport evidence base identifies whether planned housing and employment growth could affect the safe and efficient operation of relevant SRN junctions and corridors, including locations outside the CEC administrative boundary.
At this Scoping Consultation stage, National Highways would not expect the detailed assessment of potential SRN impacts to have been completed. The key requirement is instead to establish the principle that the emerging transport evidence base will need to be capable of assessing these matters as the Local Plan progresses, before spatial options and site allocations are fixed. This should include identifying the need to consider trip generation, distribution and assignment, existing network constraints, future traffic demand, cumulative impacts from multiple development sites, opportunities to reduce reliance on private car travel, and whether proportionate modelling, mitigation, infrastructure interventions or policy wording may be required at later stages.
Early engagement between CEC and National Highways will be important as the evidence base develops, with involvement from adjoining authorities where relevant to cumulative or cross-boundary impacts. This will help ensure that any SRN issues are identified at an early stage and can be addressed through the Local Plan, rather than deferred to individual planning applications.
Comments on Scoping Consultation
National Highways has reviewed the information published by CEC as part of the scoping consultation for the new Local Plan. Further transport evidence will be required as the Local Plan progresses.
At this stage, National Highways’ principal comments are:
•
National Highways is in the process of reviewing a number of Local Plan scoping consultations, as many Local Authorities are commencing the preparation of new Local Plans under the new system. It is noted that the level of detail provided in the CEC scoping consultation is lower than has been seen in other equivalent consultations, where more detail has been provided on the Local Plan matters, key issues and challenges, including analysis of Strengths Weaknesses Opportunities and Threats (SWOT). Whilst it is recognised that this is an early-stage scoping document, future stages of plan preparation should include a robust transport evidence base.
•
The spatial strategy should seek to align future growth with accessible locations and sustainable transport objectives, whilst ensuring that strategic connectivity is maintained and supported.
•
The Local Plan scoping consultation webpage states that the preparation of the Local Plan will be informed by a range of evidence, including the Local Transport Plan and the Manchester Airport Sustainable Development Plan. It also states that various new evidence documents are in production or are planned. This includes ‘Highways Network Modelling’. From National Highways’ perspective, the evidence base should demonstrate how planned growth can be accommodated whilst maintaining the safe, efficient and resilient operation of the transport network and SRN, including the M6, M56 and A556 corridors. Consideration should be given to cumulative and cross-boundary impacts, and freight movements.
•
National Highways should be involved in the development of the transport evidence base from an early stage, including through agreement of the scope, methodology, assumptions, assessment scenarios and modelling requirements.
•
The Local Plan scoping consultation webpage states that the Local Plan will need to encourage active travel both in new developments and existing areas. Where the Plan seeks to reduce reliance on car travel, National Highways will need confidence that this is supported by credible and deliverable active travel and public transport infrastructure. This will help ensure that any mode shift assumptions are realistic and that planned growth does not place unmitigated pressure on the SRN.
•
Where transport evidence is being prepared or updated for neighbouring authorities over a similar timeframe, there may be opportunities to align assumptions, assessment scenarios, modelling approaches and engagement arrangements across the local geographies. This would help ensure that evidence prepared for CEC can be integrated with future cross-boundary assessment and avoids duplication or inconsistent assumptions across overlapping Local Plan processes.
Future Engagement
We welcome further engagement with Cheshire East as you progress your Local Plan.
We would also like to share with you our Planning for the future – A guide to working with National Highways on planning matters, which is available from our website. This planning guide describes the approach we take to engaging with the planning system and the issues we look at when considering draft planning documents such as Local Plans.
We have also prepared a short explainer video outlining how we engage with planning, available on our website at https://nationalhighways.co.uk/roads-and-travel/road-projects/planning-and-the-strategic-road-network-in-england/.
Comment
Local plan scoping consultation
Active Travel
Representation ID: 6350
Received: 05/10/2026
Respondent: National Highways
National Highways’ response emphasises that Cheshire East’s new Local Plan must be supported by a robust transport evidence base demonstrating that planned growth can be accommodated without harming the safety, capacity or resilience of the Strategic Road Network (SRN), including the M6, M56 and A556. It advocates a vision-led approach that aligns development with sustainable transport, active travel and accessible locations rather than reliance on private cars. National Highways stresses the need to assess cumulative and cross-boundary traffic impacts, freight movements and infrastructure requirements early in the plan-making process. It seeks ongoing engagement to ensure appropriate modelling, mitigation and transport investment accompany future development.
National Highways has been appointed by the Secretary of State for Transport as a strategic highway company under the provisions of the Infrastructure Act 2015. We are responsible for operating, maintaining and improving the Strategic Road Network (SRN) in England, in accordance with the Licence issued by the Secretary of State for Transport (April 2015) and Government policies and objectives.
Our response to this consultation on the Cheshire East Local Plan (Scoping Consultation) is written in the context of statutory responsibilities as set out in National Highways’ Licence, and in the light of Government policy and regulation, including the:
•
National Planning Policy Framework (NPPF);
•
Town and Country Planning Development Management (Procedure) Order (England) 2015 (DMPO); and
•
DfT Circular 01/2022 The Strategic Road Network and the delivery of sustainable development (‘the Circular’).
Within the planning system, National Highways has a role at both plan-making and decision-taking stages. At Local Plan stage, the role is strategic and evidence-led, ensuring that growth options, site allocations and supporting transport evidence take appropriate account of the safe and efficient operation of the SRN. This requires early engagement with local planning authorities so that cumulative impacts, cross-boundary movements, infrastructure requirements and any necessary mitigation are considered before spatial strategies and site allocations are fixed.
This role is guided principally by DfT Circular 01/2022, which expects Local Plans to support sustainable development without undermining the operation, safety or resilience of the SRN. Site allocations should not be promoted primarily on the basis of access to the SRN, except where there is a clear functional need for such access,
such as roadside facilities or other uses that are demonstrably dependent on the SRN. Local Plan evidence should therefore consider how growth can be supported by sustainable transport choices and whether any residual impacts on the SRN need to be mitigated.
Where potential SRN impacts are identified, the evidence base should establish the scale, timing and deliverability of any required mitigation or infrastructure interventions, including how these would be secured through policy, infrastructure delivery planning, developer contributions or other mechanisms. This provides a clear framework for subsequent decision-taking on planning applications.
Planning applications then allow National Highways to review the detailed proposal, including access, phasing, trip generation, distribution, cumulative effects and proposed mitigation. Where a site has been allocated without specific SRN mitigation, National Highways may still seek further assessment, conditions, obligations or proportionate mitigation if the application evidence demonstrates a need.
However, application-stage mitigation should be grounded in clear evidence and should not generally be relied upon as a substitute for resolving strategic matters that could reasonably have been addressed through the Local Plan evidence base.
National Highways’ engagement in the planning system is not limited to its statutory consultation function. Through early and constructive involvement in plan-making, National Highways can help local planning authorities identify potential SRN matters at an early stage, support the development of proportionate evidence, and ensure that planned growth is supported by appropriate transport interventions where required. This is consistent with National Highways’ licence, which includes a requirement to “Support local and national economic growth and regeneration.”
Vision-Led Planning in Local Plans
National Highways aims to be a proactive partner in the planning system and has adopted vision-led planning within its policies. A vision-led approach to Local Plan preparation starts by defining the type of place the authority is seeking to create and the outcomes the Plan is intended to deliver. From the outset, this should include consideration of the role of roads and the SRN in supporting sustainable growth, particularly where existing or emerging capacity, safety or resilience issues may influence the location, scale or sequencing of development. In line with the Working with National Highways to deliver a vison-led approach for Local Plans guidance document, National Highways should therefore be consulted as the vision and spatial strategy are developed, so that SRN matters are considered alongside wider place-making, sustainability and growth objectives.
Transport planning should then be shaped around those outcomes, rather than being treated solely as a response to forecast traffic growth. In practice, this means planning development in locations and forms that reduce reliance on private car use, while maximising opportunities for walking, wheeling, cycling and public transport. Transport and land-use should therefore be planned in an integrated way, recognising that the location, density, mix and design of development strongly influence how people travel and whether everyday journeys can be made conveniently by active and sustainable modes.
Local Plans should prioritise well-connected, mixed-use developments and align site allocations with wider transport strategies and investment programmes, including Local Transport Plans (LTPs), Local Cycling and Walking Infrastructure Plans (LCWIPs), Rights of Way Improvement Plans (ROWIPs) and Bus Service Improvement Plans (BSIPs). This alignment will be important in demonstrating that any assumed shift away from car travel is credible, deliverable and supported by the right infrastructure.
Where the Plan seeks to reduce reliance on car travel, National Highways will need confidence that this is supported by credible and deliverable active travel and public transport infrastructure. This will help ensure that mode shift assumptions are realistic and that planned growth does not place unmitigated pressure on the SRN.
Preparation of a Local Transport Evidence Base
When producing the Local Plan, it is key to National Highways that any future development will not negatively impact the functionality and safety of the SRN, and that the transport evidence base ensures this. This is set out in Paragraph 26 of the DfT Circular:
In relation to the preparation of local plans and spatial development strategies, the government expects that the relevant authorities will engage with the company from the outset of this process, to understand the interaction between land use designations and the impacts on road safety and future performance of the SRN. The involvement of the company will ensure that the strategic transport evidence base will provide a robust assessment of any positive and negative impacts on the SRN and inform a transport strategy and the Strategic Environmental Assessment (SEA) for the study area that aligns with the safe operation and long-term integrity of the SRN.
It is important that the Local Plan is based on proportionate transport evidence which demonstrates that suitable schemes and mitigation have been considered, and will be implemented, that will shift demand into less carbon-intensive forms of travel. This is set out in Paragraph 33:
A robust evidence base will be required, including demand forecasting models, which inform analysis of alternatives by accounting for the effects of possible mitigation scenarios that shift demand into less carbon-intensive forms of travel.
The Local Plan should be produced in line with the Circular, paying due cognisance to its position as National Highways’ policy.
We expect the beginning stages of plan-making to be supported by baseline evidence for the highway networks across Cheshire East, with our focus being on the SRN.
This needs to set out current and future baseline information on the performance of junctions across the highway networks (end of plan period plus extant permissions). This could be informed by a strategic transport model. Baseline information on the current and expected performance of junctions across the highway networks (without the emerging Local Plan) is relevant to the selecting of sites for development and needs to be produced early in the process.
We are happy to be engaged with the scoping, calibration, and validation of this work, along with colleagues who manage and maintain the local highway network.
The Strategic Road Network in Cheshire East
Paragraph 4.4 of the scoping consultation page states that Cheshire East is a large unitary authority in north-west England, covering 1,166 km² with a population of around 421,300 (mid-2024). It has a lower population density than the national average and borders multiple neighbouring authorities, including Cheshire West and Chester, Warrington, Greater Manchester authorities, High Peak, Newcastle-under-Lyme, Stoke-on-Trent and Shropshire. Part of the borough lies within the Peak District National Park, where planning responsibilities rest with the National Park Authority.
In terms of connectivity, paragraph 4.5 of the page states:
“Cheshire East benefits from strong transport connections, with the M6 and M56 providing access to major regional and national destinations. Rail connectivity is centred on Crewe, a key national rail hub with direct services to many major UK cities, while Macclesfield and Wilmslow also have direct links to London. Manchester Airport, located on the edge of the borough, further enhances the area’s connectivity.”
Within Cheshire East, the Strategic Road Network (SRN) includes the following sections:
•
M6 motorway (from junction 16 to junction 20 Lymm Interchange)
•
M56 motorway (from junction 9 Lymm Interchange to Ringway, between junctions 6 & 7)
•
A556 from M6 Junction 19 Tabley Interchange to M56 Junction 7 Bowdon Interchange
These routes are of high strategic importance, with the M6 being one of the principal north-south strategic routes in the country, the M56 providing access to Greater Manchester and Manchester Airport, and the A556 providing a direct link between these two motorways.
National Highways’ Route Strategies set out National Highways’ plan for the SRN. They are a key research element underpinning the Road Investment Strategy (RIS), which informs the process of future road investment. The M6 motorway is included within the Route Strategy for ‘London to Scotland West (North)’. The M56 and A556 are included within the Route Strategy for ‘South Pennines (West)’. The respective Initial Overview Reports for the routes present analysis of current and future issues & opportunities, along with feedback received from customers and stakeholders.
Future growth within Cheshire East may therefore influence SRN demand through cumulative and cross-boundary travel movements. National Highways’ interest in the new Local Plan will focus on ensuring that the transport evidence base identifies whether planned housing and employment growth could affect the safe and efficient operation of relevant SRN junctions and corridors, including locations outside the CEC administrative boundary.
At this Scoping Consultation stage, National Highways would not expect the detailed assessment of potential SRN impacts to have been completed. The key requirement is instead to establish the principle that the emerging transport evidence base will need to be capable of assessing these matters as the Local Plan progresses, before spatial options and site allocations are fixed. This should include identifying the need to consider trip generation, distribution and assignment, existing network constraints, future traffic demand, cumulative impacts from multiple development sites, opportunities to reduce reliance on private car travel, and whether proportionate modelling, mitigation, infrastructure interventions or policy wording may be required at later stages.
Early engagement between CEC and National Highways will be important as the evidence base develops, with involvement from adjoining authorities where relevant to cumulative or cross-boundary impacts. This will help ensure that any SRN issues are identified at an early stage and can be addressed through the Local Plan, rather than deferred to individual planning applications.
Comments on Scoping Consultation
National Highways has reviewed the information published by CEC as part of the scoping consultation for the new Local Plan. Further transport evidence will be required as the Local Plan progresses.
At this stage, National Highways’ principal comments are:
•
National Highways is in the process of reviewing a number of Local Plan scoping consultations, as many Local Authorities are commencing the preparation of new Local Plans under the new system. It is noted that the level of detail provided in the CEC scoping consultation is lower than has been seen in other equivalent consultations, where more detail has been provided on the Local Plan matters, key issues and challenges, including analysis of Strengths Weaknesses Opportunities and Threats (SWOT). Whilst it is recognised that this is an early-stage scoping document, future stages of plan preparation should include a robust transport evidence base.
•
The spatial strategy should seek to align future growth with accessible locations and sustainable transport objectives, whilst ensuring that strategic connectivity is maintained and supported.
•
The Local Plan scoping consultation webpage states that the preparation of the Local Plan will be informed by a range of evidence, including the Local Transport Plan and the Manchester Airport Sustainable Development Plan. It also states that various new evidence documents are in production or are planned. This includes ‘Highways Network Modelling’. From National Highways’ perspective, the evidence base should demonstrate how planned growth can be accommodated whilst maintaining the safe, efficient and resilient operation of the transport network and SRN, including the M6, M56 and A556 corridors. Consideration should be given to cumulative and cross-boundary impacts, and freight movements.
•
National Highways should be involved in the development of the transport evidence base from an early stage, including through agreement of the scope, methodology, assumptions, assessment scenarios and modelling requirements.
•
The Local Plan scoping consultation webpage states that the Local Plan will need to encourage active travel both in new developments and existing areas. Where the Plan seeks to reduce reliance on car travel, National Highways will need confidence that this is supported by credible and deliverable active travel and public transport infrastructure. This will help ensure that any mode shift assumptions are realistic and that planned growth does not place unmitigated pressure on the SRN.
•
Where transport evidence is being prepared or updated for neighbouring authorities over a similar timeframe, there may be opportunities to align assumptions, assessment scenarios, modelling approaches and engagement arrangements across the local geographies. This would help ensure that evidence prepared for CEC can be integrated with future cross-boundary assessment and avoids duplication or inconsistent assumptions across overlapping Local Plan processes.
Future Engagement
We welcome further engagement with Cheshire East as you progress your Local Plan.
We would also like to share with you our Planning for the future – A guide to working with National Highways on planning matters, which is available from our website. This planning guide describes the approach we take to engaging with the planning system and the issues we look at when considering draft planning documents such as Local Plans.
We have also prepared a short explainer video outlining how we engage with planning, available on our website at https://nationalhighways.co.uk/roads-and-travel/road-projects/planning-and-the-strategic-road-network-in-england/.