Written evidence submitted by the Heathrow Strategic Planning Group (HEN0032)

Spelthorne Borough Council

Elmbridge Borough Council

Runnymede Borough Council

Surrey County Council

Royal Borough of Windsor & Maidenhead

Slough Borough Council

London Borough of Ealing

London Borough of Hounslow

Summary

1. This is an interim response by Heathrow Strategic Planning Group (HSPG) to the Transport Select Committee's enquiry on the draft Heathrow Expansion National Policy Statement (HENPS). HSPG is a partnership of local authorities surrounding Heathrow Airport.  This response has been prepared by the Partnership’s secretariat and consulted on with officers and elected members through June and July 2026.  Given the short timescales available for submitting of evidence to the Transport Select Committee, many members are still considering the background information and have yet to agree a final, formal position.  As such, this response should be taken as an interim position of the Partnership.
2. As a core principle, HSPG does not take a position on whether Heathrow Airport expansion should go ahead, but argues that if it proceeds, impacts on surrounding communities must be minimised and benefits maximised.
3. Areas of concern with the current draft HENPS presented in this response are:

• Lack of Environmentally Controlled Growth regime. A key recommendation to this response is the inclusion of an "Environmentally Controlled Growth" (ECG) regime, secured through the Development Consent Order (DCO) — binding limits that make further growth conditional on environmental and mitigation thresholds actually being met, rather than relying on post-consent monitoring and mitigation. A clear role for impacted local authorities must be provided in the governance of such a regime. This should build on best practice from the Luton Airport DCO.
• Clarity/enforceability: The draft lacks precision on the scheme's purpose and key attributes (notably in respect to runway length) and relies too heavily on post-consent mitigation rather than upfront, enforceable controls;
• Cumulative/in combination effects: There is a weak framework for assessing combined effects, especially given possible phased delivery and multiple promoters/DCOs running in parallel;
• Silent on coordinator challenge of multiple DCOs: Whilst recognising that any DCO put forward at the airport must be assessed against the HENPS on its own merits, where there is the potential for multiple DCOs to be brought forward (by different promoters) the HENPS must ensure that sufficient guidance is given to the applicants and stakeholders for Heathrow Expansion. The current draft HENPS lacks any guidance (or requirement) on how applicants promoting a DCO within the same geographic area and along similar timeframes should collaborate.
• Introduces tension in respect to affordability for airport users vs mitigation for communities: The draft HENPS appears to prioritise affordability for airport users over community mitigation. This risks undermining necessary mitigation measures; and weakening the role of the DCO process, as directed by the Planning Act 2008.
• Critical National Growth Infrastructure (CNGI) designation: CNGI status shouldn't override the need to avoid unacceptable risks to human health; "unacceptable risk" needs clearer definition within the HENPS.
• Four tests:
• Economic growth – this area needs mandated local benefit targets and clearer roles for delivery.
• Air quality – recommend changing multiple references around compliance from "should" to "must," recognition of WHO guideline compliance, full source apportionment, and removing the clause allowing deterioration without automatic refusal.
• Noise –a stricter night flight ban (ideally 23:00–07:00), WHO-aligned protections, binding noise envelopes, safeguards against weakened flight-altitude protections and unregulated Advanced Air Mobility.
• Climate – support the Carbon Management Plan requirement but offsets should be made mandatory (not voluntary) and better links to local decarbonisation projects.
• Evidence/methodology: Forecasts (especially surface access/mode-shift targets) are seen as overly optimistic and under-tested; recommends stress-testing against adverse scenarios.
• Surface access: Major concern over removal of "no more traffic" commitment, weakened mode-shift targets, and rail improvements too dependent on uncertain future funding and consenting, risking passenger growth outpacing sustainable transport capacity.
• Alignment with wider policy: Only partial alignment with Government transport, planning, and climate/environment policy — falls short of newer integrated, vision-led, and outcome-focused approaches.
• Legacy of 2018 legal challenges: the draft doesn't fully absorb lessons from prior litigation (air quality, noise, surface access, habitats, cumulative assessment).

a. The extent to which the draft HENPS provides clear and coherent guidance to the Secretary of State about how to assess a proposed scheme

4. The draft HENPS will help shape a more effective decision-making framework to (for instance on good design, growth and noise), but remains weakened by:

• Insufficient consideration to cumulative and in-combination effects. Expansion may be delivered over many years, potentially through multiple phases or even multiple promoters, while interacting with other major growth and infrastructure proposals across the sub-region. In such circumstances, the key question is not simply whether individual impacts are acceptable in isolation, but whether the combined effects remain acceptable over time. The absence of a clear framework for assessing and managing cumulative/in combination impacts sits uneasily with wider Government policy on integrated transport, strategic planning and environmental protection. HSPG considers that an Environmentally Controlled Growth regime would provide an appropriate mechanism for ensuring that cumulative impacts are monitored, controlled and linked to future growth decisions;
• Lack of precision about the intended purpose of the development in relation to UK aviation policy, the objectives of the required development, or the key attributes of the scheme (notably in respect to runway length and whether there will be a formal cap on future movements; and
• Lack of enforceable controls to prevent adverse impacts, particularly for communities in the area surrounding the airport, and heavy reliance on post-consent mitigation including balancing impacts and benefits over several decades of phased development and growth.

5. We also note that the draft also introduces some ambiguities that will be unhelpful to effective decision making unless they are clarified in the final version. For example:

• What are the implications of the statement that the HENPS covers development including “A Northwest Runway having a runway length of up to 3,500m and forming part of a scheme which, on completion, is capable of enabling at least 260,000 additional air transport movements (ATMs) per annum”? Does that mean that for a phased approach to be allowed there must also be a wider scheme of which the first phase forms a part? This inadequate precision can therefore be interpreted differently by promoters and stakeholders. Why is there no minimum runway length or maximum ATMs? 
• Does the DfT accept the view from Heathrow West about the practical obstacles (the necessary demolitions, the changes needed to rivers and lakes, the electricity substation, the rail head for fuel, the energy from waste plant) that would very significantly delay construction of a 3,500 m runway? If not, why? But if they do accept them, why is the long runway still considered the most deliverable scheme?
• What discussion have taken place with the CAA about their minimum expectations in terms of assumed inputs to the EIA, such as likely flight pathways? And what have the CAA stated as their minimum requirements to avoid a situation in which they challenge or raise questions about this during the examination? Also, discussions with UKADS about minimum expectations for updated 'indicative flightpaths' for the EIA (reflecting ANG/AND 2026 and strategy for the modernisation of London TMA airspace) and what the timescale for producing these is?
• The absence of any specific provision for the practical consequences of two promoters developing schemes in parallel. (e.g. on contributions towards mitigation measures including infrastructure)?

b. The robustness of the Government's evidence and rationale for the need for a third runway at Heathrow Airport

6. The partnership does not take a position on the merits or otherwise of the scheme.  However, if the airport is to grow then all members wish to see the negative impacts minimised and positive benefits, largely in respect to jobs, economic growth and the surrounding environment maximised.

7. The case for expansion must be contingent on;

• A comprehensive and integrated scheme for compensation and mitigation which is proportionate in scale to the impact of change and expansion at the airport, and with clear ongoing future funding certainty;
• Clear mechanisms to secure local economic benefits in practice (not just in principle) and a proper balance of impact and benefits at points throughout the phased growth and development;
• Robust controls (via an ECG regime) ensuring that environmental and community impacts are effectively managed so that increased operations are permitted only once the necessary measures are in place to limit their impacts (to those assessed within the envelope of the EIA undertaken); and

8. Without these safeguards being secured through a DCO, any strategic case, risks being achieved at disproportionate cost to surrounding local communities.

c. Whether it is appropriate for Heathrow expansion to be designated as Critical National Growth Infrastructure

9. Whilst HSPG recognises the Government's intention that Heathrow expansion should be treated as Critical National Growth Infrastructure (CNGI), that designation cannot and should not remove the need to demonstrate that unacceptable impacts on local communities are avoided, mitigated and effectively controlled over time and at end-state.
10. In particular, the draft HENPS does not clearly explain what constitutes an "unacceptable risk to human health" or how such a threshold would be assessed in practice across issues such as noise, air quality, climate-related impacts and cumulative/in combination environmental effects. In the absence of a robust Environmentally Controlled Growth (ECG) framework embedded within both expansion proposals and associated DCOs, there is a risk that adverse impacts are identified only after growth has occurred, leaving local communities exposed to potentially unacceptable harm.
11. HSPG considers that where expansion gives rise to unacceptable risks to human health, identified through the scheme assessments and the EIA, this should constitute an exceptional circumstance capable of outweighing any presumption arising from CNGI designation. The final HENPS should therefore provide a clearer definition of unacceptable risk to human health and require a binding ECG framework to ensure that operational growth remains contingent upon the achievement and maintenance of agreed environmental and health outcomes.  In the event that such a designation is provided, HENPS should make clear that this does not:

• Override the need for robust, high-quality mitigation measures. It is clear in the draft HENPS that a scheme promoter must demonstrate that they have followed the mitigation hierarchy, starting with avoidance principles.
• Weaken the primacy of the DCO process, in particular through references to affordability as a core consideration for the SoS (which can be interpreted as being in conflict with ensuring that all required mitigation to deliver the scheme in planning terms is secured and funded).

12. Mitigation should be directly related to the impact and delivered in a timely manner.

d. How effectively and robustly the draft HENPS sets out the assumptions and requirements of the Government’s ‘four tests’ for expansion, on:

• Economic growth across the country
• Air quality
• Noise
• Climate change mitigation

13. HSPG would offer the following response to each of the four tests:

Economic growth across the country

14. The explicit requirement to demonstrate delivery of local and regional growth is a major positive in the new draft statement.  The partnership also welcomes the retention of the commitment from government to review the apportionment and retention of business rates generated by the scheme.  The current arrangement is neither fair on our members who are hugely impacted by airport operations but receive no recompense; nor offers the best framework for incentivising all layers of government to leverage the private investment at the airport to deliver wider economic growth.
15. However, the framework should go further by:

• Mandating targets for local economic benefits;
• Clarifying roles of Heathrow, local authorities and Government in delivery with the aim of a much clearer joint plan for economic development in the sub-region. The draft HENPS gives insufficient attention to strategic cross-boundary planning across the Heathrow functional economic geography, including potential interactions between multiple DCO promoters, cumulative impacts and the role of local authorities in shaping growth outcomes. This sits uneasily with modern planning policy's emphasis on collaboration, strategic planning and place-making and risks missing opportunities to ensure that private investment at the airport is appropriately leveraged to deliver wider growth;
• Linking growth more explicitly to investment in surface access and other infrastructure (e.g. energy);
• Encouraging the promoter, and their supply chain, to support efforts to: (a) stimulate the local new build housing market, for example by supporting the piloting and scale-up of a new 'Employment Related Accommodation' (ERA) housing product; and (b) staff accessing good quality rental accommodation, for example by scaling payroll loans to support rental deposits. These measures should sit alongside wider measures to align measures to meet the housing needs over the different phases of the project such as repurposing of to-be-demolished hotels for short-term construction worker accommodation which would relieve some of the pressure on local housing stock and hotels; and
• Requiring the identification of benefits and development impacts at a series of key dates in the phasing and trajectory of ATM and passenger capacity growth.

Air quality

16. This response identifies significant weaknesses in the air quality provisions of the draft HENPS. While the draft acknowledges the potential for adverse impacts, it does not impose sufficiently robust and enforceable, requirements to ensure protection of public health, compliance with emerging statutory duties, or alignment with contemporary scientific evidence. The Air Quality section relies heavily on indicative analysis, non‑binding language, and assumptions that do not reflect operational realities or the cumulative impacts of construction and expansion.
17. The draft HENPS must be strengthened to ensure that Heathrow expansion does not worsen air quality (and indeed moves constructively towards achieving more stringent guidelines put forward by the World Health Organisation), increase exposure for vulnerable communities, or undermine local authority air quality management duties.
18. The shift from a requirement of compliance to a test of “not causing new breaches or materially worsening existing ones” represents a weakening of policy.

19. We recommend:

• Reinstating a clear requirement for compliance with UK legal limits; and no deterioration in exposure for vulnerable groups;
• Introducing a requirement for an air quality positive development that delivers a progressive improvement in air quality (recognising that UK standards are now considerably weaker than those proposed by the WHO and other bodies); and
• A mandatory air quality strategy and action plan, supported by detailed local modelling and monitoring (funded by the promoter), developed with local partners and secured through DCO requirements. The action plan should include tackling UFPs (ultrafine particles) using best available evidence, it should also safeguard provision for further future action to tackle UFPs if additional evidence about impact comes to light in the years following consent. The strategy should be based on defined minimum mitigation standards and enforceable commitments.

20. Without significant strengthening, the NPS risks enabling a scheme that increases pollution, increases exposure, and places unsustainable burdens on local authorities. There is therefore significant risk that the Government’s air‑quality test cannot be met under the current drafting.

Noise

21. We support:

• Requirement for a noise envelope;
• Recognition of emerging more sophisticated evidence on noise impacts for communities around airports (ANNE/ANAS 2026). However, this evidence now needs to be translated effectively in the HENPS (and a new related noise policy, thresholds, limits and nighttime restrictions) to ensure compliance in a DCO process.  There is also a need to move away from temporal metrics such as LAeq which can mask short term impacts. e.g. at the critical nighttime shoulder periods before 23:00 and 07:00;
• Commitment to predictable respite designed with effective engagement and consultation with the impacted communities; and
• The requirement for a night ban on scheduled flights.

22. However as currently drafted the noise section of the HENPS is insufficiently robust to ensure protection of public health and quality of life for communities affected by Heathrow expansion. It relies on optimistic assumptions, non‑binding language, and indicative modelling. Without significant strengthening, the HENPS risks enabling a scheme that increases noise exposure, reduces respite, and undermines community wellbeing.

23. In particular:

• The noise envelope should be fit for purpose and part of an Environmentally Controlled Growth framework;
• Following emerging evidence from the ANNE study related to public health the night ban on scheduled flights must protect the communities in the early morning hours. Ideally the night ban should be for eight hours, 23:00 to 07:00:
• The overall test that noise should be “no worse than 2024” is insufficiently ambitious and difficult to quantify or apply;
• There is reliance on management rather than control, with limited enforceability;
• No explicit prohibition/limitation is provided on multi-mode runway operations, a key concern of local communities and a threat to the respite afforded by a system of segregated mode runway (and flightpath) alternation; and
• Actual impacts remain highly uncertain given that the future airspace design work is yet to be undertaken, with indicative flightpaths dating from 2015 to be used for assessing impact. There is a very significant disconnect between these indictive flightpaths and future flightpaths, and airspace change through the advent of UKADS and post 2026 ANG / CAP 1616. The HENPS should facilitate better integration between these processes.

24. We recommend a stronger approach:

• No increase in impacts for most affected communities, and no new communities significantly impacted;
• No changes to noise protections from flying at 7,000 to 4,000 feet. Changes to these requirements are being considered in the context of the new Air Navigation Guidance. If changes are made it will lead to further divergence with the indicative flightpaths used in the DCO. Given the unique situation of Heathrow, the HENPS should make clear that this will not happen;
• The HENPS should require a distinct assessment of the economic case for any night-time operations against the physical and mental health, sleep disturbance, cognitive development and community impacts identified in emerging noise evidence. It is not clear that any new analysis has been undertaken on the economic benefits of night flights to the extent that their significant impact on communities can be properly justified; and
• There are insufficient safeguards around the potential impact of the future introduction of Advanced Air Mobility (AAM, heavily championed by Government and the UK aviation industry) at the airport.  The HENPS is silent on the subject. It should require promoters and those responsible for the relevant airspace processes to explain the strategy or the indicative provisions for passenger and cargo AAM at Heathrow and the wider campus or airport related development. There should be assurances that existing helicopter routes that remain available with the third runway will not be used as a basis for future AAM routeings (indeed some could not operate with the new runway) without further consultation and engagement with impacted communities, with local government given a clear role in any final decision.

25. The draft should be strengthened by:

• Replace all “should” with “must” in noise assessment and mitigation clauses;
• Require compliance with WHO night‑noise guidelines (8‑hour protection);
• Mandate full, multi‑scenario noise modelling including construction and operation overlap years;
• Require modelling of worst‑case meteorology, airspace changes, and fleet‑mix uncertainty;
• Require cumulative noise assessment across aircraft, ground operations, and surface access;
• Mandate binding noise envelopes with enforceable limits and population‑exposure caps;
• Protect and extend respite periods; certainly do not reduce them;
• Require a minimum 8‑hour night‑flight ban aligned with WHO guidance;
• Require Heathrow to fully fund local authority noise monitoring and enforcement;
• Require independent verification of noise modelling and mitigation performance;
• Require protection for vulnerable groups, identified through the HIA and EIA process (children, elderly, shift workers); and
• Require transparent reporting and real‑time noise monitoring accessible to communities.

Climate change mitigation

26. The requirement for a Carbon Management Plan is positive. However:

• The lack of an overarching Environmentally Controlled Growth regime means there are insufficient safeguards in place to ensure impacts above and beyond that assessed as part of the EIA are exceeded;
• Offset mechanisms to deal with (likely quite substantial) residual emissions appear to remain voluntary; and
• There is insufficient linkage to ensure support for local decarbonisation opportunities - e.g. supporting the removal of residual emissions with a presumption in favour of local carbon offsets.  These could include local nature-based solutions; support for zero emission vehicles; renewable energy infrastructure; low carbon heat; public estate decarbonisation etc.

27. We recommend:

• Stronger requirements for the carbon management plan to support in-setting/local carbon reduction projects for all residual emissions;
• Clearer demonstration of alignment with local and regional net zero trajectories; and
• Clear consequences for delivery failure.

e. How adequate the information published alongside the draft HENPS is, including its accuracy, comprehensiveness and methodology, and how effectively evidence and data have been reflected in the draft HENPS, including on cumulative impacts

28. The strategic appraisals undertaken are, by their very nature, high level and conclude a range of significant effects, from major beneficial to major adverse.  This should not replace more detailed studies and assessment which will be required by any promoter of a Heathrow Expansion DCO. These project level assessments should use the mitigation hierarchy to ensure adverse impacts are minimised, which starts with achieving a high-quality design (so impacts, where possible, are designed out at an early stage).
29. Regarding cumulative impact, any promoter of a Heathrow Expansion DCO, must comply with the Infrastructure Planning (Environmental Impact Assessment) Regulations 2017 (the EIA Regulations). This requires each Environmental Statement to assess cumulative effects with other existing and approved projects. Where two live applications share the same receptors, the Examining Authority will expect each applicant to account for the other's potential impacts. The draft HENPS however needs further clarification on how multiple competing DCOs should consider cumulative and in combination effects in both the construction and operational phases.
30. The final Aviation Night Noise Effects / Aviation Noise Attitude Survey is not incorporated. This could have significant impacts on UK noise policy and hence on the proposed thresholds and limits. In addition, new Air Navigation Directions (AND) and Air Navigation Guidance (ANG) will impact the indicative flight paths used for the impact assessment (with the potential for specific adverse changes for affected communities if there is a change to the protections currently in place for communities from aircraft flying below 7000ft). 
31. Whilst the “Making Best Use” policy doesn’t apply to Heathrow, the implication of this policy over time on supply and demand across the UK’s aviation sector – and specifically in London – will have implications for Heathrow.  It is not clear that this is fully considered, and whether appropriate thought has been given to how London airports as a whole can operate as a more integrated system to maximise benefits of aviation connectivity.
32. Finally, the lack of attention given to the implications of emerging technology, particularly Advanced Air Mobility, and its implications on a hub airport leaves a concerning gap in how infrastructure might cope in a future world which is very different today.
33. Overall, there is inadequate guidance around how the process will address two DCOs in parallel (from pre-application through submission, examination, condition discharge and construction/operation).

f. How robust are the methodology and data used for any forecasts or assumptions about the future underlying the analysis presented in support of the HENPS, and whether the range and use of scenarios in the document are appropriate

34. HSPG considers that the methodology and data used to support the forecasts and future assumptions in the draft HENPS are not yet sufficiently robust, transparent or comprehensive to give confidence that the full range of potential impacts has been properly assessed. The issue is not simply whether individual forecasts are reasonable in isolation, but whether the draft HENPS has tested the right range of future scenarios, uncertainties and delivery pathways for a scheme of this scale and duration. 
35. The draft HENPS relies heavily on assumptions about future demand, mode shift, technology, airspace change, night flight redistribution, carbon performance, surface access capacity and delivery of infrastructure. In several areas, those assumptions appear optimistic or insufficiently stress tested. Given the long timescales involved, and the possibility of phased development and more than one promoter, the policy should be more explicit about how uncertainty will be managed and how future forecasts will be updated, tested and enforced through the DCO process.
36. HSPG is particularly concerned about the treatment of surface access. The analysis does not appear to provide a sufficiently clear or realistic basis for understanding the transport impacts of expansion under different demand and delivery scenarios. The rationale for the proposed passenger mode share targets, and how those achieve the objective of minimising transport impacts of the proposal, is missing.  The targets are considerably less ambitious than set out in the previous policy, in particular given the removal of “no more traffic” reference and the fact that the target percentage mode shares remain the same as in 2018, even though the baseline has moved on considerably.  Previously stringent staff mode shift targets have been removed entirely, and no provision is provided for freight and construction trips to be proactively managed, other than in respect to an effort to “minimise” impacts.  Analysis suggests that, even where mode share targets are achieved, substantial (in the tens of thousands each day) additional car trips could still arise. The supporting analysis should therefore have provided a clearer understanding of how the proposed approached to mode shift targets had been derived, and the extent to which these ensure that severe impacts on the network are avoided.  Further comments on Surface Access are made in our answer to question G.
37. There are also concerns about the use of assumptions in relation to noise and airspace. The assessment appears to rely on indicative flight paths and assumptions about the redistribution of night flights that may not reflect eventual real-world operations. Future airspace design of the London Terminal Control Area (TMA), the role of UKADS, potential changes to Air Navigation Guidance and emerging evidence on noise effects could all materially affect the impacts experienced by communities. HSPG does not consider it sufficient for these uncertainties to be left largely to later processes without clearer safeguards in the HENPS to address the significant uncertainties.
38. On climate and environmental forecasting, HSPG welcomes the requirement for a Carbon Management Plan, but considers that the wider methodology should better address uncertainty around future technology, fuel uptake, operational performance, residual emissions and offsetting. Assumptions about future decarbonisation should not be used to reduce the need for enforceable mitigation or local carbon offsetting measures. There should also be clearer testing of cumulative and in-combination environmental impacts, particularly where more than one DCO may be promoted in parallel or where expansion is phased.
39. The range of scenarios used should therefore be broadened. At a minimum, HSPG would expect scenarios that test: delayed delivery of surface access infrastructure; lower-than-expected public transport mode share; higher car-based demand; different runway phasing options; different promoter models; alternative airspace outcomes; updated noise evidence; freight and cargo growth; slower aviation decarbonisation; and cumulative impacts with other major development and infrastructure schemes in the sub-region.
40. Overall, HSPG’s view is that the current scenario work is too narrow and too dependent on central-case assumptions given the uncertainties and extended timescales involved. For the HENPS to provide a sound basis for decision-making, it should require promoters to demonstrate that expansion remains acceptable not only under an optimistic or preferred forecast, but under credible adverse scenarios. Where outcomes depend on infrastructure, mitigation or behavioural change being delivered, those requirements should be secured as enforceable commitments, with clear triggers, thresholds and consequences. This again reinforces HSPG’s view that an Environmentally Controlled Growth regime is needed so that future growth is conditional on evidence that assumptions are being met in practice.

g. How comprehensive and realistic the requirements are in terms of environmental mitigation, supporting measures for communities who will be affected by expansion, and surface access to the airport

41. HSPG considers that the requirements are currently insufficiently comprehensive. While the draft HENPS contains positive elements, including references to mitigation, community support and surface access, the overall framework remains too reliant on post-consent monitoring and reactive mitigation rather than clear, enforceable controls that must be in place before growth occurs.
42. In particular, HSPG is concerned that the draft HENPS does not provide a sufficiently robust Environmentally Controlled Growth regime. Given the scale, duration and uncertainty of expansion — including the possibility of phased delivery, multiple promoters and changing future baselines — there needs to be a clear framework of environmental thresholds, triggers, caps and consequences. Without this, local communities risk bearing the impacts of underperformance while the promoter retains the benefits of growth. Expansion should only proceed in stages where the necessary mitigation has been delivered, environmental limits are being met, and independent oversight (including with input from local authorities) confirms compliance.
43. On environmental mitigation, the requirements should go further than monitoring and later intervention. HSPG would expect stronger provisions on noise, air quality, carbon, water, biodiversity, flood risk and construction impacts, with clear requirements secured through the DCO. Mitigation should be delivered ahead of impact wherever possible, rather than after harm has occurred. This is particularly important for noise insulation, where recent experience suggests that requirements must be set out clearly if delivery is to be reliable and adequately funded through the economic regulation regime.
44. On supporting measures for affected communities, the draft remains too limited. Compensation and mitigation should be proportionate to the scale of change experienced by communities around the airport and should include broader mechanisms to address both direct/in combination and cumulative impacts. Affected communities should not be expected to rely on uncertain future funding decisions or discretionary measures.
45. HSPG would support broader and more certain funding mechanisms, including mechanisms linked to airport-related revenues, to ensure long-term delivery of community benefits, compensation, environmental enhancement and local decarbonisation. Given the recent experience of having proposed spend by Heathrow between 2027 and 2031 on projects of community interest, notably in respect to noise insulation and surface it is access enhancements, deemed “unnecessary” by the CAA, it is key that the future community mitigation is robustly secured, outside of the vagaries of the current economic regulation system.
46. On surface access, HSPG has significant concerns. Whilst there is much to like in the wording used in both the Statement and the accompanying "Surface Access Vision" around making public transport the default choice for accessing the airport, the draft HENPS also appears to weaken previous ambitions for “no more highway trips” and mode shift to sustainable modes, and does not provide sufficiently binding requirements to ensure the infrastructure needed to support expansion comes forward in a timely way, or arguably at all.
47. To achieve the welcome objectives, it relies heavily on future plans, yet to be defined third-party investment and uncertain funding pipelines - particularly for essential rail enhancements. This creates a real risk that passenger growth could occur before any real enhancement to sustainable transport capacity is delivered, increasing congestion and imposing significant costs on residents, businesses and the general travelling public.
48. The removal of a clear “no more traffic” constraint is particularly concerning, as even meeting the proposed mode share targets could still result in substantial (tens of thousands a day) additional car trips. The removal of previously ambitious targets for staff mode shift, with a suggestion only that a "majority" should come by sustainable modes in future, when 48% (in 2024) already do so, is significant weakening that must be reviewed. 
49. Similarly, the removal of "no more traffic" to be replaced with a more subjective obligation to "minimise" traffic arguably reduces requirements to drive more efficient freight and construction trips, which have particular impacts on local communities and local authority highway assets.   The linking of targets to passenger numbers risks moving the requirement to deliver improvements to many years in the future – the suggestion that rail interventions will only be needed in some twenty years or more when the airport has delivered all elements of the scheme with the exception of the new T5 satellite terminal is particularly concerning.  This moves us a long way from the situation pre-pandemic where a DCO for a western rail link was being proactively progressed, with active plans for a privately funded solution for a southern rail link (identified as a "quick win" by the Airports Commission) also in flight. The Statement also needs to make absolutely clear that targets must be achieved before new capacity comes online.  The “backstop date” approach could be a useful tool to ensure certainty of delivery, further reassurance to communities could be provided if government made clear this would be within a maximum of two years beyond scheduled completion of relevant phases that bring enhanced capacity increases into effect.
50. HSPG therefore considers that surface access requirements should be strengthened by restoring a clear and objective constraint on traffic growth, linking capacity increases to delivery of sustainable transport infrastructure in a binding way (i.e. secured as a DCO Requirement), reinstating meaningful targets for staff and freight movements, and provide certainty and therefore reassurance to stakeholders of future funding via the establishment of a dedicated sustainable transport fund which will ensure resourcing is available to mitigate both identified and unexpected outcomes.
51. Surface access should also be treated not only as mitigation, but as a key mechanism for distributing the economic benefits of expansion more equitably across the wider sub-region.
52. Specifically considering rail, whilst the requirement for the promoter to produce a credible plan for delivery of required rail improvements is welcome, further detail is needed on what this needs to cover and when it needs to be in place.  We support the proposal made by the Heathrow Area Transport Forum that, at a minimum, the plan should include:

• a preferred rail solution, including detail on phasing and the rationale for prioritisation;
• an explanation of how any trade-offs affecting existing routes will be identified, rationalised and mitigated as far as practicable;
• detailed delivery arrangements, including consenting route and timeline;
• an identified credible promoter;
• a clear implementation timetable, ready to commence by the start as soon as possible or at the latest by commencement of Phase 1 of the expansion programme;
• robust funding and/or financing arrangements; and
• clear governance proposals.

53. Local authorities, alongside government departments, TfL and Network Rail/Great British Railways should be key consultees on the development of this plan. The plan should be provided as an integrated part of the Surface Access Strategy submitted for examination, so stakeholders can scrutinise it as part of the consent process. Delivery of the plan should be considered a condition of any consent granted. 
54. More could also be said on demand management to support the contention that this will be a truly vision led approach.  In particular, there should be a reaffirmation of support for the cap on parking numbers agreed through the Terminal 5 consent.  Workplace parking levy powers should be mentioned alongside Road Access Charging as a potential tool for supporting the optimum use of parking stock, particularly given much of this is outside the control of any promoter.  The NPS should set a strong preference for the greatest possible provision of road space for sustainable modes within both existing and new highways (particularly the existing northern and proposed Southern Road Tunnels) for buses and active travel.  This should also include schemes on the approach to the airport, funding for which should be provided by the DCO promoter (either up front via Section 106 or Section 278 commitments, or through our proposed ongoing Sustainable Transport Fund).  A clear commitment to tackle anti-social parking issues driven by airport users and workforce which continue to blight many of the surrounding communities should also be provided.
55. Promoters should also be required to give due regard to issues relating to network resilience and highway asset integrity.
56. Overall, HSPG’s view on environmental mitigation and surface access is that the draft HENPS sets out several important aspirations, but does not yet provide a sufficiently comprehensive, realistic or enforceable framework to ensure that environmental mitigation, community support and surface access will be delivered at the scale and pace required. The final HENPS should place stronger obligations on any promoter via the creation of a robust Environmentally Controlled Growth regime, give local authorities a clearer governance role in that regime, and ensure that growth is conditional on mitigation and infrastructure being in place before impacts arise.

h. How the Government’s decision to select the Heathrow Northwest Runway scheme to inform the review has affected the draft HENPS and is likely to affect potential promoters

57. HSPG offers no comment on behalf of possible promoters, however from a local planning authority perspective it is not clear whether an initial development phase for a (potentially much) shorter runway must be linked to a longer-term plan. This raises concerns about how planning blight might be managed and how multiple operators will be held to account for delivering required community mitigation.

i. How well the draft HENPS reflects Government policy on airports and aviation, and on other elements of broader a) transport, b) planning and c) climate and environment policy

58. We provide perspectives on the draft HENPS and wider government policy in Q J below.  On Transport, Planning and Climate and environment policy we offer the following comments.

a) Transport

Position: Partial alignment, but significant inconsistencies remain.

59. HSPG welcomes the greater prominence given to surface access, public transport connectivity and the recognition that Heathrow expansion must be supported by improvements to the wider transport network. However, we believe the draft HENPS does not fully reflect either the ambition or the delivery principles set out in the Government's recently published Better Connected: A Strategy for Integrated Transport. That strategy places strong emphasis on using transport to create better-connected places, aligning transport and development, empowering local leaders and ensuring that infrastructure is planned proactively to support growth. Ultimately it seeks to develop a sustainable transport network that works for all users.
60. The draft HENPS contains many references to these objectives, but, as we have set out in answer tin question G, the policy requirements fall short in several important respects:

• The surface access framework relies heavily on future plans, aspirations and monitoring rather than binding delivery mechanisms, to be provided upfront in order to embed highest possible public transport mode shares from day one;
• Proposed passenger mode share targets are weaker than previous policy positions and do not provide a clear constraint on traffic growth – indeed compliance with them would mean tens of thousands more cars on the road each day;
• Requirements relating to staff travel, freight movements and wider transport system performance are limited and, in most cases, significantly watered down from the existing NPS;
• Critical rail interventions remain largely dependent on future funding decisions and third-party delivery, despite the central role that sustainable transport plays in mitigating expansion impacts. As a consequence, there is a risk that a third runway Heathrow will be no better connected than it is today by train, with undoubtedly severe impacts on the local and strategic road network; and
• The framework allows substantial growth in passenger numbers before key public transport enhancements may be required, contrary to the integrated and vision-led approach promoted by national transport policy.

61. The Government's new transport strategy also emphasises partnership with local leaders and the importance of transport supporting wider place-making and economic development. HSPG considers that the draft HENPS misses an opportunity to establish a stronger strategic planning framework across the Heathrow sub-region and to provide impacted local authorities with a more formal role in transport governance and delivery.
62. As noted elsewhere the lack of any clear reference to seizing the opportunities of new technological advancements such as AAM also feels at odds with wider government policy, notably in respect to innovation and economic growth.
63. Overall, while the draft HENPS broadly recognises Government transport objectives, it does not consistently translate those objectives into enforceable policy requirements and therefore only partially reflects current Government transport policy.

b) Planning

Position: Broadly aligned in principle, but not fully consistent with modern planning policy expectations.

64. The draft HENPS contains several welcome updates which better reflect current planning policy than the 2018 Airports National Policy Statement. In particular, HSPG welcomes:

• Greater emphasis on good design and placemaking;
• Recognition of local economic growth and regeneration outcomes;
• Stronger references to biodiversity, flood risk and environmental enhancement; and
• The requirement for applicants to demonstrate how local economic benefits will be delivered in practice.

65. However, the National Planning Policy Framework (NPPF) places considerable emphasis on sustainable development, high-quality place-making, plan-led growth, cross-boundary collaboration, environmental enhancement and proactively coordinated infrastructure delivery.

66. HSPG is concerned that the draft HENPS does not fully reflect these principles because:

• It contains limited provision for (and gives little attention to) the opportunities that strategic planning across the Heathrow functional economic area could deliver. The draft does not adequately address how Heathrow expansion should contribute to wider local and sub-regional spatial planning objectives;
• It provides insufficient guidance regarding collaboration where multiple Heathrow expansion promoters may bring forward separate Development Consent Order (DCO) applications;
• It relies heavily on project-level mitigation and post-consent monitoring rather than setting clearer strategic requirements upfront; and
• It is not clear that impacted Local authorities are being given an appropriate governance role in matters where they possess statutory responsibilities and place-based expertise, including design review, biodiversity implementation and environmental monitoring.

67. The NPPF also increasingly supports a vision-led approach to infrastructure and transport planning. As noted above, HSPG considers that the draft HENPS remains closer to a traditional "predict and mitigate" model than one which actively shapes growth around agreed environmental and infrastructure outcomes.
68. The draft HENPS should explicitly recognise the current disconnect between land-use planning and airspace planning processes and seek to resolve some of these, given the importance of interactions in this particular geography. It could and should do more to improve the interaction between these regimes, particularly at a time when the airspace planning framework is changing through UKADS and when significant new noise evidence, policies, levels and limits have yet to be reflected in updated Air Navigation Guidance.
69. Accordingly, while the draft HENPS reflects many planning policy objectives at a strategic level, it does not yet provide a sufficiently integrated or place-based planning framework consistent with wider Government planning policy.

c) Climate and Environment Policy

Position: Partial alignment, but important gaps remain.

70. HSPG welcomes the fact that the draft HENPS has been updated to reflect significant changes in climate legislation policy since 2018, including the UK's Net Zero target, carbon budgets and wider environmental objectives. The inclusion of a requirement for a Carbon Management Plan and stronger references to biodiversity enhancement, nature recovery and flood resilience are positive developments.
71. The draft HENPS reflects the principles of Government climate and environmental policy but falls far short on their practical application for three principal reasons.
72. First, the framework remains heavily reliant on monitoring and mitigation after impacts have occurred, rather than embedding a clear system of environmental limits, controls and accountability. This contrasts with the wider policy direction towards outcome-focused environmental management and adaptive governance.
73. Second, although climate obligations are recognised, there remains excessive reliance on future assumptions regarding technology, operational efficiencies and carbon reduction pathways. The HENPS provides insufficient clarity on the consequences if these assumptions are not realised in practice.
74. Third, the draft does not sufficiently embed the principle that growth should be conditional upon environmental performance. The environmental appraisals accompanying the draft HENPS identify potentially significant adverse impacts across a range of environmental and health indicators. In HSPG's view, these findings strengthen the case for an Environmentally Controlled Growth regime which would link operational growth to demonstrable achievement of environmental thresholds. This approach would be more closely aligned with the Government's wider environmental objectives and emerging best practice from other airport expansion proposals.
75. There should be a genuinely integrated environmental framework. Carbon, air quality, noise, nature recovery, flood risk, water quality and health impacts should not be treated as separate mitigation workstreams to be resolved after consent. They should form part of a single enforceable environmental performance regime, with transparent thresholds, local authority oversight, independent scrutiny and clear consequences where agreed outcomes are not achieved.
76. In relation to air quality, HSPG is concerned that the draft HENPS appears to move away from a clear requirement to demonstrate compliance with legal limits and towards a narrower test of avoiding new breaches or material worsening of existing exceedances. That does not fully reflect the direction of environmental health policy, which should seek progressive improvement in air quality for affected communities. The final HENPS should require a mandatory air quality strategy and action plan, developed with local partners and secured through the DCO, including clear treatment of ultrafine particles and the cumulative effects of surface access, freight, construction activity and airport operations.
77. In relation to noise, HSPG is concerned that the draft HENPS does not yet adequately reflect the direction of wider Government aviation noise policy. The Government’s own evidence base is moving quickly, including the Aviation Night Noise Effects (ANNE) study and the Aviation Noise Attitudes Study (ANAS), both of which point to the need for policy to respond more fully to the lived experience, health effects and annoyance impacts of aviation noise. It is therefore concerning that the draft HENPS appears to settle on thresholds, limits and a “no worse than 2024” test before the full implications of that evidence have been translated into policy. Similarly, the HENPS does not provide sufficient clarity on how any future Air Navigation Directions or Air Navigation Guidance may affect the indicative flightpaths used for assessment, including potential changes to protections for communities below 7,000 feet.
78. This could mean that the scheme is deemed acceptable in planning terms based on a forecast which is very much removed from subsequent operational reality.  The final HENPS should therefore require any promoter to demonstrate how its noise assessment, noise envelope, respite proposals and mitigation package remain consistent with the latest Government noise evidence and airspace policy, rather than leaving these issues to be resolved through later processes.
79. Finally, the NPPF requires planning decisions to contribute to climate change mitigation and adaptation, avoid increasing flood risk, protect and enhance the natural environment and support the transition to a low-carbon future. While the draft HENPS acknowledges these objectives, it stops short of creating the enforceable framework necessary to ensure they are achieved throughout construction and operation.

j. To what extent the draft HENPS adequately takes into account changes in the context of airport expansion since 2018, such as, for example, current and future capacity at other airports, new legislative requirements, and developments in technology

80. HSPG feels this is a particular gap in the current NPS. Whilst the “Making Best Use” policy doesn’t apply to Heathrow, the implication of this policy over time on supply and demand across the UK’s aviation sector – and specifically in London – will have implications for Heathrow.  It is not clear that this is fully taken into account, and in particular whether appropriate thought has been given to how the London system in particular can operate in a more integrated way to maximise benefits of aviation connectivity. 
81. Finally, the lack of attention given to the implications of emerging technology, particularly Advanced Air Mobility, and its implications on a hub airport leaves a concerning gap in how infrastructure might cope with its introduction.

k. Whether the draft reflects lessons learned from legal challenges to the 2018 Airports NPS

82. HSPG considers that the draft HENPS only partially reflects the lessons from the legal challenges to the 2018 Airports NPS. It is recognised that the 2019 High Court challenges did not ultimately succeed on most of the grounds advanced, and that the Court accepted that a number of matters could lawfully be addressed in more detail at the DCO stage. However, HSPG does not consider that this should be read as meaning that the underlying issues raised by local authorities and communities have gone away. Many of the matters that formed part of the 2019 challenge remain live local authority concerns and should be addressed more clearly in the final HENPS.
83. Key amongst those issues were air quality, noise, surface access, transport infrastructure, habitats and wider environmental protection, the adequacy of strategic environmental assessment, the treatment of reasonable alternatives, and the realism of assumptions about mitigation and delivery. Although the courts found that the previous ANPS met the legal standard for a policy-setting document, local authorities remain concerned that reliance on later DCO processes can leave too much uncertainty for affected communities, particularly where impacts are long-term, cumulative and dependent on future infrastructure, airspace change and operational controls. Given the size and complexity of the DCO and potential adverse consequences arising from it there is an important role for government leadership here.
84. In HSPG’s view, the lesson from the previous litigation is not simply that the Government should make the HENPS more legally defensible. It is that the policy should provide greater clarity and certainty at the outset about how key environmental and community risks will be controlled. The draft HENPS should therefore do more than state that issues will be assessed later. It should set clearer expectations for what any promoter must demonstrate, what outcomes must be secured through the DCO, and what consequences will follow if assumptions are not met.
85. This is particularly important in relation to the issues that were central to earlier local authority concerns:

• Air quality: The final HENPS should provide stronger assurance that expansion will not lead to breaches or worsening of legal limits, and should require clear monitoring, intervention and improvement mechanisms;
• Noise: It should provide greater certainty on the noise envelope, respite, night flight controls, insulation and the treatment of future airspace change, rather than relying on indicative flight paths and later processes;
• Surface access: It should restore a clear constraint on traffic growth, require credible funded rail improvements that are linked in a binding way to expansion in capacity, and ensure that airport growth is directly linked to achieving significantly higher sustainable transport mode share;
• Habitats and environmental protection: It should provide clearer requirements for mitigation, enhancement, biodiversity net gain, water and flood risk, with an appropriate role for local authorities in oversight and approvals; and
• SEA, cumulative impacts and alternatives: It should more clearly explain how cumulative and in-combination impacts will be assessed, particularly if more than one DCO is promoted or expansion is phased.

86. HSPG also considers that the Government should learn not only from the Heathrow litigation, but from more recent airport DCO experience, including the Gatwick Northern Runway Project and particularly Luton. The Luton DCO demonstrates the growing importance of a Green Controlled Growth approach as a central mechanism for managing airport expansion within environmental limits. HSPG’s recommendation for an Environmentally Controlled Growth regime reflects this direction of travel and would provide greater confidence that expansion could only proceed where agreed environmental thresholds, triggers and mitigation requirements are being met.
87. Such a regime would help bridge the gap between the strategic policy level and the later DCO process. It would provide local authorities and communities with greater comfort that the issues which underpinned previous legal challenges are not simply deferred, but are actively managed through enforceable controls. It would also help reduce legal and delivery risk for promoters by making expectations clearer from the outset.
88. Overall, HSPG’s view is that the draft HENPS does not yet fully absorb the practical lessons from previous legal challenges. The fact that many grounds failed in court should not be treated as a reason to carry forward the same level of uncertainty. Rather, the final HENPS should use those challenges, and subsequent airport DCO experience, to strengthen the policy framework, clarify the role of local authorities, and require a robust Environmentally Controlled Growth regime as part of any future Heathrow expansion consent.

l. The effectiveness of the Government's consultation on the draft HENPS.

89. HSPG offers no substantive comment on this, however it has been noted by officers during our meetings that, given the very real and severe impacts of expansion undertaken in accordance with the current draft of the HENPS, the lack of direct engagement by officials and ministers with impacted communities is regrettable.

July 2026