Written evidence submitted by the London Borough of Hillingdon (HEN0034)

Opening

1. Before responding to the detailed questions, it is important to recognise the very real impact that the continued promotion of a Third Runway has on local communities. Each Government announcement, consultation or policy review prolongs uncertainty for residents whose homes, businesses and neighbourhoods remain under threat. For many communities, this has been a source of blight, stress and frustration for decades.
2. Too many people have spent too long living with the consequences of a proposal that remains unresolved. The human impact of that uncertainty should not be underestimated and must no longer be a side issue of any consideration of Heathrow expansion.
3. Residents are being asked to sacrifice homes, health and quality of life for an economic case that the Government's own evidence struggles to substantiate. The claimed benefits remain uncertain, the supporting analysis has been subject to limited scrutiny, and the overall appraisal remains negative. That is not a credible basis on which to impose lasting harm on affected communities.

Background

4. The London Borough of Hillingdon is the host authority for Heathrow Airport and would be affected more than any other local authority by expansion through the Heathrow Expansion National Policy Statement (draft HENPS). We recognise Heathrow's economic importance, but our priority is to reduce the significant environmental and community impacts already experienced by our residents and to secure a fairer balance between the benefits and burdens of airport operations.
5. Expansion would move further away from that balance. The evidence points to significant additional harm for local communities, while the benefits remain uncertain, unevenly distributed and insufficiently evidenced. In our view, the case for Heathrow expansion has not been made.
6. We welcome the opportunity to provide evidence to the Transport Select Committee. While our submission is structured around the Committee's questions and the Government's four tests, these are not our only concerns. The evidence identifies a much wider range of impacts on communities, health, wellbeing and quality of life which are not adequately reflected in the draft HENPS. Our response to the draft HENPS consultation will address these issues in greater detail.
7. Should the Government nevertheless decide to proceed with expansion, the Council will continue to work constructively with promoters to secure the best possible outcome for our residents. That starts with rigorous scrutiny of the draft HENPS and robust challenge of how any scheme would be designed, delivered and operated. The draft HENPS must be a strong policy framework that protects communities and holds promoters to account, not a flexible mechanism designed primarily to make expansion easier to approve.

Summary

1. The case for expansion remains unproven. The Government's own appraisal identifies a negative Net Present Value, while wider economic benefits are uncertain and modest.
2. The draft HENPS lacks clear pass or fail criteria. It is unclear what would cause Heathrow expansion to be refused, even if significant adverse impacts arise.
3. Local communities are not sharing fairly in Heathrow's success. Despite hosting one of the world's busiest airports, nearby areas remain among the more deprived in London, with no mechanism to secure local jobs or supply chain benefits.
4. Community impacts are largely overlooked. The draft HENPS focuses on four tests and fails to properly address cumulative effects on health, wellbeing, quality of life and community cohesion.
5. The air quality test protects legal compliance, not public health. Pollution can increase provided legal limits are not breached, despite evidence that harmful effects occur below those limits.
6. The noise test permits redistribution of harm. New communities can be exposed to significant aircraft noise while overall airport noise metrics appear unchanged.
7. The climate test relies on uncertain future technologies and fuels. Many of the assumptions required for compliance are outside Heathrow's control.
8. Expansion depends on rail schemes that may become harder to deliver. The draft HENPS does not assess whether airport expansion could constrain Western Rail Access or Southern Rail Access, despite their importance to achieving modal shift targets.
9. Parliament is being asked to approve expansion without a credible transport delivery plan. There is no certainty on the interventions, funding or infrastructure needed to achieve the required public transport mode share.
10. Overall, the draft HENPS asks Parliament to approve a principle without defining clear limits, safeguards or failure points.

Structure of Response

8. Our response to the Transport Select Committee's call for evidence focuses on the Committee's key questions and is intended to assist its scrutiny of the draft HENPS. However, the Council has significant concerns with the draft HENPS and the decision-making framework it establishes. While this submission concentrates on the Government's four policy tests and a number of related matters, these represent only a subset of our concerns.
9. The Council will be responding robustly to the draft HENPS consultation and will set out a more detailed assessment of the policy's shortcomings. In particular, we will consider not only the four headline tests, but also the wider failings of the draft HENPS, including the extent to which it fails to recognise, assess and mitigate the full range of impacts arising from Heathrow expansion.

A Missing Community Impact Test

10. The Government has consistently focused on four tests for Heathrow expansion: economic growth, climate, air quality and noise. However, the Appraisal of Sustainability identifies a much wider range of impacts on local communities, including effects on health, wellbeing, quality of life, community cohesion, housing, access to services, stress and disruption. By elevating four selected tests above all others, there is a risk that these wider and cumulative impacts are marginalised in decision making.
11. We therefore recommend the introduction of a fifth Community Impact Test. This should require decision makers to assess the cumulative effects of expansion on the people who live, work and study around Heathrow, rather than considering individual impacts in isolation. The test should encompass physical and mental health, wellbeing, stress, community severance, displacement, quality of life, and the combined effects of multiple environmental and social pressures over time.
12. A Community Impact Test would ensure that the assessment of Heathrow expansion reflects the lived experience of affected communities. It would also provide a more balanced framework for decision making by recognising that the success of a nationally significant infrastructure project should not be judged solely against economic, climate, air quality and noise metrics, but also against its overall impact on the health and wellbeing of the communities expected to bear its consequences.

Current Relationship Between Heathrow and the Borough

13. Heathrow expansion is expected to deliver significant economic benefits, including new jobs, investment and growth for local communities. However, as shown on the map below, one of the world's busiest airports is surrounded by areas that continue to experience high levels of deprivation. This raises legitimate questions about how effectively the benefits of the existing airport are distributed and the extent to which neighbouring communities share in its economic success.

Source: https://dclgapps.communities.gov.uk/imd/iod_index.html#

14. The extract below from Trust for London’s 2025 analysis compares the city wide poverty profile with the previous 2019 iteration.  This shows that areas around Heathrow Airport have seen further decline. 

Source: Deprivation deep dive (4): Where has seen the biggest shifts in London? | Trust for London

15. There are currently no regulatory mechanisms requiring local employment outcomes or securing local supply chain benefits within surrounding authorities. As a result, claims that expansion will generate local jobs and prosperity should be considered in the context of an airport that already operates at a global scale, yet is located alongside communities that continue to experience significant socio-economic disadvantage.

Transport Select Committee Questions

Question 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

16. The draft HENPS does not provide a sufficiently robust decision-making framework for a project of this scale and significance. Whilst it identifies four tests relating to economic growth, air quality, noise and climate change, it fails to clearly define what constitutes compliance with those tests or the evidence required to demonstrate that they have been met.
17. More fundamentally, the draft HENPS does not explain how the four tests should be applied by the Secretary of State. It is unclear:

• Whether all four tests must be met.
• Whether failure of a single test should lead to refusal.
• Whether economic benefits can outweigh adverse impacts on air quality, noise or climate.
• What weight should be given to each test where there are competing outcomes.
• What are the economic objectives required to meet the test.

18. This is particularly concerning because designation of the draft HENPS would establish the principle of Heathrow expansion before a DCO examination takes place. The DCO process will focus primarily on the details of the scheme rather than revisiting the strategic case for expansion. The draft HENPS must therefore contain a clear, transparent and robust framework for decision making.
19. As drafted, there is a risk that the principle of expansion is approved before it has been demonstrated that the Government's own four tests can be satisfied. If these tests are intended to be genuine conditions of expansion, the draft HENPS should clearly state what constitutes a pass or fail and the consequences of failing any of them.

Question B:              The robustness of the Government's evidence and rationale for the need for a third runway at Heathrow Airport

20. The draft HENPS identifies economic growth and increased airport capacity as the primary rationale for expansion.   However, the economic case is not supported by a transparent, robust and independently scrutinised evidence base, which fundamentally undermines the justification for expansion. 
21. With regard to the economic benefits of expansion, the Appraisal of Sustainability (AOS) refers to 'new analysis' undertaken by Government.  However, it does not clearly identify, summarise or evaluate the economic modelling that underpins its conclusion of significant economic benefits.  There is no reference to an evidence base that supports the conclusions and no supporting literature included.  Nonetheless, even in the vacuum of clear evidence, the AoS is telling in that it concludes that the economic impacts at a local level are ‘mixed’ and at a national level are ‘uncertain’.  This is not an overwhelming endorsement. 
22. Separately, two updated economic reports have been produced to inform the draft HENPS.  These have been supplemented by a Literature Review and a Peer Review. 

Heathrow Expansion Appraisal Report (HEAR)

23. The Heathrow Expansion Appraisal Report (HEAR) identifies a range of benefits associated with expansion, including increased airport capacity, improved connectivity, passenger welfare benefits and wider economic impacts. The report estimates total monetised benefits of between £29.2 billion and £42.4 billion, largely driven by passenger benefits arising from increased choice, lower fares and reduced congestion.
24. However, when these benefits are assessed alongside environmental impacts, airport expansion costs and impacts on airline and airport profitability, the overall Net Present Value (NPV) remains negative in all core scenarios, ranging from -£23.4 billion to -£62.5 billion. The HEAR therefore does not conclude that Heathrow expansion delivers a positive economic case under the Government's conventional cost benefit appraisal framework.

Spatial Computable General Equilibrium Modelling of Capacity Expansion at Heathrow Airport (SCGE)

25. The HEAR nevertheless argues that the conventional appraisal may not fully capture the strategic value of a hub airport and is supported by complementary Spatial Computable General Equilibrium (SCGE) modelling. 
26. The SCGE analysis identifies a positive impact on UK GDP, principally through improved connectivity, trade and productivity, but the magnitude of the effect is extremely modest, amounting to approximately 0.05% of GDP by 2056.
27. The Peak Economics Peer Review of the SCGE found:

£19.6 billion (approx. 88%) of the GDP gain from expansion is due to expenditure on construction of the airport, and only £2.7 billion is due to the enhanced air connectivity the expanded airport offers.

28. Consequently, while the evidence suggests that Heathrow expansion may generate some wider economic benefits, neither the HEAR nor the SCGE analysis demonstrates transformational economic gains.
29. Taken together, the two assessments indicate that the justification for expansion rests primarily on strategic connectivity and competitiveness considerations rather than on a strong positive economic return in conventional appraisal terms

Supporting Economic Documents

30. The timing of the supporting documents is also problematic. The SCGE report was published after the consultation started and is dated 22 June 2026.  It is therefore difficult to see how this key analysis could have informed the AoS that was intended to support and justify the consultation proposals from the outset.
31. Further concerns arise from the peer review of the SCGE modelling dated 23 June 2026. The reviewer notes that the report was effectively an amalgamation of working papers developed during the project, that some methodological questions remained unanswered, and that details of the modelling were in places opaque or ambiguous.
32. Most concerningly, the peer reviewer states:

Whilst having sight of some earlier working notes, modelling results including the sensitivity tests were only made available to me on 4th June. This peer review has therefore been completed over a short timeframe of a week.

33. This raises legitimate questions about the depth and robustness of the scrutiny applied to work that appears to form a central component of the economic justification for expansion.
34. The scale of the impacts associated with Heathrow expansion demands an economic justification that is clear, compelling and beyond reasonable doubt. The evidence presented falls well short of that standard. Parliament should not be asked to endorse such significant harm on the basis of an economic case that remains uncertain and inadequately tested.

Question C:              Whether it is appropriate for Heathrow expansion to be designated as Critical National Growth Infrastructure

35. The Government's own appraisal concludes that the scheme has a "negative Net Present Value" when all impacts are monetised. In simple terms, the costs outweigh the benefits. If the evidence shows the country is worse off overall, it is difficult to understand how Heathrow expansion can be described as Critical National Growth Infrastructure.
36. The designation risks creating a perception that the conclusion has been reached before the evidence has been fully tested. Rather than demonstrating that Heathrow expansion is critical to growth, the Government appears to have assumed it is and built the policy framework around that assumption. The growth case remains uncertain and heavily dependent on forecasts, most of which are extremely modest.  In contrast, the impacts on noise, air quality and carbon emissions and wider community and environment effects are significant, measurable and largely undisputed.
37. The real concern is the prejudicial effect of the CNGI designation. By labelling the scheme as "critical" before the Government's four tests have been shown to be met, the planning balance is tilted towards approval from the outset. The question becomes not whether expansion should proceed, but how it can be made to proceed. That risks reducing the tests on economic growth, air quality, noise and climate change to exercises in mitigation rather than genuine requirements that must be satisfied.

Question 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               [Test 1]
•                                                                                                                                                            Air quality               [Test 2]
•                                                                                                                                                            Noise               [Test 3]
•                                                                                                                                                       Climate change mitigation                             [Test 4]

Test 1:              Economic Growth Across the Country

38. The economic growth test is arguably the least clearly defined and least robust of the four tests.
39. A fundamental weakness is that the draft HENPS never properly defines what the test actually is. It repeatedly refers to supporting economic growth across the country, but there is no objectively measurable threshold against which compliance can be tested. Unlike air quality, which has legal limits, or noise, which has identified thresholds and contours, there is no economic benchmark that a promoter must satisfy. The test therefore risks becoming impossible to fail.
40. The draft HENPS largely assumes that Heathrow expansion delivers economic growth because Heathrow is a major international hub airport. However, the draft HENPS presents little evidence that the specific proposal under consideration will generate net additional national economic growth rather than simply redistribute economic activity from one part of the country to another.
41. This is particularly concerning given that the Appraisal of Sustainability itself recognises uncertainty regarding national economic impacts and notes that some economic activity may simply move location rather than represent wholly additional growth. The distinction between redistribution and genuine national growth is critical, yet the draft HENPS appears to gloss over this issue.
42. The test also fails to define:

• how much economic growth is required;
• over what geographical area growth should occur;
• whether redistribution of activity is acceptable;
• what level of confidence is required in the forecasts; and
• what evidence would be sufficient to demonstrate failure.

43. As drafted, almost any claimed economic benefit can be presented as satisfying the test.
44. The economic case is further weakened by the emergence of remote working, digital connectivity, and changing business travel patterns since the Airports Commission first developed much of the original economic rationale. The draft HENPS largely relies on assumptions that long term economic growth remains heavily dependent on increased aviation capacity, despite profound structural changes in how businesses operate.
45. In effect, the economic growth test is not a test at all. It lacks measurable criteria or a point at which failure can be defined. Without a defined threshold for success or failure, the test risks becoming little more than a presumption that expansion delivers economic benefit, irrespective of what the evidence ultimately shows.

Test 2:              Air Quality

46. The air quality test is fundamentally flawed because it is based on legal compliance rather than health protection.
47. The draft HENPS effectively asks whether a future DCO application can demonstrate that Heathrow expansion will not result in new breaches of air quality limit values. This creates a very low threshold for success.
48. The World Health Organisation advises that there is no safe level of air pollution and modern public health evidence is clear that impacts occur even below legal limit values. The WHO has repeatedly concluded that no threshold has been identified below which particulate pollution can be considered harmless.
49. The draft HENPS completely fails to acknowledge this fundamental point.
50. Instead, the policy creates a situation whereby expansion can increase pollution substantially, provided legal limits are not exceeded. This is particularly problematic in locations where existing pollution concentrations are significantly below legal thresholds. In those areas Heathrow could materially increase pollution exposure while still passing the test.
51. The test also assesses future operations against legal standards that exist today. Heathrow expansion is expected to operate for many decades, potentially until the end of the century, yet the benchmark remains today's regulatory framework. There appears to be little consideration of whether those standards remain appropriate over the lifetime of the project.
52. A further concern is that UK legal limits remain materially weaker than those increasingly being applied elsewhere.

53. The result is that Heathrow expansion could pass the draft HENPS air quality test while exposing local communities to levels of pollution that would not be considered acceptable under more stringent international standards. 
54. To illustrate this point, the data below has been taken from the London Heathrow Bath Road air quality monitoring station for a single day in January. The recorded 24-hour mean PM2.5 concentration was 32.3 µg/m³. While this would not constitute an exceedance under current UK air quality objectives, it would count towards the 18 exceedances/year of the 24-hour mean PM2.5 limit (25 µg/m³) introduced under the revised EU Ambient Air Quality Directive, which comes into effect from 2030.  It is more than double the recommended WHO 2021 guideline level.

55. However, the draft HENPS does not require assessment against the EU standard and, therefore, such an obviously high level of pollution would not necessarily be identified or treated as significant within the policy framework used to assess Heathrow expansion.  Nonetheless, given the position in the EU and at the WHO, the levels represent harmful degrees of air pollution.   
56. This creates a clear contradiction with wider Government health policy, which seeks to reduce avoidable exposure to harmful pollutants.
57. A truly robust air quality test would:

• seek continuous improvement rather than regulatory compliance;
• align with best available public health evidence;
• recognise that health effects occur below legal limits;
• require measurable reductions in exposure; and
• assess future operations against future health expectations rather than current minimum legal standards.

58. The draft HENPS does none of these things.

Test 3:              Noise

59. The noise test is perhaps the most problematic of all four tests.  At its core, the test is based on a simple proposition:

Heathrow expansion should not result in greater overall aircraft noise exposure than the 2024 baseline.

60. This appears reasonable at first glance. However, closer examination reveals significant weaknesses.  The first issue is that the assessment relies on sub regional aggregate noise exposure rather than individual community impacts.
61. This allows large noise increases in some communities to be offset by reductions elsewhere.  Consequently, a community that currently experiences little or no aircraft noise could become heavily affected in the future while the overall Heathrow noise contour still satisfies the test.
62. In practical terms, this means the policy can create entirely new populations exposed to aircraft noise while claiming overall success.  The second problem is that the draft HENPS never demonstrates that the 2024 baseline is itself acceptable.
63. The policy assumes that 2024 represents a suitable benchmark but provides no evidence that current Heathrow noise exposure levels are consistent with modern understandings of health protection.
64. Recent evidence from the Aviation Noise Attitudes Survey demonstrates that people are highly annoyed at significantly lower noise levels than previously assumed. The research indicates that adverse effects occur well below many of the thresholds that currently drive Heathrow's mitigation regime.
65. As a result, many communities are already experiencing noise related harm without receiving meaningful mitigation. This means that:

• the benchmark contains existing unmitigated harm;
• the benchmark is not demonstrated to be acceptable; and
• expansion is being assessed against an already harmful baseline.

66. The third issue is that much of the claimed future improvement comes from fleet modernisation and quieter aircraft rather than from Heathrow's own mitigation measures.  The Noise Annex demonstrates that future two runway Heathrow scenarios already achieve substantial reductions in noise exposure because aircraft become quieter.  Expansion then erodes part of those improvements.
67. Therefore, it is misleading to present future noise reductions as a benefit of expansion. Much of the improvement would happen anyway.
68. The noise test is also inconsistent with the latest evidence regarding annoyance and health effects. The existing Heathrow noise management approach largely reflects historic thresholds established before the latest national evidence became available. Yet the new evidence suggests that many more people may experience harm than the draft HENPS acknowledges.
69. The noise test is not measuring whether expansion produces acceptable noise outcomes. It is merely measuring whether expansion remains no worse overall than an already problematic baseline.

Test 4:              Climate Change Mitigation

70. The climate change test suffers from a similar weakness to the economic growth test.  It is far from clear what would constitute failure.
71. The draft HENPS largely relies on assumptions regarding future technological developments, operational efficiencies and wider decarbonisation across the aviation sector.
72. However, many of these factors are outside the direct control of Heathrow Airport and outside the scope of the development consent process.  The policy therefore depends heavily on uncertain future developments to demonstrate compatibility with carbon reduction objectives.
73. There is also a significant risk that assumptions which appear reasonable today may prove unrealistic over the lifetime of the project.  The climate test consequently relies on future performance rather than present certainty.

Sustainable Aviation Fuel

74. Sustainable Aviation Fuel (SAF) is often presented as a key solution to reducing aviation emissions, but there is growing competition for the same feedstocks from other sectors seeking to decarbonise. The dominant SAF production route, HEFA, relies on waste oils, used cooking oil and animal fats, which are also used to produce Hydrotreated Vegetable Oil (HVO), a renewable diesel increasingly adopted by industry and power generation.
75. A clear example is the rapidly expanding data centre sector. In one Hillingdon scheme, 16 standby generators were proposed, each containing around 31,000 litres of HVO, representing almost 500,000 litres of fuel on a single site. As data centres continue to proliferate, particularly in west London, demand for HVO is likely to increase significantly. A litre of waste oil can become either HVO for backup power generation or SAF for aviation, but it cannot be both. Policymakers should therefore recognise that SAF is competing for a finite pool of feedstocks with other sectors that are also under pressure to reduce their environmental impact, raising questions about long term availability, cost and sustainability of supply
76. A more robust approach would require clearer demonstration of how expansion aligns with carbon budgets under more pessimistic scenarios, rather than primarily relying on optimistic assumptions regarding technological change and future decarbonisation pathways.

Conclusion

77. Across all four tests, a common weakness emerges. The tests are framed in a manner that makes them extremely difficult to fail.

• The economic test lacks a measurable benchmark.
• The air quality test is based on legal compliance rather than health protection.
• The noise test compares future impacts against an already harmful baseline and permits significant redistribution of harm.
• The climate change test relies heavily on uncertain future technological developments.

78. Taken together, the four tests are better at explaining how Heathrow expansion might be approved than how it could be refused. They establish no clear limits, no meaningful failure points and no objective basis for determining when the impacts become unacceptable. Parliament is being asked to approve a framework that contains no obvious mechanism for saying no.

Question 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

79. The draft HENPS does not provide Parliament with sufficient certainty that communities and the environment will be adequately protected. Whilst it contains a series of policy tests and mitigation requirements, many are expressed as aspirations or future obligations rather than clear, enforceable safeguards. There remains considerable discretion for a future promoter to argue how impacts should be managed, leaving significant uncertainty over what level of protection affected communities will actually receive.

Surface Access

80. Surface access is a particular concern. Parliament is effectively being asked to approve a policy framework without knowing whether the proposed public transport mode share targets are achievable, what interventions would be required to deliver them, or what the consequences would be if they are not met. There has been no clear assessment of whether the targets are realistic, nor what measures may ultimately be needed, including potentially punitive charging regimes for private vehicle access to the airport.
81. Fundamentally, it is unclear what Parliament is being asked to approve. The Government's accompanying surface access vision acknowledges the importance of rail connectivity and identifies a range of potential interventions, yet there is no committed programme, funding mechanism or delivery strategy in place.
82. The absence of a strategic and integrated transport plan is particularly concerning in relation to Western Rail Access to Heathrow.  As shown below, previous proposals for the route relied on safeguarded land between the M25 and Terminal 5 for construction and delivery.
83. As shown on the extract below from the Heathrow Expansion masterplan (Draft draft HENPS Annex B) The land required for construction outlined above will no longer be available if airport expansion proceeds. The expansion proposal may therefore place a significant impediment to the cost effective delivery of both Western Rail Access and Southern Rail Access because new runway, taxiway and terminal infrastructure, along with river diversions, would be situated around the safeguarded rail connections at Terminal 5.

84. The expansion proposals would reduce the space available for the shafts, construction compounds and tunnelling works needed to build future rail links and undermine previous plans.  Whilst there may be engineering solutions to overcome these constraints, the loss of this land invariably makes the delivery of the rail connections more complex, costly and difficult to deliver.
85. From the information provided, Parliament is likely to anticipate that rail interventions such as Western Rail Access and Southern Rail Access would help support Heathrow expansion and facilitate the required modal shift to public transport.  This is consistent with the wider surface access vision underpinning the policy framework. However, the draft HENPS does not require an assessment of whether those schemes remain technically deliverable following expansion, nor whether the proposed runway, taxiway and associated airport infrastructure constrain future construction access to the safeguarded rail connections at Terminal 5. This applies equally to both Western Rail Access and Southern Rail Access.

86. Consequently, Parliament will have no clear understanding of what engineering measures, additional infrastructure, cost or complexity may be required to deliver the principal rail schemes expected to facilitate the modal shift on which the expansion case relies.

Question 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

87. By basing the review on the Heathrow Northwest Runway scheme whilst simultaneously allowing alternative promoters to advance competing proposals, the draft HENPS has created uncertainty rather than clarity. Instead of providing a clear direction of travel, it effectively opens the door to more than one promoter pursuing different schemes, leaving communities caught in the middle.
88. This lack of a definitive decision from Government is increasing confusion, frustration and blight for affected residents. In some cases, homeowners face the prospect of engagement with two separate promoter teams and legal processes relating to compulsory purchase. In others, properties may be affected by one scheme but not another, creating significant uncertainty about future homes and neighbourhoods. The position is unsatisfactory for communities and local authorities alike. Concerns have been raised directly with the Secretary of State, but no response has been received to date

[see Hillingdon Letter to Secretary of State: Two Promoters].

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

89. The consultation has not, in our view, met the standards expected for a nationally significant infrastructure proposal of this scale. On 3 June 2026 local authorities were invited to comment on the proposed consultation approach ahead of an unspecified launch date. On 10 June 2026, the Council responded with concerns raised regarding the limited scope of engagement, the need for more in-person events, and the lack of clarity for communities facing multiple Heathrow-related expansion proposals from competing promoters. No response was received and the consultation commenced on 18 June.  No such in-person events have been arranged or advertised.
90. The previous ANPS was subject to a considerable engagement:

• Independent oversight
• An Independent Consultation Adviser (Sir Jeremy Sullivan) was recruited to ensure good practice.
• Events
• 20 public local events in affected areas
• 12 regional stakeholder events across the UK 
• Target Communication
• Focus on 17 local authority areas likely affected by noise impacts
• Input from local authorities on venues and publicity
• Publicity and outreach
• Radio and newspaper advertising
• 1.5 million leaflets distributed locally
• Digital advertising and search optimisation
• Targeted engagement with minority communities via specialist outreach
• Support and access
• Freephone helpline for information and document requests
• Multiple response channels:
• Online form
• Email
• Freepost

91. Given the complexity, scale and local significance of Heathrow expansion, the latest consultation relies too heavily on written material and provides insufficient opportunity for meaningful public engagement.  Carrying it out over the summer holidays is also against good practice and the principles of effective communication. 
92. This is particularly concerning given the Government's decision to allow multiple promoters to pursue alternative schemes.  Whilst we understand that the Government position is that this is just a reaffirmation of an existing policy, it does introduce some major changes, notwithstanding the time elapsed from the previous consultation.  Unlike the previous consultation, communities are now being asked to engage with a policy framework that supports more than one expansion proposal, each with potentially different impacts.
93. Dealing with a single expansion proposal is challenging enough. Expecting communities to understand and respond to two competing schemes without any meaningful face-to-face explanation from Government risks turning an already complex consultation into an incomprehensible one.

Further Commentary:              Ongoing scrutiny of Heathrow Airport operations

Committee for the Independent Scrutiny of Heathrow Airport (CISHA)

94. We value the role of CISHA and recognise its ability to secure information and challenge Heathrow Airport Limited (HAL). However, scrutiny without powers can only go so far. Effective oversight requires independent regulation and the ability to enforce change.
95. More than 15 years after Terminal 5 opened, there is still no robust regulatory framework that adequately protects communities from the impacts of Heathrow's operations. Too often, the airport has appeared to set its own targets, assess its own performance and judge its own success.
96. This has damaged public trust. Many residents believe the system is weighted in favour of the airport, with community, environmental and public health impacts consistently taking second place.
97. For example:
1. noise mitigation has not kept pace with where impacts are experienced.  The evidence shows that annoyance and significant health effects occur at much lower levels.  The noise insultation and mitigation packages have not been required to keep pace with the changing social response to aircraft noise. 
2. There is no regulatory requirement on Heathrow Airport Ltd to achieve air quality standards around the airport or support public transport measures to reduce pollution. 
3. As set out above, there are no requirements on the airport operators to secure economic benefits in the communities it impacts the most. 
98. CISHA has an important role to play, but communities should not be expected to rely on scrutiny alone. Before any further expansion is considered, Heathrow Airport should be subject to much stronger statutory controls, independent oversight and meaningful enforcement. The experience since Terminal 5 shows that self-regulation has failed.

How to improve the draft HENPS

1. Define clear pass/fail criteria for each of the four tests. Parliament should know what level of economic benefit, air quality impact, noise impact and climate impact would be sufficient to justify expansion, and what level would result in refusal.
2. Include a fifth Community Impact Test. Expansion should only proceed where the cumulative effects on health, wellbeing, quality of life, housing, community cohesion and displacement are demonstrated to be acceptable.
3. Require health-based air quality assessment, not just legal compliance. The final HENPS should require continuous improvement in air quality and consideration of emerging international health standards over the lifetime of the airport. Air quality neutral, i.e. no worsening of the existing position should be a minimum starting point. 
4. Prevent the redistribution of environmental harm. Noise and air quality assessments should demonstrate that impacts are acceptable at a community level and not simply offset by improvements elsewhere.
5. Require a credible and deliverable carbon reduction pathway. Compliance should not depend primarily on optimistic assumptions regarding future technology, sustainable aviation fuel availability or wider sector decarbonisation.
6. Require a fully costed and deliverable surface access strategy. Expansion should not be approved unless the transport interventions needed to achieve the required public transport mode share are identified, funded and capable of delivery.
7. Demonstrate that key rail interventions remain deliverable. The final HENPS should include assessment of whether Heathrow expansion constrains the practical delivery of Western Rail Access and Southern Rail Access, including any additional engineering works, cost or complexity created by expansion.
8. Secure local economic benefits. The final HENPS should require measurable commitments for local employment, apprenticeships and supply chain opportunities so that communities hosting the airport share fairly in its economic success.
9. Provide stronger independent oversight and enforcement. Mitigation measures should be subject to clear regulatory controls, independent monitoring and meaningful sanctions where commitments are not achieved.
10. Make clear that failure of any key test may justify refusal. The final HENPS should operate as a framework for decision making, not simply a framework for mitigation.

July 2026