Written evidence submitted by Logistics UK (HEN0040)

About Logistics UK

Logistics UK is one of the country’s largest business groups, and the only trade association which represents all of logistics. Our mission is to support, shape and stand up for a safe, sustainable and efficient logistics sector. Our membership of more than 22,000 includes global, national and regional businesses and SMEs spanning road, rail, waterways, sea and air freight, in ports, airports and warehousing, as well as the customers of freight services such as retailers and manufacturers. We deliver services, representation and thought leadership, helping members and policymakers to seize new opportunities for the sector and the economy as a whole, right across the country.

About the logistics sector

Nothing moves without logistics. The sector employs 8% of the UK workforce in good jobs with strong career progression, contributes £175 billion in GVA each year, and underpins the resilience of the everyday economy.

Logistics plans and coordinates the movement and storage of the goods that businesses, public services and households rely on – using ports, airports, roads, railways, waterways, warehouses and smart digital systems to tie it all together.

With the right policies, logistics can drive up UK growth by £8 billion a year.[1] However, rising costs, red tape and poor infrastructure are holding the sector back – putting firms out of business, fuelling inflation, and undermining productivity and supply chain resilience. As a result, the UK has fallen from 4th to 19th in the World Bank Logistics Performance Index over the decade to 2023.

Introduction

Heathrow's significance extends beyond passenger travel. Heathrow is one of the UK's most important international freight gateways and logistics hubs; it plays a critical role in supporting the movement of high-value, time-sensitive goods between the UK and global markets.

Logistics UK’s position is that:

• The economic case for expansion should place greater emphasis on freight, trade and supply-chain resilience.
• The draft Heathrow Expansion National Policy Statement (HENPS) should provide clearer recognition of air cargo as nationally significant infrastructure.
• The Government should strengthen requirements for surface access improvements that support both passenger and freight movements.
• Expansion should be assessed in terms of its contribution to UK-wide economic growth and international competitiveness.
• Heathrow's role as a strategic freight gateway supports the case for its designation as Critical National Growth Infrastructure.

Response to questions

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

The draft HENPS establishes an appropriate framework for assessing airport expansion for passenger operations, but it would benefit from stronger recognition of the movement of goods and the needs of UK supply chains.

Throughout the document, freight activity is often treated as a secondary consequence of airport operations. Freight is, however, a fundamental economic purpose of Heathrow's operation, which should be reflected accordingly within the policy framework.

Freight recognition

The final HENPS should explicitly recognise:

• Air freight's role in supporting UK trade.
• The importance of efficient customs, border and trade facilitation processes in realising the economic benefits of air freight.
• The need for supporting freight infrastructure to be developed alongside runway capacity.
• The importance of international connectivity for high-value manufacturing sectors.
• The contribution of cargo movements to national productivity.
• The role of airports within wider multimodal supply chains.

The Committee should recommend that freight outcomes feature alongside passenger outcomes when assessing the benefits of expansion.

Surface access

The HENPS should provide greater clarity regarding surface access expectations.

For logistics businesses, efficient access to Heathrow is critical. Congestion on surrounding strategic road networks can undermine reliability and increase operating costs for freight operators and their customers.

During both construction and latterly for the efficient movement of goods, rail freight offers a significant opportunity. The benefits of rail freight include reducing road congestion, improving air quality, reducing carbon emissions and building supply chain resilience.

The Government should therefore set clearer expectations regarding:

• Road and rail network performance.
• Freight access arrangements.
• The resilience and reliability of the Strategic Road Network serving Heathrow, including key freight corridors such as the M25 and M4.
• Integration with strategic rail freight infrastructure.
• Funding responsibilities for supporting transport improvements.
• Construction logistics arrangements, including opportunities to maximise the use of rail freight and reduce HGV movements on local roads.

Surface access should be considered an integral component of expansion rather than a consequential mitigation measure.

Carbon assessment

The draft HENPS should more clearly establish how proposals will be assessed against:

• UK carbon budgets.
• The statutory Net Zero target.
• Aviation sector decarbonisation pathways.
• Delivery assumptions regarding Sustainable Aviation Fuels and future aircraft technologies.

The current framework risks placing excessive reliance on assumptions about future technological change without sufficient clarity on how delivery risks will be managed.

Regional connectivity

The draft statement should better articulate how Heathrow expansion contributes to connectivity outcomes across all UK nations and regions.

The economic case should distinguish between:

• National economic benefits.
• National connectivity benefits.
• Benefits concentrated in London and the south.

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

Economic growth and international competitiveness

The strongest rationale for Heathrow expansion is its contribution to economic growth and international competitiveness.

As the UK's largest hub airport, Heathrow provides connectivity that supports inward investment, international trade and access to global markets. Capacity constraints risk limiting connectivity and reducing the flexibility required to support future economic growth. The Committee should also consider Heathrow's contribution to supply-chain resilience and economic security. Recent disruption to global supply chains has highlighted the importance of maintaining reliable international gateways for critical goods, including pharmaceuticals, medical equipment, high-value manufacturing components and other time-sensitive products.

The Committee should therefore assess whether the draft HENPS gives sufficient weight to:

• Economic growth.
• Export competitiveness.
• International trade.
• Foreign direct investment.
• Productivity benefits.

The strategic case for expansion is strongest when considered through these economic outcomes rather than passenger demand alone.

The draft HENPS should place considerably greater emphasis on freight.

Air cargo provides critical support for many sectors, including several highlighted in the UK’s Modern Industrial Strategy as being ‘highest potential’[2], including:

• Life sciences.
• Advanced manufacturing.
• Digital and technology.
• Defence.
• Other sectors including pharmaceuticals and high value retail.

Many of these sectors depend on reliable international connections and rapid movement of goods. £293 billion worth of goods move through Heathrow annually, which is more than a quarter of all UK trade by value[3]. This reflects the airport's role as a strategic national logistics asset. Realising the full economic benefits of this trade requires sufficient cargo-handling, warehousing, customs and border-processing capacity alongside runway expansion. The HENPS should therefore consider how supporting freight infrastructure will develop in parallel with increased airport capacity.

The Committee should recommend that the Government strengthen the evidence base relating to:

• Future air freight demand.
• Cargo capacity requirements.
• Trade facilitation benefits.
• Supply-chain resilience.
• The economic value of goods movement.
• UK’s need for trade routes for new market access eg Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP) countries.

Expansion should not be assessed solely as an aviation project; it should also be viewed as an investment in national trade and logistics infrastructure.

UK-wide economic benefits

The economic benefits generated by the airport extend across the United Kingdom.

Businesses throughout Scotland, Wales, Northern Ireland and the English regions rely upon Heathrow's international connectivity to access export markets and global supply chains.

The HENPS should therefore provide greater consideration of:

• UK-wide economic benefits.
• Impacts on domestic connectivity.
• The role Heathrow plays in supporting regional economic growth.
• How expansion contributes to national economic objectives.

Capacity constraints and night flights

Early morning arrival slots at Heathrow are economically valuable, particularly for long-haul passenger and cargo services that rely on overnight operations to connect UK businesses with global markets at the start of the working day. Further restrictions on night flights risk reducing the availability of these critical slots, while operational constraints at alternative airports mean that this demand cannot simply be displaced elsewhere. In addition, limiting early morning arrivals could exacerbate existing airspace congestion, increasing the need for aircraft holding patterns over Essex and East London where stacking capacity is already under pressure. Any assessment of night flight restrictions should therefore recognise both the economic value of early morning connectivity and the wider operational consequences for airspace efficiency. Consistent with ICAO Doc 4444 (PANS-ATM) [4], scheduled flight times should be assessed using the internationally recognised off-block/on-block definition when evaluating the impacts of any proposed restrictions.

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

Heathrow should be considered Critical National Growth Infrastructure.

Growth depends upon efficient movement of people and goods. Heathrow's role as a strategic gateway for trade and international connectivity means it performs a function that extends beyond the aviation sector.

Its importance to freight movements, exports, supply-chain resilience and inward investment provides a strong case for recognising Heathrow as infrastructure of national economic significance. As the UK's primary air freight gateway, it supports national trade flows, critical supply chains, inward investment and export growth across the whole of the United Kingdom. These characteristics are consistent with Government's wider objectives to promote economic growth, resilience and international competitiveness through nationally significant infrastructure.

Such designation should not diminish environmental scrutiny or stakeholder engagement. However, it should reflect the airport's strategic contribution to UK growth and competitiveness.

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

The Government's four tests should place greater emphasis on freight and logistics.

The logistics sector enables growth across all sectors of the economy. Improved international connectivity can support exporters, manufacturers and retailers throughout the UK.

The Committee should consider whether the HENPS sufficiently captures:

• Productivity gains from improved connectivity.
• Trade benefits associated with increased cargo capacity.
• Supply-chain resilience benefits.
• Wider economic impacts beyond the aviation sector.

A more comprehensive assessment of these benefits would strengthen the strategic justification for expansion

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

Logistics UK recommends that freight demand forecasts are assessed independently from passenger forecasts and are tested against a range of trade, economic growth and supply-chain scenarios.

In Section 8, ‘Combined Costs and Benefits’, of the Heathrow Expansion Appraisal Report[5], there is insufficient consideration of the benefits associated with air cargo and global trade. The assessment focuses on passenger and wider economic benefits but does not explicitly recognise Heathrow's critical role in facilitating international trade through air freight. As the UK's largest port by value of goods traded[6], Heathrow enables the movement of high-value, time-sensitive exports and imports, supporting business growth, investment, and connectivity to global markets. Failure to fully account for these trade-related benefits risks understating the overall economic value of airport expansion and is an incomplete appraisal of its costs and benefits.

The Committee should consider whether sufficient sensitivity testing has been undertaken in relation to:

• Future international trade patterns.
• Changes in supply-chain structure.
• Growth in high-value manufacturing sectors.
• Air freight demand.
• Technological developments and decarbonisation pathways.

Given Heathrow's role as the UK's largest air freight gateway, robust freight forecasting is essential to understanding the long-term economic case for expansion.

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

As per answer to (e).

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

Surface access requirements should be strengthened to ensure that both passenger and freight movements can be accommodated efficiently.

In particular, the HENPS should set clear expectations around:

• Construction logistics planning.
• Use of rail freight during construction.
• Minimisation of HGV impacts on surrounding communities.
• Management of freight traffic associated with airport operations.
• Delivery of supporting road and rail infrastructure.

Construction and operational impacts should be assessed with regard to both local communities and the efficient movement of goods.

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

Logistics UK does not take a view on the relative merits of alternative runway alignments or airport development options. However, whichever scheme is progressed should be assessed against its ability to support efficient freight operations, provide sufficient cargo capacity and deliver effective surface access for the movement of goods.

The HENPS should ensure that freight impacts and opportunities are considered consistently across any scheme brought forward.

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

The draft HENPS is broadly consistent with the Government's objectives to support economic growth, improve international connectivity and deliver nationally significant infrastructure. Heathrow's role as a strategic gateway for trade and investment aligns with wider ambitions to enhance UK competitiveness and growth.

From a logistics perspective, however, the draft HENPS would benefit from greater recognition of freight connectivity and the role of supporting infrastructure. In particular, the final HENPS should place greater emphasis on:

• The potential use of rail freight during the construction phase to reduce pressure on the strategic road network and minimise construction-related congestion, supporting both climate targets and the UK government’s rail freight growth target.
• Protection and enhancement of future freight connectivity to the airport, recognising Heathrow's role as a key international cargo gateway.
• Integration with wider strategic rail and freight networks to support efficient movement of goods and improve network efficiency.

The success of Heathrow expansion will depend not only on runway capacity but also on the effective movement of construction materials and future air cargo. As such, the HENPS should more clearly align with wider Government objectives for integrated transport networks, freight growth and sustainable infrastructure delivery.

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

The logistics, aviation and wider economic landscape has evolved considerably, including changes in global supply chains, trade patterns, technology and the increasing focus on economic growth and resilience.

From a logistics perspective, the draft HENPS appropriately recognises the continued strategic importance of Heathrow as a nationally significant gateway for international connectivity. However, it could give greater consideration to the role of freight and cargo in supporting UK trade and economic growth. Since 2018, supply chain resilience and the efficient movement of high-value goods have become increasingly important to businesses across the UK, highlighting the value of reliable international freight connections.

The draft HENPS would also benefit from greater recognition of developments in freight and transport infrastructure. In particular, there is an opportunity to strengthen expectations around the use of rail freight during the construction phase and to ensure long-term integration with the strategic rail freight network. This would support wider Government objectives to improve network efficiency, reduce congestion and enhance freight connectivity.

Expansion should be assessed not only in terms of aviation capacity, but also in terms of the economic and trade benefits enabled through improved freight connectivity.

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

It will be particularly important for the Government to demonstrate how consultation responses have informed the final HENPS, especially in relation to:

• Freight and cargo connectivity.
• Surface access requirements.
• Construction logistics and the use of rail freight.
• The wider economic and supply-chain impacts of expansion.

A transparent approach to responding to stakeholder feedback will help ensure confidence in the final policy framework and support the delivery of infrastructure that meets the needs of businesses across the UK.

Conclusion

The strategic case for Heathrow expansion is ultimately an economic one. While environmental impacts must be rigorously assessed and mitigated, the Committee should examine whether the draft HENPS sufficiently recognises Heathrow's role as a national asset supporting trade, exports, inward investment and high-value freight movement. The strongest argument for expansion lies not simply in accommodating additional passengers, but in enhancing the United Kingdom's international competitiveness and strengthening its position as a globally connected trading economy.

The Committee should therefore recommend that the final HENPS places greater emphasis on:

• Freight and cargo capacity.
• International trade benefits.
• Supply-chain resilience.
• Productivity impacts.
• Export growth.
• UK-wide economic benefits.

A revised statement with a stronger economic and freight focus would provide a more comprehensive framework for assessing the long-term national significance of Heathrow expansion. The Committee should also recognise that Heathrow's role as the UK's primary air freight gateway supports its designation as Critical National Growth Infrastructure.

July 2026