Written evidence submitted by Airports UK (HEN0045)

 

About AirportsUK

 

  1. AirportsUK is the trade association that represents UK airports with a mission to see UK airports grow sustainably. AirportsUK represents the views of over 50 UK airports to government, Parliament and regulators to secure policy outcomes that help deliver its mission. For more information, please email petercampbell@airportsuk.org.

 

About the UK airports sector

 

  1. According to CAA data, UK airports served a record 302m passengers in 2025 and carried almost 2.7m tonnes of freight, connecting the country with around 470 international destinations in 104 countries, As an island nation, these links to global markets are vital to support the UK’s businesses, to help friends and family remain in touch, and to support the visitor economy, both domestically and abroad.

 

  1. According to research conducted by Steer for AirportsUK, this connectivity means that Aviation contributes £159bn in gva (6.4% of the national economy) and supports almost 1million jobs.

 

Introduction

 

  1. AirportsUK is pleased to be able to contribute to the House of Commons Transport Committee’s scrutiny of the government’s Heathrow Expansion National Policy Statement (HENPS). HENPS provides a solid framework, and we would encourage the TSC to acknowledge that timely delivery is essential to providing certainty for communities, the regulator, government, and industry, enabling informed decision-making and long-term planning.

 

  1. Heathrow's expansion should be supported through an appropriate and balanced HENPS because a globally competitive hub strengthens the UK's entire aviation network. The HENPS should be carefully drafted to ensure that requirements relating specifically to Heathrow are not interpreted as wider policy tests applicable to all airport expansion proposals. Any policy tests associated with expansion should also be proportionate, deliverable and cost-effective, supporting the successful implementation of a third runway while remaining appropriate for the wider sector.

 

  1. Current capacity constraints at Heathrow are limiting the UK’s economic potential, with the airport running effectively at capacity for the last 15 years, and therefore losing connectivity, particularly to underserved South American destinations and secondary cities in India and China. Every year of delay to expansion is estimated to cost consumers £3bn, rising to £40bn for a ten-year delay. However, the economic contribution of expansion includes increased cargo capacity to support global trade, the creation of tens of thousands of skilled jobs, and improved productivity through enhanced international connectivity.

 

Committee 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

 

  1. Overall, AirportsUK supports the view that the HENPS provides a clear framework that enables timely decision-making and would give confidence to investors that wish to finance expansion at Heathrow. It builds on the earlier work of the Airports Commission and updates the existing Airports NPS based on the latest evidence, policy, technology and market conditions.

 

  1. It should, however, go further in recognising the complementary roles of Heathrow, as the UK's hub airport, and other airports around the country serving domestic and international markets. It should also do more to recognise the role Heathrow plays in various economic factors, including trade (especially bellyhold cargo), inward, private sector investment and productivity.

 

  1. AirportsUK would also like to see further distinction between requirements that are specific to Heathrow and those that represent wider government policy. HENPS must be deliverable and balanced, otherwise they will not only undermine Heathrow expansion, but could adversely affect other airports developments around the country as well airports around the country. 

 

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

 

  1. There have been numerous studies, from government, Heathrow Airport, AirportsUK, and disinterested organisations that provide strong economic evidence supporting the strategic importance of maintaining an internationally competitive UK hub airport that strengthens the UK aviation network. The importance of a hub model is the transfer of traffic with direct passengers and freight, making long-haul routes economically viable that would otherwise fail. The sector, however, faces increasing costs and burdens which puts UK airports at a comparative disadvantage compared to international competitors. Research carried out on our behalf by WPI Strategy (available on request) found that owing to poor performance in several areas, including business taxes, regulatory regimes, planning costs and sustainability commitments, the UK risks falling behind. With the expansion of runway capacity at Heathrow this would strengthen connectivity that would benefit passengers and businesses across the UK through the increased choice that comes with enhanced domestic and international links to help ensure the UK is not falling behind.

 

  1. Whilst much of the analysis in HENPS is robust, the economic modelling conducted in both TAG and SCGE significantly undervalues the benefits of expansion. The TAG modelling used to conduct the cost-benefit analysis does not take account of the chief economic benefits of expansion - trade, private investment, connectivity, jobs, agglomeration, supply chain benefits, wellbeing, and the transformative impact of additional hub capacity for the UK. Additionally, the passenger forecast assumptions which have been input into the SCGE modelling do not match reality. The Department assumes a high level of displacement which is inconsistent with previous assumptions and the market reality Heathrow faces of strong demand for unique long-haul routes which are not served by other airports in the UK. For these, Heathrow is competing with European hubs, not other UK airports, given the unique mix of cargo, business passengers, and leisure passengers. We recommend DfT conduct additional sensitives for the passenger forecasts used in the SCGE modelling and include additional wider economic benefits in the TAG modelling, which would more accurately reflect the likely impact of expansion to the UK.

 

  1. Additionally, we know that a strong hub would complement, rather than compete with, successful regional airports by positioning the UK at the heart of an extensive global network that provides access to global markets. AirportsUK feels that the HENPS should continue to recognise that a thriving, broader airport network is supported by growth at Heathrow.

 

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

 

  1. AirportsUK supports the designation of Heathrow as Critical National Growth Infrastructure because of the unique national role that it plays. This designation reflects Heathrow's contribution to national and international connectivity, trade and inward investment, all of which benefit the whole UK through direct, indirect and induced means.

 

  1. AirportsUK additionally wants to emphasise that in recognising Heathrow's strategic importance, the HENPS should ensure that it does not diminish the importance of continuing to support a thriving wider airport network. The HENPS should avoid any implication that airports without this designation are in some way disadvantaged when their future plans for growth and expansion under other aviation policy frameworks are considered.

 

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

 

  1. AirportsUK accepts the need for Heathrow expansion proposals to conform to the government’s tests.  In general, these are clear and unambiguous.  Questions remain about whether 2024 is an appropriate baseline to utilise for noise in this case, but that is a matter for Heathrow specifically.  This benchmark should not become a policy lever for airports in general as it could stifle growth plans around the UK.  Established Government policy is to limit and where possible reduce noise impacts, and AirportsUK believes this should in general remain the requirement, rather than an inflexible reduction requirement and also following the ICAO Balanced Approach, which is the global framework for managing aircraft noise.

 

1. Economic growth across the country

 

  1. Through its extensive network of destinations across the UK, Heathrow already plays a significant role in supporting the economies of the nations and regions of the UK through the onward global connectivity it provides. This supports inbound and outbound tourism, business travel, imports and exports and inward investment through the creation of a timely, efficient and reliable network that is fed by the UK’s wider airport network, underpinning its economic viability.

 

  1. Recent research by Frontier Economics for Heathrow, for instance, has found that expansion could support new routes to places like Cornwall Airport Newquay, Leeds Bradford, Liverpool John Lennon and Teesside International Airports. This would unlock a further £335m in tourism spend, supporting trade, investment and jobs on top of the estimated £1.2bn already spent by travellers supported by Heathrow’s existing domestic routes.

 

  1. Estimates suggest that 60% of the economic benefits will be delivered in areas outside London and the South East. In addition, through the 50% increase in cargo capacity expansion would provide, the country would see growth in the already £300bn in goods that go through Heathrow, supporting businesses across the whole of the UK. All told, expansion could potentially unlock £17bn per year for the UK economy.

 

  1. It is also important to note that Heathrow expansion represents £33bn of private sector investment in the UK, meaning that this additional economic growth will be delivered with no taxpayer funding required. This will strengthen the links between the UK’s nations and regions and the global economy while also demonstrating our ability to deliver major infrastructure.

 

  1. In our view the HENPS should, therefore, explicitly acknowledge the important role regional airports play in feeding and complementing the UK's hub capacity. Furthermore, when considering the merits of Heathrow expansion under its economic growth test, the government should be mindful that this growth is complementary to and dependent on continued growth elsewhere in the UK.

 

  1. Air quality

 

  1. In the view of AirportsUK, the HENPS outlines environmental requirements that are robust and proportionate to the characteristics of the Heathrow proposal. We would caution, however, that it is important that these remain fair and consistent, without constant changing that would undermine confidence in the process and deter investors. It is also important that the HENPS should avoid creating expectations that Heathrow-specific mitigations automatically apply to airports with different operational circumstances.

 

  1. Noise

 

  1. Similarly, in regards to the noise mitigation test, the HENPS provides a satisfactory framework that reflects Heathrow's unique operating environment and its impact on the surrounding population. Again, constant changes should be avoided, and the policy should distinguish between Heathrow-specific measures and wider aviation policy to avoid unintended precedents.

 

  1. For example, the HENPS references a ban on night flights ‘…based on take-off and landing times’ which is not the current regime (which is based on when flights are scheduled) and does not take into account the need for operational flexibility. In addition, it is this type of change that could set an undesirable precedent that is unfairly applied to other airports in future growth discussions. We recommend the ICAO international definition of “scheduled” is used for the purposes of night flights, which is the time on the ticket. To change this would undermine operations and global flight timing.

 

  1. Climate change mitigation

 

  1. AirportsUK agrees with the principle that the HENPS should align with national climate objectives, while recognising that aviation decarbonisation is a sector-wide change. It should further recognise that the sector does have a robust strategy in the form of the Sustainable Aviation decarbonisation road-map that lays out how UK air travel will reach net zero by 2050, and that this is accommodated with around 60% growth in passenger demand. We would further hope that the HENPS’ requirements are proportionate and avoid establishing Heathrow-specific obligations as default expectations for future airport developments elsewhere.

 

e.  Adequacy of the supporting information

 

  1. While the text of the HENPS makes it clear that government understands the strategic national role that Heathrow plays and the wider economic benefits of expansion, AirportsUK is of the view that the data forecasts provided alongside the HENPS are too narrow in their assessment of the benefits. We support calls for there to be additional analysis that will further demonstrate how the benefits of Heathrow expansion would make a more significant positive impact on the economy, and support connectivity across the broader UK airport network.

 

  1. We also feel that it should be explicit that this further evidence refers only to Heathrow-specific impacts and does not apply to broader policy principles. This would reduce the risk that this Heathrow-specific evidence would be used to set an unrealistic precedent for unrelated airport developments, which should be judged on their own terms and as separate projects.

 

f. Robustness of forecasts and assumptions

 

  1. As stated above, AirportsUK feels that, while the HENPS overall recognises Heathrow's vital long-term strategic role, the forecasting supplied to assess the benefits of the project is drawn too narrowly and does not take sufficient account of the wider impacts from increased capacity. There is plenty of analysis from various sources illustrating how improved connectivity contributes significantly to economic growth through increased trade and investment opportunities, and in our view the government should take account of this in its own analysis.

 

  1. In addition, scenario testing should continue to recognise the complementary growth potential of regional airports. At present, however, there is an overly negative view of the amount of demand that will be displaced from other airports to Heathrow. Again, historic data show that increased capacity stimulates latent demand, and increases passenger traffic at other airports, enabling airlines to develop further routes to satisfy that demand.

 

  1. A wider analysis of the impact of expansion at Heathrow would reinforce the notion that increased hub capacity has a stimulating effect on national aviation demand and this would be served by a vibrant network of airports with different functions. Furthermore, setting the precedent by taking such a narrow approach to forecast assumptions could be used to oppose and limit future capacity growth elsewhere, despite local demand for increased connectivity and passenger choice.

 

g. Environmental mitigation, community support and surface access

 

  1. In the view of AirportsUK, the proposed mitigation measures in the HENPS appropriately reflect Heathrow's scale and operational characteristics. Surface access improvements should strengthen national connectivity and benefit passengers from across the UK, while providing the appropriate flexibility to ensure targets that take into account the measures over which Heathrow has direct.

 

  1. Community mitigation should remain proportionate to the specific impacts of the Heathrow scheme. In addition, the HENPS should make clear that these measures are tailored to Heathrow and should not automatically become expectations for airport developments in different contexts.

 

h. Selection of the Heathrow Northwest Runway scheme

 

  1. Using the Northwest Runway as the basis for the HENPS provides clarity for the development consent process. There is a strong logic to maximising the infrastructure capability when developments are carried out – in this case via delivering a full-length runway.  Government should defer to Heathrow Airport’s view on the correct infrastructure development to support.

 

  1. Complete scheme - we support the DfT’s proposal that any application should be for the full scheme, including runway, terminals and supporting infrastructure, in order for the benefits of expansion to be realised across the country. Heathrow Airport Ltd, as the airport operator, is best placed to deliver and operate an expanded Heathrow and its proposal is comprehensive and integrated into existing infrastructure. Another applicant that seeks to put forward isolated infrastructure would not achieve the same benefits for passengers nor the country.

 

  1. Again, however, AirportsUK want to ensure that the HENPS should remain focused on the delivery of a third runway at Heathrow and avoid any approaches that could be used to prescribe approaches elsewhere. We would like to see the HENPS explicitly recognise that future airport proposals will have different characteristics and should be assessed on their own merits. This would help avoid creating unintended policy precedent for other airport promoters.

 

i. Consistency with wider Government policy

 

  1. AirportsUK feels that the HENPS is consistent with government ambitions for economic growth, trade, improved international connectivity, and the UK’s carbon emission targets. We are part of the Sustainable Aviation coalition that has produced a robust and realistic decarbonisation road-map to net zero by 2050, which illustrates how growth in demand and airport expansion can be accommodated while simultaneously reducing emissions.

 

  1. The HENPS could go further, however, in emphasising the complementary roles of Heathrow and regional airports within a single national aviation network. To do so, AirportsUK reiterates the need for the HENPS to avoid introducing wording that could unintentionally constrain future airport development beyond Heathrow. In that way, the HENPS will be able to sit alongside wider planning policy, which can continue to support sustainable airport growth where justified.

 

j. Changes since 2018

 

  1. The revised HENPS appropriately reflects changes in the economic, environmental and policy context since 2018. In addition, however, it also needs to ensure that framework it outlines recognises the increasingly important role that Heathrow plays in supporting the UK’s international competitiveness, particularly as part of a vibrant and well-connected wider airport network.

 

k. Lessons from legal challenges to the 2018 Airports NPS

 

  1. As a result of the legal challenges to the 2018 Airports NPS, AirportsUK believes that the government has taken appropriate steps to strengthen the HENPS in terms of its treatment of climate and environmental issues. Government could provide improved legal certainty, however, through additional clarity regarding the relationship between Heathrow-specific assessments and broader national planning and aviation policy. Again, this would reduce the risk of Heathrow-specific wording being relied upon in challenges to unrelated airport developments.

 

I. Effectiveness of the consultation

 

  1. The government’s consultation provides an important opportunity to strengthen the HENPS while maintaining support for Heathrow expansion. AirportsUK want to ensure that the views of stakeholders from across the UK airport sector are taken into account to help ensure the policy reflects the interests of the whole aviation network, while avoiding any wording that could later be used to challenge other airports’ proposals to grow and expand sustainably. We also want the final HENPS to reinforce the view that Heathrow and regional airports have complementary, rather than competing, roles.

 

 

July 2026