Written evidence submitted by the Heathrow Area Transport Forum (HATF) (HEN0051)

This response is made on behalf of the Heathrow Area Transport Forum (HATF), the Statutory body required under the Government’s Aviation Policy Framework (2013) to scrutinise the airport’s Surface Access Strategy.  The board consists of a wide range of organisations, all of which have been consulted and helped inform this response.  Members are: Transport for London; BusinessLDN; Confederation of Passenger Transport; Heathrow Strategic Planning Group; Airline Operators Committee; Unite the Union; Network Rail; British International Freight Association (BIFA); London Cycling Campaign; National Highways; UK Coach Operators Association; LB Hillingdon; Local Community Forum (LCF); Heathrow Access Advisory Group and; Transport Focus.

HATF brings together public- and private-sector organisations with a shared interest in improving access to Heathrow and increasing sustainable travel to, from and around the airport. Its purpose is to support better outcomes for passengers; but also for airport employees, freight operators and neighbouring communities affected by Heathrow’s operations. HATF also has a specific role in scrutinising the adequacy and effective delivery of the airport’s Surface Access Strategy – and therefore our response is solely focussed on this element of the HENPS (and associated Surface Access Vision document). With well over half of all passengers still accessing the airport by car today, despite significant recent investment in schemes such as the Elizabeth Line, HATF seeks to highlight the scale of the behavioural shift required to sustainably accommodate an expanded Heathrow, and to work constructively with the airport operator, statutory bodies represented on its Board and Government to help rise to meet that challenge.

At the headline level, HATF welcomes the positive aspirations for sustainable travel, public transport and economic growth set out in the new draft Heathrow Expansion National Policy Statement (HENPS) – aspirations that in many cases go further than set out in the current Airports National Policy Statement. However, it is concerned that these positive aspirations may be undermined by the softening of enforceable commitments and funding certainty. The forum believes Government has a role not only in setting the vision, but also in charting a clear course for realising it — particularly where not all aspects of an optimal solution will be within any individual DCO promoter’s control.

The draft HENPS asks local communities and existing transport users to accept the certainty of airport growth in exchange for the possibility of future transport mitigation. HATF's starting position is that this balance should be reversed: transport improvements should be certain before growth is realised.

The principal concerns are:

1. Removal of “no more traffic pledge”.

The removal of the previous “no more airport-related traffic” principle, replaced instead with a requirement to “minimise” additional traffic, could allow substantial growth in road traffic even if the proposed mode share targets are achieved. While the draft HENPS retains public transport mode share targets, these do not ensure that road traffic growth will be constrained. Initial analysis by forum members suggests that, even if the targets are met, expansion could still generate tens of thousands of additional vehicle movements each day on one of the most congested parts of the UK transport network. This raises questions about the robustness of the analysis that led to these targets, and whether they are sufficiently ambitious.

To reassure stakeholders, further thought should be given to defining what “minimise” will mean in practice.  For example, this could potentially build on interim modelling results from Heathrow due in summer 2026, particularly those testing more ambitious modal shift and vehicle-efficiency scenarios, or refer to an aspiration to keep traffic flows within a reasonable margin of an appropriate baseline year. HATF would be happy to convene a conversation with Government, National Highways, TfL and Local Highway Authorities to explore this further.

2. Removal of staff mode shift targets, no targets for freight or construction.

The complete removal of staff targets, and the absence of any target covering freight movements, also reduces the incentive for investment and innovation to mitigate the impacts of these trips. A requirement for a “majority” of staff to be accessing the airport by sustainable modes when 48% already do so is not sufficiently ambitious.  Previously, ambitious binding staff mode shift targets drove a focus on active travel and bus improvements — interventions that provide particular value for local communities.

Government should also consider requiring binding targets for construction-phase vehicle movements, including materials and workforce movements, given that this work is likely to last several decades and will have significant impacts on surrounding residential areas.

Members would also welcome a specific requirement to consider the cumulative impact of all trip-generating activity on the Strategic Road Network (SRN) and local road network, and ensure that safeguards are in place to minimise unexpected impacts arising from multiple traffic generating activities.

3. Demand management tools.

The draft HENPS’s support for further consideration of demand management is welcome, but should go further. In particular, it could have set a clearer vision for future airport access by reaffirming support for the parking caps introduced through the Terminal 5 consent.  It could also have explicitly identified, alongside road user charging, the potential for the promoter to assume workplace parking levy powers to help manage third-party parking provision rationally and discourage unnecessary car use, if this will help achieve required targets. The policy should also ensure that airport design does not inadvertently make car travel the easiest option, including through the location, scale and integration of car parking with terminals; or through the provision of new transformational highway capacity such as the southern road tunnel without suitable demand management measures.

While the reference to reducing “uncontrolled HGV parking” is welcome, expansion should also establish a robust framework for managing anti-social parking on residential roads. This includes parking by passengers seeking to reduce costs, rogue “meet and greet” operators, taxis and private hire vehicles, and HAL employees unable to secure on-site parking. This should be referenced as a core additional requirement of any parking strategy, as set out in paragraph 5.126.

More positively, the draft HENPS should give greater prominence to measures that improve bus reliability (on and off campus), journey times and attractiveness, as these will be central to achieving mode shift and securing local benefits.

4. Robustness of survey data.

HATF supports the use of independent CAA data to assess achievement of the mode split target. However, the airport operator has raised concerns about the accuracy of this data.  We ask the government to require the CAA to work with HATF to improve understanding of the methodology used.  Ideally, the suitability of the survey should also be independently audited.

5. Linking targets to passenger capacity and potential for unintended consequences.

While the rationale for the change is understood, linking transport obligations to passenger growth thresholds rather than fixed delivery milestones risks allowing substantial airport growth before the supporting infrastructure is in place. The suggestion that additional rail schemes may not be required until passenger numbers exceed 130 million annually — more than 50% above today’s levels — raises particular concerns around credibility.

This runs counter to best practice in transport planning, which is to provide sustainable choices from day one, before car dependency becomes embedded. It also creates a risk of infrastructure “cliff edges” that could inadvertently constrain future growth by requiring significant investment once a specific passenger threshold is breached. The previous framework sought to avoid this by specifying the year by which improvements needed to be delivered. While the suggestion of a “backstop” date may help mitigate these concerns in part, further discussion and clarity are required on how that would work in practice, particularly through the planning process. It may help reassure stakeholders to clarify that such a backstop date would be expected to fall within two years of the scheduled completion of the relevant expansion phase. The draft HENPS should also make clear that the target mode split must be achieved before the new asset becomes operational.

In addition, the draft provides less clarity on enforcement and consequences if mode share commitments are missed than has been secured through more recent airport DCOs, particularly in respect to Luton Airport’s consent. This is a missed opportunity to build on emerging good practice.

Further thought should also be given to how impacts on the surrounding network arising from a substantial variation in the assumed passenger transfer rate would be mitigated. Without this, mode split targets could be achieved while car trips are still significantly higher than assessed through the DCO examination.

6. Plans for rail need further detail, assurances around delivery.

The fact that there is a materially weaker rail investment environment than existed during the previous Heathrow DCO process in 2019-20 is not made clear:

• Western Rail Access is on long-term pause; previously, this scheme was subject to an active DCO.
• Southern Rail Access has no committed delivery programme; previously, it was the subject of the “market-led proposal” initiative.
• HS2 has been reduced to a London–Birmingham railway rather than the originally proposed national network.
• Delivery of future Piccadilly Line signalling upgrades remains unfunded, suggesting a much later delivery horizon than previously envisaged.
• Even relatively modest increases in Elizabeth Line services, such as expansion from six to eight Heathrow trains per hour, do not currently have confirmed delivery certainty.

In this context, the lack of clarity over who will deliver the rail improvements that will clearly be required is concerning. New rail capacity should be regarded as a core enabler of growth — and as a necessary tool to help address existing congestion on the highway and public transport networks — rather than solely as a future mitigation measure. Indeed, achieving the proposed mode shift targets and minimising any growth in traffic is difficult to imagine without additional capacity and connectivity, especially from directions not currently served by rail. A stronger Government steer on ensuring these strategic rail enhancements come forward as an integrated part of any expansion proposal, and as soon as practicable, would therefore be welcome.

While the draft HENPS requires a promoter to prepare a credible plan for enhancements, it is unclear what that plan must cover. A clear set of required deliverables is needed. At a minimum, this 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.

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. 

Even with this detail, some board members are concerned that placing responsibility solely on the promoter to develop the credible plan, and seemingly fund interventions in full, may lead to sub-optimal infrastructure outcomes for the general travelling public and the wider transport system. Government could help address these concerns by making clear that all relevant government departments, and TfL, Network Rail/Great British Railways, will be engaged and will actively support development of this plan.

7. Affordability concerns must not reduce funding for required mitigations

The affordability of the scheme will clearly have a significant impact on the strength of the case of expansion. This is a particular concern for the Airline Operators Committee, which sits on the HATF Board. While the logic behind the new section on affordability is therefore recognised, it raises concern among some board members that surface access mitigation recommended by the Planning Inspectorate as necessary to safeguard neighbouring communities, and the wider travelling public using transport infrastructure around Heathrow, could be removed from the consented scheme by the Secretary of State on cost grounds. Government should give further thought to adding in assurances and safeguards to ensure this does not happen, including giving consideration to a wide range of potential funding solutions if it emerges that the expansion scheme is unable to viably cover the full cost of required mitigation.

8. Managing uncertainty.

There is some welcome acknowledgement that a project of this size, complexity and duration has inherently uncertain impacts, including the suggestion that mode shift targets for growth beyond 130mppa should be determined at that time through consultation with the airport transport forum. The forum welcomes a role in that process. However, further discussion is needed on whether the forum should evolve into a body that can formally discharge consenting powers, or whether it should provide input to an overarching governance body, such as that envisaged under an Environmentally Controlled Growth regime building on practice developed in this space through the Luton Airport DCO. More is also needed to ensure a secure revenue stream is available to address unknown impacts. As well as ensuring sufficient funding is secured via obligations associated with the consent for necessary core interventions on the strategic road network (and the ongoing maintenance of these) and on the public transport network, we believe an ongoing Sustainable Transport Fund, funded by hypothecated top-slices from parking and other vehicle drop-off/access fees could help build confidence amongst stakeholder that resource will be there to mitigate currently unforeseen impacts.  This is perhaps particularly relevant given the recent experience of seeing much surface access spend in the latest regulatory round, 2027-2031, removed. Forum members representing Heathrow Strategic Planning Group also note that a more equitable business-rate retention scheme may assist in providing revenue flows for future infrastructure, and could help address some of the affordability concerns raised in point 7 above.

9. Network resilience.

Given the stresses on the current network, the limited focus on ensuring the new plans provide sufficient resilience and operational reliability in the event of unplanned incidents is concerning. This applies both to the Strategic Road Network and, as a consequence of displaced and rat-running traffic, to local roads. The NPS should make clear that any DCO promoter must assess and address these issues. It would also be helpful to recognise the impact that growing numbers of HGV movements, in particular, will have on highway asset integrity.

10. Delivering wider economic growth

The opportunity to consider how best to leverage private investment at the airport to turbo-charge economic development across the whole sub-region - and the role transport investment plays in supporting wider growth - has been missed. The draft HENPS treats Heathrow too narrowly, rather than as the anchor of a wider transport and economic geography. HATF Board members consider that expansion should be accompanied by a government-led transport strategy for the whole Heathrow functional economic area.

Such a strategy should use the scale of private investment at the airport to support wider connectivity, productivity and local economic growth, rather than treating surface access solely as mitigation for airport impacts. It should also set out how national, regional and local government will work together to plan, fund and capture the benefits of that growth for local communities. There is scope to draw on established models of cross-boundary growth governance, such as the Thames Estuary Growth Board. Without this wider strategic framework, the local and regional economic benefits of expansion are unlikely to be fully realised.

In summary, HATF is concerned that the draft HENPS moves towards a framework that permits growth first, while relying on future mitigation being determined and, possibly, delivered later. The Board considers that greater certainty on transport delivery, funding, governance and enforcement will be essential if the policy is to command confidence from passengers, local authorities and affected communities.

July 2026