Written evidence submitted by Heathrow Airport Ltd (HEN0058)
Executive summary
Enhanced aviation connectivity is critical to the UK’s economic growth, tourism, long-term competitiveness, and to connecting friends and families across the world, which is why the Government rightly supports increasing airport capacity to enable more routes, greater passenger and freight connectivity, and improved access to global markets.
In January 2025, the Government confirmed its support for Heathrow expansion which “would unlock further growth, boost investment, increase exports, and make the UK more open and more connected”.[1] This was followed by a rigorous process to identify their preferred scheme –Heathrow’s Northwest runway proposal – for informing the review of the Airports National Policy Statement (ANPS) and the subsequent publication of a draft Heathrow Expansion National Policy Statement (HENPS) in June 2026. This work built on the significant work of the Airports Commission, which sat from 2013 to 2016 conducting expert independent analysis to identify the best solution, which HM Government took forward in the ANPS and the Transport Select Committee built upon in its own inquiry in 2017-18.
The publication of the draft HENPS is a crucial milestone in delivering Heathrow expansion and represents significant work by the Government to progress a third runway. We support much of the draft HENPS and welcome the clarity it provides in relation to a future Development Consent Order (DCO) application. Crucially, the HENPS states the importance of a third runway DCO application being for the full, comprehensive scheme which includes not just a runway but the vital terminal capacity and supporting infrastructure required for the scheme to successfully deliver economic benefits for the UK. Only the complete scheme will deliver the benefits which underpin the needs case for expansion: trade, tourism, business, supply chain, jobs, private investment and economic growth across the country.
Although the modelling significantly undervalues the economic benefits, the draft is supported by a substantial evidence base, which reflects changes in policy, legislation, technology and market conditions since 2018, and appropriately balances economic, environmental and community considerations within a single policy framework.
The draft HENPS will need to be strengthened in some areas to ensure that it provides the clearest framework for the timely and efficient delivery of long-overdue hub capacity in the UK. Given the scale, complexity and benefits of Heathrow expansion, it is essential that the HENPS provides a robust, affordable and deliverable framework from the outset to help ensure the successful delivery of one of the UK's most significant infrastructure projects. Key areas highlighted in this submission are as follows:
As we are still reviewing the detail of the draft HENPS, our response draws from our initial views. As our review continues, we may submit further written evidence to clarify or add to our comments below. In the meantime, this submission seeks to assist the Committee with the specific issues raised in the published questions.
We look forward to supporting the Committee’s inquiry and stand ready to provide further information and oral evidence over the coming months.
About Heathrow Expansion
Heathrow expansion is a £33 billion privately financed project that is critical to the UK’s competitiveness, connectivity and economic growth, with an additional £15bn investment to modernise the current airport through expanding and improving the central terminal area. Heathrow is the UK’s only hub airport and largest port by value, and one of the most capacity-constrained airports in the world.
As a hub, Heathrow does not compete with other UK airports. We work with, and complement, them by acting as a central interchange to enhance connectivity between all of the UK and the rest of the world. By bringing passengers and cargo together from across the country and beyond, we help airlines fill flights with people and goods travelling to, from, and through Heathrow. This makes more routes possible and will keep the UK better connected globally than it otherwise would be. We pool demand from across the UK and Europe to connect business and passengers to 230 destinations in over 85 countries, including more than 30 destinations not accessible from other major European hubs and markets.
Unlocking growth at Heathrow is essential to supporting the trade, tourism and jobs that communities across the UK depend on.
However, expansion is not solely about providing the additional airport capacity the country needs. For more than 80 years, local communities have been central to Heathrow’s success. As we plan for the future, we want expansion to deliver a positive and lasting legacy for the people who live and work around the airport, while supporting the UK’s transition to net zero. We will only deliver expansion in a way that is consistent with net zero by 2050, while continuing to improve local air quality and providing predictable noise respite and enhanced support for our local community.
Our expansion proposals are aligned with the draft HENPS and we are ready to deliver at pace. We have a comprehensive and integrated scheme which will deliver substantial economic benefits to the country and meet the HENPS requirements for a DCO to “provide for a complete Northwest Runway scheme, including the runway, terminal capacity and other supporting infrastructure required for the scheme to operate as an integrated whole”. Our plan includes a runway up to 3,500m to the northwest of the existing airport, capacity for up to 276,000 additional flights annually, new terminal facilities capable of serving up to 150 million passengers a year, a 50% increase in cargo capacity, and significant improvements to surface access.
Expansion will deliver economic growth and job creation during planning, construction and operation, while providing a major boost to our UK supply chain, 60% of which is located outside London and the South East. Benefits will be felt across the UK’s nations and regions, creating opportunities for SMEs, businesses, airports and communities. It will support thousands of skilled jobs, apprenticeships and training opportunities, which is why trade unions including GMB, Unite and Community continue to back the project. Local Chambers of Commerce, educators and construction firms stand ready to harness the opportunities expansion can bring, while organisations including British Steel and UK Steel support our ambition to use the best of British materials, skills and expertise in building a third runway.
Expansion will improve punctuality, reduce congestion and enhance the passenger experience, while increasing airline competition and potentially saving passengers £79 billion through lower fares over the next three decades. It could support more than 30 additional daily routes, strengthen regional connectivity, increase annual passenger capacity from 82 million to 150 million, and reinforce Heathrow’s role as the UK’s largest port by value, helping British exporters reach global markets more efficiently.
Delivering expansion at pace is critical to unlock the economic growth the UK needs, with Heathrow expansion estimated to contribute £17 billion a year to the economy by 2050. The draft HENPS provides important clarity and certainty to help keep the project moving forward at the pace the UK needs.
1. The extent to which the draft HENPS provides clear and coherent guidance to the Secretary of State about how to assess a proposed scheme
1.1. The draft HENPS provides the principal planning framework for Heathrow Expansion and sets out a clear basis for the assessment, examination and determination of a future DCO application.
1.2. The draft HENPS updates and builds upon the ANPS, retaining the established case for expansion whilst reflecting changes in policy, legislation and the wider aviation sector since 2018. The clear restatement of strategic need and supporting evidence is welcome, but there is a gap in the wider economic benefits stated in the Government’s Heathrow Expansion Appraisal Report (HEAR), as well as the passenger forecast assumptions used in the SGCE model, both of which require updating to properly account for the substantial positive impact of expansion on the UK. Heathrow is currently operating at capacity, and has been for over twenty years, and expansion is critical to supporting the UK’s international competitiveness, connectivity and economic growth. The HENPS draft itself makes clear that expansion will deliver significant benefits to the UK’s nations and regions through increased connectivity, trade, investment and employment opportunities, including for communities surrounding the airport.
1.3. The draft HENPS also provides a structured assessment framework, appropriately distinguishing between the strategic need for expansion and the scheme-level assessments required through the DCO process. This provides an effective framework for decision-making and avoids revisiting matters that have already been considered through previous policy and scheme assessments, providing greater certainty for applicants, consultees and decision-makers.
1.4. The designation of Heathrow expansion as Critical National Growth Infrastructure is welcome. This reflects the compelling economic, connectivity, freight and resilience benefits of expansion and provides important context for decision-makers when weighing the benefits and impacts of the scheme.
1.5. The draft HENPS benefits from the Government's decision in November 2025 to select our Northwest Runway scheme following a competitive assessment process and to carry out its review of the ANPS on that basis. This provides a clear and mature basis for the policy framework and reflects the deliverability and operational resilience of the selected scheme. Having selected our Northwest Runway scheme as the preferred means of meeting the identified need, the HENPS should provide confidence that the principal and key characteristics of that scheme will not be revisited during a subsequent DCO process. The purpose of the HENPS is to establish the policy framework and identify the scheme to be supported, with the DCO process focusing on detailed design, environmental assessment and mitigation rather than reopening questions already decided through the National Policy Statement (NPS) review process.
1.6. The provisions in the draft HENPS relating to scheme flexibility and phasing would benefit from further clarification. Whilst appropriate flexibility should be retained for the DCO process to allow refinement of the scheme and efficient delivery, such flexibility should not permit material departure from the Heathrow Northwest Runway scheme identified in Section 3 of the HENPS. Any phased scheme must not be at extra or inefficient cost and must demonstrably integrate into the airport. The HENPS is clear, and we support it, that the DCO must be for the full scheme given the scale of benefits associated only with delivering the whole. To deliver isolated parts, such as a runway or terminal in isolation, would not deliver the transformative scale of benefits for the UK which come from the full scheme. It would also be an inoperable airport.
1.7. Similarly, whilst limited dimensional tolerances may be appropriate, it should be made clear that a materially different scheme from our Heathrow Northwest Runway scheme would not be consistent with the HENPS. Thus, for example, whilst the HENPS allows a runway of “up to 3,500m” and so allows some reasonable flexibility if a slightly shorter runway can be achieved, it does not allow a materially shorter runway as this would revisit and, therefore, undermine the Government’s decision in November 2025 to select our Heathrow Northwest Runway scheme. While this intention is reflected in the HENPS, it should be more clearly articulated as an assessment criterion for a DCO application to provide greater certainty that any flexibility remains within the overall decision to select our Heathrow Northwest Runway scheme.
1.8. There are several other areas where further clarity would strengthen the framework and support a more efficient consent process:
a) The interaction between the HENPS and the CAA's regulatory framework requires further clarification, particularly in relation to affordability. The respective roles and responsibilities of Government and the Planning Inspectorate (through the DCO process) and the CAA should be clearly articulated to avoid uncertainty and duplication or overlap between the planning and economic regulatory regimes. We want the scheme to be as affordable as possible and it is important that affordability is part of the process, but to avoid duplication and confusion, only one body should be responsible and accountable for assessing and ultimately judging the affordability of Heathrow expansion.
b) Additional clarity would be helpful in relation to the assessment of noise and night flights. We recognise that aircraft noise remains a significant concern for communities around the airport and we support the draft HENPS objective of reducing and mitigating its impacts. The noise assessment framework would benefit from further clarification, particularly regarding the relationship between the proposed policy tests and the noise contour assessment criteria. Greater emphasis should also be given to receptor-based measures alongside contours to ensure that assessment and mitigation are informed by how noise is experienced by affected communities in practice. The current drafting on night flights should also be clarified in line with International Civil Aviation Organisation definitions – for example scheduled operating times – to avoid uncertainty regarding the application of the relevant policy tests.
c) We support the ambitious surface access mode share targets in principle and are working towards an ambitious strategy which will include a significant uplift in public transport for both passengers and colleagues. However, achievement of these targets is dependent on rail and public transport enhancements which are likely to be delivered by third parties, such as a private rail promoter, and require consent and support from other third parties such as the Government itself through Network Rail and then Great British Railways. This introduces a level of risk into the programme and the HENPS should more clearly recognise what is within Heathrow’s control, and where responsibility lies with third parties for the progress of additional rail capacity. We therefore recommend compliance is only required in relation to what is within Heathrow’s control.
d) Greater clarity would also be welcome regarding the application of mitigation requirements. The HENPS should make clear that mitigation measures are expected to be evidence-based, proportionate and deliverable, ensuring that environmental and community benefits are achieved while maintaining the overall viability and affordability of the scheme.
2.1. The draft HENPS demonstrates that there remains a compelling need for additional hub airport capacity, which can only be delivered through expansion at Heathrow. Heathrow is effectively operating at capacity and existing constraints increasingly limit connectivity, passenger choice, airline competition and freight growth. These constraints are already affecting the UK's international competitiveness, limiting opportunities for trade and investment, reducing resilience within the aviation system and constraining wider economic growth. Expansion would increase capacity, improve connectivity and help ensure that the UK remains globally competitive.
2.2. Heathrow occupies a unique position within the UK aviation market as the country's only hub airport. Additional capacity elsewhere in the airport system is valuable, but it does not replicate the connectivity benefits generated by a hub operation which aggregates demand and supports an extensive long-haul route network. Heathrow's principal competitors are therefore not other UK airports but major international hubs such as Paris Charles de Gaulle, Frankfurt, Amsterdam Schiphol, Istanbul, Dubai, Abu Dhabi and Doha. The draft HENPS rightly recognises the strategic importance of maintaining and enhancing the UK's hub competitiveness in this international context.
2.3. The draft HENPS draws on an extensive body of evidence that has been subject to substantial scrutiny over many years, including the work of the Airports Commission from 2012 to 2015. The evidence base provides a sufficient and broadly appropriate foundation for assessing the need for additional aviation capacity, particularly given the long-term nature of the forecasts and analysis involved. The Airports Commission found that the Heathrow Northwest Runway scheme would deliver £147 billion (£209 billion in 2026 sterling) in cumulative strategic benefits to the UK over 60 years.[2] The draft HENPS notes that “the Airports Commission’s work… remains the most comprehensive independent assessment of the need for additional runway capacity in the South East of England and of the options for meeting that need.” The Airports Commission also identified substantial passenger benefits, which are consistent with more recent analysis indicating significant connectivity and consumer benefits from additional capacity.[3]
Economic modelling
2.4. Whilst the overall evidence base is robust and adequate to support the Government's conclusions, the economic appraisal is not representative of the full benefits that are associated with expansion and should be interpreted within the constraints of DfT's TAG appraisal framework. These appraisal methodologies are not designed to capture the full range of impacts associated with a transformational, privately financed strategic infrastructure project such as Heathrow expansion. Nor are they built to assess the economic value of aviation. Instead, they were designed to model the costs and benefits of publicly funded road and rail projects. As a result, important benefits relating to trade, inward investment, connectivity, agglomeration, productivity and wider economic growth are only partially reflected, or are excluded altogether, from the quantified assessment.
These are recognised limitations of the modelling approach which DfT acknowledges. Consequently, the appraisal significantly understates the overall economic value of additional airport capacity and should not be regarded as a comprehensive measure of the scheme's total economic benefits. The analysis could therefore be strengthened through:
a) Stronger recognition of the strategic role of international connectivity and hub capacity, together with clearer explanation of the extent to which these benefits are captured within the monetised appraisal results and where they remain outside the scope of the quantitative analysis.
b) Greater recognition of the regional and national economic benefits associated with major international transport infrastructure, including impacts on trade, investment, productivity and connectivity across the UK.
c) Clearer recognition of the role that private investment and economic regulation can play in supporting the delivery of nationally significant infrastructure while protecting the interests of consumers and taxpayers.
d) A peer review of the DfT’s traffic forecasting model, and additional traffic forecast sensitivities to transparently convey where the DfT’s core scenario sits within the reasonable range of possible outcomes.
e) Greater transparency around the key assumptions driving appraisal outcomes and the sensitivity of the results to those assumptions.
f) Like-for-like measurement and reporting of environmental and wider economic benefits, so these can be meaningfully compared with one another.
g) Clarification of the intended scope of the selected scheme and the proposed approach to phasing, providing greater certainty regarding the delivery pathway.
2.5. In our view, the interpretation of the economic appraisal should take account three broader considerations:
a) Within the aviation market, the relevant question is whether passengers receive greater benefits from additional capacity than the costs they contribute towards its delivery. The DfT estimates that UK passengers will receive £25 – 35 billion in benefits while contributing approximately £6 – 8 billion in funding, resulting in substantial net benefits to consumers.
b) In the wider economy, the central question is whether an additional Heathrow flight delivers more in economic benefits than it does in disbenefits: our conclusion is that it does. In 2050, for the economic benefits to outweigh the carbon costs among all additional passengers, it would be sufficient if each additional business-purpose passenger delivered at least ~ £700 in extra value because of the trip. Given that the average business-purpose visit in the UK currently spends around £1400 per trip, this is a modest return for the business to expect, and we would expect the added value of the trip to be significantly higher.[4] The DfT’s own analysis of trade benefits implies that a business trip generates on average £5,000 in additional GDP.
c) The DfT’s analysis does not meaningfully quantify the welfare benefits of holidays: the intangible value to UK society of making more overseas leisure trips, of being able to afford to travel to more destinations with faster air journey times. A cost-benefit analysis must consider how much UK residents value their international holidays - this omitted social benefit is enormous. Including wellbeing benefits is recommended by the Green Book, and these wellbeing benefits would be worth hundreds of pounds per leisure trip.[5]
2.6. The limitations of conventional transport appraisal are not unique to aviation and have wider implications for the assessment of nationally significant infrastructure projects. Where trade, investment, productivity and wider economic impacts are only partially captured, appraisals understate the value of infrastructure that improves connectivity and economic integration. Examples from other transport sectors illustrate this challenge:
a) Analysis of the Channel Tunnel suggested it delivered around -£10 billion in UK net benefits after 20 years when wider economic benefits were excluded, despite its substantial contribution to connectivity, trade and economic integration.[6]
b) The appraisal of the Thames Freeport identified very limited monetised benefits beyond incremental investment, illustrating the difficulty of capturing the wider trade, productivity and economic impacts associated with major infrastructure and growth initiatives.[7]
3.1. The designation of Heathrow expansion as Critical National Growth Infrastructure is appropriate and welcome. It reflects the national economic, connectivity, freight and resilience benefits that expansion would deliver. It should support robust and timely decision-making, helping to ensure these benefits are realised as soon as possible.
3.2. There is clear precedent for this type of designation in the Planning Act 2008 regime, with the Energy NPSs using the similar concept of Critical National Infrastructure to give additional policy support to renewable energy projects.
3.3. The designation should not, however, be interpreted as reducing the level of scrutiny applied to the project or diminishing statutory safeguards. Rather, it provides important policy context regarding the national significance of the scheme while preserving the full range of environmental assessment, planning and regulatory requirements.
4.1. We have made a clear commitment to reaching net zero by 2050. That ambition is achievable within both the airport’s current operations and our emerging plans for an expanded Heathrow with an increasing number of flights in the future. Our strong track record against other critical environmental challenges, such as local air quality and noise, along with our industry-leading work to decarbonise aviation, shows that we can and will continue to deliver on our environmental commitments.
4.2. The draft HENPS establishes a clear and robust framework through the four tests, linking planning decisions to environmental compliance and economic benefits. Bringing these requirements together within a single policy framework is welcome. It provides clarity for applicants, decision-makers and stakeholders, ensuring that the relevant evidence can be considered in a coordinated way through a single consenting process. The HENPS should remain the framework against which expansion is assessed, providing a comprehensive basis for decision-making without creating uncertainty through additional requirements outside the policy itself.
4.3. Overall, the four-test framework strikes an appropriate balance between ensuring robust scrutiny and providing a clear pathway for delivery. While we have identified a number of detailed drafting points that we will make in our response to the DfT's consultation on the draft HENPS, these relate to implementation rather than the underlying policy approach, which we support. The tests should, however, remain clear, realistic, proportionate and deliverable.
Economic growth across the country
4.4. The introduction of a dedicated economic growth test is welcome and reflects the strategic importance of Heathrow to the UK economy. The focus on benefits across the UK is particularly important, recognising that the benefits of expansion extend well beyond London through improved connectivity, trade, tourism and investment.
4.5. We are confident that expansion can meet this test by creating jobs, supporting businesses and strengthening supply chains throughout the UK, increasing domestic connections between UK regions, and facilitating greater trade and export opportunities. Frontier Economics have estimated that 60% of the economic benefits will go to communities outside London and the South East.[8] In addition, our recent domestic connectivity analysis indicates that expansion could enable at least five new or restored domestic routes – including links to Belfast International, Newquay, Leeds Bradford, Liverpool and Teesside – helping connect more regions directly to Heathrow’s global network and unlocking further trade, tourism and investment opportunities across the UK[9]. Our expansion proposals are, therefore, supportive of the Government’s devolution and regional growth agenda.
4.6. Jobs, skills, and our UK-wide supply chain are central to the development of expansion. In addition to the over 80,000 people employed at the airport, 60% of the 1,150 businesses in our supply chain are SMEs, and the jobs, skills, and suppliers will only grow with expansion. This will leave a legacy which grows key industries, helps SMEs prosper and creates long-term careers and skills opportunities for people from every part of the UK.
Air quality
4.7. The air quality framework is aligned with existing legal and policy requirements and provides an appropriate basis for assessment. Heathrow has seen significant improvements in air quality over the last decade, with all pollutants below regulated levels set by Government. Our plan ensures continued full compliance with legal limits by investing in clean technology and sustainable transport.
4.8. Further clarity would be beneficial regarding any future obligations arising from monitoring requirements and how these would be applied in practice. These issues are capable of resolution through refinement of the draft HENPS and do not affect our support for the overall framework.
Noise
4.9. The updated noise framework rightly recognises the benefits arising from fleet modernisation and quieter aircraft technology.
4.10. Further work, however, is required regarding the baseline assumptions informing the noise test, which we believe should be updated to reflect the latest fleet mix projections, growth assumptions and evolving expectations for airspace following the establishment of UKADS. In addition, in line with the Government policy of sharing benefits of new technology, fleet improvements already realised since the publication of the 2018 ANPS should also be considered. These are matters of detailed implementation rather than principle, and we will provide more detailed comments directly through the HENPS consultation process.
Climate change mitigation
4.11. The climate change framework appropriately reflects current climate policy and recognises both airport-level and wider system impacts.
4.12. Further clarity would be beneficial regarding the assessment methodology and practical requirements for demonstrating compliance with the climate test. These issues are capable of resolution through refinement of the draft HENPS and do not affect our support for the overall framework.
5.1. The information published alongside the draft HENPS provides a comprehensive evidence base, including updated aviation forecasts, the Heathrow Expansion Analysis Report, economic appraisal and a full suite of supporting assessments, such as the Appraisal of Sustainability, Habitats Regulations Assessment, Equality Impact Assessment and Health Impact Assessment. However, the evidence significantly undervalues the benefits of expansion.
5.2. The accompanying assessments provide an appropriate foundation for policy development and demonstrate that the review is supported by extensive technical analysis across a broad range of economic, environmental and social issues.
5.3. The scheme comparison process run between June and November 2025 was evidence-based and thorough, resulting in the reselection of the Heathrow Northwest Runway scheme on demonstrable grounds. This provides confidence that the draft HENPS is based on a robust assessment of alternative options and reflects the most mature and deliverable scheme. Our privately funded proposal is detailed, achievable, and has been shaped by a decade of scrutiny and engagement, which is why we agree with the Government’s assessment that it is the preferred option.
5.4. The evidence base has been subject to extensive development, testing, consultation and independent review over many years. Taken together, the supporting documents provide a robust assessment of the likely economic, environmental and social impacts of Heathrow expansion. While some methodologies could be refined further, these issues do not affect the overall adequacy of the evidence underpinning the draft HENPS. If anything, the analysis is conservative and understates the benefits of expansion, including the gains in connectivity, capacity and investment associated with the UK's hub airport.
6.1. The methodology underpinning the draft HENPS is broadly appropriate and provides a sufficient basis for assessing the impacts of expansion, particularly given the long-term nature of the forecasts involved. The methodology has benefited from extensive independent review, sensitivity testing and scenario analysis. Given the inherent uncertainty associated with forecasting over several decades, the use of multiple scenarios and assumptions is appropriate but would benefit from an additional and more realistic scenario regarding incremental passenger growth. The analysis would also be strengthened by validating the HEAR baseline airfare assumptions against observed market data to provide additional assurance that the forecasts are anchored in real-world market conditions.
6.2. Given the considerable uncertainty associated with long-term aviation demand in the Government’s updated forecasting framework, further scenario testing would provide greater transparency regarding the sensitivity of forecast outcomes to key assumptions. In particular, forecasts should be tested against a broader range of airline responses and competitive market behaviours, recognising that future demand will be influenced by the strategies of both incumbent carriers and potential new entrants.
6.3. The extensive updating of the modelling framework, together with independent review of the analysis, provides confidence that the forecasts and assumptions used to support the draft HENPS are consistent with established appraisal guidance and are TAG-compliant.
Economic modelling
6.4. As noted in section 2, whilst the methodology is consistent with established Government appraisal guidance, it is important to recognise the acknowledged limitations of the Green Book, TAG and CGE-based approaches when applied to major aviation infrastructure, which means the current economic analysis is not proportionate or representative. As noted within the HEAR, these frameworks do not seek to capture the full range of strategic, economic and connectivity benefits that may arise from airport expansion, including impacts on international trade, inbound tourism, foreign direct investment and wider productivity gains.
6.5. These limitations are not specific to Heathrow expansion but are inherent within conventional transport appraisal methodologies, which were principally developed for the appraisal of publicly funded transport schemes such as road and rail. Heathrow expansion differs from many projects assessed under these frameworks because 1) it would be wholly privately financed, 2) it’s a transformational infrastructure project, 3) it requires adequate measuring of global passenger demand, international trade, and hub airport economics.
6.6. The economic appraisal would therefore be strengthened through additional sensitivities and scenarios and additional narrative explaining the extent to which wider strategic benefits fall outside the scope of the core modelling framework. Greater transparency would also be helpful regarding the sensitivity of outcomes to assumptions relating to traffic forecasts, carbon appraisal, competition effects, geographic scope, appraisal periods and the treatment of wider economic impacts.
6.7. Alternative robust analysis undertaken by Frontier Economics estimated that Heathrow expansion could increase UK GDP by approximately 0.43% by 2050 and support around £17 billion of additional economic activity annually. Whilst such estimates are based on different methodologies and assumptions, they illustrate the importance of considering strategic and wider economic impacts alongside conventional transport appraisal metrics when assessing infrastructure of this scale and national significance.
7.1. The draft HENPS sets out clear policy expectations in relation to environmental mitigation, community support and surface access. The overall framework is comprehensive and provides an appropriate basis for assessment. It is important, however, that requirements remain clear, realistic, proportionate and deliverable, and do not inadvertently undermine the affordability of the overall scheme through disproportionate mitigation requirements.
7.2. We are fully committed to supporting local communities, protecting the environment and improving surface access. Many of the requirements set out in the draft HENPS build on measures and commitments that are already in place, or that we are intending to deliver voluntarily as part of our scheme.
Environmental mitigation
7.3. The draft HENPS provides a comprehensive framework for environmental assessment whilst recognising that it cannot exhaustively prescribe every impact or mitigation measure. This strikes the right balance between setting clear policy expectations and allowing detailed mitigation to be developed through the DCO process.
7.4. The approach to decarbonisation is sensible. Heathrow is a world-leader in aviation decarbonisation through our SAF landing charge incentive and investment in airspace modernisation and we welcome the expectation that these commitments will continue to develop as part of expansion.
7.5. We recognise that noise remains one of the most significant concerns for communities around the airport and support the draft HENPS objective of reducing and mitigating its impacts. We have already reduced our noise footprint to the smallest it has been since the 1970s, despite serving more passengers than ever, through quieter aircraft, optimised flight paths and restrictions on night flights. However, further refinement is required to ensure that the assessment framework properly reflects the impacts experienced by communities. In particular, greater weight should be given to receptor-based measures alongside wider noise contours, enabling a more accurate assessment of how noise is experienced in practice. Further consideration should also be given to the proposed approach to night flights to ensure it delivers meaningful benefits for affected communities while remaining proportionate and evidence-based. These are primarily matters of detailed policy drafting rather than fundamental concerns with the framework itself and will be addressed through our consultation response to the Department.
Communities
7.6. Local communities are central to the successful delivery of expansion and a strong package of mitigation, compensation and support is therefore critical.
7.7. The draft HENPS sets out several expectations for community compensation by an applicant, including 125% market value payments for certain owner-occupier homes, the provision of up to £3,000 for acoustic insulation within designated noise contours, and a compensation fund which the Airports Commission suggested could be £50m a year, amounting to £750m over a 15-year period.
7.8. The requirement to consider mental health impacts and support is welcome and reflects issues raised directly by local communities. We have already been developing initiatives in this area in response to community feedback and remain committed to working in partnership with local communities to understand their concerns and identify the support they need. We welcome the engagement, scrutiny and challenge provided through CISHA, organised forums and our direct engagement activities, all of which play an important role in shaping our approach and ensuring that community views are reflected in decision-making.
Surface access
7.9. We support the surface access framework set out in the draft HENPS. The three guiding principles of: making public transport the first choice for passengers and staff; minimising impacts on the road network; and prioritising environmental sustainability, provide a clear and coherent basis for the assessment and delivery of airport expansion.
7.10. The 2018 ANPS anticipated the delivery of a number of rail schemes during the 2020s to support increased public transport mode share, including HS2 and upgrades to Piccadilly line signalling. It also reflected Government support for improved rail access to Heathrow, including a commitment at the time to co-fund the Western Rail Link to Heathrow. However, neither HS2 nor the Piccadilly line signalling upgrades have been delivered, and Government financial support for the Western Rail Link has since been withdrawn. The HENPS should be updated to reflect these materially changed circumstances.
7.11. We support the ambition to increase public transport mode share and reduce reliance on private vehicles. To ensure the framework remains realistic and deliverable, it should more clearly recognise Heathrow's dependence on infrastructure and services provided by third parties. Mode share requirements should therefore reflect the timing and delivery of external rail and other public transport enhancements including the rail schemes envisaged in 2018 that haven’t been delivered. Greater clarity on what a compliant submission looks like through the planning process would further strengthen the framework and help ensure that its objectives can be achieved. Financing requirements for future rail projects should reflect that they have wider benefits for the country and Government, and could be commercially attractive to promoters other than Heathrow. We will engage constructively with Government on detailed drafting relating to mode-share targets and third-party dependencies through the HENPS consultation process.
8.1. The draft HENPS benefits from the extensive work of the Airports Commission, subsequent Government analysis and further scheme development by Heathrow. The selection of our Heathrow Northwest Runway scheme provides a mature and robust evidence base for the review and supports the only efficient and deliverable route to success.
8.2. Our Northwest Runway scheme was selected by the Government in November 2025 as the basis for the ANPS review because of the scheme’s deliverability, operational resilience and maturity. The draft HENPS appropriately recognises the complexity of integrating expansion with the operation of the UK's only hub airport and the importance of maintaining a safe and resilient airport throughout delivery.
8.3. The draft HENPS correctly recognises that expansion must be delivered as a full scheme. The runway, terminals, surface access, operational infrastructure, environmental mitigation and community measures are interdependent, and the benefits of expansion depend on their coordinated delivery. In selecting our Heathrow Northwest Runway scheme the Government rightly recognises that “the runway length proposed is important because it provides greater operational resilience and supports the accommodation of a broader range of aircraft. The further work carried out for the review of the Airports NPS has also assessed the need for Heathrow expansion and the likely impacts and benefits of a Northwest Runway scheme. Taken together, that work confirms that the 3,500m scheme provides the most credible and deliverable basis on which to take forward expansion at Heathrow.”
8.4. The Government's decision in Section 3 of the draft HENPS to select our Heathrow Northwest Runway scheme as “the most deliverable option” provides important policy certainty. Having undertaken a competitive assessment of alternative schemes and selected its preferred option, it is important that the subsequent DCO process does not permit that decision to be revisited. Reopening questions regarding alternative runway concepts or materially different expansion propositions during a DCO process would undermine the very purpose of the National Policy Statement process in delivering certainty and would instead create unnecessary duplication of effort, cost to the consumer, uncertainty and delay. The HENPS should set the policy criteria against which our Heathrow Northwest Runway Scheme should be assessed and not, however inadvertently, allow the Government’s November 2025 decision to be undermined.
8.5. In that context, and to promote certainty in the policy framework for bringing forward this nationally significant project, we recommend that the normal definition of the "appropriate person" to carry out the development, should not be artificially limited to responsibility for statutory blight. In our view, it is important for there to be clarity for our local communities, local authorities, regulator and customers over who is responsible for developing, consulting on, promoting and, ultimately, delivering the infrastructure and its mitigation. Anything else risks confusion and, again, uncertainty. It should also be made clear that Heathrow Airport Limited is “the appropriate person”, rather than “an appropriate person”, given we are the only possible “statutory undertaker” for airport-related development at Heathrow Airport.
8.6. Heathrow Airport Limited is the only organisation able to deliver expansion in accordance with the ‘full scheme’ vision and requirements of the HENPS. As operator of the existing airport, we have the experience, expertise and operational responsibility necessary to build and integrate new infrastructure within a complex live airport environment. The Committee and Government can have confidence in our ability to deliver major infrastructure projects, having successfully delivered Terminal 2 and Terminal 5 on time and on budget, while maintaining safe and efficient airport operations.
8.7. Appropriate scrutiny and competition are important elements of our delivery model. Proposed arrangements such as the appointment and scrutiny of a joint independent assurer demonstrate our intention for robust oversight, enabling meaningful scrutiny and challenge from our partners, while ensuring clear accountability for delivery.
8.8. It is not, however, the role of National Policy Statements to provide a framework for competition. Paving the way for multiple promoters to seek consent for the same scheme, as the draft HENPS appears to do, would not create meaningful competition benefits for passengers, airlines or the wider economy, since only one scheme can ultimately be delivered. The Government has already undertaken a competitive assessment and selected our Heathrow Northwest Runway scheme as its preferred option. Duplicative consent processes would risk additional cost, complexity, delay and confusion for local communities, local authorities, the Planning Inspectorate, the Civil Aviation Authority and other stakeholders, without creating corresponding public benefits.
9.1. The draft HENPS reflects wider Government policy effectively and provides an appropriate and updated framework for the consideration of expansion. The draft correctly maintains the distinction between the role of the NPS and wider aviation policy. It preserves the role of the 2013 Aviation Policy Framework and the Making Best Use policy in supporting growth across the wider UK airport system, whilst providing a bespoke policy framework for Heathrow expansion.
Transport policy
9.2. The draft HENPS is well aligned with current transport policy and appropriately reflects the increasing importance of integrated and sustainable surface access. In particular, the surface access requirements are aligned with DfT's Better Connected strategy and recognise the importance of enhancing rail and public transport connectivity to support airport growth.
9.3. Airspace modernisation is also a critical component of successful expansion. The draft appropriately recognises the relevance of the UK’s airspace modernisation strategy and the associated programme of airspace change. We continue to engage closely with the CAA, DfT and NATS and believe it is important that the planning framework for airport infrastructure and airspace develops and is deployed in a coordinated manner to ensure that the benefits of expansion can be fully realised.
9.4. Greater clarity is needed regarding the respective responsibilities of Heathrow and Government in delivering supporting surface access transport infrastructure. Financing requirements for future rail projects should reflect that they have wider benefits for the country and Government, and could be commercially attractive to promoters other than Heathrow.
Planning policy
9.5. The draft HENPS appropriately retains a bespoke planning framework for Heathrow expansion whilst reflecting wider developments in planning policy since 2018. We welcome the inclusion of updated design principles, including reference to the NISTA principles of climate, people, place and value, which are consistent with current Government expectations for nationally significant infrastructure and support the delivery of high-quality and sustainable development.
9.6. The draft has appropriately reflected updates to the National Planning Policy Framework (NPPF), has captured the significance of the project with the designation of Critical National Growth Infrastructure, and, apart from affordability, has correctly identified what measures and mitigations are appropriate for an NPS to cover and what are appropriate for the DCO process.
9.7. We also note that the draft HENPS appropriately retains the established policy position in relation to the need for additional hub capacity in the South East and Heathrow's role in meeting that need. Maintaining this continuity provides clarity and certainty within the planning framework while allowing it to be updated to reflect changes in legislation, policy, evidence and Government priorities.
Climate and environmental policy
9.8. The draft HENPS appropriately reflects significant developments in climate and environmental policy since 2018. This includes recognition of the Jet Zero Strategy, the Government's Aviation Noise Policy Statement for England, the ICAO Balanced Approach to noise management and the Environment Act 2021.
9.9. The draft also appropriately incorporates biodiversity net gain requirements and reflects the current environmental governance framework. These updates ensure that the HENPS remains aligned with Government objectives relating to decarbonisation, environmental protection and sustainable growth.
10.1. The draft HENPS appropriately reflects the relevant changes that have occurred across the aviation sector since the designation of the ANPS in 2018. The draft takes account of developments in airport capacity, legislative and policy requirements, and emerging technologies.
10.2. The draft HENPS recognises that a number of UK airports, including Stansted, Luton, Gatwick, Bristol and London City, have received planning consent to increase capacity since 2018. These developments have been appropriately incorporated into the updated demand and forecasting analysis, providing the most up to date and accurate assessment of future aviation capacity across the UK.
10.3. The draft also appropriately reflects changes in the international competitive environment. Major European hub airports, including Paris Charles de Gaulle and Frankfurt, continue to operate four-runway systems with available capacity, while rapidly growing hubs in Dubai, Abu Dhabi, Doha and Istanbul have benefited from Heathrow's long-standing capacity constraints. The erosion of the UK's hub competitiveness is a well-evidenced trend, and the draft is right to acknowledge the increasing challenges facing Heathrow and the UK aviation sector in this regard.
10.4. We welcome the extent to which the draft HENPS has been updated to reflect the current climate and environmental policy framework. This includes recognition of the Sixth Carbon Budget, the Environment Act 2021, the Air Quality Standards (Fine Particulate Matter) (England) Regulations 2023 and the Environmental Principles Policy Statement. These updates ensure that the HENPS reflects the current legislative framework and wider Government objectives on environment.
10.5. The draft HENPS also acknowledges the evolving role of technology and aviation decarbonisation measures. In particular, it reflects developments such as the Sustainable Aviation Fuel (SAF) Mandate and the SAF Act 2026. We are already actively supporting the deployment of SAF through our incentive scheme and have achieved the second-highest level of ACI Airport Carbon Accreditation, committed to reducing Scope 1 and 2 emissions by 45% by 2030[10].
10.6. Whilst we are supportive of the approach taken, there are several areas where the draft HENPS could be refined further. In particular:
a) Whilst additional capacity across the wider airport system is welcome, hub capacity delivers distinct benefits and serves a different strategic function. The draft could more clearly reflect the unique contribution of hub capacity to the UK's connectivity and economic objectives.
b) Whilst the freight analysis is robust, it could be strengthened through greater recognition of the relationship between long-haul passenger connectivity and air freight capacity. Heathrow's position as the UK's hub airport enables significant belly hold freight capacity on long-haul passenger services. This capacity cannot be replicated to the same extent at non-hub airports and represents a distinctive benefit of expansion at Heathrow, supporting UK trade, economic growth and international competitiveness.
11.1. The HENPS demonstrates that lessons from previous litigation in relation to the ANPS, and other NPSs, have been incorporated. Overall, we consider the draft HENPS to be materially more robust than the 2018 ANPS from both a legal and policy perspective.
11.2. Climate change considerations have been significantly strengthened, and the framework now better reflects developments in Government climate policy and legislation. For example, the draft explicitly references the Paris Agreement, and the climate change chapter has been fundamentally revised to reflect the current environmental policy and legislative context. Other issues, such as non-CO₂ aviation impacts, are explicitly addressed.
11.3. The supporting assessment framework has likewise been substantially refreshed. In particular, the Appraisal of Sustainability has been updated to provide a more comprehensive and robust assessment of environmental, social and economic impacts, helping to strengthen the evidence base underpinning the policy.
12.1. Although the process remains ongoing, the consultation appears to be consistent with the applicable consultation requirements, including the Cabinet Consultation Principles 2018, and the statutory requirements of the Planning Act 2008 (s.7), as supplemented by MHCLG guidance on the NPS review process.
12.2. The consultation process appears broad in scope and provides stakeholders with a meaningful opportunity to review the draft HENPS and supporting evidence base and to submit representations. We note that the Government continues to actively promote the consultation and encourage stakeholder participation.
12.3. The current consultation also builds upon a substantial programme of stakeholder engagement and consultation undertaken over a number of years. This includes the extensive work of the Airports Commission, Heathrow's consultations on expansion proposals in 2014, 2018 and 2019, and the Government's consultations on the Airports National Policy Statement in 2017.
12.4. The Government has committed to an open and transparent process with stakeholders.
July 2026
Endnotes
[1] Government backs Heathrow expansion to kickstart economic growth - GOV.UK
[2] Airports Commission: final report para 6.81
[3] S-CGE modelling of Heathrow Airport expansion peer review, section 3.4.3
[4] ONS travel tourism statistics, 2025 Q2.
[5] Wellbeing_guidance_for_appraisal_-_supplementary_Green_Book_guidance.pdf.
[6] The Channel Tunnel Cost Benefit Analysis after 20 years of operations, para 127
[7] Delivering the Thames Freeport, annex A9
[8] The economic benefits of expansion at Heathrow | Frontier Economics
[9] Keeping the UK connected - domestic connectivity at Heathrow
[10] According to a 2019 baseline