Village boundaries are proposed as a development restrictive device being inconsistent with (NPPF 11 a) decreasing future flexibility. -- plans should be sufficiently flexible to adapt to repaid change. Imposition of boundaries round communities are planning restriction devices contrary to NPPF 11a
Downward alteration of proposed housing sites in BA, LG, NS, HT, and GA sites are not correct. – These target figures are inaccurate as they do not include inward migration from London correctly nor do they include meaningful affordability uplift (which should be a factor of 1.59 uplift) of local need.
Inclusion of these 2 critical NPPF policy elements would increase the housing need target considerably.
Large Developments on the London commuter rail line will not resolve local housing shortage
Latest surveys 2021 indicate that some 1.6 million (4.6%) of London residents wish to relocate out of London within the next 12 months. If current relocation trends continue most of the dwelling built around the commuter rail line to London will be bought up by London commuters and dwellings will not be available to supply current local housing need.
Every property sale to an incoming UK internal migrant creates another local housing need for the resident who has been replaced by the purchaser from outside North Herts. These displaced members of the public are not recorded in the housing need statistics as needing housing. The ONS outflow count cannot be interpreted as members of the public disappearing from the North Herts area. The recorded annual migrant inflow of 8136 will produce the same number of people looking for another house in the NH area. and is not recorded.
Over the period 2019- 2021 the migration from London to the East of England has far exceeded the presented local housing need figures which was compiled in 2018 and published 2019. Inward flow is now many times higher annually than 8136 quotes by ONS for period to 2018
NPPF para 159 Re housing need – “meets household and population projects , taking account of migration and demographic change
Inserted targets in FM057 are too low