Further Proposed Modifications to the North Hertfordshire Local Plan 2011- 2031

Serious flaws in the assessment of housing need. NHDC statement - Housing need occurs for the reasons supplied by NHDC such as “people living longer, changes in social patterns, and the attractiveness of the place to live”
Fails to assess housing need that adequately includes migration as NPPF para159
NPPF para 159 Re housing need – “meets household and population projects , taking account of migration and demographic change”
Estate agencies report between 65 and 73% of all houses sold in North Herts are to city dwellers moving out of London. North Herts is supplying a considerable number of houses to resolve the London Housing need (and not NHDC local need) but there is no statical representation for this critical issue. Population is not the driver of housing need, Population will increase when housing is made available. Downward alteration of expected population forecast and subsequent housing need reduction is setting housing targets much to low.

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Every property sale to an incoming UK internal migrant creates another local housing need for the resident who has been replaced by the purchaser from outside North Herts.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

Housing need and affordability - ref NNPF para 20
Affordability in the North Herts area is significantly worse than the national average of 7.5 times salery
Housing need is very much affected by affordability. With house pricing at 13.3 x average salary, the need adjustment calculations produce an Adjustment factor of 1.58 times the basic housing need figures
This uplift is not adequately recorded in the NHDC housing need total figures either

Transfer of property from NH residents to people migrating from London is generating a very considerable housing need for local displaced residents but this is not taken into consideration at-all in the calculation of housing need which is far greater than documented in the proposed LDF and proposed development of strategic sites will only increase migration from London and not reduce the local need for local residents as per FM 058
In the year to mid-2019, the number of people moving out of London to somewhere else in the UK increased by 2.6% to 349,000, while the number of people moving into London increased by 7.6% to 255,000. Overall, this meant that 94,000 more people moved out of London than into it; - Source ONS 2019