Comment on 20,106 new homes until 11.59pm on 25 October. The council's leader is asking the minister to drop it: the water firm forecasts 317 homes a year.

The consultation on Tonbridge and Malling’s draft Local Plan opened on Friday. It closes at 11.59pm on Sunday 25 October.

That is the last chance anyone gets to comment before a government inspector takes over. The plan allocates land for 20,106 homes across the borough to 2042.

The council is running the consultation because it has been ordered to. On the same day it opened, the Leader wrote to the housing minister demanding the order be withdrawn.

The number in that letter

Cllr Matt Boughton’s letter to Matthew Pennycook MP sets out what he calls the exceptional circumstances. The hard figure is in paragraphs 20 and 21.

South East Water’s own Position Statement, published in the plan’s evidence base in August, contains a table comparing what each West Kent council must plan for against what the company forecast in its 2024 water resources plan. For Tonbridge and Malling the table reads:

  • Housing need under the standard method: 1,097 a year.
  • Annualised housing growth in South East Water’s plan for 2025-26 to 2041-42: 317 a year.
  • Shortfall: 780 a year.

Cllr Boughton’s letter uses 1,117 as the need figure, the number the minister himself used, and so arrives at a shortfall of 800 a year. The two figures are close and the point is the same either way: the company’s own planning assumptions cover roughly a quarter of the homes the government wants built here.

He writes that progressing the plan “would be costly and counterproductive” because “the majority of houses within it cannot actually be delivered”. He goes further, and says the effect would be to “actively frustrate the Government’s ambitions for housing delivery” and “potentially result in even more sustained water shortages throughout the borough”.

Housing need against South East Water's forecast, four West Kent districts Paired bars for four districts. Tonbridge and Malling: housing need 1,097 homes a year, water company forecast 317, shortfall 780. Sevenoaks: need 1,164, forecast 525, shortfall 639. Maidstone: need 1,358, forecast 906, shortfall 452. Tunbridge Wells: need 1,098, forecast 666, shortfall 432. Source: South East Water Planning Position and Options Statement, August 2026, Table 2. What West Kent must plan for, and what the water company forecast Homes a year. Dark bar: housing need. Light bar: South East Water's WRMP24 growth forecast. Tonbridge and Malling 1,097 317 short by 780 Sevenoaks 1,164 525 short by 639 Maidstone 1,358 906 short by 452 Tunbridge Wells 1,098 666 short by 432 South East Water's own note on its figures: the Sevenoaks row should be treated with caution, because the company supplies only about half that district. Source: South East Water, Planning Position and Options Statement, August 2026, Table 2, in the council's Local Plan evidence base. Graphic by Tonbridge Today
The water company's comparison of housing need against its own forecast, for the four West Kent districts. Tonbridge and Malling has the widest gap.

What the water company says it can build, and when

South East Water’s statement does not stop at the shortfall. It sets out the package of schemes the government’s Water Delivery Taskforce asked it to take forward, with delivery dates and the risks attached to each. For scale, the company says that one extra megalitre a day supplies roughly 3,800 new homes.

  • New borehole at Saints Hill treatment works, up to 1.5 megalitres a day, deliverable by summer 2028. The statement says the yield “is uncertain until the borehole is drilled and tested”, and that several of the company’s boreholes in that geology “did not produce a meaningful yield” and were abandoned.
  • A second borehole at Lilley Farm, up to 1 megalitre a day, summer months only, also by summer 2028.
  • A licence trade at Decoy Woods for winter abstraction. Benefit and cost both listed as to be confirmed.
  • A 7km pipeline from SES Water’s Bough Beech reservoir to Riverhill, up to 10 megalitres a day. Lead time: six years.
  • A treated water main from Butler works at Aylesford to Halling service reservoir, roughly £6m to £7m. Lead time: four to five years.

The statement also records why two obvious options were dropped. Cutting leakage further was excluded because the company is already missing its current target: it reported average leakage of 104.8 megalitres a day in 2024-25 against a target of 81. Water efficiency was excluded for similar reasons.

Funding is the open question. Three of the five schemes are not in the company’s 2024 water resources plan at all, and the statement says elements of the package “will require funding over and above” its current investment commitments, because they were not in the business plan it submitted to Ofwat. It expects to have “clear project scope, programme and costs” by October 2026, which is when it can start Ofwat’s cost change process.

The vote the minister overruled

The recorded vote from the 3 September meeting has now been published. Councillors backed Cllr Boughton’s amendment to pause the plan by 33 votes to 9, with one abstention, out of 43 members eligible to vote.

The resolution did not reject the plan. It said the council was “not able to agree to the progression of the Regulation 19 Local Plan to publication and submission … at this time”, and would keep working with South East Water “to seek the evidence that is necessary to enable the Local Plan to move forward”.

The minister directed the council to consult anyway, the next day. Cllr Boughton’s letter makes a point of the timing: the direction came “less than 24 hours after” a vote on which there was “cross-party consensus from four different political parties”.

His public line is blunter than the letter. “We have launched the consultation today because we are legally required to do so,” he said, “but we do not believe that this is a good use of taxpayers money or time.”

What it means for you

If you want to comment, you have until 11.59pm on Sunday 25 October. After that the plan goes to the Secretary of State and an independent inspector examines it.

  • Comment online at the council’s consultation portal, reg19tmbcconsult.commonplace.is. A downloadable form is available for anyone who cannot use the portal.
  • Read it on paper at the council offices at Kings Hill, at Tonbridge Castle, and at every library in the borough, throughout the consultation.
  • Say what you think is unsound, not just what you dislike. At this stage the test is legal compliance and soundness: whether the plan was positively prepared, and whether it is justified, effective and consistent with national policy. A comment that engages with a specific policy, paragraph or the policies map carries further than a general objection.
  • You can ask to be heard in person. The statement of representations procedure says anyone making a representation may request to take part in the examination hearings, and that you select this when you submit.
  • Do not send a group of identical comments. The council asks that people who share a view submit one representation naming those it represents, rather than repeating it separately.
  • Late is late. Representations received after the deadline “will be marked as late and may not be accepted by the appointed Planning Inspector”.

One practical note. The consultation is on the council’s Local Plan page and the Commonplace portal. It was not listed on the council’s own consultations page when we checked on 14 September, where the only current entry was the council tax reduction scheme.

The allocations themselves have not changed since the vote was called. The largest are at Borough Green, north east Tonbridge, Kiln Barn Road in East Malling, Broadwater Farm at Kings Hill and Holborough Lakes at Snodland. About 71 per cent of the borough is Green Belt.

Sources