What is the Local Plan and why does it matter?
Like all councils, TMBC is required by government to prepare a Local Plan which serves as a blueprint for how the borough should develop between now and 2042. It sets out how we can balance the need to provide new homes while also controlling development in green spaces and protecting the environment.
Crucially, having a Local Plan in place will provide control and certainty about where development will be permitted. Elected councillors will have stronger powers to reject applications in inappropriate locations or which conflict with the policies on preserving the character of our towns and villages and protecting the environment.
Why doesn’t Tonbridge and Malling already have an up-to-date Local Plan?
Our previous draft plan had to be stopped when the government announced in 2024 its intention to revise the NPPF. This review saw the formula used for housing targets increase the number of homes to be delivered by an average of 30 per cent.
This required significant reworking of our plan to accommodate additional housing numbers. We are now working at pace to deliver a Local Plan which will meet the new government-set target while managing impacts on the Green Belt and protecting the character of our towns and villages.
What happens if there is no Local Plan?
Without a plan, developers can apply to build almost anywhere. Even if the council refuses permission, applications may win on appeal because we don’t have an up-to- date plan to guide development.
With a plan, we have greater control over where development can happen. We can make sure new homes are built in the right places with the necessary infrastructure provided.
How many homes are proposed?
The plan is based on meeting a government-set target to identify where 19,746 homes can be provided over the 18-year period covered the plan (2024 – 2042). This assessment is reached using a government-backed formula set out in the National Planning Policy Framework and National Planning Policy Guidance.
Where does the government say you have to meet its mandated housing target?
The updated 2024 National Planning Policy Framework (NPPF), which all councils have to follow in preparing Local Plans, provides the basis for revised housing targets. In a letter to councils in July 2024, the then Secretary of State for Housing stated that “local authorities will be expected to make every effort to allocate land in line with their housing need.”
The NPPF does allow for lower targets in exceptional circumstances, for example if there are constraints on land availability such as flood risk. However, the evidence prepared for the current draft Tonbridge and Malling plan shows that the housing target can be met.
How many sites have been earmarked for development?
Following analysis of more than 500 sites, the current draft plan identifies 54 as potentially suitable for housing and nine sites for employment.
How have sites been chosen?
The sites were subject to a Sustainability Appraisal (SA) to identify potential impacts of development and inform decision making.
Where possible, we’ve focused on brownfield land and previously undeveloped sites close to existing towns and villages which can accommodate some growth. However, this does not provide enough land to meet the Government’s housing need figure, therefore we have also focused on greenfield sites in sustainable locations.
Who are all the houses for?
The population of Tonbridge and Malling is growing with more than 1,000 people moving into the borough every year*. Without providing additional homes, demand is for places to live will continue to outstrip supply, pushing up prices and making existing affordability issues worse for many.
The Local Plan takes into account a range of factors, including future population projections and age structure, household size, affordability and labour supply with the aim of ensuring an adequate supply of affordable homes of all types for those living or working in the borough.
*ONS 2023-24
Will new affordable homes provided under the Local Plan only be for people from my town/village?
Most properties delivered under the plan will be sold or rented on the open market. However, our Local Lettings Plan Policy will apply to all new developments in the borough and will give priority to people with a local connection when bidding for newly built affordable homes on the Housing Register.
Why are the sites split into ‘settlements’ - what do these represent?
Showing allocated sites on a settlement basis reflects the places and local identities that many residents will be familiar with. It also helps with infrastructure planning so improvements can be focused on the right places.
The Local Plan also uses a “settlement hierarchy” to identify the most sustainable places for future development, focusing places with good infrastructure that can accommodate growth. Where roads and other local services need to be improved, this will be addressed by the Infrastructure Delivery Plan which forms a key part of the Local Plan.
How is housing density calculated on sites?
The density of development (ie the number of units in a given space) takes into account of site characteristics, its location and local character and any constraints. Higher densities in appropriate locations, such as towns, help reduce the need for development on greenfield sites.
We will progress further work on density to help inform the Regulation 19 version of the plan.
What developments have been approved because we don’t have an up-to-date Local Plan?
Not having an up-to-date Local Plan for our borough makes it harder to refuse applications which don’t meet the standards and policies we set for development.
Even if an application is refused, a developer may often appeal and cite the lack of a Local Plan and the lack of a five-year housing land supply to support their case.
Read the latest on our housing land supply position published in January 2025.
Why isn’t the council focusing on bringing empty homes back into use to minimise the need for new homes to be built?
Bringing empty properties back into use does not count towards our housing target.
However, we recognise the importance of bringing empty homes back into use and have recently employed a dedicated officer to focus on working with property owners to reduce the number of vacant homes in our borough. Latest estimates indicate there are more than 400 homes in the borough that have been vacant for six months or more.
How can the public have a say in the plan?
We recognise the high level of public interest in development. Our consultation is a vital opportunity for the public to have a say in the plan. If agreed, it is due to opens on Monday 10 November and runs for 6 weeks.
In addition, there will be a series of public meetings where the council will be available for any questions on how to take part in the consultation.
Can you guarantee the necessary new infrastructure will be provided?
Our plan is explicit that infrastructure improvements must be considered alongside any new development. Developer contributions, known as Section 106 Agreements, will be used to fund projects. In 2022-23, more than £7 million in contributions were raised linked to development in the borough.
We have developed an Interim Infrastructure Delivery Plan (IDP) which sets out the needs of the borough arising from additional homes and developers will be required to make contributions for improvements to roads, health, education and other services as part of the planning process. This IDP is a live document and will be updated as the Plan progresses to its next stage.
How much Green Belt or greenfield land is proposed for development?
In a borough which is 71% Green Belt, it is inevitable that some of this land and previously undeveloped land needs to be included in the plan.
However, no high-quality Green Belt land is being proposed for development.
Instead, we are focusing on so called Grey Belt land. This is defined by the government as land which is considered part of the Green Belt but which is low-quality land that does not strongly contribute to Green Belt purposes.
This type of land provisionally identified for residential and business development makes up 2.37% of the total Green Belt within Tonbridge and Malling.
Subject to further analysis, we expect Grey Belt land will make up just over 62% of land earmarked for housing and 47% of the space allocated for employment.
The draft plan allocates around 23% of new homes to land that is either brownfield (previously developed) or locations that are a mix of brownfield and greenfield. Just under 77% of sites identified are currently undeveloped greenfield sites. Of the sites identified for employment, around 87% are greenfield sites with 13% brownfield.
Sites within the Green Belt that are taken forward as part of the next stage of the Local Plan (Regulation 19) will identify necessary mitigation measures to ensure national policy set out in the National Planning Policy Framework is complied with.
Can public opposition get a site removed from the plan or a policy changed?
The plan is still in draft form and can be amended. Sites are either rejected, proposed for development or subject to further investigation.
Following the consultation, we will consider all responses received as well as carry out further analysis to ensure that the plan we submit is justified, sound and robust.
There is scope to make changes based on feedback to our consultation and we will be undertaking further work on our evidence base, including that relating to sites, ahead of the next stage in the process (Regulation 19).
What has the highways assessment looked at so far and what else will be looked at before the final plan?
For the Regulation 18 Local Plan, we have tested a number of scenarios for growth as well as some early modelling on 27 key junctions to understand what improvements may be needed. Further work will be required to support the Regulation 19 Local Plan including further testing of the preferred growth scenario and junction design.
How were the 27 junctions that have been modelled chosen?
These junctions showed impacts in the early stages of transport modelling. The were also flagged by studies commissioned to support this phase of the plan and were agreed by National Highways.
Should other junctions be highlighted during future modelling, they may also be included in the next round of work.
Why have certain area been identified for large numbers of new homes?
Our plan focuses where possible on areas that already have good transport links and access to services to minimise pressure on green field sites.
Government policy requires the council to demonstrate that it has examined fully all reasonable options for meeting its needs outside Green Belt boundaries.
Who has the final say on the plan?
Following public consultation, borough councillors will decide whether to approve the final version. The plan will then be submitted for review by government Planning Inspectors. We are currently required to submit our plan to the Inspectorate by December 2026.
When will the plan be finalised?
We expect the final Local Plan to be adopted by the end of 2027.