Tonbridge and Malling Borough Council has published three previously missing pages of monitoring indicators for its draft Tonbridge Local Plan. The material concerns strategic policies SP3 to SP10 in Annex 7 of the Regulation 19 consultation documents, which cover the Kent borough’s planning strategy up to 2042.
The council says the tables were accidentally left out when the consultation documents were published. It has now provided the missing indicators on its official Local Plan website, while maintaining that the underlying policy wording has not changed. The consultation began on 11th September 2026 and is proceeding after a government direction required the council to move forward.
The council has also extended the Regulation 19 consultation to 11.59pm on Monday 26th October 2026, following a temporary interruption to its online consultation system. The new closing date is expressly confirmed on the council’s current Local Plan page and its official deadline-extension announcement. Although an older Statement of Representations Procedure still shows Sunday 25th October, consultees should rely on the council’s later published update. I would not treat the restored monitoring pages as a minor administrative detail: they affect what consultees can test before the plan reaches independent examination.
Why Tonbridge Local Plan monitoring tables matter
A monitoring framework is not simply an administrative appendix. It identifies the measurements a council expects to use to judge whether its planning strategy is achieving what it says it will achieve. It can show, for example, whether employment land is being retained, rural housing is coming forward or decisions affecting Green Belt land follow the intended approach.
The newly available three-page Annex 7 document fills a gap across eight strategic policies. The council explains that all the omitted indicators except those for SP10 had appeared in an earlier Regulation 18 consultation. SP10 is a new policy, so its monitoring information was not previously available in that earlier version.
The council’s published statement is deliberately narrow: They do not change the wording, content or operation of any Local Plan policy.
Tonbridge and Malling Borough Council says this on its current Local Plan page. That matters. The missing material is evidence about how policy outcomes would be measured; it is not a replacement for an allocation, a new restriction on development or an adopted development-plan policy.
For promoters and objectors, Tonbridge Local Plan monitoring information could still be relevant to soundness. A credible policy needs to be capable of implementation and review, and a clear performance indicator may expose an assumption that deserves testing at examination. But it would be wrong to claim that the council has amended SP3 to SP10 merely because their indicator tables were added.
What the eight policies will monitor
SP3 covers the settlement hierarchy and general development principles. Its new table tracks homes approved within or next to Tier 5 settlements and net additional affordable dwellings completed on rural exception sites. SP4 concerns accommodation for Gypsies, Travellers and Travelling Showpeople, with an indicator concerning permitted pitches and plots.
SP5 deals with employment growth, monitoring gains and losses in office, industrial and storage floorspace, including strategic and non-strategic employment locations. SP6 looks at town centre performance, including annual retail floorspace completion and vacancy rates. These indicators may help test whether the growth strategy is realistic, but none is itself a permission or a prohibition.
The Green Belt indicators are particularly significant in a borough where development pressures and protected land are closely connected. SP7 monitors the total area of Green Belt land; SP8 records permissions for inappropriate Green Belt development and dwellings permitted on Green Belt and grey belt land. The accompanying targets include minimising loss of Green Belt and minimising relevant housing permissions, which must be read as monitoring ambitions rather than a rewriting of national planning law.
SP9 tracks appeals involving refusal under the Local Green Gap policy. SP10 concerns healthy communities and health impact assessment, with a measure based on the proportion of residents who report good or very good health. It is worth noting that a health outcome measured through census data is broader than the determination of any one planning application.
Someone assessing the Tonbridge Local Plan against its supporting evidence should read each indicator alongside the actual policy text, the plan’s supporting appraisal and its proposed allocations. An indicator labelled “zero” or “minimise” cannot lawfully substitute for the policy criteria and planning balance required in an individual decision.
Council extends consultation to 26 October
Tonbridge and Malling Borough Council has now announced an extension, with representations due by 11.59pm on Monday 26th October 2026. The official extension notice explains that the change follows temporary unavailability of the consultation system. The council’s live Local Plan page shows the revised deadline.
The Statement of Representations Procedure, published earlier in September, still specifies 11.59pm on Sunday 25th October 2026. That reflects the original deadline and is now overtaken by the council’s express extension. The presence of the earlier date in the linked document does not, by itself, undo the later published announcement.
Anyone making a representation should use the official consultation portal before the revised closing time and keep a dated confirmation of submission. If the portal is inaccessible, contact the council’s Planning Policy Team at [email protected]. The extension changes the deadline, not the tests of legal compliance and soundness on which Regulation 19 representations should focus.
It would also be premature to suggest that the omission automatically invalidates the consultation. The council has publicly acknowledged it and says the additional pages will be explained when the plan is submitted. Whether the consultation was legally compliant and whether any deficiency affects soundness are matters to assess on the evidence, potentially during examination.
Why this consultation is not an ordinary planning objection
The Tonbridge Local Plan consultation uses the saved legacy Regulation 19 process, not the new gateway process introduced elsewhere in England in 2026. The council explicitly says representations must address legal compliance or the four familiar soundness tests: positively prepared, justified, effective and consistent with national policy.
Our guide to England’s old and new Local Plan systems explains why the correct statutory route matters. The Local Plan examination guide goes further into how an Inspector tests evidence, representations and any necessary modifications after submission.
A strong response to the missing indicators would identify a particular policy or outcome and explain what is not measurable, why that matters and what supporting evidence is missing. Simply objecting to an unrelated site allocation because three pages were omitted is unlikely to address the relevant test. The separate underlying arguments about growth, water infrastructure, traffic, affordable housing and the Green Belt still need their own evidence.
Government direction still governs the next stage
The timing is unusually sensitive because the Secretary of State intervened after councillors voted to halt progression of the Tonbridge Local Plan over concerns about water supply. The minister’s direction of 4th September 2026 required a Regulation 19 consultation and submission of the emerging plan by 31st December 2026. That direction did not amount to adoption or a finding that the plan is sound.
After representations are considered, the authority expects to submit the plan, evidence and comments for independent examination. The council says it will explain the omission and later publication at that point. The Inspector can then consider any significant procedural or evidential questions within the examination framework.
For live planning applications, the emerging Tonbridge Local Plan is still not the adopted development plan. Our guide to emerging Local Plans explains how decision-makers should approach the weight of unsettled policies. The immediate practical task is clear: check the restored tables, prepare any policy-specific soundness points and submit representations by the council’s extended deadline of 11.59pm on 26th October 2026.
Original documents
The primary documents are the council’s current Local Plan consultation page, its deadline extension notice, the three additional monitoring pages, its Statement of Representations Procedure and the ministerial intervention letter. We previously reported the separate government intervention and water supply dispute.
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