16.04.2026
Concerns around water supply capacity have been brought into focus following comments from South East Water in response to the emerging Tonbridge and Malling Borough Council Local Plan, which proposes significant housing growth over the next two decades.
The draft Local Plan aims to deliver more than 19,000 new homes between 2024 and 2042, reflecting nationally driven housing targets and local evidence of need. However, South East Water has indicated that its current supply planning does not provide sufficient headroom to support the level of growth now being proposed.
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South East Water has confirmed that its existing water resources management plan, prepared using 2023 housing data, does not reflect the scale of housing uplift identified in the Council’s draft Local Plan. As a result, the company has stated that it cannot currently accommodate the proposed level of growth within its supply forecasts.
The water company has emphasised that this is not a rejection of planned development, but a recognition that infrastructure planning must be aligned with updated growth trajectories. Without sufficient headroom, additional investment and revised supply strategies would be required to support delivery.
Tonbridge and Malling Borough Council’s draft Local Plan identifies 54 potential development sites to meet its housing requirement across an 18‑year plan period. As part of the statutory consultation process, infrastructure capacity — including water supply — forms a key component of the evidence base.
In response to the comments from South East Water, the Council has confirmed that it is seeking clarification on the issues raised and has reiterated that the consultation stage is intended to gather feedback and identify areas requiring further work. The Council has also emphasised the importance of working closely with infrastructure providers to ensure growth plans are
deliverable.
The situation in Tonbridge and Malling reflects a broader national challenge facing the planning system. Housing delivery targets have increased significantly as part of the Government’s ambition to deliver 1.5 million new homes by 2029, placing growing pressure on utilities, transport networks and social infrastructure.
Water supply constraints in particular are becoming an increasingly prominent issue across parts of the South East, where population growth, climate change pressures and historic under‑investment combine to create capacity challenges.
Planning policy is clear that development should be supported by adequate infrastructure, but equally recognises that infrastructure delivery and housing growth often need to evolve in parallel. The key challenge for plan‑making authorities is ensuring that Local Plans are realistic, flexible and supported by robust evidence, while also enabling providers to plan investment with confidence.
At the Local Plan stage, identified infrastructure constraints do not necessarily prevent growth from being planned. However, they do reinforce the need for:
For developers and landowners, water supply constraints underline the importance of understanding infrastructure issues early in the promotion of sites and being prepared to engage with utilities as schemes come forward.
The emerging position on water supply capacity also has important implications for the determination of live and forthcoming planning applications within Tonbridge and Malling.
We understand that the Council is currently seeking Counsel’s advice to inform its approach to decision‑making where strategic infrastructure constraints — such as water supply — have been identified but not yet fully resolved. This reflects a desire to ensure that planning committees are properly and lawfully advised on the matters they must consider, including the weight to be afforded to infrastructure evidence, the status of emerging Local Plan work, and the balance to be struck against housing need.
In this context, it is understood that the Council has indicated it will not be progressing planning applications to committee until there is greater clarity around water supply solutions and members are content with the approach being taken. Officers are presently asking applicants to demonstrate water capacity or engage proactively with the issue, while further understanding is sought on how these matters should be assessed and reported to members.
This cautious approach highlights the need for decision‑makers to apply appropriate weight, sound evidence and clear reasoning when determining applications, particularly where refusal, deferral or approval could give rise to legal challenge if infrastructure constraints are either overstated or under‑weighted.
For applicants and developers, this emphasises the importance of submitting robust, well‑evidenced schemes that engage constructively with water supply considerations, rather than assuming such matters sit solely at Local Plan stage. Greater clarity is expected in the coming weeks as the Council’s position evolves and members are advised accordingly.
At DHA Planning, we increasingly see infrastructure capacity — particularly water, wastewater and surface water management — playing a central role in both plan‑making and the determination of planning applications.
The TMBC example highlights the importance of aligning housing ambitions with deliverable infrastructure strategies, supported by up‑to‑date evidence, clear engagement with providers and a sound understanding of how weight should be applied at different stages of the planning process.
As Local Plans continue to evolve in response to increased housing targets, careful consideration of infrastructure constraints — and the evidence underpinning them — will remain critical to ensuring that growth is sustainable, coordinated, legally robust and achievable.
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