If you are planning to build or extend in the borough, getting to grips with the daylight requirements in Tunbridge Wells early can save time, cost and frustration. The local planning authority is Tunbridge Wells Borough Council (a shire district covering Royal Tunbridge Wells, Southborough, Paddock Wood, Pembury, Cranbrook and the surrounding High Weald villages), not Kent County Council. This guide sets out the policy framework that now applies, the technical standards used to judge light impacts, and how a professional assessment can support your scheme.
The newly adopted Tunbridge Wells Local Plan
Tunbridge Wells has very recently moved to an up-to-date plan. The Tunbridge Wells Borough Local Plan 2020-2038 was formally adopted by Full Council on 10 December 2025. It replaces the previous trio of documents that applicants relied on for years: the Local Plan (2006), the Core Strategy (2010) and the Site Allocations Local Plan (2016).
This matters in practice. If you are working from older guidance or a planning report written before December 2025, the policy references may be out of date. Decisions on current applications are now made against the adopted 2020-2038 plan, so it is worth confirming the live policy wording on the council's website before you finalise a submission.
Policy EN1 and residential amenity
The key development management policy for light and amenity in the new plan is Policy EN1: Sustainable Design. It applies to development proposals across the borough and sets out a broad suite of criteria covering design, character and site context; landscape, trees and amenity; residential amenity; and design and construction guidance.
On light specifically, EN1 requires that a proposal:
would not cause significant harm to the residential amenities of adjoining occupiers, and would provide adequate residential amenities for future occupiers of the development, when assessed in terms of daylight, sunlight and privacy.
That is an unusually explicit hook: the policy names daylight and sunlight directly as the measures against which amenity harm is judged. EN1 also addresses privacy and overlooking, noting that the overlooking of principal rooms or of private garden areas is a particularly important consideration, and that careful window positioning and boundary treatment can help overcome concerns. The policy is supported by EN1's wider design criteria on scale, layout, orientation, site coverage and roofscape, all of which influence how a building relates to its neighbours and how much light it blocks.
How daylight and sunlight are actually assessed
Tunbridge Wells does not set its own bespoke numerical daylight targets within Policy EN1. Instead, the policy's daylight, sunlight and privacy test is applied using nationally recognised technical guidance, brought to bear through the Local Plan:
- BRE BR 209 (2022) – "Site layout planning for daylight and sunlight: a guide to good practice". This is the standard reference used to assess impact on neighbouring properties. It covers the Vertical Sky Component (VSC) and daylight distribution (No Sky Line) tests for daylight, Annual Probable Sunlight Hours (APSH) for sunlight to existing windows, and the two-hours-on-21-March test for overshadowing of gardens and amenity areas.
- BS EN 17037 – "Daylight in buildings", which deals with the daylight provided to habitable rooms within the new development itself – directly relevant to EN1's requirement to provide adequate amenity for future occupiers.
- The National Planning Policy Framework (NPPF), which requires high-quality design and a good standard of amenity, while cautioning that daylight and sunlight standards should be applied flexibly and not used to prevent otherwise acceptable development, particularly in town-centre and higher-density locations.
The borough's Local Validation List sets out the supporting information required with an application; following adoption of the new Local Plan the council has been reviewing and updating that list, so for any non-trivial scheme it is sensible to check whether a daylight and sunlight assessment is expected, or to provide one proactively where neighbouring amenity is in play.
Heritage and townscape context in Tunbridge Wells
Two local characteristics make light and massing especially sensitive in this borough. First, the historic core of Royal Tunbridge Wells – including the colonnaded Pantiles and the surrounding conservation areas, with their close-grained Georgian and Victorian frontages – creates tight back-to-back relationships where small changes in height or depth can have a noticeable effect on a neighbour's light. Second, a substantial part of the borough lies within the High Weald National Landscape (formerly the High Weald Area of Outstanding Natural Beauty), where design quality and sensitivity to setting are scrutinised closely. In both contexts, a well-evidenced daylight and sunlight assessment helps demonstrate that an extension or infill scheme respects its neighbours and its surroundings, in line with EN1.
What this means for your project
If your proposal involves a two-storey or first-floor extension near a boundary, a rooftop addition, a backland or infill dwelling, or a flatted scheme, light impact is likely to be a live issue under Policy EN1. Commissioning a BRE BR 209 (2022) assessment early lets you test the design against recognised benchmarks, adjust massing or fenestration before submission, and present clear technical evidence that addresses the council's daylight, sunlight and privacy test head-on. It also gives you a credible basis to respond if a neighbour objects or the matter proceeds to appeal.
How Fortress Associates can help
Fortress Associates provides our daylight and sunlight report service to BRE BR 209 (2022), BS EN 17037 and the relevant national and local policy, so your evidence answers Policy EN1 directly. We work nationwide with a 4 to 5 working day turnaround and require no advance payment. We can also prepare Building Regulations drawings for your project. For a Tunbridge Wells scheme, please contact our team.
Sources & further reading
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