Medway Local Plan (Regulation 18, 2023)

F D Attwood and Partners have a significant landholding of 365ha, which runs the full length of the Capstone Corridor from Darland Banks to the M2 motorway (identified on the attached plan). This single family landowner supports the overall Medway vision for the plan, particularly in the following areas:
• The overall framing of the vision and the recognition that development can bring forward positive benefits if planned well. It is positive that there is recognition the vision must be ambitious (para 2.4) and looks forward and is not overtly influenced by past choices that were taken in a different context based on a specific locational preference which has dominated past spatial decision making, namely Hoo. It is also right that the vision should be the starting point from which spatial options can later derive to identify the “best fit.”
• The need to address existing inequalities and create more inclusive communities is identified in the vision and this is supported by FD Attwood and Partners and can best be addressed by new development for the suburban and urban waterfront options. The focus on urban regeneration is fully supported and rightly prioritised subject to the caveats highlighted in our response to Question 2. The highlighting of the important role of existing High Streets within the vision is also commended and again the urban and suburban spatial options which are geographically the closest, and already serve a large urban area catchment, will be better placed to meet this important objective and help revitalise the town centres as important social meeting places and reinforcing the identity of Medway.
• The need to meet growth through mixed communities and the desire to create jobs alongside housing and reduce existing levels of out commuting is also fully supported in the vision and clearly, options that improve travel choice and infrastructure, will best deliver this aspect of the vision.
• Highlighting that infrastructure and services must be delivered with new development to create balance for the existing and new communities is pivotal and fully supported and this certainly has not been delivered by national planning decision making in the past and is another reason to support the need for the vision to be positive and ambitious rather than to be governed by what didn’t happen in the past.
• Meeting the full spectrum of housing needs, including first time buyers and importantly the increased delivery of affordable housing, is supported.
• Highlighting that the vision should be underpinned by quality development which includes SUDS, open space, recreational and health, alongside community and social infrastructure, is fully supported and it is right to emphasise this can best be achieved through a comprehensive masterplanned approach where healthier, safe and better connected and sustainable places which are more inclusive can be delivered.
• The recognition of the central importance of climate change and addressing air quality in driving decision making is fully supported alongside the emphasis on the importance of connected spaces and particularly green infrastructure, which in the case of the Capstone Corridor, represents a unique opportunity to connect existing urban areas and the planned growth at Lidsing Garden Community (which will include significant areas of green and blue infrastructure ) with existing green assets in this corridor such as the Capstone Country Park.
Message Summary
The Attwood family have a very significant strategic landholding at Capstone which offers an opportunity for the stated objectives of the vision to be met through comprehensive masterplanning and coordinated infrastructure delivery to meet a range of development needs, whilst also delivering significant biodiversity gains.

The comments relating to the strategic objectives overlap in a number of areas with F D Attwood and Partners vision response at Question 1.
It is highlighted that the prospects of the vision being executed are increased if landowners, the community, the LPA and other stakeholders work collaboratively. F D Attwood and Partners firstly would welcome the chance to work collaboratively during the emerging local plan process rather than in an attritional way, which will give the best prospects of the vision and strategic objectives being delivered. This is even more important for the Capstone Corridor as important decisions on the masterplanning of Lidsing Garden Community (occupying 119ha of the southern portion of the corridor) will be taken in early 2024, led by the masterplanning team of the Attwood family and Maidstone Borough Council alongside community input.
The highlighted strategic objectives, each of which is supported by the landowner, will also best be delivered where comprehensive scale masterplanning opportunities are available, which ideally should be within single landownership control. This will allow a long-term strategy to be formulated to implement the vision and there is greater certainty of phased delivery providing long term certainty for all.
For the urban and suburban spatial options, the noted existing shortcomings of infrastructure provision, services, transport and open space connectivity in the surrounding area can benefit from new development, particularly of greater scale and where it is comprehensively planned. In the case of the Capstone corridor, the Capstone Country Park represents a “hub” that local communities could be better connected to for recreation and health objectives. These benefits of addressing existing inequality and infrastructure shortcomings will not be delivered by the new settlement spatial option, as explained further below.
In the case of the urban area extension of Capstone, another unique benefit is that development can capitalise on the development nucleus planned at the Lidsing Garden Community (in the adjoining Maidstone borough), comprising significant areas of open space, 2,000 dwellings, 14ha of employment and a new village centre. Medway Council has the opportunity to work alongside the landowner and Maidstone Council to progress the emerging masterplan framework for the southern portion of the Capstone corridor in early 2024. This has direct relevance to the consideration of Medway’s spatial options as the Lidsing Garden Community includes a large 14ha employment area close to the M2 Junction 4 and the Medway vision and strategic objectives focus on the need for out commuting to be reduced and the vision delivering mixed communities with jobs close to housing and services. Lidsing is therefore already a planned development platform in the southern portion of the corridor and it would represent a “missed opportunity” not to give this advantage some weight when considering the remainder of the corridor (which is possible because of the single family land ownership) to the north of Lidsing. This is a unique advantage of the Capstone Corridor falling within the suburban/edge of urban area spatial option.
The single ownership and partnership approach offered by F D Attwood and Partners, as landowners, is unique and for other reasons can best deliver the vision and strategic objectives. For instance, because of the single family land ownership control, viability work already undertaken for the landowners has “priced in” necessary infrastructure and services alongside the mix of development uses. These benefits, which will also impact on the existing urban areas surrounding the site, will be delivered without the need for public funding.
Lessons have been learnt from past suburban estate development and as the Medway vision suggests, the emerging local plan must look forward, not back. The Capstone Valley is today an arbitrary residual land corridor that is a legacy of piecemeal suburban growth in the 1980 and 1990’s where major road infrastructure (which should have accompanied housing growth), was not delivered alongside it causing congestion of the network. The remaining land within the corridor, by many (particularly local residents), has been regarded as a “battleground” where no further development should encroach. However, successive appeal decisions by Local Plan Inspector’s (Lidsing…2,000 dwellings) and Section 78 appeal Inspector’s, East Hill (800 dwellings) and Gibraltar Farm (450 dwellings), have disagreed with the past landscape value assessment that has derived from past political commitments made when the 2003 Medway Local Plan was adopted.
There is now an opportunity for the corridor to be reassessed in a new and positive context, to consider objectively how the outlined vision and strategic objectives can best be delivered. For the suburban option, there is the opportunity to knit the existing urban communities together with recreational public open space and wildlife corridors, linking up with the Capstone Country Park and the planned Lidsing Garden Community and delivering a more widely accessible north-south and east-west axis that will still maintain the separate identities of the existing urban sub areas and community identities.
In the past, strong views have been held that development in the Capstone corridor would exacerbate existing congestion. 3,250 dwellings within the control of the landowner are already planned along the corridor’s length, which individually demonstrate clear transport benefits. A fully comprehensively planned transport corridor, if supported by the local plan process, would deliver even greater transport benefits to add to the east-west transport links and rebalancing of M2-J4 and J3 as well as enhanced opportunities for non-car mode improvements that are already to be delivered by planned development in this corridor.
Message Summary:
• Local plan vision and the overlapping strategic objectives are fully supported.
• Comprehensive masterplanning of land within single family control will best create the framework for the vision and objectives to be delivered and there will be long term certainty for planning decision making.
• If the vision is delivered at the suburban edge where existing urban areas can be “knitted together”, these existing communities will also benefit from new infrastructure and the planned mix of uses including new services, open space and local jobs. This represents a “double benefit” of growth compared with a new settlement where the principal planning objective is to make a non-sustainable location “self-contained.”
• To allow real visioning and consideration of how the strategic objectives will best be achieved along side it, FD Attwood and Partner’s believe that historical strongly held and emotive views relating to growth in the Capstone Corridor should be reevaluated in the new positive and visioning context that is suggested will be adopted.

The primary consideration in delivering a sustainable spatial strategy should firstly focus on brownfield redevelopment of the riverside and town centre. It is agreed that the support for High Streets and urban regeneration should underpin the whole strategy and this is fully supported by F D Attwood and Partners subject to the following caveats which relate to the housing capacity yield from development in this area including ;
• The historic character of the riverside has to be preserved and part of the character for this area derives from the mix of uses including employment. The document rightly acknowledges heritage value in the vision and objectives and the role of this area for tourism (see paragraph 4.2) should also not be underestimated. These factors will influence estimates of housing yield that is deliverable within the plan period.
• As well as the need to preserve the character of the area as outlined above, there are also viability considerations which need to be taken into account in this area and the likelihood that these sites may only be delivered by high density apartment construction which will not deliver a range of housing and are also subject to greater market sensitivity, that in turn affects housebuilder interest and deliverability.
The principle of adopting a sequential approach to the spatial strategy that focuses on brownfield riverside development and urban regeneration is supported but for the reasons outlined above, there must be caution in the net capacity of these areas to meet the housing need and the timescale to delivery and for this reason, we support the riverside being a component of a suite of spatial options.
As part of the sequential spatial approach, the next favoured option in terms of sustainability benefits, should be the suburban extension choices which, as previously highlighted (if planned comprehensively alongside infrastructure), would also benefit the existing urban areas adjoining these areas and in this case, could provide certainty to the whole of the Capstone corridor length.
The opportunity of a comprehensive masterplanned approach to link the existing planned building blocks within the Capstone Corridor, including Lidsing Garden Community (2,000 dwellings), Gibraltar Farm (450 dwellings) and East Hill (800 dwellings), which are also within the control of the landowner, offer a unique opportunity to deliver a wide range of planning benefits from this spatial option which places Capstone as a suburban extension ahead of the suburban alternative of Rainham which has:
• Greater acknowledged highway congestion and air quality issues on the A2 and road network around it;
• Is of a higher agricultural land value;
• Is part of a strategic gap between Rainham and Newington;
• Lies in closer proximity to the Medway Estuary SPA and its setting.
As part of a sequential approach, it would only be in the event that Medway Council cannot deliver road, open space and community/utility infrastructure alongside biodiversity enhancements to support growth in the suburban areas (alongside riverside growth), that a new community on the Hoo Peninsula should be considered as a third option, with its more limited objective to create a self-contained community in a non sustainable location.
The past ‘driver’ of LPA decision making which favoured Hoo vis a vis the Capstone Corridor (aside from the HIF Funding for infrastructure), was a perception that development in the Capstone Corridor would erode the character of the valley and its function as a green lung for the existing urban areas around it. However, successive Inspector’s (for local plan and Section 78 appeals) have disagreed with this assessment and now these planned developments can provide building blocks of a new comprehensive vision for the whole of the corridor integral to which will be green infrastructure and biodiversity enhancements that links with the surrounding communities.
Whilst the local plan evaluates objectively all spatial options to deliver the vision and agreed strategic objectives, FD Attwood and Partners consider that an alternative high-level assessment of character impact should now be utilised, which is very different to that adopted in the past in order to drive spatial decision making. This new approach is justified because it is acknowledged throughout the plan that the character of Medway on the headland, to the north of the river Medway, is very different. Whilst large new country parks have previously been offered to mitigate the impact of major growth on the headland, the siting of major development in this area will comparatively affect to a greater degree, the more remote character of this part of Medway ( which is recognised at paragraph 5.36) and is also more environmentally sensitive (protecting natural assets is recognised at paragraph 4.2 and 5.10) and important to tourism and the character of Medway in its totality as an administrative area.
For these reasons, it is asserted that, in the consideration of spatial options, major scale development on the headland should only be considered as a spatial option in the event that the suburban growth option is discounted for the reasons outlined above. Major growth at Hoo, even if it could address road capacity, rail connectivity and environmental impact considerations, is not as well placed as other spatial options to support the High Street, create more inclusive and connected communities that address current inequalities, or support tourism. The principal vision and strategic objective of major growth at Hoo is to make it “self contained” to boost its sustainable credentials and rely on the fact that it is likely to be the subject of less public objections, because it is located well way from the main populace of Medway. For these reasons, in terms of delivering the supported vision and strategic objectives, Hoo represents a third-tier option.
The Reg 18 Document at paragraph 5.41 when referencing Hoo specifically asserts that;
“Such development could also help to meet the Council’s ambition for greener growth with higher environmental standards in construction, communities better connected for walking and cycling and within easy reach of local services.” This assertion is strongly contested by F D Attwood and Partners for the reasons explained in this response.
The option of the Green Belt release in line with national guidance should be weighted a “last resort" spatial option. The fact that the Green Belt occupies only 2% of the land area of Medway; performs an important strategic function in preventing the urban sprawl of Strood and Higham and Snodland and Halling; and in addition to this, is designated as AONB, provides national recognition of the landscape quality of this area as well as its spatial GB functionality. As part of a sequential approach, this option should only be examined further when it is proven that the other spatial options cannot be delivered.
The technical work of FD Attwood and Partners can demonstrate that:
• Comprehensive masterplanning and delivering of infrastructure;
• Mix of uses;
• Quality of development including SUDS and other technical issues;
• Transport benefits and access considerations can be delivered; and
• Landscape open space and biodiversity linkages, particularly with the Capstone Country Park hub.
These matters can be fully addressed without the need for public funding and will also benefit the existing local communities and provide community cohesion.
At Para 5.35 of the Regulation 18 consultation document, there is recognition of the cross-border impacts and the fact that early masterplanning decisions via the Lidsing SPD document, will be starting to be made shortly. As highlighted earlier, we see this as an opportunity for better masterplanning output through collective working and cooperation between the Attwood family, Medway Council, Maidstone Council and Kent County Council across the entirety of the corridor including Lidsing.

The Interim Land Availability Assessment identifies a number of different parcels, but the FD Attwood and Partners land is the only one that offers a long-term master planned solution for such an extensive area covering the whole of the Capstone corridor.
There are a number of references of positive outcomes to be achieved, as embodied in the vision and strategic objectives from a strategic and comprehensive masterplaned approach (including paragraph 5.28 for the riverside), however this is realistically more difficult to achieve where land ownership is fragmented. This places the F D Attwood and Partners land opportunity on a different level to other options, both in terms of the visioning, but also in terms of the certainty of viability assumptions and delivery.
The message from the landowner/promoter is that:
• The totality of the land identified on the attached plan is available and deliverable and improved land use planning benefits can be delivered by a comprehensive approach which will provide certainty to all parties.
• Building blocks of development within the corridor and landowners’ control e.g. Lidsing (open space, 2,000 dwellings and 14ha employment), Gibraltar Farm (450 dwellings) and East Hill (800 dwellings), have already been approved and the opportunity exists now to masterplan the whole corridor and provide collective certainty of infrastructure provision, open space and public access and transport improvements and job creation for all. Planning in this way will ensure the maximum benefits for Medway are delivered as part of a collaborative approach and working with Maidstone BC on the development of the Lidsing masterplan framework, which will commence in early 2024.
• Medway’s planning team and members of the new administration can be confident that a comprehensive masterplan would deliver a wide range of land uses including housing, employment, recreational space and community and retail uses to meet future Medway’s needs at a sustainable location. These land uses within the site would all (via the masterplan process) be well related to existing employment sites such as the Gillingham Business Park and planned employment within Lidsing (14 ha employment hub is proposed here) the retail hub of the Hempstead Valley Shopping Centre and recreational assets such as the Capstone Country Park. It will also be demonstrated through the ecological baseline information already undertaken for this area, that significant biodiversity net gain can be secured within this development scenario and that climate change will be at the heart of decision making.
• There are benefits of a permanent and comprehensive growth strategy for this corridor where Medway residents, near and far, have certainty about what will be delivered. We believe the planned scale of green infrastructure for this corridor, alongside the development areas and linkages with the existing communities, will provide comfort to residents living in this area who have in the past, perceived that sanctioning some development in this area will destroy its character or function in a piecemeal fashion. This concern will not be relevant if the opportunity of a comprehensive masterplanned approach is taken, because of the single land ownership of the Attwood family, as evidenced on the attached plan.