The scale and height of this proposal will significantly compromise the openness and environmental value of the site itself, and wider Metropolitan Open Land.

Not only is the gas holder site designated MOL, it lies within a wider 300-acre contiguous area of MOL. All of this is also designated Metropolitan Green Chain, a particular type of MOL where green infrastructure forms a strategic corridor for biodiversity. The 2018 review concluded that the site met the criteria for Metropolitan Open Land, making an overall significant contribution.

The site is clearly distinguishable from the built-up area and forms part of a strategic green corridor and complies with the London Plan Policy G3 B.

Although some of the site can be considered ‘previously developed land’ (PDL), the applicant claims it is “100% PDL”. The proposals actually stretch beyond the footprint of the gasholders to includes areas of grassland to the north and the south. Building on these areas of grass land would make the development inappropriate. More so, if it results in substantial harm to the openness of MOL.

It would adversely affect the openness of the site and wider MOL through its spatial and visual impact. It is considerably larger in mathematical terms and more visually intrusive. There is substantial harm to openness.

MOL is afforded the same status and level of protection as Green Belt. There is a strong presumption in both national and local planning policy against development, particularly high density or high-rise construction.  Further arguments can be made that this is inappropriate beyond harm to the green belt:

• The proposals provide insufficient public green space to compensate for the loss of MOL. For example, cars could be located in underground or undercroft parking.
• There will be a negative impact on the Metropolitan Green Chain (strategic green corridor) which would be split in two.
• Building on the site would merge two neighbourhoods together (see NPPF paragraph 143 c).

Kingston Council states that it not only wants to protect but add to MOL across multiple policies (CS3, CS4, DM5-DM7).

The NPPF (paragraph 67) also states that 50% affordable housing should be provided if Metropolitan Open Land is used for development.