In their reasons for refusal, the Kingston Planning Committee minutes state:

“The proposed development, by reason of its cumulative bulk, scale and height, would result in substantial harm to the openness of the Metropolitan Open Land (MOL) and accordingly would constitute inappropriate development within the MOL, failing to meet the exceptions test as defined by Paragraph 154(g) of the NPPF. The proposal would accordingly fail to comply with Policy G3 of the London Plan which seeks to protect MOL land from inappropriate development.”

MOL is afforded the same status and level of protection as Green Belt. Not only is the gas holder site designated MOL, it lies within a wider 300-acre contiguous area of MOL.

Although some of the site can be considered ‘previously developed land’ (PDL), the applicant claims it is “100% PDL”. This is incorrect. As pointed out by the ecological reports, much of the site is grassland and felled trees and thus NOT 100% PDL. The proposals are to be built on some of this this grassland which results in the development being twice as wide as the transparent gasholders.

It would adversely affect the openness of the site and wider MOL through its spatial and visual impact. It is 111-fold larger in volumetric terms and more visually intrusive in a way that conflicts with the local context. There is substantial harm to openness, particulalrly when viewed from certain angles.

There are no ‘very special circumstances’ to outweigh the substantial harm caused to MOL. Generic housing need does not override the site-specific harm, and NPPF paragraph 11 does not apply.