Bio Diversity at Risk

Objection Points

Irreversible Harm to Biodiversity and Flawed BNG Assessment 

We strongly object to the proposed redevelopment of the Motspur Park Gasholders site on the grounds of its adverse impact on biodiversity and the questionable integrity of its Biodiversity Net Gain (BNG) assessment.

The proposed development would introduce vast building structures that fragment and degrade these habitats, sever ecological corridors, and reduce canopy cover — all of which are essential for species movement, breeding, and survival.

This directly contravenes:

London Plan Policy G6, which mandates that biodiversity impacts be addressed from the outset and that priority species and habitats be protected and enhanced.

The statutory framework under the Environment Act 2021, which requires a minimum 10% biodiversity uplift based on accurate, unaltered baseline conditions.

Given the scale of ecological loss and the questionable integrity of the Biodiversity Net Gain assessment, we believe this application fails to meet the legal and ethical standards required for approval.

The site supports a rich and interconnected ecological network, including:

Bats: Surveys recorded high levels of activity by common and soprano pipistrelle bats along the site peripheries, particularly near the railway and watercourse. These areas benefit from strong ecological connectivity via woodland and broadleaved trees, linking to habitats in the wider landscape.

Slow Worms: A total of 53 juvenile slow worms were recorded, with peak counts of 11 in a single day. This indicates active breeding and a thriving population on site.

Birds: Twenty-three breeding bird species were recorded, nine of which are of conservation concern. Two species — song thrush and dunnock — are listed under Section 41 of the NERC Act 2006 as being of principal importance in England.

Most notably, peregrine falcons— a Schedule 1 protected species — have been observed nesting on the gas holders for at least three consecutive years. However, the applicant claims they were “absent” in 2025, the very year the planning application was submitted. This is highly questionable. Local residents have continued to observe peregrine activity in 2025, suggesting either an oversight or a deliberate omission in the ecological reporting.

This pattern raises serious concerns about the accuracy and transparency of the BNG baseline. The Environment Act 2021 and NPPF §180(d) require planning decisions to secure measurable net gains for biodiversity — not gains manufactured through prior clearance or selective reporting

Pre-emptive Tree Removal Undermines Credibility of Biodiversity Net Gain Assessment

We wish to raise serious concerns regarding the pre-emptive felling of mature trees along the southern access route of the Motspur Park Gasholders site. These trees were removed approximately three years ago by SGN, who claimed they were “diseased”and would be replaced. However:

• No evidence was provided to residents to confirm the trees were diseased

• No replanting has occurred to date

• It remains unclear whether the appropriate felling license or permissions were obtained

We believe, this sequence of events has directly influenced the site’s ecological baseline, as recorded in the applicant’s Biodiversity Net Gain (BNG) Assessment. The absence of these mature trees — which previously contributed to canopy cover, habitat connectivity, and ecological niches — has allowed the applicant to present a lower baseline and thereby inflate the perceived biodiversity uplift of the proposed development.

This raises the possibility that the tree removal may have been a deliberate step to manipulate BNG calculations in favour of the developer. Such actions undermine the integrity of the BNG process, which relies on accurate, transparent, and unaltered baseline conditions.

Furthermore, the BNG Assessment acknowledges only 11 semi-mature trees on site, all in poor condition, and fails to account for the historic loss of mature trees that once lined the southern access. This omission violates the spirit of London Plan Policy G6 and NPPF §180(d), which require planning decisions to secure measurable net gains for biodiversity — not gains manufactured through prior clearance.

We urge the planning authority to reject the proposed redevelopment of the Motspur Park Gasholders site due to its considerable and irreversible impact on biodiversity.

Policy

Kingston Council’s Core Strategy (Policy C3) states “The Council will protect and improve Kingston’s valued natural and green environment by: protecting Kingston’s open space network from inappropriate development through its open spaces designations; Green Belt, Metropolitan Open Land (MOL), Thames Policy Area, Sites of Importance for Nature Conservation”

London Plan G6 Biodiversity and access to nature

B Boroughs, in developing Development Plans, should:

3) support the protection and conservation of priority species and habitats that sit outside the SINC network, and promote opportunities for enhancing them using Biodiversity Action Plans.

Visible Harm: Stumps of Lost Trees on the proposed southern access