Loss of Metropolitan Open Land

Objection Points

The planning application misrepresents the site’s contribution to MOL, selectively dismisses ecological and strategic corridor value, and fails to meet the policy tests set out in London Plan Policy G3 and NPPF 154(g).  The presence of a nationally scarce species, the site’s role in the Beverley Brook corridor, and its inclusion in Parcel 22 — which RBK has assessed as making a “significant contribution” — all support the continued protection of this land as MOL.

We respectfully urge Kingston Council to reject this application and uphold the integrity of Metropolitan Open Land protections at Motspur Park.

Misapplication of Brownfield Development Policy

The developer quotes the following in their planning application (section 6.9) in an attempt to justify building in MOL

In respect of the location for new development, the WMS strengthens support for the use of brownfield land. It states that: “The first port of call for development should be brownfield land, and we are proposing some changes today to support more brownfield development: being explicit in policy that the default answer to brownfield development should be yes; […] and in addition, strengthening expectations that plans should promote an uplift in density in urban areas.”

While we support the principle of prioritising brownfield land, this must not be used to override protections for Metropolitan Open Land (MOL) — especially where such land is ecologically sensitive and strategically designated.

The Motspur Park gas holder site:

• Lies within a 300-acre contiguous MOL corridor, including the Metropolitan Green Chain and Beverley Brook.

• Was confirmed in the 2018 review to meet MOL criteria, making a significant contribution to London’s green infrastructure.

• Is not an isolated brownfield plot, but part of a protected ecological and recreational landscape. The default “yes” to brownfield development must be applied sensibly and contextually. The Motspur Park site may be previously developed, but its MOL designation, ecological sensitivity, and community value make it inappropriate for high-density residential redevelopment.

• The London Plan and Kingston Council’s Core Strategy both make clear that MOL is to be safeguarded from inappropriate development, regardless of its brownfield status. Density uplift policies must be applied within appropriate urban contexts, not in ways that compromise strategic open land.

We urge decision-makers to:

• Reject the misuse of brownfield policy as a justification for building on MOL.

• Uphold the integrity of London’s green corridors, especially in areas like Motspur Park where community wellbeing and biodiversity are at stake.

• Distinguish between suitable and unsuitable brownfield sites

• Redirect housing delivery to truly urban brownfield sites, where density uplift aligns with infrastructure and policy

(Refer image above top right for appropriate vs inappropriate brownfield land)

Is building on MOL Sustainable?

"According to the National Planning Policy Framework (NPPF), sustainable development is defined as:

“Meeting the needs of the present without compromising the ability of future generations to meet their own needs."

Metropolitan Open Land (MOL) is designated precisely to protect open space within London’s urban fabric. It serves critical functions:

• Preserving openness and preventing urban sprawl

• Providing accessible green space for recreation, health, and wellbeing

• Supporting biodiversity and ecological resilience

Building on MOL—especially for large-scale housing or infrastructure—would almost certainly compromise these functions. It risks:

• Permanent loss of green space for future generations

• Reduced access to nature, especially in densely populated areas

• Erosion of community character and environmental quality

This proposal fails the NPPF’s test of sustainable development. It prioritises short-term housing targets over long-term environmental stewardship and community wellbeing. Once MOL is built on, it is lost forever—future generations will inherit a diminished landscape, contrary to the core principle of meeting their needs.”

Misrepresentation of MOL Contribution

The developer claims that the site makes only a “limited contribution” to MOL designation criteria. This assertion is misleading and selectively dismisses the broader context of Parcel 22, which includes:

• The Beverley Brook Strategic Corridor

• A Site of Importance for Nature Conservation (SINC)

• Adjoining woodland and allotments

• A Green Chain link connecting open spaces across the borough

These features are explicitly recognised in the Royal Borough of Kingston’s Green Belt and MOL Assessment (2018) as making a “significant contribution” to MOL designation. The developer’s attempt to isolate the gas holder footprint from the wider parcel undermines the holistic purpose of MOL, which is to preserve strategic green infrastructure and visual openness across London.

Applicant attempts to justify the site Fails to Meet MOL Criteria

section 4.13 and 4.14 from the planning statement

4.13 The Site element of larger Parcel 22 does not, therefore, make a “Limited Contribution” to this MOL criterion.

3) contains features or landscapes (historic, recreational, biodiverse) ofeither national or metropolitan value?

4.14 The gasholders are not statutory or locally listed and the Site does not contain other features of historic or recreational value which are of national or metropolitan value. The SINC within and adjoining the Site is of local value only, predominantly covering the allotments to the south (beyond the Site boundary), the Beverley Brook and a small area of woodland planting within the Site (Figure 4.3).

however, the site and its context meets multiple criteria for MOL designation under London Plan Policy G3:

• Criterion 1: The site contributes to the physical structure of London by forming a distinguishable break from the built-up area, especially when viewed from the east and west.

• Criterion 3: The site contains a nationally scarce plant species — Jersey cudweed — listed under Schedule 8 of the Wildlife and Countryside Act. This biodiversity feature is of national value, and its presence confirms ecological significance.

• Criterion 4: The site forms part of the Beverley Brook Strategic Corridor, a recognised Green Chain linking major open spaces across south-west London.

The developer proposes to translocate the Jersey cudweed to biodiverse roofs, but this does not negate its current contribution to MOL. Nor does fencing or lack of public access diminish the ecological and spatial value of the site within the MOL network.

Inappropriate Development Under NPPF 154 (g)

Paragraph 154(g) of the NPPF allows redevelopment of previously developed land within the Green Belt or MOL only if it does not cause substantial harm to openness. The proposal introduces:

• Significant new built form and massing

• Increased traffic and activity

• Loss of spatial and visual openness from key public viewpoints

The site’s adjacency to MOL Parcel 21 and the wider swathe of open land to the east and west amplifies the impact of the proposed development. The applicant’s own Metropolitan Open Land Assessment acknowledges that the site is distinguishable from surrounding MOL and that its redevelopment will alter the openness of the corridor.

Harm to Openness Is Admitted — and Not Just Within the Site

Planing statement - section 10.4 

"There would be some harm to the openness of the MOL outside the Site from the spatial and visual effects arising from the development volume proposed, notwithstanding the reduced development footprint and heights of the buildings (compared to the structures), and the increase in human activity and movement. "

The applicant concedes there will be “some harm to the openness of the MOL outside the Site” due to building volume, visual intrusion, and increased human activity.

This directly contradicts the NPPF §154(g) test, which only permits development on previously developed land (PDL) if it does not cause substantial harm to openness.

The harm is not confined to the footprint — it radiates outward, affecting views, movement and spatial character.

Misusing National Policy to Justify Over development and Violation of London Plan Policy 7.17 on Metropolitan Open Land

The developer cites Chapter 11 of the National Planning Policy Framework (NPPF) to justify building 586 homes on Metropolitan Open Land (MOL). But this policy does not give a free pass to over development.

While paragraphs 124 and 125 rightly promote the effective use of land — particularly brownfield sites — they do not override the need to avoid substantial harm. Paragraph 125(c) supports brownfield development unless substantial harm would be caused. In this case, the proposal risks:

• Irreversible damage to Metropolitan Open Land (MOL) character

• Loss of ecological value along Beverley Brook

• Overwhelming height and massing that disrupts the town scape

The NPPF does not mandate approval of any brownfield scheme — it requires balanced, place-sensitive decisions. We urge planners to reject the misuse of Chapter 11 as a blanket justification and instead assess the proposal against local context, environmental impact, and community need.

The site’s MOL designation and proximity to sensitive habitats demand restraint, not maximisation (violation of London Plan Policy 7.17 on Metropolitan Open Land)

As per the London Plan Policy 7.17 

A . The Mayor strongly supports the current extent of Metropolitan Open Land (MOL), its extension in appropriate circumstances and its protection from development having an adverse impact on the openness of MOL.

Planning decisions

B.  The strongest protection should be given to London’s Metropolitan Open Land and inappropriate development refused, except in very special circumstances, giving the same level of protection as in the Green Belt. Essential ancillary facilities for appropriate uses will only be acceptable where they maintain the openness of MOL.

Summary of policies

• MOL receives equal protection to Green Belt.

• Development is refused unless it maintains openness and serves essential ancillary functions (e.g., changing rooms for sports fields)

• The strongest protection should be given to London’s Metropolitan Open Land and inappropriate development refused, except in very special circumstances.

This proposal fails to meet these standard:

• No very special circumstances have been demonstrated to justify high-density residential development on MOL.

• The scheme’s height, massing (up to 16 storeys), and density significantly compromise the openness and visual character of the MOL. Fundamentally compromise the openness of the MOL, contradicting its intended purpose as a strategic green corridor.

• The development does not support MOL’s intended uses — such as outdoor recreation, biodiversity, nature conservation or strategic green infrastructure. High-density residential blocks do not meet these criteria.

• The proposal risks fragmenting a 300-acre contiguous MOL corridor, including the Metropolitan Green Chain and Beverley Brook habitat— a sensitive ecological corridor. The development fragments this landscape and risks long-term biodiversity loss.

• Policy 7.17 also requires boroughs to consult the Mayor before altering MOL boundaries — yet the current scheme appears to pre-empt this process by proposing substantial change without full transparency or public accountability.

Contradiction with Kingston Council’s Core Strategy

In point 4.5 of the planning application, the developer states:

“RBK Officers support the comprehensive residential redevelopment of this previously developed Site in the MOL and the overall vision and design approach.”

This statement, while possibly reflecting informal officer-level feedback, directly contradicts Kingston Council’s formal planning policies, which prioritise the protection and enhancement of MOL:

• CS3 – The Natural and Green Environment: Commits to protecting and enhancing open spaces, green corridors, and biodiversity.

• CS4 – Sustainable Development: Requires development to respect local character and environmental assets.

• DM5–DM7 – Open Space and Biodiversity: Emphasise safeguarding MOL, enhancing ecological networks, and resisting inappropriate development.

These policies are statutory and binding. Officer support cannot override them, nor can it justify development that fragments a strategic green corridor and undermines ecological integrity.

Misapplication of the PDL Exception

The developer, asserts that the Motspur Park gas holder site qualifies as Previously Developed Land (PDL). Based on this designation, they argue that:

Planning statement section 10.2 “As PDL, It would amount to an exception to ‘inappropriate development’ in the MOL, providing that the Proposed Development would not cause substantial harm to the openness of the MOL.” (Referencing NPPF §154(g) and London Plan Policy G3)"

• NPPF §154(g) allows limited infilling or redevelopment of PDL in Green Belt or MOL only if it does not cause substantial harm to openness.

• London Plan Policy G3 reinforces that MOL is afforded the same level of protection as Green Belt, and development must be appropriate and justified.

the scale, height, and massing of the proposed development — including five blocks up to 52 metres tall — would introduce a dense urban form that fundamentally alters the spatial openness of the MOL. The Planning Statement emphasizes “visual permeability” and “naturalistic landscaping,” yet these do not mitigate the physical encroachment of built form across a protected green corridor. The applicant’s own massing diagrams and block plan (Planning Statement section 3.7–3.11) show a concentration of development across the western and central portions of the site, with limited setbacks and minimal gaps between buildings.

Moreover, the applicant’s assertion that the gasholder frames already establish a “baseline” for MOL impact (Planning Statement §4.6, GLA feedback) ignores the fact that these are skeletal industrial remnants, not habitable structures with bulk, depth, and continuous occupancy. The proposed buildings would introduce substantial and permanent harm to the openness, character, and ecological function of the MOL — particularly along the Beverley Brook corridor and adjacent SINCs.

Selective Interpretation of Paragraphs 125(d) and 126

Paragraph 125(d) encourages the use of under-utilised land where supply is constrained. Paragraph 126 calls on authorities to proactively identify suitable land for development.

However, MOL is not under-utilised land. It is strategically protected open space, afforded the same status as Green Belt under London Plan Policy G3. The site contributes to London’s green infrastructure network and supports nationally scarce biodiversity (Jersey cudweed, perigrine falcons, bats, hedghogs , slow worms etc). These paragraphs do not override MOL protections or justify speculative development on ecologically sensitive land.

Misapplication of Paragraphs 130 and 135

Paragraph 130 supports efficient use of land, with flexibility on daylight/sunlight standards. Paragraph 135 encourages visually attractive, well-designed schemes.

These principles apply to suitable sites within settlements — not to protected open land. The applicant’s proposal introduces five residential blocks up to 52 metres tall, causing a marked change to openness and visual harm beyond the site boundary, as admitted in their own MOL Assessment. Design quality cannot compensate for the irreversible loss of protected land.

Policy Cherry-Picking to Serve Developer Interests

The applicant’s use of NPPF paragraphs is selective and self-serving. It ignores:

• The site’s designation as MOL

• The ecological value of the land

• The requirement for “very special circumstances” to justify development

We urge decision-makers to 

• Uphold the intent of Policy 7.17 and refuse planning permission for any scheme that undermines the permanence, openness, and ecological value of Metropolitan Open Land.

• Uphold Kingston Council’s adopted Core Strategy policies (CS3, CS4, DM5–DM7)

• Reject any attempt to fast-track inappropriate development on protected land

Motspur Park deserves thoughtful, place-sensitive development — not one that hides behind selective interpretations of policy while ignoring long-term environmental and community impacts.

The proposed towers DO NOT Preserve Openness of MOL