For official use only (date received): 23/11/2020 09:49:20

The Planning Inspectorate

COMMENTS ON CASE (Online Version)

Please note that comments about this case need to be made within the timetable. This can be found in the notification letter sent by the local planning authority or the start date letter. Comments submitted after the deadline may be considered invalid and returned to sender.

Appeal Reference: APP/E2734/W/20/3261729

DETAILS OF THE CASE

Appeal Reference APP/E2734/W/20/3261729

Appeal By LIMITED

Site Address Land Comprising Field at 435074 475842 Hutton Conyers North Grid Ref Easting: 435074 Grid Ref Northing: 475842

SENDER DETAILS

Name MR GORDON GLEDSON

Address Westfield Hutton Conyers Ripon Ripon HG4 5DY

Company/Group/Organisation Name Hewick and Hutton Parish Council

ABOUT YOUR COMMENTS

In what capacity do you wish to make representations on this case?

Appellant Agent Interested Party / Person Land Owner Rule 6 (6)

What kind of representation are you making?

Final Comments Proof of Evidence Statement

Page 1 of 2 Statement of Common Ground Interested Party/Person Correspondence Other

YOUR COMMENTS ON THE CASE

Dear Sir, I am the chairman of Hewick and Hutton Parish Council. Rather than send in a representation covering points already submitted to you the Parish Council prefer to endorse the representation submitted to you by Sandra Shackleton of Hutton Grange Cottage, Hutton Moor, Ripon. Hewick and Hutton Parish Council therefore recommend REFUSAL of the appeal.

Page 2 of 2 For official use only (date received): 24/11/2020 10:47:22

The Planning Inspectorate

COMMENTS ON CASE (Online Version)

Please note that comments about this case need to be made within the timetable. This can be found in the notification letter sent by the local planning authority or the start date letter. Comments submitted after the deadline may be considered invalid and returned to sender.

Appeal Reference: APP/E2734/W/20/3261729

DETAILS OF THE CASE

Appeal Reference APP/E2734/W/20/3261729

Appeal By MOTO HOSPITALITY LIMITED

Site Address Land Comprising Field at 435074 475842 Hutton Conyers Ripon Grid Ref Easting: 435074 Grid Ref Northing: 475842

SENDER DETAILS

Name MR. GORDON GLEDSON

Address Westfield Hutton Conyers Ripon North Yorkshire HG4 5DY

Company/Group/Organisation Name Hewick and Hutton Parish Council

ABOUT YOUR COMMENTS

In what capacity do you wish to make representations on this case?

Appellant Agent Interested Party / Person Land Owner Rule 6 (6)

What kind of representation are you making?

Final Comments Proof of Evidence Statement

Page 1 of 2 Statement of Common Ground Interested Party/Person Correspondence Other

YOUR COMMENTS ON THE CASE

I am the chairman of Hewick and Hutton Parish Council. I understand that this appeal may be heard in conjunction with the appeal for an MSA at Kirby Hill in the same county. Kirby Hill residents have formed an organisation called RAMS (Residents Against Motorway Services). RAMS has submitted an extremely well researched and professionally laid out document KH/O1 dated 18th March 2020. They have clearly worked on this document for some considerable time and I give them full credit for their work and commitment. Having studied the document I am of the opinion that much of it, approximately 80 per cent, also applies to the appeal for a service area at junction 50 on the A1. My Parish Council is small and we do not have the resources nor the time to produce a similar document. I would therefore ask the appeal panel if they would take into consideration that much of the information in document KH/01 dated 18th March 2020 produced by RAMS also applies to the appeal for an MSA at junction 50. I give full acknowledgement and credit to RAMS for producing the document. Hewick and Hutton Parish Council hope that when all the representations and submissions have been considered that the appeal for an MSA at junction 50 will be REFUSED.

Page 2 of 2 For official use only (date received): 16/11/2020 13:27:42

The Planning Inspectorate

COMMENTS ON CASE (Online Version)

Please note that comments about this case need to be made within the timetable. This can be found in the notification letter sent by the local planning authority or the start date letter. Comments submitted after the deadline may be considered invalid and returned to sender.

Appeal Reference: APP/E2734/W/20/3261729

DETAILS OF THE CASE

Appeal Reference APP/E2734/W/20/3261729

Appeal By MOTO HOSPITALITY LIMITED

Site Address Land Comprising Field at 435074 475842 Hutton Conyers Ripon North Yorkshire Grid Ref Easting: 435074 Grid Ref Northing: 475842

SENDER DETAILS

Name LADY HALINA GRAHAM

Address Norton Conyers Hall Wath Ripon North Yorkshire HG4 5EQ

ABOUT YOUR COMMENTS

In what capacity do you wish to make representations on this case?

Appellant Agent Interested Party / Person Land Owner Rule 6 (6)

What kind of representation are you making?

Final Comments Proof of Evidence Statement Statement of Common Ground Interested Party/Person Correspondence

Page 1 of 2 Other

YOUR COMMENTS ON THE CASE

1. This MSA will have a detrimental effect on the tourism of Ripon and and detract from local businesses. It should not be forgotten that Junction 50 is the direct stepping off point from the A1(M) to the exceptional Norton Conyers Grade II listed late medieval manor house and gardens near Wath, winner of The Historic Houses Association & Sotheby's Restoration Award 2014. It will also impact on Ripon Cathedral, Newby Hall and Fountains Abbey and Lightwater Valley. 2. The Secretary of State rejected this site 8 years ago after a lengthy and costly public enquiry - nothing has changed since then and therefore this application will mean that more public money will be wasted in opposing this. The non-suitability of this site has therefore already been determined by a previous Appeal at the highest level. 3. The site has a water table relatively close to the surface a number of local farmers depend on bore holes to irrigate crops. Natural water could become contaminated by the development through surface water run-off. The site is at a significant distance from the nearest sewerage facilities and the hotel and amenity block will give rise to a significant sewerage load 4. The applicant draws attention to the creation of jobs for local people. However, as Thirsk and Ripon are the two towns closest to the development and have unemployment rates below the national average and the average for North Yorkshire it is unlikely that these will be local jobs. Moto representative admitted that employees were likely to come from (27km) and (31km). 5. There is no sustainable transport for workers - only 13 car parking spaces for staff. The nearest bus stop is over 2 miles away. There are no footpath and the traffic is fast moving so it is unsafe to cycle. 6. Moto already owns 4 MSA locations on the A1(M) a further 5th location would strengthen Moto's monopoly discouraging healthy competition for fuel, shop, food and parking and service prices on this 39 mile stretch of the A1(M). Their current fuel, shop and food pricing is some of the highest in Northern and gives motorists a very poor value for money. 7. Noise and light pollution, 24/7. Even though we live 4 miles away from the A1(M) we can hear its traffic noise. Moto admit that there will be some additional light pollution which is inappropriate for a rural area. Local areas approx. 25km away which look in this direction have been designated Dark Sky Discovery Sites and an increase in light pollution may have an impact. 8. The agricultural land on which they want to build is most "versatile and sustainable land with high quality soils and structure to support many types of crops". It is not low grade land as suggested by the applicant. 9. Moto now owns the site at Leeming Bar, Junction 51 which was considered suitable for a MSA and it has not yet developed it. Work is due to start at some time in the future making the Baldersby MSA unnecessary. 10. Also at Junction 51 is Exelby Services which offers fuel for cars and commercial vehicles, toilets and showers, shop, café which are open 24/7. It has parking overnight with security for 150 HGV's and free wi-fi in the lorry park. This again shows that there is no need for more such facilities at Junction 50. 11. Moto objected to an application for a MSA at Junction 50 by Refined Estates Limited in the previous planning enquiry in 2012. They stated that there was no need for an MSA at this location as it was only 17 miles away from Services (which they own) . The logic and reasoning behind their objection to an MSA at Junction 50 is still relevant. 12. Borough Council have rightly rejected this application on the grounds that it will damage and degrade a hitherto intact landscape.

Page 2 of 2 For official use only (date received): 16/11/2020 14:39:33

The Planning Inspectorate

COMMENTS ON CASE (Online Version)

Please note that comments about this case need to be made within the timetable. This can be found in the notification letter sent by the local planning authority or the start date letter. Comments submitted after the deadline may be considered invalid and returned to sender.

Appeal Reference: APP/E2734/W/20/3261729

DETAILS OF THE CASE

Appeal Reference APP/E2734/W/20/3261729

Appeal By MOTO HOSPITALITY LIMITED

Site Address Land Comprising Field at 435074 475842 Hutton Conyers Ripon North Yorkshire Grid Ref Easting: 435074 Grid Ref Northing: 475842

SENDER DETAILS

Name SIR JAMES GRAHAM

Address Norton Conyers Hall Norton Conyers RIPON HG4 5EQ

ABOUT YOUR COMMENTS

In what capacity do you wish to make representations on this case?

Appellant Agent Interested Party / Person Land Owner Rule 6 (6)

What kind of representation are you making?

Final Comments Proof of Evidence Statement Statement of Common Ground Interested Party/Person Correspondence Other

Page 1 of 3 YOUR COMMENTS ON THE CASE

I, Sir James Graham Bt of Norton Conyers object to this proposal for the following reasons:-

1. The agricultural land on which they want to build is most "versatile and sustainable land with high quality soils and structure to support many types of crops". It is not low grade land as suggested by the applicant.

2. There is no sustainable transport for workers - only 13 car parking spaces for staff. The nearest bus stop is over 2 miles away. There is no footpath and the traffic is fast moving so it is unsafe to cycle.

3. The applicant drew attention to the creation of local jobs. My objection was that Thirsk and Ripon, the two nearest towns, had unemployment rates below the national average and the average for North Yorkshire. The current epidemic, has of course, created and will continue to create an entirely new situation as far as employment is concerned.

4. The Secretary of State rejected this site 8 years ago after a lengthy and costly public enquiry. Nothing has changed since and therefore this application will mean that more public money will be wasted in opposing it. The non-suitability of this site has therefore already been determined by a previous Appeal at the highest level.

5. Even Moto state that there will be some additional light pollution which is inappropriate for a rural area. Local areas approx. 25km away which look in this direction have been designated Dark Sky Discovery Sites and an increase in light pollution may have an impact on them.

6. This MSA would furthermore have a detrimental effect on the tourism of Ripon and Thirsk and detract from local businesses. It should not be forgotten that Junction 50 is the direct stepping off point from the A1(M) to the exceptional Norton Conyers Grade II* listed late medieval manor house and gardens near Wath, winner of The Historic Houses Association & Sotheby's Restoration Award 2014.

7. Moto now owns the site at Leeming Bar, Junction 51 which was considered suitable for a MSS and it has not yet developed it. Work is due to start at some time in the future making the Baldersby MSS unnecessary.

8. Also at Junction 51 is Exelby Services which offers fuel for cars and commercial vehicles, toilets and showers, shop, café which are open 24/7. It has parking overnight with security for 150 HGV's and free wi-fi in the lorry park. This again shows that there is no need for more such facilities at Junction 50.

9. Moto already owns 4 MSA locations on the A1(M) a further 5th location would strengthen Moto's monopoly discouraging healthy competition for fuel, shop, food and parking and service prices on this 39 mile stretch of the A1(M). Their current fuel, shop and food pricing is some of the highest in Northern England and gives motorists a very poor value for money.

10. Moto objected to an application for a MSA at Junction 50 by Refined Estates Limited in the previous planning enquiry in 2012. They stated that there was no need for an MSA at this location as it was only 17 miles away from (which they own) . The logic and reasoning behind their objection to an MSA at Junction 50 is still relevant.

11. The site has a water table relatively close to the surface and a number of local farmers depend on bore holes to irrigate their crops. Natural water could become contaminated by the proposed development through surface water run-off. The site is at a significant distance from the nearest sewerage facilities, and the proposed hotel and amenity block will give rise to a significant sewerage load.

12. The proposal, if carried out, will attract disreputable hangers-on and become a breeding ground for petty crime in an area which is currently exceptionally free from it. Prostitution, and with it drug-taking and drug-peddling, is also an all-too-likely result.

Page 2 of 3 Page 3 of 3 For official use only (date received): 25/11/2020 11:58:18

The Planning Inspectorate

COMMENTS ON CASE (Online Version)

Please note that comments about this case need to be made within the timetable. This can be found in the notification letter sent by the local planning authority or the start date letter. Comments submitted after the deadline may be considered invalid and returned to sender.

Appeal Reference: APP/E2734/W/20/3261729

DETAILS OF THE CASE

Appeal Reference APP/E2734/W/20/3261729

Appeal By MOTO HOSPITALITY LIMITED

Site Address Land Comprising Field at 435074 475842 Hutton Conyers Ripon North Yorkshire Grid Ref Easting: 435074 Grid Ref Northing: 475842

SENDER DETAILS

Name MRS PAMELA JOHNSON

Address North Yorkshire County Council, Business & Environmental Services County Hall Racecourse Lane DL7 8AH

Company/Group/Organisation Name North Yorkshire County Council as Local Highway Authority

ABOUT YOUR COMMENTS

In what capacity do you wish to make representations on this case?

Appellant Agent Interested Party / Person Land Owner Rule 6 (6)

What kind of representation are you making?

Final Comments Proof of Evidence Statement Statement of Common Ground

Page 1 of 3 Interested Party/Person Correspondence Other

Page 2 of 3 COMMENT DOCUMENTS

The documents listed below were uploaded with this form:

Relates to Section: REPRESENTATION Document Description: Your comments on the appeal. File name: 20-11-25- letter to PINS.pdf

PLEASE ENSURE THAT A COPY OF THIS SHEET IS ENCLOSED WHEN POSTING THE ABOVE DOCUMENTS TO US

Page 3 of 3

The Planning Inspectorate Transport and Development Reference APP/E2734/W/20/3261729 Highways & Transportation By email County Hall NORTHALLERTON North Yorkshire DL7 8AH

Your ref: APP/E2734/W/20/3261729 Tel: 01609 532295 Our ref: 18/02713/EIAMAJ Email: [email protected] Contact: Pam Johnson Web: www.northyorks.gov.uk Date:

Dear Sirs

TOWN AND COUNTRY PLANNING ACT 1990 - APPEAL UNDER SECTION 78 APPEAL BY: Moto Hospitality Ltd SITE AT: Land Comprising Field At 435074 475842 Hutton Conyers North Yorkshire

PROPOSAL: Outline application for the erection of comprising amenity building, lodge, petrol filling station, parking to include heavy goods and coach parking and associated infrastructure; Formation of access and landscaping. APPEAL REF: APP/E2734/W/20/3261729 COUNCIL REF: 20/00088/NREFPP START DATE: 27 October 2020

I refer to the above appeal.

North Yorkshire County Council, in its role as Local Highway Authority (LHA) for the area, has raised no objections to the principle of the propose development. In assessing the proposed development the LHA has worked closely with Highways England who are responsible for the strategic road network. In the vicinity of the site the SRN includes the A1(M), the slip roads at Junction 50 and the overbridge and roundabouts at Junction 50. Responsibility for the management of the A61 and the A6055 lies with the LHA.

Should the Inspector be minded to allow the appeal it is requested that the following conditions are attached to any permission granted.

MHC-07 Delivery of off-site highway Works The following schemes of off-site highway mitigation measures must be completed as indicated below:  Amendments to the western roundabout at junction 50 (A1M) including the A61 and A6055 legs prior to the first occupation

For each scheme of off-site highway mitigation, except for investigative works, no excavation or other groundworks or the depositing of material on site in connection with the construction of any

OFFICIAL Page 2 of 3 scheme of off-site highway mitigation or any structure or apparatus which will lie beneath that scheme must take place, until full detailed engineering drawings of all aspects of that scheme including any structures which affect or form part of the scheme have been submitted to and approved in writing by the Local Planning Authority.

An independent Stage 2 Road Safety Audit carried out in accordance with GG119 - Road Safety Audits or any superseding regulations must be included in the submission and the design proposals must be amended in accordance with the recommendations of the submitted Safety Audit prior to the commencement of works on site.

A programme for the delivery of that scheme and its interaction with delivery of the other identified schemes must be submitted to and approved in writing by the Local Planning Authority prior to construction works commencing on site.

Each item of the off-site highway works must be completed in accordance with the approved engineering details and programme.

Reason for Condition To ensure that the design is appropriate in the interests of the safety and convenience of highway users.

INFORMATIVE Notwithstanding any valid planning permission for works to amend the existing highway, there must be no works in the existing highway until an Agreement under Section 278 of the Highways Act 1980 has been entered into between the Developer and the highway authorities. To carry out works within the highway without a formal Agreement in place is an offence.

MHC-09B Provision of Approved Access, Turning and Parking Areas at INSERT LOCATION No part of the development must be brought into use until the access, parking, manoeuvring and turning areas for all users within the site have been constructed in accordance with the details approved in writing by the Local Planning Authority. Once created these areas must be maintained clear of any obstruction and retained for their intended purpose at all times.

Reason for Condition To provide for appropriate on-site vehicle facilities in the interests of highway safety and the general amenity of the development.

MHC-14 Travel Plan Delivery The development must be carried out and operated in accordance with the approved Travel Plan. Those parts of the Approved Travel Plan that are identified therein as being capable of implementation after occupation must be implemented in accordance with the timetable contained therein and must continue to be implemented as long as any part of the development is occupied.

Reason for Condition To establish measures to encourage more sustainable non-car modes of transport.

OFFICIAL Page 3 of 3

MHC-15A Construction Management Plan No development for any phase of the development must commence until a Construction Management Plan for that phase has been submitted to and approved in writing by the Local Planning Authority. Construction of the permitted development must be undertaken in accordance with the approved Construction Management Plan.

The Plan must include, but not be limited, to arrangements for the following in respect of each phase of the works: 1. details of any temporary construction access to the site including measures for removal following completion of construction works; 2. wheel and chassis underside washing facilities on site to ensure that mud and debris is not spread onto the adjacent public highway; 3. the parking of contractors’ site operatives and visitor’s vehicles; 4. areas for storage of plant and materials used in constructing the development clear of the highway; 5. measures to manage the delivery of materials and plant to the site including routing and timing of deliveries and loading and unloading areas; 6. details of the routes to be used by HGV construction traffic and highway condition surveys on these routes; 7. protection of carriageway and footway users at all times during construction; 8. protection of contractors working adjacent to the highway; 9. details of site working hours; 10. erection and maintenance of hoardings. 11. means of minimising dust emissions arising from construction activities on the site, including details of all dust suppression measures and the methods to monitor emissions of dust arising from the development; 12. measures to control and monitor construction noise; 13. an undertaking that there must be no burning of materials on site at any time during construction; 14. removal of materials from site including a scheme for recycling/disposing of waste resulting from demolition and construction works; 15. details of the measures to be taken for the protection of trees; 16. details of external lighting equipment; 17. details of ditches to be piped during the construction phases; 18. a detailed method statement and programme for the building works; and 19. contact details for the responsible person (site manager/office) who can be contacted in the event of any issue. Reason for Condition In the interest of public safety and amenity

Yours faithfully

P Johnson

Pam Johnson Technical Specialist Development Management

Copies to: Highways England Jamey Fearnside Harrogate BC Area Office

OFFICIAL For official use only (date received): 30/11/2020 10:14:53

The Planning Inspectorate

COMMENTS ON CASE (Online Version)

Please note that comments about this case need to be made within the timetable. This can be found in the notification letter sent by the local planning authority or the start date letter. Comments submitted after the deadline may be considered invalid and returned to sender.

Appeal Reference: APP/E2734/W/20/3261729

DETAILS OF THE CASE

Appeal Reference APP/E2734/W/20/3261729

Appeal By MOTO HOSPITALITY LIMITED

Site Address Land Comprising Field at 435074 475842 Hutton Conyers Ripon North Yorkshire Grid Ref Easting: 435074 Grid Ref Northing: 475842

SENDER DETAILS

Name MR COLIN REID

Address The Orchard Baldersby YO7 4PE Thirsk North Yorkshire YO7 4PE

ABOUT YOUR COMMENTS

In what capacity do you wish to make representations on this case?

Appellant Agent Interested Party / Person Land Owner Rule 6 (6)

What kind of representation are you making?

Final Comments Proof of Evidence Statement Statement of Common Ground

Page 1 of 3 Interested Party/Person Correspondence Other

Page 2 of 3 COMMENT DOCUMENTS

The documents listed below were uploaded with this form:

Relates to Section: REPRESENTATION Document Description: Your comments on the appeal. File name: MSA Letter Final.pdf

PLEASE ENSURE THAT A COPY OF THIS SHEET IS ENCLOSED WHEN POSTING THE ABOVE DOCUMENTS TO US

Page 3 of 3 The Orchard Baldersby Thirsk YO7 4PE 30th November 2020

The Planning Inspectorate The Square Temple Quay Room 3 O/P Temple Quay House 2 Bristol BS1 6PN

Dear Sirs,

TOWN AND COUNTRY PLANNING ACT 1990 - APPEAL UNDER SECTION 78

APPEAL BY: Moto Hospitality Ltd

SITE AT: Land Comprising Field At 435074 475842 Hutton Conyers North Yorkshire

PROPOSAL: Outline application for the erection of motorway service area comprising amenity building, lodge, petrol filling station, parking to include heavy goods and coach parking and associated infrastructure; Formation of access and landscaping.

COUNCIL REF: 20/00088/NREFPP

APPEAL REF: APP/E2734/W/20/3261729

START DATE: 27 October 2020

I am writing to confirm my objection to the proposal to develop an MSA at Junction 50 of the A1M.

I have already objected in writing and addressed the Planning Committee of Harrogate Borough Council when the planning application was rejected. I understand these objections and associated documentation will be passed to the Inspector as part of the Inquiry process. I concur with the reasons given by the Planning Officer for recommending rejection to the Planning Committee. I have considered carefully requesting to appear formally at the inquiry as a Rule 6(6) party. After studying the helpful guidance published by the Planning Inspectorate I have concluded that the task of the Planning Inspector would not be enhanced by a succession of individuals, such as myself, appearing and sharing their perspective on the matter. I also note from previous Inquiry reports that Inspectors have, on occasion, suggested that evidence submitted by those who have not appeared in person at the Inquiry and thus not been subject to cross examination should be given less credence and, in some cases, discounted. I stress that I am happy to appear at the Inquiry if the Inspector wishes me so to do and considers that such an appearance would be beneficial.

I request that the Inquiry which is to be convened to determine the appeal to the Secretary Of State against the rejection consider the following matter. I recognise that the Planning Inspectorate is, quite properly, primarily concerned with matters pertaining to planning policy, guidance and legislation. I submit however that the overall context of a proposal or appeal is relevant and in this particular case it is important to take account of the appellant’s changed position in regard to MSA developments and applications on this stretch of the A1M.

MOTO, the appellant, has demonstrated a lack of consistency and has been somewhat economical with the truth on occasion.

I note from the reports of the previous public enquiries issued in October 2012 that the Inspector in drawing his conclusions made observations about the testimony of some witnesses, including MOTO. In these he indicated that their underlying motivation was such that he had reason to discount or lessen the weight he applied to their evidence. I trust therefore that the Inspectorate will feel able to take account of the facts outlined here as this inquiry proceeds.

MOTO Hospitality’s Position 2012 to 2020

Outlined below is a summary of MOTO’s position on the provision of MSAs at Junctions 50 and 51 on the A1M since 2012

MOTO’s Position at 2012 Planning Enquiry

Throughout the inquiry MOTO opposed the developments at Kirby Hill, Ripon, Coneygarth and Baldersby Gate. They raised many points of objection among which were :

- there was no real need or justification for an MSA between Wetherby and Motel Leeming (Junction 51)

- Wetherby MSA had adequate capacity both presently and projected

- the landscape and environmental impacts at the greenfield sites of Kirby Hill, Ripon and Baldersby Gate were much greater than that of the brownfield Motel Leeming

- minimal agricultural land would be lost at Motel Leeming compared with the losses at Kirby Hill, Ripon and Baldersby Gate

MOTO’s Position at Public Consultation Event 2018

At this event held in the Market Square in May 2018 in Ripon I asked the MOTO representatives what their plans were to develop the present at Leeming (Junction 51) into an MSA. I reminded them that Planning Permission had been granted for this development and it had been the preferred solution of the Secretary of State following the 2012 Public Enquiry. I suggested to MOTO that they had no intent to pursue this development if they received approval of their current proposal for Ripon Services at Junction 50. The response was that irrespective of the outcome of the proposal for Junction 50 MOTO was going to develop Leeming Bar into an MSA, that work was due to start in 2019 and that there was commercial justification for MSAs at both Junction 50 and Junction 51. The reason for the delay in starting the work was simply some detailed planning issues which had to be resolved with Council.

Attachment 1 is a note of that event prepared at the time.

Since then no material progress has been evident at the Leeming site.

MOTO’s Position at 2020 Planning Application to Harrogate Borough Council

Two or three days before the application for Ripon Services at Junction50 was to be considered by the Harrogate Borough Council Planning Committee MOTO wrote to the committee indicating that they had no intent of developing the Leeming site at Junction 51 and suggesting they would be happy if this condition was applied should their application for Junction 50 be successful.

I agree with MOTO’s position outlined at the 2012 Planning Enquiry. Indeed the reasons attributed to them at this time for objecting to the developments at Kirby Hill, Ripon and Baldersby Gate are virtually identical to many of those made by objectors to MOTO’s current proposal for Ripon Services at Junction50. One can only surmise why MOTO’s position has changed so dramatically since then.

It is regrettable that MOTO gave assurances at the public consultation event that they intended to proceed with the development at Leeming (for which permission was in place) whether or not their application for Ripon Services was successful. Quite why they made this statement is not clear. One is drawn to the rather sad conclusion that MOTO is not a company which keeps its word and that its representatives will say whatever is expedient at the time.

One can only guess at what motivated the eleventh hour offer by MOTO to the Harrogate Borough Council Planning Committee not to proceed with the development at Leeming. I would observe that a number of those who had objected to the proposal had pointed out MOTO’s dominant market position in the area should the application be approved viz Wetherby, Ripon, Leeming and so it seems not unreasonable to assume this may have been a contributory factor. I would also surmise that the site at Leeming could be sold and developed for light industrial, warehousing/storage or housing thus furnishing MOTO with significant benefit. Thus an offer to allay concerns of lack of competition materially benefits MOTO.

Although I am troubled by MOTO’s motivation and integrity my main concern remains the impact on the landscape of the proposed development. MOTO in their submissions has indicated that their design and landscaping would be much better than that proposed by the previous developers in 2012. It would also be similar in style to MOTO’s Wetherby MSA.

Many hundreds of pages of text, dozens of drawings and reports, cross sections and detailed arguments are offered to justify the position that the impact on the landscape will be minimal. I simply offer the following two photographs taken on the same afternoon, one at Junction 50 and one at Wetherby MSA. I ask the Inspector to consider if this is the legacy we wish to leave our children and grandchildren especially taking into account the existence of a brownfield site around 11 miles to the north at Junction 51.

Our Legacy ??

Jct 50 Roundabout : View from Proposed Access Road

Wetherby MOTO Services : View of site across Access Road

In engaging with this issue and the various levels of the planning process I have been struck by the fact that there never seems to be an end to it. Over many years on a number of occasions planning permission for MSAs at Junctions 49 and 50 have been rejected by Harrogate Borough Council and appeals have also been rejected. Yet time and again developers reshape and redraft their proposals, cite changes to planning guidance and come back to try again. It reminds me of the old legend about Robert the Bruce watching the spider try seven times to spin its web in the cave he was hiding in and deciding that he would try once more to defeat the all powerful English Army - which of course he did at Bannockburn. No doubt the cost to councils, central government and other agencies comes out of the public purse and is not inconsiderable not to mention the time and energy expended by hard pressed and busy people. One wonders if applicants and appellants would be quite so keen to try, try and try again if they were made liable for all costs, including those of objectors, associated with repeat processes.

In conclusion I apologise for the length of this communication. I hope my concerns are clear and once again I would be happy to appear at the inquiry or discuss any issues directly if the Inspectorate wishes.

Yours faithfully

Colin W Reid

Attachment 1

I attended the public consultation event run by Moto regarding the proposals for a new Moto MSA at J50, A1(M) on 24th May 2018.

I had a number of questions which were answered in varying degrees of detail by three of the Moto representatives present.

1 Justification

The Moto representatives stated more than once that this was their “number 1 site for development on the motorway network”. During discussion it emerged that the costs of development would be lower than at other sites and that the Moto representatives believed that there was “public demand” for this development. When closely questioned as to how this demand was assessed they stated that they formed this view because of the fact that Wetherby MSA – the next MSA to the south – was overwhelmed at times. It was suggested by the Moto representatives that this alone justified the development at Baldersby Gate. They had no comment to make when challenged that the current higher use of Wetherby may be due to the difficulty of accessing the Scotch Corner service/rest area due to the protracted work on the roundabout there making access very difficult and the fact that the service/rest area at Leeming has yet to be developed despite having had planning approval for some years.

There was little doubt in my mind that Baldersby represents the most economically attractive opportunity for Moto so unsurprisingly as a commercial operator they wish to promote this development in preference to other options. Also given their domination of service area provision in this area another motivation for Moto will be, quite understandably, to squeeze out any other competition, Thus by building at Baldersby Gate the economics of the MSA proposed at Kirby Hill by a Moto competitor will be adversely affected.

The representatives stated frequently that there was no minimum distance now specified between MSAs and that private sector companies such as Moto were being held responsible by national government to provide what was seen as critical infrastructure. They accepted my point that the lack of joined up planning was regrettable ie plan and approve MSAs at the same time as planning and approving motorways. They did not accept that provision of MSA’s on greenfield sites was in effect creeping urbanisation of the countryside but rather that they saw them as providing much needed safety related infrastructure and that the environmental impacts could easily be mitigated. They informed me that they hope to start development of Leeming MSA in 2019. They claimed that two MSA’s positioned at two junctions ie 50 and 51 was completely justified because of increasing congestion on motorways resulting in longer journey times which required more provision. In response to my point that the section of the A1M North of Wetherby was largely rural, did not have large conurbations adjacent, was not subject to regular congestion and thus the need for multiple MSAs at adjacent junctions was not justified they again stated that this was “the number 1 site for development” and it was important to future proof the motorway network.

My conclusion from this part of the debate was that the primary reason for this development was that it represents a profitable investment opportunity for Moto rather than an identified need on safety grounds as claimed. If all proposed schemes are developed we will have three new MSAs in the 28 mile stretch of road between Wetherby and Scotch Corner – Leeming, Baldersby Gate and Kirby Hill which would seem, given the relatively smooth flowing nature of this stretch of road, over provision. One risk of such over provision is that one or more of these facilities will not prove commercially viable with the possible result of early closure and/or a rundown scruffy site. Such blight would not be acceptable particularly at Kirby Hill and Baldersby Gate where the present land use and aspect is open agricultural land with, in the case of Baldersby Gate. wide ranging rural views towards the Dales National Park.

2 Environmental Impact

Moto accepted that there would be environmental impact on the site but indicated that all could be mitigated successfully. In particular drainage and sewerage would be treated on site with no need to connect to fixed sewage facilities. They were unable to give any clear indication of night time delivery schedules.

3 Traffic Impact

Moto indicated that a detailed traffic survey would be included in the planning submission but that impact on traffic and the associated risks were a matter for the Highways authority. Moto believed that the two roundabouts and the single lane on and off ramps were adequate for the increased traffic. They indicated that they anticipated an average of three hundred vehicle movements into and away from the site every hour on average. Although it is dangerous to draw any conclusions from average figures that would represent an vehicle movement every 12 seconds or so. As a regular user of A61 travelling from Baldersby to Ripon I believe that such a frequency would give rise to increased traffic congestion particularly on the A61 branches at the roundabouts. Also the present ergonomics of the connecting roads onto the roundabouts are not ideal – although I am sure they meet required standards – and the insertion of another connecting road into the roundabout on the Ripon side with a very short spacing between the existing two roads will I fear create a dangerous road layout.

For official use only (date received): 18/11/2020 12:19:37

The Planning Inspectorate

COMMENTS ON CASE (Online Version)

Please note that comments about this case need to be made within the timetable. This can be found in the notification letter sent by the local planning authority or the start date letter. Comments submitted after the deadline may be considered invalid and returned to sender.

Appeal Reference: APP/E2734/W/20/3261729

DETAILS OF THE CASE

Appeal Reference APP/E2734/W/20/3261729

Appeal By MOTO HOSPITALITY LIMITED

Site Address Land Comprising Field at 435074 475842 Hutton Conyers Ripon North Yorkshire Grid Ref Easting: 435074 Grid Ref Northing: 475842

SENDER DETAILS

Name MISS SANDRA SHACKLETON

Address Hutton Grange Cottage Hutton Moor Ripon North Yorkshire HG4 5LX

Householders at Hutton Grange Cottage and Braisty Company/Group/Organisation Name Cottage

ABOUT YOUR COMMENTS

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Final Comments Proof of Evidence

Page 1 of 3 Statement Statement of Common Ground Interested Party/Person Correspondence Other

Page 2 of 3 COMMENT DOCUMENTS

The documents listed below were uploaded with this form:

Relates to Section: REPRESENTATION Document Description: Your comments on the appeal. File name: Moto appeal letter 2020 updated.docx

PLEASE ENSURE THAT A COPY OF THIS SHEET IS ENCLOSED WHEN POSTING THE ABOVE DOCUMENTS TO US

Page 3 of 3 Hutton Grange Cottage, Hutton Moor, Ripon, North Yorkshire, HG4 5LX. Harrogate Borough Council, planning Dept

Copies to Hewick and Hutton Parish Council.

Planning Appeal Moto Hospitality Limited, Site Land comprising field at 435074 475842, Hutton Conyers, North Yorkshire.

Appeal Reference: APP/E2734/W/20/3261729

Dear members of the Planning Department/Parish Councillors,

I would like to outline my objections to the MSA at Junction 50 A1

Harrogate Borough Council has objected:

The proposal is outside development limits and represents an unsustainable development that would result in a significant encroachment into open countryside causing harm to the landscape in conflict with Policies EC3 (A & C) GS3 and NE4 of the Harrogate District Local plan. This has not changed in anyway.

To develop on a greenfield site which is categorised as good quality land which is capable of growing a variety of crops has to be as the very last resort. We have encroachment in many local villages for housing on such land and need to preserve our farmland and the countryside as a whole. This development will have a severe and lasting negative impact on the landscape, degrading it to a brownfield site leaving it open to possible further development.

The developers (Moto) have permission to develop the Leeming site (after a lengthy and very costly appeal in 2012 where the Secretary of State which concluded that the brownfield site at Leeming was best suited for the purposes of an MSA). This is still awaiting development by Moto. To break new ground on a greenfield site may be less costly for the developers but cannot be in the interests of the wider community. We need to protect our landscape for future generations and ensure food security by growing more food in the UK.

Is there really a need for an MSA ? If we take into account the site to be developed at Leeming and proposals for an MSA at the Catterick site. Modern vehicles are reliable and capable of getting from Wetherby to the next service station at Leeming in very short order. The legislation has been changed from the 28 miles distance between service stations allowing developers to propose an MSA on every junction, that is not the same as need. As there is an existing lorry park, fuel and facilities at Leeming Bar services station there can be no real need for an MSA at junction 50.

The local economy will not be served by this MSA. It will take custom away from the retailers in Ripon and surrounding villages. It will also undermine established businesses in the area.

There is always the issue of road safety. Motorists and cyclists alike have to negotiate a roundabout with multiple exits, adding ramps in and out of the site will add to the problem. There will be additional noise from an MSA which operates 24hours 7 days a week, not to mention litter. There is an established pattern of criminal activities on these sites with an increase in county lines drug trafficking. I do not wish this to be ¼ mile from my home. My property and that of my neighbour Miss Gill at Braisty Cottage is located on the A61 and is not shown on the plan for the development site and is less than 400 yards from the boundary. We have a unique and beautiful view of this landscape and have the privilege of living here. I ask that you preserve this for the coming generations. We have used the fields extensively over the years with permission from Mr Potter to walk our dogs and more recently it has been invaluable during the lockdown period where we could take our hours exercise. The loss of this would be a real blow to us residents. The change to the landscape in terms of noise would be intolerable.

There is no need for this MSA as stated in my points above and it will have a lasting and detrimental impact on our landscape. Hutton Grange Cottage, Hutton Moor, Ripon, North Yorkshire, HG4 5LX. Sandra Shackleton, Mark Fairclough at Hutton Grange Cottage, and Miss E Gill of Braisty Cottage, Hutton Moor, Ripon, HG4 5LX.

For official use only (date received): 08/11/2020 15:38:05

The Planning Inspectorate

COMMENTS ON CASE (Online Version)

Please note that comments about this case need to be made within the timetable. This can be found in the notification letter sent by the local planning authority or the start date letter. Comments submitted after the deadline may be considered invalid and returned to sender.

Appeal Reference: APP/E2734/W/20/3261729

DETAILS OF THE CASE

Appeal Reference APP/E2734/W/20/3261729

Appeal By MOTO HOSPITALITY LIMITED

Site Address Land Comprising Field at 435074 475842 Hutton Conyers Ripon North Yorkshire Grid Ref Easting: 435074 Grid Ref Northing: 475842

SENDER DETAILS

Name MR ANDREW WILKINSON

Address Melmerby Ripon North Yorkshire HG4 5HA

ABOUT YOUR COMMENTS

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Page 1 of 3 YOUR COMMENTS ON THE CASE

18/02713/EIAMAJ | Outline application for the erection of motorway service area comprising amenity building, lodge, petrol filling station, parking to include heavy goods and coach parking and associated infrastructure; Formation of access and Landscaping. | Land Comprising Field at 435074 475842 Hutton Conyers North Yorkshire

I strongly object to the above application and appeal for the following reason: -

There is no recognised need for this proposed development.

The 2012 decision by The Secretary of State (Department of Communities & Local Government) made it clear that a requirement then existed for no more than one new MSA between Wetherby and Scotch Corner. The current applicant, Moto, clearly agreed with this view at that time, having objected to the application submitted by Refined Estates Limited for a MSA at Junction 50.

Moto had indicated in their objection that there was no need for the proposed MSA at Junction 50 as it would be situated only 17 miles from Wetherby Services (owned by Moto) and yet they now wish to create a further MSA of their own at the very site they had previously objected to.

The operational capacity of the Leeming Bar MSA (owned by Moto) has since been maximised and meets the requirement stipulated by the Secretary of State. I am not aware of any change to the A1(M) to indicate that the proposed MSA would now be necessary.

It could easily be assumed that Moto only submitted this current application because one of their competitors, , had applied for permission for another MSA at Kirby Hill, (18/00123/EIAMAJ) and that they are unhappy at the prospect of such a threat to their complete monopoly of MSA sites on the A1(M) from Wetherby to Newcastle.

Following the Secretary of State's decision in 2012 a subsequent Department for Transport Circular (02/2013) provided for new applications to be submitted. However, it also gave specific advice to local planning authorities and it is clear that each application should continue to be judged on the balance of need versus harm:

“In determining applications for new or improved sites, local planning authorities should not need to consider the merits of the spacing of sites beyond conformity with the maximum and minimum spacing criteria established for safety reasons. Nor should they seek to prevent competition between operators; rather they should determine applications on their specific planning merits.”

I believe that serious consideration should be given to the possible reasons behind Moto’s current application which may well be motivated more by greed and resistance to competition than any concern for the motorist.

The distance from Wetherby to Leeming Bar, measured by the Highways Agency and agreed by all interests at the 2012 Public Inquiry is 27.5 miles and therefore remains within the maximum recommended distance.

The disruption to local communities and the environmental harm (including light pollution, threat to local aquifers, loss of agricultural land and increased airborne particulates and litter) that this major development would generate is simply not worth the questionable benefits that Moto propose to motorists, particularly as there is no recognised need for an additional MSA at the site.

It is worth considering that there have been approximately 20 MSA proposals submitted for the A1 between Wetherby and Leeming since 1982. The true cost to the taxpayer is difficult to imagine. The

Page 2 of 3 Secretary of State made the decision in 2012 that no further MSA is required between these areas and I strongly urge consideration be given to now putting a stop to these applications by private companies and save valuable taxpayers’ funds.

Finally I truly believe we need to preserve as much of our valuable (and ever-decreasing) countryside as possible and look to innovative and sustainable developments which do not harm our precious landscape.

Page 3 of 3 For official use only (date received): 08/11/2020 16:52:08

The Planning Inspectorate

COMMENTS ON CASE (Online Version)

Please note that comments about this case need to be made within the timetable. This can be found in the notification letter sent by the local planning authority or the start date letter. Comments submitted after the deadline may be considered invalid and returned to sender.

Appeal Reference: APP/E2734/W/20/3261729

DETAILS OF THE CASE

Appeal Reference APP/E2734/W/20/3261729

Appeal By MOTO HOSPITALITY LIMITED

Site Address Land Comprising Field at 435074 475842 Hutton Conyers Ripon North Yorkshire Grid Ref Easting: 435074 Grid Ref Northing: 475842

SENDER DETAILS

Name MS LESLEY WILKINSON

Address Doone Lodge Melmerby Ripon North Yorkshire HG4 5HA

ABOUT YOUR COMMENTS

In what capacity do you wish to make representations on this case?

Appellant Agent Interested Party / Person Land Owner Rule 6 (6)

What kind of representation are you making?

Final Comments Proof of Evidence Statement Statement of Common Ground Interested Party/Person Correspondence

Page 1 of 3 Other

Page 2 of 3 COMMENT DOCUMENTS

The documents listed below were uploaded with this form:

Relates to Section: REPRESENTATION Document Description: Your comments on the appeal. File name: MSA objection.docx

PLEASE ENSURE THAT A COPY OF THIS SHEET IS ENCLOSED WHEN POSTING THE ABOVE DOCUMENTS TO US

Page 3 of 3 18/02713/EIAMAJ | Outline application for the erection of motorway service area comprising amenity building, lodge, petrol filling station, parking to include heavy goods and coach parking and associated infrastructure; Formation of access and Landscaping. | Land Comprising Field at 435074 475842 Hutton Conyers North Yorkshire

I object to this Appeal for the following reasons:

Loss of agricultural land Adverse effect on the surrounding local villages and communities Harm to the valued open landscape at this location The development is contrary to both national and local policies

I believe it is vital to consider Moto’s proposed MSA application at this location in relation to the 2012 Public Inquiry into the siting of MSAs along this stretch of the A1(M). This application by Moto is contrary to the Secretary of State’s determination in 2012, following the extensive Public Inquiry, at taxpayers’ expense, that there should be no MSA sited at junction 50. In deciding the outcome of that Inquiry, the Secretary of State had regard to section 38(6) of the Planning and Compulsory Purchase Act 2004 which requires that proposals be determined in accordance with the development plan unless material considerations indicate otherwise. In other words, proposed development that is in accordance with the Local Plan should be approved whilst development that is in conflict with it should be refused, unless there are overriding and compelling material considerations to indicate otherwise. Surely therefore Moto are required to demonstrate an unequivocal need and safety case in this instance.

At the 2012 Public Inquiry the Secretary of State gave permission to upgrade the existing Leeming Bar Services to full MSA status. The distance from Wetherby to Leeming Bar, measured by the Highways Agency and agreed by all interests at the Public Inquiry, is 27.5 miles and therefore remains within the maximum recommended distance. Permission was granted to Leeming Bar because the site would be based on an existing Trunk Road Service Area and the Secretary of State recognised it as being the most sustainable of all options presented at that time, whilst also conforming in general terms with the development plan. It would be built on brownfield land with no additional land take. It was further recognised that the two MSA proposals at junction 50 would have been constructed in open country on greenfield sites, taking agricultural land and causing visual impact. The non- suitability of this site has, therefore, already been determined by a previous Appeal.

This application by Moto has been submitted before the Secretary of State’s decision regarding Leeming Bar (along with further permission for a truck stop at Coneygarth) has been given time to be fully implemented and operational. I struggle therefore to understand how any economic viability is anything but speculative for this application as surely both MSAs, one not yet fully operational, would be located so close to each other.

The 2012 decision by the Secretary of State made it clear that there was a need for one only new MSA between Wetherby and Scotch Corner. There was no disagreement with this decision at the Inquiry nor at any subsequent Appeal.

Since the Secretary of State’s decision in 2012 a Department for Transport Circular (02/2013) allows for new applications to be submitted. However, it gives specific advice to local planning authorities and it is clear that each application should continue to be judged on the balance of need versus harm.

“In determining applications for new or improved sites, local planning authorities should not need to consider the merits of the spacing of sites beyond conformity with the maximum and minimum spacing criteria established for safety reasons. Nor should they seek to prevent competition between operators; rather they should determine applications on their specific planning merits.”

Of note, with regard to competition between operators, is the fact that Moto controls all MSAs from Wetherby to Newcastle. I fail to view this as anything but a monopoly.

From a personal point of view, I drive regularly up and down the stretch of the A1(M) from Ripon to Wetherby and Ripon to Scotch Corner. Traffic flow never seems to be a problem to me. I therefore have concerns about the number of motorists that would actually make use of a MSA at Ripon which brings into doubt once again the economic viability of essentially 3 MSAs stretching over 40 miles. And, this does not include the proposed Road Chef application for an additional MSA at J52 (Catterick). Surely the Department for Transport’s circular was aimed at more congested parts of the network system? I would therefore consider that the current MSAs in existence on the A1(M) provide sufficient facilities to meet the required safety standards and there is not a specific requirement for this development which must be weighed within the planning balance accordingly.

I believe the Development Plan relevant to this application consists of the 2009 Harrogate District Core Strategy and saved policies of the Harrogate District Local Plan (2001). Policy T7 (Motorway Service Areas) states that “Within Harrogate District planning permission will be granted for not more than one motorway service area serving the A1 (M). The provision of an MSA is to be dependent on there being a need for such a facility taking into account existing and planned services on the A1 and linked motorways elsewhere in Harrogate and Yorkshire” and goes on to state that proposals will be assessed against strict criteria including the desirability of excluding extraneous services and facilities; the need to provide safe and convenient access without interfering with the free and safe flow of traffic on the motorway or the local highway network; minimising the loss of agricultural land; minimising the impact on listed buildings, registered parks and gardens and their settings; and minimising the impact on residential amenity.

This application by Moto contravenes this policy as the Secretary of State granted permission in 2005 for the Wetherby Services which is located within the southern part of the Harrogate District Authority area.

I believe that it is essential that greenfield sites be safeguarded against development wherever possible, particularly given the significant encroachment that is already evident for housing needs. It is also important that the UK now seriously considers self sufficiency in crops grown and food supply.

Part H of Local Plan Policy T7 refers to minimising the impact on residential amenity. I am concerned that residents of the surrounding villages of Melmerby, Wath, Baldersby and Rainton will be detrimentally impacted by the location of this MSA. As facilities mentioned by Moto such as Costa and W H Smith and, recently, a Marks and Spencer’s food hall are available 4 miles away in Ripon it is very unlikely that these will be utilised by local residents. Fuel will be prohibitively expensive due to the monopoly that Moto would hold. Local people therefore would have all the disadvantages of living so close to a MSA without any of the claimed advantages.

Furthermore, national and local planning policies exist which set out that proposals which introduce significant noise or light pollution to the detriment of residential communities should be refused if not capable of being adequately mitigated against. Paragraph 123 of the NPPF sets out that “planning decisions should avoid noise from giving rise to significant adverse impacts on health and quality of life as a result of new development” and Paragraph 125 provides that “planning decisions should limit the impact of light pollution from artificial light on local amenity”. Although the surrounding local villages are located close to the motorway, we are still rural communities, with residents valuing this aspect of our lives and often struggling to limit the encroachment of industrialisation into the countryside. And what of cumulative effect? If this Appeal succeeds more greenfield sites will surrender to further development. This proposed MSA would cause harm to the surrounding open and rural landscape which has long distance views to both the Moors and the Dales and is greatly valued by many residents. Government policy regarding planning major developments in the open countryside makes clear the need to protect the countryside from development for its own sake, regardless of whether the area under threat is the subject of any special designations. Exceptional justification is required before this should be allowed to occur.

I believe that this MSA would furthermore have a detrimental effect on the tourism of Ripon and Thirsk and detract from local businesses. Please give consideration to the fact that junction 50 is the direct stepping off point from the A1(M) to the exceptional Norton Conyers Grade II listed late medieval manor house and gardens near Wath, winner of The Historic Houses Association & Sotherby’s Restoration Award 2014.

Policy GS7 (Health and Wellbeing) of the Harrogate District Local Plan advises that, among other points, development proposals should promote, support and enhance health and wellbeing by contributing to a high quality, attractive and safe public realm to encourage social interaction and facilitate movement on foot and cycle; create opportunities for employment in accessible locations; ensure high levels of residential amenity; support and enhance community and social infrastructure; and alleviate risk from unhealthy and polluted environments such as air and noise pollution and water and land contamination.

Searching through Moto’s application details I fail to read anything to reassure me that it is possible to meet any of the above requirements. Of note here are the sole 13 staff parking spaces allocated by Moto in their application, despite a proposed 200 permanent jobs created. No indication is given as to how these employees (likely to originate from Middlesbrough or Darlington, according to Moto’s public consultation) are to travel to their destination on public transport.

Research by the Transported Asset Protection Association indicates that MSAs have now become notorious centres for organised crime. The Analysis of police recorded incidents for a comparable MSA in operation on the A1(M) states there were 78 crimes and 8 anti-social behaviour incidents recorded during the 12-month period. Inevitably, this raises questions among local residents about how this will impact upon their residential amenity. This MSA would be very close to our villages and would offer a convenient launching pad for crime to take place at a time when the Police are already experiencing significant cutbacks to their resources. It is believed that this occurred near the Wetherby MSA when shortly after opening Kirk Deighton residents experienced increased crime rates with the inherent rise in insurance premiums. Despite the security measures proposed by Moto on the site I cannot comprehend how this can ever mitigate against increased crime in the surrounding area.

Finally, on a very personal note. I love skylarks. They are currently on the RSPB’s red list. They are an iconic bird and I have spotted and heard them in this area. The fact that Moto propose to mitigate against siting their MSA so close to nesting sites by providing an encouraging place for them to continue their habits, does not automatically mean that the skylarks will choose to nest there, amid the noise and cacophony of a 24/7 service station.

In summary, this development could not be incorporated into the large open landscape without a severe and negative impact. This rural environment is very sensitive to development of this kind. I consider that there is no quantitative need for this proposal and therefore the harm that would be caused significantly outweighs any proposed benefits at this location.

A1(M) MOTORWAY SERVICE AREA : JUNCTION 50 RIPON SERVICES.

APP/E/2734/W/20/3261729

APPLICANT : MOTO HOSPITALITY LTD.

PAPER CONCERNING THE ABOVE APPEAL FOR THE ATTENTION OF THE PLANNING INSPECTOR.

1.SITUATION .

I have been based in Baldersby since 1973. Because of my job I was a frequent user of the UK motorway network and for a period between 1995 and 2007 I used the A1 (M) every working day on account of my duties as the Catterick Training Area Range Officer. Now retired I am still a frequent user of the motorway network due to the dispersion of my family and my conservation interests at Local Nature Reserve ,Catterick Garrison.

Over the past forty years I have witnessed the development of the A1 from a dual carriageway trunk road interspersed with roundabouts, one of which was located at the now “ Junction 50” . I applauded its’ removal and that of the associated garages which took place in the seventies. I also applauded the subsequent construction of the fly-over modified in 2015 to accommodate the upgrade of the A1(M) to a three lane motorway.

I find the present “Junction 50” works very well and the same applies to the stretch of motorway from Wetherby to Scotch Corner. From time to time I use the service areas at Scotch Corner and Wetherby and know those service areas to be clean, well landscaped, and equipped with wide ranging facilities. This is particularly apparent at Wetherby which includes a picnic area and nature walk and, as Motorway Service Areas go, it is in my opinion “state of the art”.

Some ten minutes drive north of Junction 50 is the Leeming Bar Service area owned by Moto Hospitality Ltd. Virtually adjacent is the Exelby Services , Coneygarth, developed by the owners. This is primarily an HGV Service Area but provides extensive services for the motorist.

As a frequent user of the Motorway system I know the stretch of road between Wetherby and Scotch Corner to be easy driving and traffic queues and tailbacks rare. The latter occurred frequently when the A1 had only two lanes and HGVs jostled with each other for overtaking rights but now a three lane motorway, that scenario has been virtually eliminated. As far as service areas are concerned it is in my opinion that the Wetherby – Scotch Corner sector of the A1(M) is well covered.

Moto Hospitality Ltd disagree and have been pressing for permission to build an MSA at Junction 50 for the past decade but to date have not been successful in this quest.

2.TIMELINE

The timeline set out below shows the historical background leading to the present situation.

1987. Scheme to improve the A1(M) between Dishforth and Leeming enters the Roads Programme.

1990. Secretary of State for Transport states that the A1 from to Tyneside would become a motorway. 1991. Department of Transport notify local residents of scheme to develop the A1 Dishforth to North Leeming.

1994. Highways Agency publish details relating to the upgrade of the A1 trunk road to motorway standard. Dishforth to North Leeming sector.

2006 . Public Enquiry relating to above upgrade

2009-2012. Work on upgrade of A1 to motorway standard

2010. April. Planning application for an MSA at the A1/A61 Junction South submitted to Harrogate Council by Jaytee(Rainton)LLP

2010. June. Planning application for an MSA at the A1/A61 Junction North West submitted to Harrogate Council by Refined Estates Limited

2010. 2 November 2010 – 4 February 2011, 12 February 2012- 2 March 2012. Public enquiries held on various dates to examine MSA proposals on the A1(M). Kirby Hill, Ripon Services MSA, Baldersby Gate MSA ,Motel Leeming MSA, and Truck Stop Proposal at Fairfield Farm (Coneygarth)

2012. October . As a result of the above enquiries the Secretary of State grants a planning permission as follows: a.A planning application for an MSA at Motel Leeming Services. b.A planning application for the Coneygarth Truck Stop.

2012. October . As a result of the above enquiries the Secretary of State decided to refuse planning permission for the following three cases. a. A planning appeal for an MSA at Kirby Hill b. A planning application for the Ripon Services MSA at the junction of the A1 and A61 (Jaytee(Rainton)LLP c. A planning application for the Baldersby Gate MSA of the A1 and A61. Refined Estates Ltd

2014. Mr Carl Lees sells Motel Leeming Services to Moto Hospitality Ltd

2014 . Moto Hospitality Ltd take over the development of the Baldersby Gate site from Refined Estates Ltd

2014 – 2018. A1(M) Dishforth to Scotch Corner upgraded to three lanes

2018. Moto Hospitality Ltd launch a publicity campaign to promote their aspiration to construct an MSA at Junction 50 on the A1(M) upgraded three lane motorway.

2018. 24 May. Moto invite local residents to have a chance to have their say on their proposals for a new MSA at Junction 50 To achieve this Moto established a stand in Ripon Market Place on Thursday 24 May between 9am and 4 pm and another at the Ripon Community House 4.30pm -8pm.

{I attended the morning session. It was a very low key event and the Moto Staff on duty at the time were unable to answer my questions . I was told that the Team Project Leader was at a meeting.

The Moto Staff suggested that I submit my views to Moto Hospitality Ltd. This I did and was referred to the following documents: a.RCDO2 Ripon Motorway Service Area Planning Statement. (Moto document) b.RCDO3 Ripon Motorway Service Area Alternative Sites Assessment .(Moto document)

Not surprisingly the above were written by Moto with Moto in mind backed by statistics based on Moto owned assets. Exelby Services ,Coneythorpe were not mentioned. The focus was on creating a new MSA on a greenfield site rather than developing the Leeming Bar Services, an asset Moto already owned and had been granted a planning application for an MSA.

Moto calculated that some 200 persons had visited their stands on 24 May 2020 to find out about their proposals}

2018. August. Mr Mark Franks, Property Director, Moto Hospitalty Ltd, proposes an outline application for the erection of a Motorway Service Area at what is now known as Junction 50 on the A1(M) upgraded three lane motorway. Case No 18/02713/EIAMAJ

2018. Notification letter of above distributed by Harrogate Borough Council.

2019. Exelby Services , Coneygarth, expand parking facilities to accommodate a further 50 HGVs

2020 October 9. Letter from Harrogate Borough Council stating that the proposal to build an MSA at Junction 50 has been turned down for environmental reasons

2020 November 3.Letter form Harrogate Borough Council giving notification of an appeal by Moto Hospitality Ltd with a start date of 27 October 2020.

2020 December 22. Moto insert summary of events in Motorway Services Online in respect of Ripon Services and the associated Planning History. Moto states in the article The Mayor of Harrogate has objected to the proposals,commenting that “We are blighted by Service Stations” Visitor Feedback was requested by Moto. As at 8 February 2021 there was none.

2021. February 1. Letter from Harrogate Borough Council giving notification of a Virtual Public enquiry to be held on 16 February 2021 starting at 10.00am relating to Appeal APP/E2734/W/20/3261729.

3. JUNCTION 50 MSA. FACTORS CONTRA TO THE BUILDING OF RIPON SERVICES.

The factors are as follows:

a.WIDENING THE A1(M) TO THREE LANES.

This development has cut the journey times for most traffic and it is reasonable to achieve the following:

Northbound.

Wetherby Services to Scotch Corner Services. 40.9 miles at 70mph = 35 minutes

Wetherby Services to Exelby Services Coneygarth 29.7 miles at 70mph = 26 minutes

Wetherby Services to Leeming Bar services 29.1 miles at 70 mph = 25mins

Wetherby Services to proposed Ripon Services 19.4 miles at 70mph = 17 mins Southbound.

Scotch Corner Services to Exelby Services 11.2 miles at 70mph = 9.6 mins

Scotch Corner Services to Leeming Bar Services 11.8 miles at 70 mph = 10.1 mins

Scotch Corner Services to proposed Ripon Services 21.5 miles at 70mph = 18.5 mins

Scotch Corner Services to Wetherby Services 40.7 miles at 70mph = 34.9 mins

(Above figures produced as a result of a trial carried between 11am and 2 pm on Wednesday 29 August 2018. Traffic average , delays – none).

The times show that it is a matter of minutes to reach the existing facilities at Exelby / Leeming whether or not the start point is Scotch Corner or Wetherby. It is a fast stretch of motorway slicing through the Vale of encountering no industrial cities or towns and no trunk roads until the A66 junction at Scotch Corner. b.LEEMING BAR SERVICES. JUNCTION 51

Leeming Bar Service area was bought by Moto in 2014. Although given permission for a planning application in 2012 Moto declined to activate it despite making a statement reported in the Northern Echo to the effect that the location was excellent and Moto would expect to increase the number of jobs on the site significantly. (5 February 2014)

In 2021 the Leeming Bar facilities are as follows:

Accommodation . The Lodge complete with Meeting Room, Workspace, Showers and Toilets.

Costa, WH Smith.

Forecourt. BP Fuels, Costa Express, AdBlue.

(Covid-19 has caused some facilities to be temporarily closed)

Car Park £15 per night

HGV Park for approximately 40 HGVs.£17.50 per night ,

The car and HGV parking areas are currently managed and operated by CP Plus on behalf of Moto Hospitality Limited.

Adjacent to the Lodge is a well established MacDonalds Restaurant and Drive-Through

The services cannot be accessed directly from the A1(M) but they are well signed

(Connect photographs taken on 9 Feb 2021)

c.DEVELOPMENT OF EXELBY SERVICES CONEYGARTH. JUNCTION 51

Exelby Services, Coneygarth, located at Junction 51 on the A1(M) was opened on 2014 as primarily a Truckstop. In 2021 it now has the following facilities.

Parking for approximately 190 HGVs , LPW Truckwash, Showers, Diner 51 Forecourt. Shell ,Costa Express,Subway, Londis, Rollover,AdBlue, Air 1. (Covid 19 has caused some of these facilities to be temporarily closed)

This dynamic enterprise now caters for motorists and sells petrol and diesel at competitive prices when compared to those at conventional MSAs.

It is a family run business and is considered quick to use , safe and well run with good facilities.

It is easily accessed by A1(M) traffic travelling both North and south.

(Connect Photographs taken on 9 February 2021)

d.LACK OF INTEREST AND SUPPORT FROM GENERAL PUBLIC.

Despite the Moto Hospitality Ltd public relations offensive launched in May 2018 there appears to be no evidence in the media to suggest that their proposals regarding the Ripon Services MSA has caught the imagination of the public . Few people seem to want it.

4.CONCLUSION.

In 2018 there was a change in legislation by the Department for Transport removing the minimum distance between motorway service areas and this was possibly the genesis for the current application and the subsequent appeal by Moto with regard to Ripon Services.

Despite the facilities listed above at Leeming Bar Services and Exelby Services Coneythorpe, Moto are arguing that there is a need for an MSA on the 40 mile stretch from Wetherby to Scotch Corner. Whilst it is true that there is no one dedicated MSA there is a sufficient coverage of facilities and services provided for cars, HGV’s and coaches and all other motorway users between those two sites.

Should Moto deploy the argument that there are not enough HGV parking spots the photograph taken circa mid-day on 9 February 2021 of the Leeming Bar Services HGV park shows otherwise.

Moto Hospitality Ltd have failed to prove a need for Ripon Services and thus should be denied permission to build and the appeal refused once again. This will result in the proposed site at Junction 50 being left as it is for the foreseeable future. (Connect photograph)

T P G Helps.

12 February 2021

Planning Inspectorate References: APP/E2734/W/20/3245778 APP/E2734/W/20/3261729

A1 Motorway Service Area Junction 50 A1M.

Applicant: Moto Hospitality Ltd

Report for Planning Inspector

NEED

1. Moto Hospitality Ltd have not demonstrated that the need for an MSA on this site has increased between 2011 (previous application refused at appeal) and the present day.

2. In the event of extra need being substantiated the following have taken place.

a. In 2012 Leeming Bar Road Services was formally given permission to become a Motorway Services Area.

b. In 2014 this site was sold to Moto Hospitality Ltd who quoted at the time “ Leeming Bar is an excellent location and we expect to increase the number of jobs on this site significantly over the years.” (Northern Echo 5/2/2014.)

c. Exelby Services at its Coneygarth site received approval on 24/5/2019 for 50 extra HGV spaces with increased facilities (showers, toilets, fuel)

3. The above approvals since 2011 suggest that the possibility of an oversupply of MSA provision, if this site is approved, is a realistic possibility.

LOCATION

4. The proposed site is on Grade 2 Agricultural Land in open countryside and plans by Moto Hospitality showing an attempt to screen the site (as per DWaG report Harrogate Council Landscaping) would in itself have a serious impact on the site and not achieve any improvement in screening.

5. As a regular user of the 2 roundabouts and bridge at Junction 50 I feel that the access and egress points to the site can only exasperate the problems of an already very busy junction.

CONCLUSION

6.This planning appeal should be refused for the following reasons:-

a. The detrimental effect on the landscape (Harrogate Borough Council DRaW report leading to refusal 9/10/2020). Especially as this application is contrary to Harrogate District Council Local Plan policies EC3 (A&C), GS3 and NE4.

b. Risk of creating an “over supply” of MSA provision ( approvals already granted since previous refusal 2011) resulting in a redundant brown field site on open grade 2 Agricultural Land.

I totally agree with Harrogate Borough Council Planning Committee reasons for refusal of this planning application.

As a former member of Harrogate Borough Council for many years, I have been heavily involved with these applications which have been refused on sound planning grounds at committee and appeal level since 2011. Harrogate Council now has a Local Plan which is quoted in their refusal notice which resulted in this appeal. The Planning Committee members supported the recommendations of the Planning Officers to refuse this application on the grounds of conflict with Landscape Policies EC3 (A&C), GS3 and NE4 of the Local Plan.

This appeal should once again be refused.

Christopher Brown M.B.E

Alderman Harrogate Borough.

North End Farm,

Baldersby,

Thirsk. YO7 4PN