28 May 2020 SN/ALCJ50A1M/180520 Mr M Parkes Stuart Nicholls E: [email protected] Principal Planner DL: +44 (0) 1732 879 060 Place Shaping and Economic Growth Harrogate Borough Council 23 Kings Hill Avenue PO Box 787 West Malling ME19 4UA Harrogate T: +44 (0) 1732 879 050 HG1 9RW F: +44 (0) 1732 879 051 savills.com Dear Mr Parkes, APPLICATION REFERENCE: 18/02713/EIAMAJ - PROPOSED DEVELOPMENT OF A MOTORWAY SERVICE AREA (MSA) AT JUNCTION 50 OF THE A1(M), HUTTON CONYERS, NORTH YORKSHIRE Further to the report dated 20th April 2020 (ref 2761-01/NDR), submitted on behalf of Applegreen PLC, by Axis PED Ltd (“the Axis report”), in respect of the above planning application, the review undertaken by Alastair Field has overlooked key relevant points and provides misleading evidence to support the review. The soil survey was undertaken by Daniel Baird MSc. M.I Soil Sci., a director of Daniel Baird Soil Consultancy Limited. Daniel has over 25 years of relevant experience in the soil and land surveying sector and is a full member of the British Society of Soil Scientists, the category open only to soil scientists and other professionals with a minimum of 5 years track-record in soil science research or application. Daniel has significant experience undertaking Agricultural Land Classification surveys, including a period working for ADAS, undertaking Soil and Land Resources Surveys for MAFF Land Use Planning, of which said surveys are made reference to in the Axis report. MAFF ALC Surveys Figures 1a and 1b within the Axis report do not correspond with the nationally available public resource, as published on Magic Maps (see Appendix 1). Figure 1a, from the Axis report, appears to have a cartographic error (north and east of Northlands Farm). Figure 1b, from the Axis report, includes a section of mapping that is not published on the national resource; north of junction 49 through to Carthorpe, including the site of the planning application (see Appendix 2). A small section at Ainderby Quernhow was subject to an ALC site survey, undertaken in January 1994 by ADAS Offices and associates throughout the Americas, Europe, Asia Pacific, Africa and the Middle East. Savills (UK) Limited. Chartered Surveyors. Regulated by RICS. A subsidiary of Savills plc. Registered in England No. 2605138. Registered office: 33 Margaret Street, London, W1G 0JD for MAFF (job number 006\94) and is mapped on the national resource. However, Axis figure 1b does not accurately reflect this (see Appendix 3). From correspondence with Natural England, they hold no record of any MAFF site survey work or desktop assessments, for the section from junction 49 through to Carthorpe and therefore reference to the MAFF ALC Surveys within the Axis report should be disregarded. Within the publically available resource, the site has not previously been surveyed by MAFF and it is not possible to draw conclusions about areas of land adjacent to the site. Furthermore, the site was previously surveyed in 2010 and this survey was not consistent with that presented in figure 1b of the Axis report. Figure 1b, of the Axis report, shows a margin of Grade 2 down the eastern edge of the site, whereas in the 2010 report this is shown as Grade 3a. Natural England did not flag up a discrepancy between the 2010 findings when consulted on this survey and what is suggested, as MAFF site assessments, in the Axis report. It is likely that Natural England would have commented on a variation between the grading of the site should the Axis report data have been available in the public resource. For the plans in the Axis report to be considered, the sources should be cited and the plans should identify those where a site assessment was undertaken and that only of a desktop appraisal. Agricultural Land Classification Within the Axis report, reference is made to the MAFF survey findings in the Walshford to Dishford section of the A1(M) surveys. The closest point of this section is over 3km south of the proposed site and is therefore not relevant to the survey. These comments should therefore be disregarded. The Axis report makes reference to a site survey undertaken in 2010. From a review of the Agricultural Resources chapter, submitted as part of the 2010 planning application, there is no reference to large stones in the topsoil as a limiting factor. A significant large stone content was found on site, which limited the grade to 3b in some instances. The presence of several areas of increased stoniness places a limitation of the versatility of a wider area. This is not addressed in the Axis report. (See Appendix 4) Specifically addressing comments made in the report, the uniform classification of subgrade 3b was given due to pattern limitation on the site. This is not considered within the Axis report. A pattern limitation exists where soil and site conditions vary significantly and repeatedly over short distances and impose a practical constraint on cropping and land management. The effect on grading is judged according to the severity of the limitations imposed on cropping and management and is supported by ALC guidelines. 2 The report raises concerns regarding the calculation of droughtiness. An allowance is made for additional soil material below the depth that can be reached by auger and where the soil is shallow, a single auger boring is not relied upon. Some points were found to be Grade 4 in isolation in this approach but based on surrounding land, were raised to 3b. Conclusion In conclusion, the report provided by Axis contains both inaccurate and uncited material, which cannot therefore be considered in light of this application. The site appears to have only been surveyed once previously and there are concerns regarding the approach to top soil stoniness limitations within this survey. Furthermore the Axis report does not consider a pattern limitation for the site, the key limitation for a unilateral grade for the site, nor does it consider stone content in the top soil. The assessment provided by Moto includes field data and notes the significant presence of large stones in the topsoil. Neither of the previous assessments that the Axis report relies upon provide field data, with the A1(M) corridor work appearing to be a desktop assessment of unknown origin and the 2010 survey did not note the presence of significant large stones in the top soil. The surveys undertaken in 2018 and 2020 identified the site as Grade 3b land, non-best and most versatile and we do not consider it necessary to review the position in regards to the agricultural land classification of the site. Yours sincerely Stuart Nicholls Associate Food & Farming 3 Appendix 1 Figure 1a - Post 1988 Agricultural Land Classification (England) Wetherby to Husingore from MAFF Field Assessment data held by Natural England 4 Figure 1b - Post 1988 Agricultural Land Classification (England) Husingore to Arkendale from MAFF Field Assessment data held by Natural England 5 Figure 1c - Post 1988 Agricultural Land Classification (England) Arkendale to Kirby Hill from MAFF Field Assessment data held by Natural England 6 Figure 1d - Post 1988 Agricultural Land Classification (England) Kirby Hill to Junction 50 A1(M) from MAFF Field Assessment data held by Natural England 7 Figure 1e - Post 1988 Agricultural Land Classification (England) Junction 50 A1(M) to Sinderby from MAFF Field Assessment data held by Natural England 8 Figure 1f - Post 1988 Agricultural Land Classification (England) Sinderby to Leeming from MAFF Field Assessment data held by Natural England 9 Appendix 2 Figure 2a Figure 2b Extract from Axis report figure 1b Published A1(M) Extract from Figure 1d - Post 1988 Agricultural Land Agricultural Land Classification – uncited source Classification (England) Kirby Hill to Junction 50 A1(M) from MAFF Field Assessment data held by Natural England Figure 2a highlights the uncited survey work in the Axis report, compared to the nationally available resource. 10 Appendix 3 Figure 3a Figure 3b Extract from Axis report figure 1b Published A1(M) Extract from Figure 1e Post 1988 Agricultural Land Agricultural Land Classification – uncited source Classification (England) Junction 50 A1(M) to Sinderby from MAFF Field Assessment data held by Natural England Figure 3a highlights the mapping error within the uncited survey work in the Axis report, compared to the nationally available resource. 11 Appendix 4 Figure 4a Figure 4b Prominent and common areas with significant large stone content found on the site. For reference the auger head is 20cm long. 12 .