There is countless metadata'd photographic evidence available from local residents to the planning officers for them to see if there are species listed, using the proposed areas as functional land. This then should trigger the commissioning of an independent HRA .
5.11 Fails to identify the residents of areas within the 2.5km zone as active walking users of the SPC/SAC areas. It is not factual to only identify those resident within 400m in this group. At least 50% of the population of Burley-in-Wharfedale, for example, will have walked from home to the moors.
5.14 Out-of-date references.
5.15,16,17,18,19: Visitor data is now 3years old and extremely unreflective of current usage.
5.21: Table 3 correctly identifies numerous impacts on the SPC/SAC areas, which should be divided into those that cannot be policed & those that can. If there is a high level of risk, development should not be given permission, regardless of mitigation.