There is no evidence that a strategy has been evaluated that seeks to achieve sustainable development through locating and designing development to deliver and take advantage of a step change in the quality and availability of sustainable travel modes, and public transport in particular. No attempt has been made to examine or define the kinds of public-transport- focused schemes, including bus priority, that would significantly boost the quality, efficiency and attractiveness of bus services, thus damping both existing demand on the local and strategic highways network, and achieving a significantly higher mode share for bus services, necessary to mitigate the impacts of additional traffic, especially south of the urban area.
In fact, modelling undertaken to date by Warwickshire County Council (WCC) within the Warwick Strategic Transport Assessment (WSTA) has assumed current bus mode shares, given that S-PARAMICS cannot model mode shift or dynamically reassign journeys between modes. Even now, over 2 years after the initial modelling was undertaken, the scope of studies has not been broadened to look at alternative approaches, or mitigation strategies, where sustainable modes including public transport, are the focus of measures aimed at achieving much higher mode shares both from new development, and for the existing and forecast travel demands from the current baseline population.

There has been no consistent or meaningful attempt to engage, on WDCs part, with Stagecoach Midlands as the area's leading local public transport operator, to allow the plan strategy to be shaped with a sufficiently broad and deep view of the opportunities to deliver development where public transport can credibly provide for a much greater proportion of travel requirements than today.
This is contrary to the requirements of NPPF which demands that Plans are positively prepared with a duty to co-operate, not only with neighbouring authorities, but "private sector organisations". As the vast majority of local public transport is commercially provided by Stagecoach Midlands, advice as to the appropriateness, effectiveness and deliverability of matters relating to developing and improving bus services to support the overarching LP strategy, or specific development allocations and proposals, could only, credibly, be supplied by ourselves. To the extent that we have provided, on our own initiative, such advice as part of duly-made representations at previous stages in plan-making, Stagecoach Midlands sees no evidence whatever that this input has been used to improve the draft plan.
Planning Authorities recognise their duties to liaise with infrastructure providers in the private sector to inform plan-making. This is particularly true for utilities. We submit that commercial bus operators in particular could reasonably be viewed as being scarcely less important in terms of informing the LPA of the constraints and opportunities presented to the land-use strategy by the existing and potential development of the commercial bus network, and thus take advantage of the opportunities for sustainable transport required by NPPF paragraph 34 and 35. To the extent the draft Plan does not take such opportunities, it is inconsistent with NPPF and is therefore unsound for this reason.
A plan based on maximising the use of sustainable transport modes, including public transport, has not been evaluated sufficiently, if it has even been considered at all. The opportunities that such a strategy may offer to cost-effectively limit the costs of the overall mitigation package has not been explored, consulted upon or tested. Thus the Plan cannot be in conformity with NPPF paragraph 32 which requires that the strategy takes opportunities to cost-effectively mitigate the highways impacts of development.