Publication Draft

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.

It is also impossible to state, to comply with the statutory tests of soundness outlined at paragraph 182 of NPPF, that the Plan meets objectively assessed infrastructure requirements arising from the strategy, consistent with the principles of sustainable development. Therefore the Plan is unsound on this basis.
In fact, despite the work undertaken through WSTA to date, the potential of, and impacts of, sustainable transport measures, has still not been undertaken. This is made clear by the recommendations of WSTA Phases 3 and 4. Stagecoach Midlands notes, too, that WCC 's specialist consultants conclude at page 7 of WSTA phase 4, that "it is critical that sustainable transport improvements form part of the mitigation package for housing and employment growth proposals...". The Company also note that the phase 4 report finds at section 1.6 on p 6. that "in areas where the most severe increases (in delay) occur appear to be in regions where there is potential to further optimise the proposed mitigations to overcome the issues." In other words, the reasonable alternatives, merely to accommodate the plan strategy, have not yet been defined fully, nor optimised or tested sufficiently robustly to allow a reasonable examination to conclude that the Plan represents the most appropriate strategy when considered against reasonable alternatives, based on proportionate evidence. The Plan is therefore unsound for this reason.
Without having a suitable evidential base, nor a rigorously defined transport strategy to prevent unmitigated impacts becoming severe, it is no surprise that the IDP does not comprise a suite of schemes that holistically and demonstrably achieve the mitigations required, and are equally evidentially supported as being deliverable. The Plan makes absolutely no provision for bus priority schemes needed to address the clear serious deterioration in peak traffic conditions that WSTA makes clear will arise. Not is there any evidence on the siting and operation of Park and Ride facilities, such that their effectiveness and viability can be evaluated. Indeed the failure even to allocate a site for a Park and Ride to the south of Leamington and Warwick, on the basis of its optimum impact and commercial viability is evidence that this element of the Plan strategy is little more than a concept, rather than a commitment to deliver an effective mitigation intervention.
Stagecoach notes that, despite representations to WCC and WDC over many years, the scope for a Park and Ride north of Leamington, where provision of the required bus capacity already exists taking advantage of the existing "Unibus" corridor, and along which demand would be expressed contra-flow to the student peak, has not even been considered.

Without measures to mitigate transport-related development impacts being tested for cost and effectiveness, and then defined in the Plan and the IDP, Stagecoach is quite clear that there can be no effective means of the LPA of Highways Authorities securing the required developer funding, compliant with CIL Regulation 122, to effect their delivery. Thus the Plan cannot be considered either positively planned or effective, and thus must be considered unsound.

Despite evidence previously given that this site cannot, by virtue of its location, be effectively served by public transport owing to its severance from the main bus network and its peripherality, it has nevertheless been included as a draft allocation.

The allocation is contrary to NPPF paragraph 14 being a fundamentally unsustainable location that cannot be made sustainable. It can only be wholly dependent on personal car use, with perhaps, some limited scope for cycling.