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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.