The evidence used to select the preferred option for development was factually inaccurate leading to a flawed decision.

Paragraph 1.38

As a point of clarification, the Sports Pitches and indoor sports strategy are not completed, if they are not completed and adopted by the time of the EIP, I would have to consider them unsound as an evidence base.

Re: Strategic Transport Assessment.

The Assessment did not include the fact that there is a river and a railway running through Warwick and Leamington Spa. The only road into Warwick has a river bridge. The assessment shows improvements to a junction just prior to the bridge but does not consider that improving the junction cannot change the number of vehicles using the bridge.

The Assessment also did not include vehicle movements going to and from Schools. These journeys add considerably to the morning traffic figures.

Evidence has not been assessed fully enough at a local level to each recommended site in the plan

This objection relates to the Strategic Transport Assessment evidence document.

With regard to cycling, as part of the SWOT analysis (table 2.1, p.16), it quotes
a "well developed cycling network" as presented as a strength of the area. In section 2.2.24 the document refers to a figure of 3.5% of the population as cycling to work from the 2001 census while also claiming that the "cycle network has been expanded and improved over the last 10-15 years" (section 2.2.22). However, more recent census data from 2011 (http://www.ons.gov.uk/ons/rel/census/2011-census-analysis/cycling-to-work/2011-census-analysis---cycling-to-work.html ) show a decline in the cycling to work percentage from the 3.5% in 2001 to 3.1% for the district.

Thus, in spite of the investment in cycle infrastructure over the last 10 years there has been no corresponding increase in cycling. The 2011 census also shows that in the same timeframe other local authorities have succeeded in increasing these percentages from similar levels over the last 10 years to much higher percentages in 2011. The lack of an increase in cycling in the Warwick District, in spite of the increase in the cycling infrastructure, could be attributed to its poor quality, as identified in a recent study by Cycleways, (http://www.cycleways.org.uk/campaign/review-of-cycling-provision/).
The study shows that much of the problem lies in poor design and in non compliance of planning standards. In addition, one of the most salient features of the STA, in relation to cycling, is the lack of an integrated approach to transport, as identified in Cycleways' Cycle Review (section 7.1.2.).

In conclusion, there is no evidence base to support the claim of a well developed cycling network that encourages more sustainable transport in the district and would be able to mitigate increases in transport from the proposed developments of the Local Plan. Getting the evidence wrong has resulted in a lack of development planning for sustainable transport options and cycling in particular in the Local Plan.

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.

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