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Both terms "Strategy" and "Plan" are commonly used across following processes of the Automotive SPICE 3.1 PAM:
SYS.4 System Integration and Integration Test
SYS.5 System Qualification Test
SWE.4 Software Unit Verification
SWE.5 Software Integration and Integration Test
SWE.6 Software Qualification Test
SUP.1 Quality Assurance
SUP.8 Configuration Management
SUP.9 Problem Resolution Management
SUP.10 Change Request Management
The following figure shows the general relationship between strategy and plan in any of these processes.
Figure D.7— Strategy and plan
Each of these processes requires the development of a process-specific strategy. The strategy always corresponds to a process-specific "Plan". For each process-specific "Plan" there are process- specific work product characteristics defined (e.g. "08-52 Test Plan", "08-04 Configuration Management Plan").
Capability Level 2 or higher:
Each process-specific "Plan" (WP 08-nn) inherits the work product characteristics represented by the Generic Plan (WP 08-00). This means that for a process-specific "Plan" both the process-specific characteristics (WP 08-nn) and the generic characteristics (WP 08-00) apply.

Plan
Generic plan
WP 08-00
CL >= 2
CL = 1
Process specific plan
WP 08-nn
BP1:
Develop Strategy