The IP-One Area contains the greatest concentration of heritage assets within the town (both designated and non-designated) and is a location that requires both conservation and change. We welcome the amendments to part (e) of Policy CS3 that requires the AAP to have policies that identify heritage assets which development proposals will need to have regard to. We note part (c) which provides a strong policy link to the Opportunity Areas contained within the AAP. It will be important that these opportunity areas contain adequate development principles relating to the historic environment (see separate representations).

The Port of Ipswich provides an extensive range of facilities to meet the needs of businesses and industry based in Norfolk and Suffolk. It is the UK's leading grain exporter and largest of ABP's short-sea ports handling containers, dry bulks, forest products, general cargo and offering extensive roll-on roll-off facilities. The total port area (including water) is approximately 275 acres (111 ha) and the Port handles approximately two million tonnes of goods per year. The Port is rail connected and can offer intermodal services from the port to inland facilities including rail terminals such as ABP's own Hams Hall Railfreight Terminal in the Midlands. The Port is also the base for expanding Marina activities. Together with ABP's other East Anglian Ports at Kings Lynn and Lowestoft, the Port contributes some £241m directly into the regional economy and supports 3,577 jobs in the area.

The key strategic challenges for Ipswich identified at paragraph 5.25 of the Core Strategy and Policies DPD Review emphasise the need to manage and gain best benefit from further significant growth in all its forms. This is not restricted to housing - it includes economic activity - including the 'significant role' of the Port which can drive further growth in the region through future expansion (consistent with the Port's recognition in the NALEP Strategic Economic Plan and at paragraphs 5.6, 6.19 and 9.153 - 9.154 of the Core Strategy and Policies DPD Review).

Given that the Core Strategy seeks to focus the provision of a significant number of Ipswich's new homes within central Ipswich (paragraph 6.17), and that important elements of the Port are within or adjacent to central Ipswich, one of the more detailed issues that the Core Strategy and Policies DPD Review should identify is the need for these (sometimes competing) requirements to be sensitively addressed and balanced. This is the context in which ABP's representations are made.

ABP supports the objectives for the IP-One area and the preparation of an area action plan incorporated into the Site Allocations and Policies development plan document to guide its delivery. There are, however, important elements of the Port within or adjacent to this area. New development should, therefore, have regard to these existing uses and activities so as to ensure that these uses (where they are "appropriately located" consistent with the key strategic challenges for Ipswich identified at paragraph 5.25) are protected.

The Port of Ipswich is situated both within and immediately adjoining the Waterfront area of IP-One. As well as maintaining its operational activities, ABP is concerned to ensure that it retains the right and ability to fully use its land and infrastructure for port purposes in the performance of its statutory duties and responsibilities as a harbour undertaking. The importance of the Port continuing to flourish as a major economic driver in the sub-region is recognised in the NALEP Strategic Economic Plan and at paragraphs 5.6, 6.19 and 9.153 - 9.154 of the Core Strategy and Policies DPD Review (consistent with the advice in the Ports NPS).

The Port's infrastructure includes quay and dockside facilities, accommodation, locks, navigation rights and private vehicle rights over roads within the Wet Dock/Waterfront area, routes over Orwell Quay and passing Eagle Quay and Gasworks Quay, the railhead into the West Bank Terminal at Griffin Quay, and relatively direct road access to the trunk road network (A12 and A14). It also includes rights granted to ABP and to occupiers on the port estate under both the Dangerous Substances in Harbour Areas Regulations 1987 to handle and store explosive substances at Ro-Ro Berths 1 and 2 on the West Bank and at the Power Station Berth on Cliff Quay, and the Planning (Hazardous Substances) Act 1990 to handle and store hazardous substances (including ammonium nitrate fertilizer) at Cliff Quay and in the area around the former Vopak Terminal.

The Island Site presently accommodates successful high profile marine businesses (including Fairline Boats Ltd and Spirit Yachts Ltd) and the commercially successful Ipswich Haven Marina (which has contributed significantly to the regeneration of the waterfront area). Accommodating these activities in the future development of the Island Site so that they continue to contribute to an active and appealing waterfront environment for further regeneration will be critical. This should be properly reflected in the wording of Policy CS3 by the inclusion of an additional criterion.

Whilst, therefore, ABP is keen to support the realisation of the wider development objectives and aspirations of the Core Strategy and Policies and Site Allocations DPDs, it must protect its 'significant (economic) role' and ability to expand further and assist in driving growth in the region.

ABP requests that recognition is made in Policy CS3 and its accompanying text to the Port and to other important existing employment and other activities within and adjoining the IP-One area which the Council wishes to safeguard and support. New development should be sensitive to these existing uses and avoid potential impacts which may prejudice the continued operation and, where appropriate, expansion of these uses.

We support the relocation of the two bus stations to a single site (most probably to the Cox Lane/Tacket Street area, in our view), thereby allowing for extension of the Tower Ramparts/Sailmakers centre.

The Conservative Group supports the principle of developing and regenerating the town centre to boost employment in the town. It is important that Ipswich is developed as a successful shopping centre, but it must be recognised that this means that major challenges have to be faced:

(i) The impact of on-line shopping which is growing rapidly.
(ii) Competition from better shopping destinations such as Norwich, Cambridge and even smaller towns such as Bury St Edmunds and Woodbridge.

The retail sector is seen as a high jobs growth sector in Ipswich between 2011 and 2031 in the EEFM. The town centre clearly has an important part to play in this and needs to be re-vitalised through such measures as:

(i) Residential development. Such development as proposed in the Mint Quarter and in DM20 supporting residential use in the Central Shopping Area above ground floor retail use is to be welcomed.
(ii) There is a need to extend car park provision to support shopping and tourism. The erection of electronic signs showing car park capacities would be a small move in the right direction.
(iii) Greater emphasis should be placed on cultural and tourist attractions in or near the town centre e.g. museums, Christchurch Mansion, galleries.
(iv) The proposed retail development at the Westgate site needs to be re-thought. The Central Shopping Area should be redefined omitting the Westgate site and concentrating on links between the town centre and the Waterfront. A simple town trail highlighting items of historic interest could be a simple - and inexpensive start.