Proposed Submission Core Strategy and Policies Development Plan Document Review

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.

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 welcomes and supports the definition of its land at the Port of Ipswich (at the West Bank and Cliff Quay) as existing employment areas defined on the policies map and the protection of this land for employment uses. This is consistent with the Port's recognition in the NALEP Strategic Economic Plan as part of the port and logistics 'underpinning sector' for the regional economy and the recognition given in the DPD Review of the strategic role and importance of the Port of Ipswich (at paragraphs 5.6, 6.19 and 9.153 - 9.154).

ABP supports Policy CS13(b).

ABP supports Policy CS20 and the wording of the DPD at paragraphs 8.207 - 8.214 as it relates to the package of transport measures outlined there.

ABP is aware that the Wet Dock Crossing has been a longstanding aspiration of IBC to provide for through traffic and potentially provide relief from town centre traffic congestion (particularly on the Star Lane Gyratory). Further work is needed to fully assess the feasibility and impact of such a new crossing (to ensure that the design of a Wet Dock Crossing maintains boat access through the lock and navigation along the New Cut) and to identify clear delivery mechanisms available to deliver it. In this context, ABP welcomes the approach taken in the wording of the Core Strategy and Policies DPD Review and to the absence at this time of specific reference to this proposal in Policy CS20.

ABP recognises the desire for a new crossing and will assist the Council in seeking to develop a feasible solution which addresses all safety, security and operational issues and avoids any adverse impact on port operations. In particular, ABP is concerned to ensure that a Wet Dock Crossing:

1) avoids an unacceptable impact on existing vessel access to the Wet Dock via the Lock Pit to the detriment of continued port operations, commercial businesses and the vitality and viability of the Ipswich Haven Marina
2) avoids any adverse impact (e.g. through traffic congestion) on Cliff Road, which is the primary access onto Cliff Quay.
3) avoids a routing which would affect the existing railhead into the West Bank Terminal
4) does not prevent the Port from meeting the stringent security requirements of the International Ship and Port Facility Security Code, and
5) allows for navigation rights along the New Cut

Development of the Island Site will require access improvements but by itself does not require the provision of a Wet Dock Crossing. Redevelopment of the Island Site will most likely require road access from the West, via Mather Way, from the North via Bridge Street and St. Peters Quay and a pedestrian and cycle connection across the Wet Dock lock gates to connect to the town centre and the surrounding area.

These access improvements do not require the provision of a Wet Dock Crossing and, in our opinion, the Wet Dock Crossing is not required to deliver future development in the Waterfront area and the Core Strategy Growth.

ABP recognises, however, that there may be some synergies between the need for improved access to the Island Site and the Council's aspirations for a Wet Dock Crossing. In this context, ABP will support the Council in seeking to develop a feasible solution which addresses all safety, security and operational issues and avoids any adverse impact on port and marine operations.

ABP supports the safeguarding of the defined Employment Areas identified in Policy DM25 including, particularly, its land within the Ipswich Port estate at the West Bank (E9) and Cliff Quay (E12). In respect of this policy:

i) The Port estate comprises a large area of land situated within Ipswich, part of which (the Wet Dock) lies immediately adjacent to the central area and within the IP-One regeneration area where the Core Strategy seeks to focus the provision of a significant number of Ipswich's new homes. The Port operates 24 hours a day and normal port operations involve activities (for example, heavy good vehicle movements and lighting used to create a safe working environment) and intermittent noises (such as audible alarms and ships horns) which can potentially cause disturbance and nuisance to occupiers and residents outside but in close proximity to the port estate; and

ii) Within ABP's estate, a number of consents exist under both the Planning (Hazardous Substances) Act 1990 and the Dangerous Substances in Harbour Areas Regulations 1987. These consents/licences permit the handling and storage of explosive substances at Ro-Ro Berths 1 and 2 on the West Bank and at the Power Station Berth on Cliff Quay, and the handling and storage of hazardous substances including ammonium nitrate fertilizer at Cliff Quay and in the area around the former Vopak Terminal. The effect of these consents/licences is to potentially restrict the types of uses which are appropriate within defined limits of the areas in which these hazardous activities are permitted. These licenses/consents, and the activities they permit, are an important element of the infrastructure and facilities that the Port is able to offer to its customers and which, therefore, ABP would wish to vigorously safeguard.

In the context of the above, ABP welcomes and supports Policy DM25 and the supporting wording at paragraphs 9.153 and 9.154.

Whilst Policy DM25 will serve to safeguard existing employment areas, it is important that care is exercised when development proposals are brought forward in the vicinity of these areas (consistent, perhaps, with other policies of the DPD) to ensure that this new development does not prejudice existing employment uses and business operations which are "appropriately located" (consistent with the key strategic challenges for Ipswich identified at paragraph 5.25). ABP requests, therefore, that the local planning authority does not apply the policies of the Core Strategy and Policies DPD Review uncritically and in isolation in exercising its development control functions.

Support for Policy DM25.