Proposed Submission Site Allocations and Policies (incorporating IP-One Area Action Plan) Development Plan Document

ABP supports the allocation of Site IP037 - Island Site for housing as part of a mixed use development. Given the nascent proposals for the site, the notional housing capacity set out in the policy can only be indicative at this stage, although it is below ABP's expectations. ABP welcomes the recognition in the Policy that the precise split should be a matter for a future master plan and/or planning application. 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.

A critical challenge to realise successful redevelopment of the Island Site, given the significant development costs on this site, will be viability (which is recognized at paragraph 2.11 as one of the more detailed issues emerging from the evidence which this plan needs to address). The low indicative development capacity for homes, which is at the lower end of the Policy DM30a range and high proportion of 'open space' use (proposed under Policy SP6) is significantly lower than in previous iterations of the IP-One AAP, has not been informed by a detailed study and does not take account of any viability considerations. In this context, ABP welcomes the wording at paragraph 4.8 which recognizes that the figures given in Policy SP2 are indicative to help ensure that developments can be viably delivered.

ABP supports the allocation of Site IP037 - Island Site for employment as part of a mixed use development. Given the nascent proposals for the site, the notional area/split set out in the policy can only be indicative at this stage. ABP welcomes the recognition in the Policy that the precise split should be a matter for a future master plan. 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. ABP welcomes the retention of boat related uses including boat building in the wording of Policy SP5 and the wording at paragraph 4.32 which recognizes that the figures given in Policy SP2 are indicative to help ensure that developments can be viably delivered.

Site IP037 - Island Site is situated within the Wet Dock area - part of an existing 'blue network' which provides an attractive waterfront area with public access for the town. The requirement, therefore, that 15% of the development area of the Island Site should be reserved for open space uses is excessive and ignores the amenity function that the water area plays. On this basis, and notwithstanding its support for the allocation of Site IP037, ABP requests amendment to the wording of the policy to allow for a lesser amount of open space in the proportional split of acceptable uses where a master plan or the preparation of more detailed proposals show this is appropriate and expedient.

ABP supports the overall site allocation but requests amendment to the wording of the policy to allow for a lesser amount of open space in the proportional split of acceptable uses where a master plan or the preparation of more detailed proposals show this is appropriate and expedient.

Redevelopment of Site IP037 - 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.

Nevertheless, 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). ABP is content, therefore with the wording in Policy SP9 that the development layout should not prejudice future provision of a Wet Dock Crossing, provided that this does not ignore that the critical challenge to realising successful redevelopment of the Island Site will be viability (which is recognized at paragraph 2.11 as one of the more detailed issues emerging from the evidence which this plan needs to address).

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.

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 therefore welcomes the recognition given at paragraph 5.20 (in support of Policy SP11) to the need for new development to take account of the Port's operational needs given its situation within and adjacent to the Waterfront.

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 Policy SP16 and paragraph 5.46.

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 identification of the Island Site as an opportunity area, and generally supports the points set out under 'Development Opportunities' and 'Development Principles'. However, ABP requests the removal of reference to "lower rise development" in the supporting text and to "generally low to medium rise development (3, 4 and 5 storeys)" to allow more flexibility in the development of a viable scheme capable of addressing the particular development costs on this site. ABP also requests the removal of "(max 50%)" against the residential reference, allowing a more flexible proportion of acceptable uses.