The more detailed issues which this plan needs to address, listed in paragraph 2.11, do not accurately reflect the key strategic challenges for Ipswich identified at paragraph 5.31 of the focused review Core Strategy. Those strategic challenges 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 (recognised at paragraphs 5.46 - 5.48 of the draft Site Allocations DPD and consistent with the advice at paragraphs 8.146 - 8.147 and Policies CS17 and DM25 of the CSFR).

Given that the Core Strategy seeks to focus the provision of a significant number of Ipswich's new homes within central Ipswich (CSFR 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 Site Allocations DPD should identify is the need for these (sometimes competing) requirements to be sensitively addressed and balanced.

ABP supports the safeguarding of the defined Employment Areas identified in Policy DM36 including, particularly, its land within the Ipswich Port estate at the West Bank (9) and Cliff Quay (12). In respect of this policy:

i) The reference numbers provided for each area do not appear to link to a specific identified annotation on the policies map. We request that the policies map should be amended and annotated accordingly to identify these Employment Areas; 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 this context, the existence of these consents/licences and the activities they permit should be acknowledged in the DPD and in appropriate other policies and allocations where the DPD addresses potential new development in the vicinity.

ABP supports the allocation of Site IP037 - Island Site for housing as part of a mixed use development. However, the proportional split of uses set out in the policy can only, given the nascent proposals for the site, be aspirational. 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. This should be properly reflected in Policy DM39 and in the Opportunity Area development principles and guidelines in Part C of the draft DPD.

A critical challenge to realise successful redevelopment of the Island Site, given the significant development costs on this site, will be viability. The high proportion of 'open space' use and low indicative development capacity for homes, which is at the lower end of the Policy DM30a range and 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, the requirement at paragraph 5.8 for the proportion of housing to be within + or -5% of the proportion indicated in the policy is onerous and, in our opinion, may prejudice or even preclude redevelopment. ABP would instead request that this wording is amended to acknowledge that changes may be agreed to these proportions if accepted as part of the preparation of a master plan or planning application.

ABP supports the allocation of Site IP037 - Island Site for housing as part of a mixed use development. However, the proportional split of uses set out in the policy can only, given the nascent proposals for the site, be aspirational. 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. This should be properly reflected in Policy DM39 and in the Opportunity Area development principles and guidelines in Part C of the draft DPD.

A critical challenge to realise successful redevelopment of the Island Site, given the significant development costs on this site, will be viability. The high proportion of 'open space' use and low indicative development capacity for homes, which is at the lower end of the Policy DM30a range and 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, the requirement at paragraph 5.8 for the proportion of housing to be within + or -5% of the proportion indicated in the policy is onerous and, in our opinion, may prejudice or even preclude redevelopment. ABP would instead request that this wording is amended to acknowledge that changes may be agreed to these proportions if accepted as part of the preparation of a master plan or planning application.

ABP supports the allocation of Site IP262 and the wording of the site allocation details. The site (which totals c 5.6ha in area, some of which is in Babergh DC's adjoining administrative area) is in the ownership of ABP and adjoins the Power Station Berth which has the benefit of a licence allowing the handling of explosive materials under the Dangerous Substances in Harbour Areas Regulations 1987 and consents to both ABP and Origin under the Planning (Hazardous Substances) Act 1990 and the Planning (Hazardous Substances) Regulations 1992 for the handling of ammonium nitrate fertiliser. ABP welcomes the identification of the site for port-related uses (which are not defined or limited in the DPD). As the full extent of the site intended for port-related use is split by the Borough boundary, a note referencing this adjoining area would be beneficial in aiding understanding of the full extent of the area capable of development (not least given the proximity of the Orwell Country Park SSSI and Nature Reserve).

ABP supports the allocation of Site IP262 and the wording of the site allocation details. The site (which totals c 5.6ha in area, some of which is in Babergh DC's adjoining administrative area) is in the ownership of ABP and adjoins the Power Station Berth which has the benefit of a licence allowing the handling of explosive materials under the Dangerous Substances in Harbour Areas Regulations 1987 and consents to both ABP and Origin under the Planning (Hazardous Substances) Act 1990 and the Planning (Hazardous Substances) Regulations 1992 for the handling of ammonium nitrate fertiliser. ABP welcomes the identification of the site for port-related uses (which are not defined or limited in the DPD). As the full extent of the site intended for port-related use is split by the Borough boundary, a note referencing this adjoining area would be beneficial in aiding understanding of the full extent of the area capable of development (not least given the proximity of the Orwell Country Park SSSI and Nature Reserve).

ABP supports the allocation of the Island Site in the draft DPD.

ABP supports the allocation of Site IP037 - Island Site for employment as part of a mixed use development. However, the proportional split of uses set out in the policy can only, given the nascent proposals for the site, be aspirational. 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. This should be properly reflected in Policy DM42 and in the Opportunity Area development principles and guidelines in Part C of the draft DPD.

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.

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 at paragraphs 5.46 - 5.48 of the draft Site Allocations DPD and at paragraphs 8.146 - 8.147 and Policies CS17 and DM25 of the CSFR and is 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 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 requests that recognition is made in Policy DM52 and its accompanying text to the Port and to other important existing employment activity within and adjoining the Waterfront area which the Council wishes to safeguard and support. New development in the Waterfront should, therefore, be sensitive to these existing uses and avoid potential impacts which may prejudice the continued operation and, where appropriate, expansion of these uses.