Explanation and justification should be provided for removing the Norwich Policy Area (NPA). This is a long-standing policy tool which has now been omitted and there is no reference to it within the consultation document. We consider that an explanation should be provided as to why it is no longer to be used as this helped to ensure that housing growth took place in sustainable locations focussed around Norwich. It is understood that OAN now has to be calculated across the whole of the plan area but the NPA approach to ensuring that the majority of development for the three Districts takes place in and around the City has been a sound approach to date, ensuring that the majority of development takes place in the most sustainable settlements with good access to jobs and services and reducing the need to travel. The new strategy which includes a significantly higher degree of dispersal to smaller settlements outside of the old NPA has not been adequately explained or justified.

If it is the case that the Strategic Growth Area effectively replaces the NPA then the plan should ensure that new allocations are focussed within that area, particularly the Cambridge Norwich Tech corridor part of it. A significant proportion of new allocations, particularly in South Norfolk towns and yet to be identified small rural villages are proposed outside of the Strategic Growth Area which conflicts with the main vision and aims of the plan.