Section 2.
You state that new housing and economic growth need to be considered together but you have not done this for the JT2 Alternative, a "Credible " Alternative to the wildly aspirational JT1. In fact JT1 is taken as a given in the SHMA doc and JT2 is not tested. JT2 is unlikely to have JT1s "significant negative effects" on the SA. Consequently all the test options are based on JT1.(7.3.21).
I object to the denigration of JT2 as "business as usual" as it exceeds the current strong growth trends.
Further baseline comment is that you require to deduct windfall from your baseline and not ignore it or use it as additional delivery buffer- see section 7, 7.3.4.

Section 6.
Page 24. Higher release does not equal higher delivery as national builders and speculators will simply land bank to maintain prices.
Strategic transport improvements require to be assessed in the SA due to cumulative impact, particularly the NWL that is dependent on west/north west GNLP growth model - See WSP stakeholder Consultation on behalf of NCC.

Section 7.
7.3.4. Windfall housing requires to form part of the baseline calculation as 5,600 is a "reliable figure". Even using JT1 inspired OAN the arithmetic should be 39,486-5,600 = 33,886 (30,658 for 2017-36).
7.39. Contrary to what you say, there is justification for lower the OAN.
A) use the JT2 input in SHMA. B) there are constraints (7.3.8) on JT1 based OAN ie the significant negative effects in the SA. Otherwise why produce an SA.
7,3.13. NPPF (para 4) can also mean that you adjust downwardly should the gung ho aspirational development of JT1 prove wide of the mark, very likely due to an automation transition period concurrent with the Plan period. You do not consider this factor. A hand on tiller approach based on JT2 is better as it is easier to step up rather than down.

Section 8.
8.3.4. The overarching transport policy is not neutral as A) you ignore cumulative impact, B) you have not quatified carbon abatement costs, C) virtual shelving of all sustainable transport measures in the NDR DCO and NATS. And D) you are actually encouraging greater car reliance (8.3.7).
8.8 CC1 is unfit as it is not based on up to date methodology, does not take account of "the significant and ongoing carbon emissions" from the NDR ( SOS for Transport) and uses weak language - mitigate, proportionate, if practicable etc.
Flooding. The lead flood authority's guidelines were flouted on the food hub LDO treated as reserved matter and not concurrent.
Green infrastructure. Please insert" a safe cycle and walking network, including disabled facilities will be provided between all villages, residential areas and places of work.
Landscape. Norfolk's beauty is understated therefore susceptible to 'just another field' mentality.
Water. We are under severe water stress yet this will be exacerbated possibly to the point of crisis by pursuing the wildly aspirational JT1 while ignoring the credible JT2 Alternative.
Communities. The roads budget will swallow any Cil money, see the overspend on the NDR and the £50million and rising per mile NWL. Thus your growth model will have significant negative effect as there will be no money for community infrastructure, big Society projects or schools improvement.
Monitoring.
There is a lack of historical perspective. There should be a preface on past promises eg on NATS and NDR where £50million should have been spent/allocated for sustainable transport, yet only £1.5 million spent. A review is currently taking place by NCC in breach of the DCO.