What you seem to be saying,
niknak, is that the airspace is not justified now and it is only on NIA's expectation (and not actual fact) that the application is being pursued. Moreover it seems to be going ahead in its present form only because it would be too much work for it to be changed to suit actual and perhaps more realistic requirements.
My opinion is that an airfield the size of Norwich might find it nice to have a Class D CTR/CTA the size proposed but it really is not necessary. Considering other "stakeholders", it would actually be perfectly adequate to simply safeguard the IAP lanes with a much narrower CTR along the extended runway centrelines within the vertical limits proposed - perhaps with something more the shape of a MATZ - leaving much more Class G unaffected by the CAS "grab". Furthermore, I see absolutely no reason to have such a large CTA, with its base extending at the ridiculously low level of 1500' all the way out to 13nm from the ARP.
I speak with experience in both commercial aviation and GA and I have to say, in summary, that I do not see the proposal as being reasonable, given either the traffic density expected or the IFR routings required.
JD