This is a guide to submitting an effective objection to the Supplementary Planning Document (SPD) for the Land East of Gamston and North of Tollerton. It focuses on Contamination and Human Health Risk, which is a key Material Planning Consideration.
Scroll down for the ‘How to structure your objection’ guide!
Why Contamination Matters
The site of the former RAF Tollerton has a documented history of hazardous contamination. Soil surveys and historical records confirm the presence of substances that pose serious risks to human health, water quality, and ecological integrity.
These include:
PAHs (linked to cancer and cardiovascular disease)
PFOS and PFOA (PFAS “forever chemicals” with no safe exposure level)
Radium-226 (radioactive for thousands of years, causes bone cancer)
Suspected asbestos (linked to mesothelioma)
Lead and arsenic (toxic heavy metals)
These contaminants are dangerous when disturbed, and development without proper assessment and remediation could expose future residents, construction workers, and wildlife to unacceptable risks. If you would like to know more about contaminations on the former RAF Tollerton, please click here.
Concerns with the SPD
The SPD fails to address the serious contamination risks associated with development on the airfield. There is:
- No site-wide contamination survey
- No remediation strategy
- No reference to known contamination reports
- No SEPA-standard radiation testing
- No protection for future residents or ecosystems
How to Structure Your Objection
Use your own words, but try to include the following elements:
1. Quote the SPD
Refer to Section 3.23 (p31), which states:
“Due to the current and historic uses of the site there is the potential for land contamination… Any potential risks… must be robustly assessed… before any excavations…”
2. Highlight the Gaps
Explain that the SPD lacks:
A full contamination survey across the entire site
A remediation and containment strategy
Reference to known contamination reports
SEPA-standard radiation testing
Health risk assessments for future residents
3. Explain the Risks
Say why this matters:
- Exposure to carcinogenic and toxic substances
- Risk to construction workers and future residents
- Contamination of watercourses and ecosystems
- Legal liability for failure to assess and mitigate risks
4. Refer to Planning Policy and Law
Mention:
National Planning Policy Framework (NPPF) Paragraphs 183–185 (land contamination and pollution)
Environmental Protection Act 1990 (Part IIA – contaminated land)
Control of Substances Hazardous to Health Regulations 2002 (COSHH)
Construction (Design and Management) Regulations 2015
Health and Safety at Work Act 1974
5. Request Specific Changes
You could ask for:
- A full contamination survey including PFAS, radium, asbestos, and heavy metals
- SEPA-standard radiation testing and public disclosure of results
- A detailed remediation and containment plan
- A condition that no planning approval be granted until contamination risks are fully assessed and mitigated
Example Phrases for Reference
Please do adapt these into your own words:
“The SPD fails to acknowledge confirmed contamination including PFAS, radium, and PAHs, posing serious risks to human health.”
“Planning approval should be conditional on full site-wide contamination surveys and remediation plans.”
“The SPD does not meet NPPF requirements for assessing and mitigating land contamination.”
“Radium-226 requires SEPA-standard testing and containment — this is not addressed in the SPD.”
Where to Send Your Objection:
Send your comments to Rushcliffe Borough Council at: localdevelopment@rushcliffe.gov.uk