HEALTHCARE
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 Healthcare provision, which is a key Material Planning Consideration.
Scroll down for the ‘How to structure your objection’ guide!
Why Healthcare Provision Matters
A development of 4,000 dwellings will generate approximately 9,200 new residents. According to British Medical Association (BMA) guidance, this would require:
5.4 Whole Time Equivalent (WTE) GPs
4 WTE clinical staff
10.6 non-clinical staff
2 WTE additional roles staff (e.g. physiotherapist, mental health, social prescriber)
40 car parking spaces
A building of 954m2 over two floors, built to NHS standards (HBN11-01, BREEAM Excellent)
Concerns with the SPD
The SPD mentions a GP surgery but fails to provide a viable or deliverable plan. Key concerns include:
No defined location: The SPD vaguely places the surgery on Vistry land, but Vistry’s own planning application denies the need for a GP practice.
No delivery model: There is no clarity on who will fund, build, or operate the facility—RBC, developers, NHS England, or a private GP LLP.
No NHS contract: There is no evidence of engagement with NHS England, the BMA, or the Integrated Care Board (ICB) to secure a contract.
No business case: GP practices are private businesses contracted to the NHS. A robust business case is required before NHS England will approve a new practice.
No contaminated land strategy: NHS buildings must meet BREEAM standards. Contaminated land would prevent certification and approval.
How to Structure Your Objection
Use your own words, but try to include the following elements:
1. Quote the SPD
Refer to section 5.2 (pages 81 and 82) that mentions healthcare provision and the GP surgery.
2. Highlight the Gaps
Explain that the SPD lacks:
A defined site and delivery model
Engagement with NHS England or the ICB
A business case or contract for a GP practice
A contaminated land strategy to meet BREEAM standards
A pharmacy licensing and delivery plan
3. Explain the Risks
Say why this matters:
The healthcare facility may never be built
Residents may be left without access to GP services
The SPD is not deliverable or legally compliant
4. Refer to Planning Policy
Mention:
- NPPF Paragraph 93 (promoting healthy communities)
- Rushcliffe Local Plan Policies GP1 and GP2 (sustainable development and climate impact)
- Health Building Note 11-01 and BREEAM Excellent standards
5. Request Specific Changes
You could ask for:
A detailed healthcare delivery plan with funding and operational model
Evidence of NHS engagement and contract negotiations
A contaminated land remediation strategy
A separate planning application for the health centre
Example Phrases for Reference
Please do adapt these into your own words:
“The SPD does not provide a viable or deliverable plan for healthcare provision.”
“There is no evidence of NHS England engagement or a contract for a GP practice.”
“Without a contaminated land strategy, the building cannot meet NHS standards.”
“The SPD risks leaving 9,200 new residents without access to primary care.”
Where to Send Your Objection:
This is the email address for comments to Rushcliffe Borough Council on the SPD: localdevelopment@rushcliffe.gov.uk