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--- 260303pd_teesport_eir_request_-_maintenance_dredging [2026/05/01 14:06] – nefcadmin
+++ 260303pd_teesport_eir_request_-_maintenance_dredging [2026/05/14 21:11] (current) – [Analysis] nefcadmin
@@ Line 7: / Line 7: @@
 I am writing on behalf of North East Marine Research Group (NEMRG) to seek the following information relating to the Tees Maintenance Dredge Protocol (MDP) Baseline Document (dated May 20, 2025) and to PD Ports Ltd’s maintenance dredging operations.
-. Trailing Suction Hopper Dredger (TSHD) Operational Data
+==== 1. Trailing Suction Hopper Dredger (TSHD) Operational Data ====
 The MDP acknowledges the use of the Emerald Duchess and Heortnesse but omits technical details on hopper overflow. Please provide the following:
@@ Line 14: / Line 14: @@
    * Request 1.3: All internal reports and studies used by PD Teesport to validate the claim of environmental sustainability of the dredging operations, specifically that green valves contribute to environmental sustainability by reducing the mass flux of contaminants, as opposed to merely reducing visual surface turbidity.
-. Estuarine Plume Modelling and Hydrodynamics
+==== 2. Estuarine Plume Modelling and Hydrodynamics ====
 The MDP provides plume modelling for the offshore disposal site (Tees Bay A) but contains no equivalent modelling for the inner estuary reaches.
    * Request 2.1: Disclose all 3D hydrodynamic or sediment transport modelling held by PD Teesport that specifically simulates the "dynamic plume" and "passive plume" created by TSHD overflow.
    * Request 2.2: Provide all data regarding the "Sediment Trap Effect" in the Tees, specifically modelling how fine particles overflowed in the main channel are recirculated by flood-dominant currents into sensitive areas like Seal Sands.
-. Contaminant Partitioning and "Fine Fraction" Enrichment
+==== 3. Contaminant Partitioning and "Fine Fraction" Enrichment ====
 The MDP relies on bulk sediment sampling and Cefas Action Levels designed for offshore disposal rather than known toxicity of contaminants. It fails to account for the fact that hydrophobic contaminants (PAHs, PCBs, PBDEs) adsorb preferentially to the fine particles (<63µm) that are systematically released via overflow.
    * Request 3.1: Disclose all chemical analysis held by PD Teesport that was conducted specifically on the overflow water/fine sediment fraction, rather than bulk bed samples.
    * Request 3.2: Provide the raw data for the Year 9 (2024) mid-licence sampling, specifically the Total Organic Carbon (TOC) levels used to normalise PBDE concentrations, which the MMO noted as a point of concern.
-. Water Framework Directive (WFD) and Protected Sites
+==== 4. Water Framework Directive (WFD) and Protected Sites ====
 The Tees Transitional water body is currently failing for PBDEs, mercury, and benzo(g,h,i)perylene.
    * Request 4.1: Provide the "WFD Compliance Assessment" specifically for the extraction phase, demonstrating that the remobilisation of these substances through dredging disturbance does not impede the recovery of the water body.
@@ Line 111: / Line 111: @@
 === Request 4.2: Disclose any evidence used to conclude that dredging-induced turbidity does not impact the foraging success of Common Terns over their entire estuarine range, particularly in the silty upper reaches. ===
-PD Teesport holds information responsive to this part of your Request.  The MDP has previously been disclosed to you.  To further assist you, we can advise  that relevant information is also availab[[https://links.uk.defend.egress.com/Warning?crId=69f35a17b3257920b9e0d612&Domain=Pdports.co.uk&Threat=eNpzrShJLcpLzAEADmkDRA%3D%3D&Lang=en&Base64Url=eNoNzDsOwjAMANAbOQsMRUKIUnVIBVOXTlWUD0TEdYidSuH08A7wXiKZT0rVkqC-AQEjemtYciHxVsASKlZ81-tNt_4zTt0yXMM3trk90vFwcYQmbmdLG9ck4HwoBp60_7cfHZMhuA%3D%3D&@OriginalLink=url.uk.m.mimecastprotect.com|le here Teesmouth and Cleveland Coast SPA, Ramsar Site and SSSI - Defra - Citizen Space. ]]
+PD Teesport holds information responsive to this part of your Request.  The MDP has previously been disclosed to you.  To further assist you, we can advise  that relevant information is also available [[https://consult.defra.gov.uk/natural-england-marine/teesmouth-and-cleveland-coast-potential-sp/|here - Teesmouth and Cleveland Coast SPA, Ramsar Site and SSSI - Defra - Citizen Space. ]]
 === Request 4.3: Records of any Turbidity/Dissolved Oxygen monitoring conducted during the dredging process to ensure compliance with WFD. ===
@@ Line 188: / Line 188: @@
 Richard Ellison
-Data Protection Officer
-PD Teesport Limited
-Enclosures
-Docusign Envelope ID: C489310D-465A-8FC6-801B-545ED10BA623
+===== Analysis =====
+No information has been supplied which suggests that any environmental impact assessment is carried out on the maintenance dredging operation.  In most case reference is made to documents where it is stated that the assessments are for disposal.
+A trailing suction hopper dredger presents two sources of contamination:
+   - the dredge head resuspending material which is not captured in the suction (up to 20% of dredged amount)
+   - the overflow from the hopper (up to 25% of the dredged amount)
+The response confirms that overflow happens every time the dredgers are deployed, but despite operating within the Tees SSSI, SPA and Ramsar, does not show any definition of the pathways when operating within the river.
+There is no evidence of a least significant effect appraisal of the maintenance dredging operations.
+==== 1. Trailing Suction Hopper Dredger (TSHD) Operational Data ====
+   - Dredge logs - 1 supplied for 20th December 2025 - no information on overflowing.
+   - Green valve - no information supplied as considered commercially sensitive.
+   - Proof of environmental sustainability of dredging operations - no information supplied as considered commercially sensitive.
+==== 2. Estuarine Plume Modelling and Hydrodynamics ====
+   - Plume dynamics from overflow - no information held.
+   - Sediment trap effect - no information held.
+==== 3. Contaminant Partitioning and "Fine Fraction" Enrichment ====
+   - Chemical analysis of overflow fraction - no information help.
+   - TOC for mid-licence sampling - MMO templates supplied.
+==== 4. Water Framework Directive (WFD) and Protected Sites ====
+   - WFD compliance for extraction phase of dredging - pointed to previous WFD for disposal.
+   - Dredging induced turbidity impact on terns etc. - MDP and should look at the [[https://consult.defra.gov.uk/natural-england-marine/teesmouth-and-cleveland-coast-potential-sp/|Teesmouth and Cleveland SPA, Ramsar Site and SSSI - Defra - Citizen Science]].  The MDP does not address operational dredging, the SPA link is a consultation, after the formation of the Tees Estuary Partnership designed to simplify continuing operations on the Tees via a Memorandum of Understanding which was signed in 2017 ([[https://marinedevelopments.blog.gov.uk/2017/11/16/tees-estuary-regulation-partnership-licence/|Improving regulation in the Tees Estuary]]) making the MMO the primary regulator for the Tees.  All these links basically assume that current business as usual is having no environmental effect.  Rather than saying is business as usual safe to continue, and certainly should be revisited after the 2021 crustacean die-offs and the ongoing harbour seal pup mortality.
+   - Records of turbidity / dissolved oxygen - PD Teesport holds no records.
+   - Test of likely significance SPA - MDP and extension of SPA.  Without plume modelling once again these documents refer to the disposal not the dredging operation.