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Request
Dear Environment Agency,
I am writing on behalf of North East Marine Research Group (NEMRG) to request the disclosure of environmental information under the Environmental Information Regulations (EIR) 2004. Our request concerns the Environment Agency’s role in assessing the impact of PD Teesport's maintenance dredging operations (specifically the extraction and overflow phases) on the Tees Transitional water body (GB510302509900).
The Tees Maintenance Dredge Protocol (MDP) Baseline Document (dated May 20, 2025) indicates that the Tees is currently failing for several priority substances, including PBDEs and mercury. We are concerned that the ongoing use of Trailing Suction Hopper Dredgers (TSHD) with active overflow by PD Teesport Limited is actively impeding the recovery of this water body by recirculating legacy contaminants that are concentrated on fine sediment particles.
We request disclosure of the following information from January 2023 to the present, or if there has been no communication in this period then from January 2014 to the present:
- Water Framework Directive (WFD) Compliance Assessments
- Request 1.1: Provide the EA’s formal review or response to the WFD assessment contained within the 2025 Tees MDP.
- Request 1.2: Disclose any assessments held by the EA regarding whether TSHD overflow constitutes a “new discharge pathway” that requires a specific assessment under your “Clearing the Waters” guidance.
- Request 1.3: The evidence used to prove that discharging of 25% to 30% of dredged material back into the river (via draghead disturbance and overflow) does not constitute a deterioration of the “Chemical Status” for PBDEs and mercury
- Impact on Protected Fisheries and Eels
- Request 2.1: Disclose all EA advice or data regarding the impact of dredging-induced turbidity and contaminant remobilization on the European eel (Anguilla anguilla), noting that eels have been detected in recent eDNA monitoring in the estuary.
- Request 2.2: Provide all internal reports discussing the risk of TSHD overflow plumes to migratory fish passage in the Tees.
- Contaminant Flux and Sediment Quality
- Request 3.1: Disclose all results from the EA’s “Intertidal Grab Sampling for Benthic Inverts and Contaminant” (Licence L/2013/00082) and any more recent WFD monitoring conducted in the Tees.
- Request 3.2: Provide the EA’s assessment of the “Sediment Trap” effect in the lower Tees and whether dredging overflow is causing a net accumulation of toxins in the surface “active layer” of the riverbed.
- Request 3.3: Assessment of whether the nitrogen and organic matter released during the agitation of anaerobic silts by the dredge head contributes to the “Unfavourable-Declining” status of the Seal Sands SSSI.
- Pollution Incident Investigation
- Request 4.1: Disclose all EA correspondence and data regarding the potential link between dredging operations and the crustacean mortality events of 2021-2022, specifically all analysis of water samples taken during active dredging campaigns.
- Request 4.2: Disclose all EA correspondence and data regarding the potential link between dredging operations and the ongoing harbour seal pup mortality events since 2021, specifically all analysis of water samples taken during active dredging campaigns.
For the avoidance of doubt, this request pertains specifically to the act of extraction and disturbance of sediment within the harbour limits. We are NOT requesting the Marine Licence or returns for sea disposal (e.g., MLA/2015/00088 and MLA/2025/00263). We are also not seeking information that is properly withheld pursuant to data protection requirements. Please provide the requested information within 20 working days.