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--- 260303pd_teesport_eir_request_-_maintenance_dredging [2026/05/01 14:39] – nefcadmin
+++ 260303pd_teesport_eir_request_-_maintenance_dredging [2026/05/14 21:11] (current) – [Analysis] nefcadmin
@@ Line 191: / Line 191: @@
 ===== 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.
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 ==== 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.
+   - 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.