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--- 260304environment_agency_eir_request_-_tees_maintenance_dredging [2026/05/14 20:01] – nefcadmin
+++ 260304environment_agency_eir_request_-_tees_maintenance_dredging [2026/05/14 20:15] (current) – [Analysis] nefcadmin
@@ Line 73: / Line 73: @@
 ** 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.
-The information you have requested is available online as Open Data.[[https://environment.data.gov.uk/ecology/explorer/| EA Ecology & Fish Data Map Explorer | Water Quality ]]
+The information you have requested is available online as Open Data.[[https://environment.data.gov.uk/ecology/explorer/| EA Ecology & Fish Data Map Explorer | Water Quality ]], [[https://environment.data.gov.uk/water-quality|Water Quality Explorer]], for the contaminant data. Any licence details will be available on the MMO licensing portal: [[https://marinelicensing.marinemanagement.org.uk/mmofox5/fox/live/MMO_PUBLIC_REGISTER| Marine case management system - Public register - MCMS ]].
-[[https://environment.data.gov.uk/water-quality|Water Quality Explorer]], for the contaminant data. Any licence details will be available on the MMO licensing portal: [[https://marinelicensing.marinemanagement.org.uk/mmofox5/fox/live/MMO_PUBLIC_REGISTER| Marine case management system - Public register - MCMS ]].
 ** 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.
@@ Line 161: / Line 159: @@
 **Factors in favour of maintaining the exception: **Disproportionate burden - The amount of information that falls within scope of your request is considerable. Responding to the request would place an undue burden on the Environment Agency's resources and would require a substantial amount of resource and potentially the need to take staff offline from their cores duties to deal with the request. We consider that this burden cannot be justified due to the impact that responding to this onerous request would have on our ability to carry out our core duties. We consider this would be disproportionate to the benefit to the world at large in providing the information.
 Having considered the public interest factors, and applying the presumption in favour of disclosure, we find that there is a stronger public interest in maintaining the exception than there is in disclosure.
 ===== Analysis =====
+The overall conclusion must be that the EA does not hold information on the risks of the dredging operations as it does not hold data related to the operations or environmental assessment.
+So the EA are not assessing the environmental impact of the maintenance dredging operations.
+==== 1. 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.
+Refers me to [[https://marinelicensing.marinemanagement.org.uk/mmofox5/fox/live/MMO_PUBLIC_REGISTER| Marine case management system - Public register - MCMS]] - which only contains information about the disposal not the actual dredging.
+** 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.
+No information held which means that PD Ports has not supplied any and that EA has not requested any as it has not been informed that this is a discharge pathway.
+** 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
+No infromation held.
+==== 2. 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.
+No information held.
+** Request 2.2: ** Provide all internal reports discussing the risk of TSHD overflow plumes to migratory fish passage in the Tees.
+No information held, I would suggest relates to 1.2.  This is just not being considered.
+==== 3. 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.
+My assessment is that little useful data is available as the data sets are so sparse, I have looked at the online water quality data, but need to examine the ecology data more fully.  The EA said available online as Open Data.[[https://environment.data.gov.uk/ecology/explorer/| EA Ecology & Fish Data Map Explorer | Water Quality ]], [[https://environment.data.gov.uk/water-quality|Water Quality Explorer]]
+** 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.
+No information held.
+** 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.
+No information stated to be Natural England's responsibility.
+==== 4. 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.
+EA does not monitor water quality during dredging operations.  Defra lead for crustacean mortality event.
+** 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.
+EA does not monitor water quality during dredging operations.  Defra lead for seal mouth rot investigations.