North East File Collection - NEFC

Only 31 samples were taken for an area of over 12 million m², even taking into account historical samples this does not provide sufficient information on the contamination within a highly heterogeneous river with the industrial history of the River Tees. I do not believe it is compliant with the UK's obligations under the OSPAR Convention as it does not show correct application of OSPAR Guidelines. The OSPAR Guidelines provide approach for both considering the spatial area that is being dredged and the volume of dredged material. Rationally for a river such as the Tees with heterogeneous contamination the spatial guidance should have been used, instead the applicant used the volume guidance which is appropriate for a deep dredge in a small area (capital dredge). This was the basis for the 2025 Judicial Review.

At the same time as the granted licence was uploaded to Marine Case Management System, a new HRA was uploaded - 20250626_MLA202500263_HRA.pdf. This was surprising both as it would presumably have been required for Natural England (and possible the Environment Agency) to make a proper assessment of the application and as such the HRA is supposed to have been included within the Maintenance Dredge Protocol, as the MMO's Marine Licensing Top Tips - Ports Sandbox April 2026 makes clear on page 16 “For those harbour authorities that have an up-to-date Maintenance Dredge Baseline Report the HRA will be included in that report.”

Initial Application - Submitted 27-May-2025

Granted - 5th-November-2025

Case ref: MLA/2025/00263

Licence ref: L/2025/00366/1

Tees and Hartlepool Maintenance Dredge Disposal

Renewal of the current maintenance dredge disposal licence L/2015/00427/7 which has been on-going over many years. This application is for a 10 year maintenance dredging disposal licence commencing 1st January 2026 and ending 31st December 2035.

The Tees Maintenance Dredging Protocol (MDP) Baseline Document has been updated for this application, it is attached below and referred to throughout the application.

Works are performed on a daily basis throughout the year and covered in the Tees MDP Baseline Document. The renewal applies to the next 10 years.

PD Teesport Limited employs two trailing suction hopper dredgers (TSHD) of 2,000m3 and 1,500m3 hopper volume to maintain depths within the navigable channel and berths within the Tees and Hartlepool. Both are traditional suction dredgers with active bottom door dumping systems, the only variation being the vessel hopper capacity. The suction dredgers operate on a nominal production time 12.5 hours per day for six days per week. This can, for a limited period, be increased to 24 hours and seven days per week where sudden increases in deposition rate occur, primarily following storm conditions.

Full details on https://marinelicensing.marinemanagement.org.uk/

PD TEESPORT LIMITED / 17-27 Queen's Square Middlesbrough / TS2 1AH

Date application submitted: 27-MAY-2025 Date application validated: 04-JUN-2025 Date initial decision made: 05-NOV-2025

Status: Completed (Discharging conditions)

MLA/2025/00263

Initial Application - Submitted 27-May-2025

Application Form

Consulted on 26 June 2025. Responded on 14 July 2025.

The consultee was asked for their comments on this case. They responded:

Please find attached EA comments.

The consultee included the following files with their response:

EA_MLA.2025.00263_Official_14.07.2025.pdf

Consulted on 26 June 2025. Responded on 18 July 2025.

The consultee was asked for their comments on this case. They responded:

Please see attached advice letter.

The consultee included the following files with their response:

PL00799246 MCMS MLA 2025 00263 Tees and Hartlepool Maintenance Dredge Disposal.pdf

Consulted on 26 June 2025. Responded on 2 July 2025.

The consultee was asked for their comments on this case. They responded:

Please see attached letter for comments

The consultee included the following files with their response:

MLA_2025_00263_NEIFCA comments.pdf

Consulted on 26 June 2025. Responded on 25 July 2025.

The consultee was asked for their comments on this case. They responded:

Please find attached the MMO North Shields response to this consultation. Should you have any concerns please contact me directly and thank you again for agreeing to the extension of the deadline.

Regards,

Jack Coe (Marine Officer)

The consultee included the following files with their response:

MLA_2025_00263_Response_JC.docx

Consulted on 26 June 2025. Responded on 22 August 2025.

The consultee was asked for their comments on this case. They responded:

Please see attached for comment.

The consultee included the following files with their response:

517225 MLA 2025 00263 Tees Maintinence Dredge disposal NE response to MMO.pdf

Consulted on 26 June 2025. Responded on 18 July 2025.

The consultee was asked for their comments on this case. They responded:

Dear Gregg,

Thank you for the opportunity to comment on the Marine Licence application for Tees and Hartlepool Maintenance Dredge Disposal. The UK Technical Services Navigation team of the Maritime and Coastguard Agency has reviewed the documents received and would like to comment as follows:

We note that the works fall within the jurisdiction of a Statutory Harbour Authority (SHA) PD Teesport Limited and therefore they are responsible for the safety of navigation within their waters. 

The MCA confirms we have no objections to a licence being granted on this occasion. This is on the understanding that all maritime safety legislation is adhered to, and that the following risk mitigation measures take place: 

Conditions: 

None

 In addition, the following advice should be provided to the applicant to facilitate the proposed works:

Advisories:

Bunding and/or storage facilities must be installed to contain and prevent the release of fuel, oils, and chemicals associated with plant, refuelling and construction equipment, into the marine environment. The site is within port limits and the applicant should gain the approval/agreement of the responsible local navigation authority or the Harbour Authority/Commissioners/Council. They may wish to issue local warnings to alert those navigating in the vicinity to the presence of the works, as deemed necessary. The MCA has considered the relevant Marine Plan as part of its assessment of this application.  

If you have any questions on this response, please let us know.

Kind regards

UK Technical Services Navigation

Consulted on 26 June 2025. Responded on 25 July 2025.

The consultee was asked for their comments on this case. They responded:

Good afternoon Gregg,

I can confirm that Trinity House has no objections or comments regarding this application.

Many thanks.

Kind regards,

C. Bransby

Consulted on 26 June 2025. Responded on 18 July 2025.

The consultee was asked for their comments on this case. They responded:

The Crown Estate is affected by the proposed works and landowner's consent is required. The applicant is requested to contact our Managing Agent for the area: Vicki Dean of Carter Jonas on 01925 940416, Vicki.Dean@carterjonas.co.uk regarding landowner's consent for the proposed activity.

and

The Crown Estate is affected by the proposed disposal activity and landowner's consent is required. The applicant is requested to liaise with Mark Wrigley on 0207 851 5062, mark.wrigley@thecrownestate.co.uk regarding landowner's consent for the proposed disposal activity.

Consulted on 26 June 2025. Responded on 27 June 2025.

The consultee was asked for their comments on this case. They didn't have any comments.

Consulted on 2 July 2025. Responded on 28 July 2025.

The consultee was asked for their comments on this case. They responded:

Please find the advice attached obo Sylvia Blake

The consultee included the following files with their response:

20250823 MLA202500263 Tees and Hartlepool Maintenance Dredge - Renewal Application SEAL Advice FINAL.docx

Consulted on 2 July 2025. Responded on 22 July 2025.

The consultee was asked for their comments on this case. They didn't have any comments.

Consulted on 19 August 2025. Responded on 15 September 2025.

The consultee was asked for their comments on this case. They responded:

Please find attached MCT's consultation response

Kind regards

Laura Trowsdale

The consultee included the following files with their response:

MLA202500263 consultation response final.pdf

Submitted on Wed 06 Aug 2025 18:50

The representation and supporting documents detail NEMRG’s key recommendations for essential restrictions to be imposed on the River Tees maintenance dredging licence renewal (MLA/2025/00263), alongside errors identified within the accompanying licence renewal documents. These points are drawn directly from NEMRG's detailed analysis to address critical concerns for the Tees marine ecosystem.

Most Important Restrictions and Recommendations for the Dredging Licence:

• Eliminate or severely restrict overspilling during dredging operations. Trailing Suction Hopper Dredgers (TSHDs) are considered the least suitable for contaminated rivers like the Tees due to sediment dispersal and mixing. Overspilled material is more contaminated due to the concentration of hydrophobic contaminants (like PAHs and PCBs) on finer particles.
• Mandate enhanced and consistent sediment analysis and sampling. More frequent analyses for PAHs, PCBs, and Brominated Diphenyl Ethers (BDEs) are needed. Sampling must be performed before, during, and after dredging operations, with specific limits set on contamination spread. Crucially, analysis should consider the surface area of sediment particles, not just overall weight, as contaminants adsorb onto smaller particles.
• Adopt a precautionary and beneficial environmental management approach. This requires urgently exploring technologies for extracting dredged material without spillage and depositing it in lined landfill sites, rather than offshore redistribution. A full-scale Beneficial Use of Dredged Material (BUDM) Program should be commissioned, initially focusing on clean sand from outer channels for beach nourishment or construction.
• Re-evaluate the continued use of TSHDs in historically contaminated, silty upper reaches of the estuary (e.g., Billingham Reach). More precise, lower-dispersal dredging methods (e.g., environmental clamshell or auger dredgers) should be explored for targeted “hotspot” management.
• Implement an Adaptive Turbidity Monitoring Program. This necessitates real-time turbidity and Total Suspended Solids (TSS) sensors (upstream and downstream) linked to pre-agreed, tiered trigger levels (Alert, Action, Stop-Work) to allow real-time operational adjustments.
• Formally adopt an Annual Calendar of Ecological Sensitivity. This comprehensive, risk-based tool would consolidate all known ecological sensitivities into a colour-coded system to proactively schedule dredging campaigns, minimising conflicts with critical wildlife periods such as harbour seal pupping season (June-July) and peak waterbird feeding times.

• “Providential” rather than precautionary approach: The licence application assumes existing practices are acceptable due to long-term occurrence, despite significant environmental damage such as the mass crustacean die-off in 2021 and high mortality of harbour seal pups.
• Incorrect application of Marine and Coastal Access Act 2009: The application incorrectly states that PD Ports meets the exemption within Section 75 for sea disposal, as the Tees Inner disposal site (Tees Bay 'A' TY160) is not classified as “surface waters” but rather the North Sea, governed by international conventions.
• Inadequate assessment of overspilled material: The environmental impact assessment in the renewal documents fails to consider the upto 25% of dredged material that is released as overspill back into the river at dredge sites. This overspill, enriched with fine particles, carries a greater fraction of adsorbed contamination.
• Inconsistent and insufficient sediment data: The reliance on limited, inconsistent data sets with missing fundamental measurements (e.g., total organic carbon, PCBs, BDEs) makes objective comparison and understanding of the system impossible. Samples are often taken from the surface and may not be representative of the underlying dredged material. The number of samples is insufficient to comply with OSPAR guidelines given the geographical spread and volume of material.
• Elevated contamination levels: Tees sediments, particularly in overspill, show significantly elevated PAH and BDE levels compared to other ports like Southampton, indicating a persistent pollution source.
• Over-simplistic plume modelling: Current modelling is over-simplified, ignoring the significant volume and highly contaminated nature of overspilled fine particles, and the continuous, chronic pressure of maintenance dredging across fragile habitats.
• Concerning sampling recommendations: Recommendations to reduce sampling frequency based on a single “good result” are concerning, given the high variability in contamination and ongoing development activities in the Tees region.

NEMRG stresses the urgent need for a shift from a “waste disposal mindset” to one of “resource management” and genuine environmental leadership, ensuring sustainable growth for the River Tees.

MLA/2025/00263 – Tees and Hartlepool Maintenance Dredging and Disposal Licence Renewal Representation from North East Marine Research Group (NEMRG)

MLA/2025/00263 – Report of the Investigation of the Sediment Quality Data of L/2015/00427/7

Best Practices for Environmentally Responsible Maintenance Dredging in the River Tees: An Integrated Framework for TSHD Operations

Submitted on Mon 04 Aug 2025 10:29

I object to the renewal of the dredge license.

Dredging is known to be deadly to sea wildlife, in this case mostly crabs and lobsters and it is time for this practice to end, or at the minimum for there to be a full environmental assessment carried out and proper decisions to be based on the conclusions of that.

I am also concerned about the dumping of the sediment gathered as a result of the dredging process as there is known historical industrial contamination in this area that is harmful to wildlife. There needs to be detailed chemical analysis and environmental assessment undertaken before any consideration is taken towards any possible decision to consider dredging in this area. It is time to put the health of our oceans before short term financial profit.

Submitted on Sun 03 Aug 2025 16:11

Subject: Objection to Tees and Hartlepool Maintenance Dredge Disposal Licence Renewal (L/2015/00427/7)

Dear Marine Management Organisation,

I am writing to strongly object to the renewal of the maintenance dredge disposal licence L/2015/00427/7 for the Tees and Hartlepool area, which proposes a 10-year licence from January 2026 to December 2035.

Many members of the public, local fishers, environmental experts, and marine conservation groups are deeply concerned about the environmental and ecological impacts of continued dredge disposal in this area. These concerns are based on the following serious issues:

⸻

Since October 2021, mass shellfish deaths have occurred along the North East coast, including in Teesside, Hartlepool, and as far as Whitby. Crabs and lobsters were found twitching and dying in large numbers. Local fishermen have reported up to 95% declines in catches—an event with devastating effects on local livelihoods and marine biodiversity.

While official reports claimed algal blooms were likely responsible, independent scientists and local observers continue to believe that dredging and the dumping of potentially contaminated sediments may be contributing to the damage. Pyridine, a toxic industrial chemical, was found at elevated levels in crab tissues. Yet no full explanation has ever been reached, and no resolution has been offered to impacted communities.

⸻

The Tees estuary has a long history of industrial pollution. Dredging in this area may disturb toxic sediments, including heavy metals and industrial chemicals such as pyridine. Disposing of this material at sea without thorough and independent chemical analysis may be putting the entire marine food web at risk.

Fishermen have expressed concern that dredged sludge is being dumped at sea when it should instead be disposed of on land under strict safety measures. Continuing to allow this dumping for another decade without proper scrutiny could further harm wildlife and public trust.

⸻

The application appears to rely mainly on the Tees Maintenance Dredging Protocol (MDP) Baseline Document. However, there is no indication that a full, transparent, and independent EIA has been carried out for this renewal. A licence of this length and scale—covering daily dredging and dumping over 10 years—must be based on robust environmental evidence and transparent public consultation.

Any sediment proposed for disposal must be tested for industrial contaminants, including pyridine. Without this, there is no way to assess the full risks to the marine environment, fisheries, or public health.

⸻

Given the scale of previous ecological impacts, the uncertain cause of crustacean die-offs, and the lack of transparency around sediment testing, I ask that you adopt a precautionary approach.

Before any licence is renewed:

• All dredged material should be thoroughly tested for industrial toxins, including pyridine and heavy metals.
• Disposal at sea should not be permitted unless the material is proven to be non-toxic.
• An independent Environmental Impact Assessment must be conducted and published for public review.
• Ongoing environmental monitoring and real-time reporting must be part of any dredging programme.
• Full consideration must be given to the voices of local communities and fisheries, who have already suffered huge losses.

⸻

This decision will shape the health of the Tees estuary and the wider North Sea coastline for the next decade. The marine ecosystem, fishing livelihoods, and public confidence in environmental protection all depend on responsible, science-based decisions.

I respectfully urge the MMO to suspend or refuse this licence application until a full, independent environmental review is completed.

MLA 2025 00263 NEMRG Representation