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1 INTRODUCTION
Marine pollution remains one of the most significant
environmental and operational threats in the maritime
sector, significantly impacting both the natural
environment and economic activities. The Baltic Sea,
characterized by heavy maritime traffic, a semi-
enclosed geography and exceptionally slow water
exchange cycles, is particularly vulnerable to marine
pollution incidents. Its unique ecological
characteristics, including low salinity, limited
biodiversity, and slow recovery rates, mean that even
moderate oil spills can cause disproportionate and
long-lasting environmental damage. For decades,
Estonia has invested in the continuous development of
marine pollution response systems and capabilities,
gradually building a functional national framework
aligned with the Helsinki Convention and HELCOM
recommendations [12], [9].
However, recent developments, most notably the
extensive planning of offshore wind farms (OWFs) in
Estonian coastal waters, have introduced a new
dimension of complexity to marine pollution response.
The Estonian Maritime Spatial Plan designates
approximately 2439 km² of sea area for wind energy
Assessing Estonia's Marine Pollution Response
Preparedness in the Context of Planned Offshore Wind
Farm Developments: an Expert-Based Qualitative Study
T. Tamm & I. Zaitseva-Pärnaste
Tallinn University of Technology, Tallinn, Estonia
ABSTRACT: The rapid expansion of offshore wind energy, driven by climate objectives and energy security
imperatives, presents novel challenges in the Baltic Sea region. In Estonia, the planned construction of offshore
wind farms (OWFs) significantly increases the complexity of maritime operations and introduces new risks to
national marine pollution response capabilities. While OWFs support the transition to renewable energy, they
simultaneously heighten navigational hazards and the potential for pollution incidents in densely developed
maritime zones. This study evaluates the readiness of Estonia's strategic marine pollution response and risk
management system in the context of planned OWFs.
Through 24 semi-structured interviews with Estonian and international marine pollution experts, response vessel
commanders and wind farm developers, this research identifies critical gaps in the current response framework.
Findings indicate that while Estonia's oil-spill response system functions adequately under standard conditions,
it lacks the specialized vessels, equipment, and regulatory frameworks required for effective operations within
constrained turbine fields.
The study proposes strategic adjustments, including investments in maneuverable response vessels, the
development of site-specific contingency plans, enhanced public-private cooperation and targeted training
programs, to align Estonia's pollution response capacity with the rapid expansion of offshore wind energy. The
article also presents a preliminary framework for developing wind-farm-specific spill response plans and
proposes a governance model for multi-agency incident management.
http://www.transnav.eu
the International Journal
on Marine Navigation
and Safety of Sea Transportation
Volume 20
Number 3
September 2026
DOI: 10.12716/1001.20.03.14
664
development, with a potential installed capacity of 15–
17 GW [15]. As of 2025, multiple developers have
initiated building permit procedures, with several
projects in the Gulf of Riga and around Saaremaa at
advanced stages of environmental impact assessment
(EIA). These developments support national
renewable energy and energy-security objectives,
including the target of significantly increasing the
share of renewable energy by 2030 [6]. At the same
time, OWFs introduce fixed infrastructure, increased
service traffic, cable corridors and offshore substations
into sea areas that are also used for navigation, fisheries
and emergency response.
While offshore wind farms play a key role in
Estonia’s transition towards a more sustainable energy
system, their construction and operation entail new
risks, particularly increased navigational hazards and
potential pollution incidents within densely packed
turbine arrays [16], [19]. The physical presence of
turbines restricts the manoeuvrability of large response
vessels, alters local sea conditions and creates
additional potential sources of oil and chemical
contamination.
OWFs are not simply additional objects in the
maritime space; they create constrained operational
environments. Turbine arrays affect vessel-domain
geometry, manoeuvring margins, access corridors and
emergency response options [19], [20], [2]. Recent
studies also show that pollution risks connected with
OWFs are broader than catastrophic ship-turbine
collisions alone. Possible pollutant pathways include
lubricants, hydraulic oils, transformer oils, corrosion-
protection systems, coolants, firefighting media and
increased vessel traffic connected with construction
and maintenance [5].
International organizations, including HELCOM,
have increasingly addressed the impact of OWFs on
marine environmental protection, but official guidance
materials and standards in this area are still evolving.
In Estonia, a comprehensive cross-sectoral analysis of
how OWF construction would affect marine pollution
response operations and what measures and
investments would be proactively required has not yet
been conducted. Several OWF projects are currently in
the EIA approval phase. Following this approval and
prior to the construction phase, it is necessary to
develop wind-farm-specific pollution response plans
and establish clear structural management among
various authorities.
The research problem addressed in this study is the
uncertainty regarding whether and how the Estonian
marine pollution response system can cope with the
additional pollution risks associated with OWFs. The
objective of this article is to investigate the readiness of
Estonia's strategic planning and risk management for
marine pollution response in the context of planned
offshore wind farms. To achieve this objective, the
study seeks answers to the following research
questions:
1. What are the current strengths and weaknesses of
the Estonian marine pollution response system
regarding the construction of OWFs?
2. How might the construction of OWFs affect the
operational activities and risk management of
marine pollution response in the Estonian marine
area?
3. What strategic and practical measures are needed to
enhance Estonia's marine pollution response
capabilities in OWF areas?
2 THEORETICAL FRAMEWORK AND
LITERATURE REVIEW
2.1 Offshore Wind Farm Development and Regulatory
Context
The development of OWFs is a crucial component of
Estonia's energy policy, aimed at increasing the share
of renewable energy and achieving climate neutrality
by 2050. The European Green Deal and the Renewable
Energy Directive provide the overarching policy
framework, emphasizing secure, affordable and
integrated energy markets based on renewable sources
[6]. Estonia's national development strategies,
including "Estonia 2035" and the national climate
policy principles, support the deployment of offshore
wind energy as a sustainable, supply-secure and
environmentally sound energy production solution.
The permitting process for OWFs in Estonia is
multi-stage and legally complex. It is governed by a
layered legal framework encompassing the Building
Code (EhS), the Planning Act (PlanS), the
Environmental Impact Assessment and Environmental
Management System Act (KeHJS), and the Water Act
(VeeS). The Consumer Protection and Technical
Regulatory Authority (TTJA), is the central
administrative body coordinating the permitting
process. The EIA process, which is mandatory for all
OWF projects, must address cumulative and indirect
environmental impacts, including navigational risks
and pollution response preparedness.
At the international level, OWF development in
Estonia is also governed by the Espoo Convention on
transboundary EIA, the Aarhus Convention on public
participation, the United Nations Convention on the
Law of the Sea (UNCLOS), the Helsinki Convention
(HELCOM), and the EU Maritime Spatial Planning
Directive (2014/89/EU). These frameworks collectively
mandate that OWF development accounts for
environmental protection, public participation and
cross-border consultation, particularly in light of the
transboundary nature of the Baltic Sea and Estonia’s
maritime interactions with neighbouring countries.
2.2 Marine Pollution Response: Capabilities and
Challenges
Estonia's national marine pollution response system is
coordinated by the Estonian Navy, which holds the
lead role in offshore incidents, in cooperation with the
State Fleet the Environmental Board the Police and
Border Guard Board (PPA) and the Rescue Board. The
national Marine Pollution Response Plan, updated in
2023, delineates clear roles and responsibilities for each
agency. The primary response assets include ENS
Kindral Kurvits, ENS Raju and EVA-316, which are
equipped with booms, skimmers and oil collection
tanks [4].
The HELCOM Manual on Co-operation in
Response to Marine Pollution provides the main Baltic
regional framework for joint response operations,
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including procedures for requesting assistance,
multinational coordination and operational
cooperation [7]. HELCOM Recommendation 31/1 also
establishes regional expectations regarding national
response capacity and preparedness [9]. These
instruments are crucial for Estonia because a large-
scale incident in the Baltic Sea may exceed the capacity
of a single coastal state and require international
assistance.
At the same time, the current HELCOM response
architecture is primarily designed for marine pollution
incidents in general maritime environments. HELCOM
documents support surveillance, cooperation,
exercises and risk-based planning, but they do not yet
provide detailed tactical guidance for pollution
response inside OWF turbine fields [7], [8]. Annual
joint exercises, such as BALEX DELTA and Clean Sea,
test the readiness of national systems and the
effectiveness of cross-border cooperation. However,
HELCOM's guidance does not yet specifically address
the unique challenges of pollution response within
OWF zones, a gap that this study seeks to highlight [7].
2.3 Estonian Pollution Response Capacity and Equipment
Estonia’s marine pollution response capability is based
on a relatively limited fleet supported by centrally
stored response equipment and pre-positioned
equipment containers in ports. In practice, the core
offshore response assets include ENS Kindral Kurvits,
ENS Raju and EVA-316, which together form the
primary state response capacity at sea. MSV Sektori
may provide additional support through cooperation
arrangements; however, its operational availability is
less stable due to the absence of a permanently
assigned crew and continuously changing manning
conditions [4], [14]. This structure provides Estonia
with a functional baseline response capability,
although its overall scale remains modest in relation to
the spatial extent of planned offshore wind
development areas.
The official analysis of waterborne pollution
incidents and response capacity for the period 2012–
2021 indicates that Estonia meets approximately 53% of
the HELCOM-recommended response capacity [14].
While the regional benchmark is the recovery of 4.5
km² of polluted water per 24 hours, Estonia’s estimated
capacity ranges between approximately 2.4 and 3.0 km²
per 24 hours depending on the asset set considered
[14]. These figures should therefore be interpreted as
analytical estimates rather than a direct representation
of real-time operational capability. In addition to
capacity limitations, geographic coverage remains
uneven, with certain areas such as the southern part of
the Gulf of Riga not reachable within six hours and
response times strongly influenced by weather
conditions and winter ice cover [14].
The fleet also has a clear internal hierarchy. ENS
Kindral Kurvits remains the principal offshore
response vessel, while ENS Raju provides a more
manoeuvrable platform for coastal and restricted
waters. EVA-316, as an Estonian State Fleet vessel, is
important for regional coverage and operational
flexibility. By contrast, MSV Sektori, also treated here
as part of the Estonian State Fleet support structure,
should be understood as an additional reserve asset
rather than a fully equivalent core platform. Unlike the
three main vessels, Sektori does not have a permanent
crew and its manning changes continuously, which
makes its operational readiness less stable. The main
technical characteristics and pollution response
capabilities of these vessels are summarized in Table 1.
Table 1. Marine pollution response vessels and technical
capabilities in Estonia.
Vessel
Oil
recovery
capacity (ice
conditions)
Booms
Storage
capacity
Supporting
systems
ENS
Kindral
Kurvits
Crane-
operated
Lamor
bucket
skimmer
LRB 150 (60
m³/h)
Lamor
HDB 1600
offshore
boom,
currently
400 m
onboard;
maximum
up to 600 m
Tank 100
m³
Steam
heating
system for
recovery
equipment
in winter
conditions
ENS
Raju
–
Lamor PVC
boom FOB
1200,
approx. 200
m onboard
Oil
collected
into
special
bags,
approx.
0.5 m³ per
bag (10
bags)
–
EVA-
316
–
–
Tank 200
m³
Steam
heating
system for
recovery
equipment
MSV
Sektori
–
–
Tank 93
m³
–
In addition to the vessels themselves, Estonia’s
response system includes centrally stored Navy
equipment and pre-positioned response containers in
ports. This equipment structure is important because it
broadens the response base beyond shipborne systems
alone and enables faster initial action in coastal and
port areas. Interviewees considered this supporting
equipment important, but also pointed out that the
existing system has been developed primarily for
conventional open-sea spills and not for the more
constrained operational conditions of offshore wind
farm areas (Expert 8; Expert 14). From the perspective
of this article, this is a central limitation: Estonia’s
current system provides a functioning baseline
capability, but it is not yet specifically configured for
pollution response inside future offshore wind farm
zones.
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Figure 1. ENS Kindral Kurvits. Source: Republic of Estonia
Defence Forces (2026).
Figure 2. ENS Raju. Source: Republic of Estonia Defence
Forces(2026).
Figure 3. MV EVA-316. Source: Estonian Maritime
Administration; photo by Andrus Liinak (2026).
Figure 4. MV Sektori. Source: State Fleet (2026).2.3 Offshore
Wind Farms as Sources of Navigational and Pollution Risk
2.4 Offshore Wind Farms as Sources of Navigational and
Pollution Risk
Offshore wind farms (OWFs) introduce new
navigational and operational risk conditions in
maritime environments. The presence of fixed
turbines, service platforms, subsea cables and
maintenance traffic alters the geometry of safe
navigation as well as emergency response operations.
Vessel-domain studies in Baltic Sea OWF contexts
demonstrate that safe navigation depends on vessel
size, hydrometeorological conditions, turbine spacing
and the configuration of access corridors [19], [20]. The
proliferation of OWFs also affects existing sea routes,
increases the complexity of maritime traffic patterns
and raises the risk of vessel collisions with turbine
structures [1].
From an operational perspective, OWFs create a
constrained spatial environment that differs
significantly from open-sea conditions. Large response
vessels may experience limited manoeuvring space,
while the deployment of booms and other response
equipment can be restricted by turbine layout.
Emergency towing, firefighting and rescue operations
may therefore depend on pre-defined access corridors
and site-specific operational planning. Policy analyses,
such as the Dutch MOSWOZ (Offshore Wind Energy
Shipping Safety Monitoring and Research Programme)
programme, explicitly treat offshore wind farm layout
as an incident-management issue, highlighting
implications for oil-spill response, search and rescue
operations, and emergency towing [18]. These findings
underline the importance of integrating response-
vessel access considerations into OWF planning and
permitting processes.
In addition to navigational risks, OWFs introduce
multiple potential sources of pollution. Accidental
ship–turbine collisions may lead to the release of fuel
oil or hazardous cargo. At the same time, wind turbines
themselves contain lubricants, hydraulic fluids,
transformer oils and other chemical substances
required for normal operation [2], [5]. Although the
volume of oil contained in a single turbine is relatively
limited, the cumulative risk across large wind farm
arrays, combined with restricted accessibility, may
complicate response operations. Recent studies have
identified a broad range of potential contaminants
associated with offshore wind infrastructure, including
substances related to coatings, corrosion protection
systems and functional polymers [5].
The implications for marine pollution response are
therefore significant. The operational constraints
imposed by turbine arrays, combined with the
presence of distributed pollutant sources and increased
vessel activity, require a broader approach to risk
assessment and preparedness. Rather than focusing
solely on large-scale spill scenarios, marine pollution
response planning in OWF areas must account for
multiple incident types, spatial limitations and delayed
response dynamics. Modelling-based research further
suggests that restricted access and complex
hydrodynamic conditions in OWF areas may reduce
the effectiveness of response operations and extend
response times, thereby increasing environmental risk
[12].
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2.5 Existing Marine Pollution Incident Management
Framework in Estonia
Estonia’s marine pollution response system is based on
a centralized, state-led command and control model
designed primarily for conventional open sea pollution
incidents. The responsibility for offshore pollution
detection, response coordination and operational
command lies with the Estonian Navy, acting through
the Maritime Operations Centre (MOC). The system is
activated following the detection of a pollution
incident by national aerial surveillance, satellite
monitoring systems or maritime stakeholders.
Once a suspected pollution incident is detected, the
initial assessment and decision-making are conducted
by the duty officers at the MOC. Depending on the
scale and severity of the incident, the response is
escalated using predefined alert levels. In larger or
environmentally sensitive incidents, the Crisis Action
Team (CAT) is activated to support strategic
coordination. The CAT integrates representatives from
relevant authorities, including the Environmental
Board, Police and Border Guard Board, Rescue Board
and other governmental stakeholders.
Operational response at sea is led by an On‑Scene
Commander (OSC), typically embarked on an Estonian
Navy pollution response vessel. Core response assets
include specialized vessels operated by the Navy and
the State Fleet, supported by auxiliary vessels and, if
required, international assistance through the
HELCOM cooperation framework. Aerial surveillance
and situational awareness are provided by the Police
and Border Guard Board’s aviation units and satellite-
based services [4].
The current management logic relies on a
hierarchical flow of information and decision-making,
with strategic control centralized at the national level
and tactical execution delegated to on‑scene
commanders. While this model has proven functional
for traditional offshore pollution scenarios, it remains
primarily designed around state-owned resources and
does not structurally integrate private maritime
infrastructure or operators, such as offshore wind farm
developers, into the operational response chain.
Figure 5. Command and control structure of marine
pollution response operations in Estonia.
2.6 International Practices in OWF Pollution Response
Planning
International practice suggests that OWF-related
marine pollution preparedness is increasingly
addressed in mature offshore wind jurisdictions, but
often through fragmented mechanisms rather than
through a single dedicated national doctrine for
pollution response inside turbine arrays. Germany,
Sweden and Denmark demonstrate this pattern
through authority-led response structures, permit-
based planning and project-level safety or
environmental requirements. Germany maintains a
centralized maritime emergency-management model
through Havariekommando, Sweden assigns at-sea
spill response to the Swedish Coast Guard within a
broader national cooperation framework and Denmark
requires successive project licences and environmental
assessment under the Danish Energy Agency's one-
stop-shop permitting model [10], [3], [22], [13].
The United Kingdom provides one of the clearest
public models for connecting national response
arrangements with developer-level obligations. The
UK National Contingency Plan covers marine
pollution from shipping and offshore installations,
while official guidance for offshore renewable energy
installations instructs developers to plan and practise
responses to marine casualties and environmental
pollution in or near project sites [13], [24]. Regulator-
hosted Marine Pollution Contingency Plans, such as
the Seagreen plan, show how OWF pollution
preparedness can be operationalized at project level
[21].
The Netherlands offers another strong example by
explicitly linking turbine-field layout, corridor design
and incident-management needs, including emergency
towing, SAR, firefighting and oil-spill response [18].
Overall, the international evidence does not indicate
that mature offshore wind states ignore pollution
preparedness; rather, it shows that responsibilities are
distributed across national response systems, permits,
developer obligations and project-level plans. These
examples suggest that Estonia should adapt existing
HELCOM, regional and national response frameworks
into site-specific planning requirements for each major
OWF development rather than waiting for a complete
international OWF pollution-response doctrine to
emerge.
3 METHODOLOGY
3.1 Research Design
This study applies a qualitative expert-based research
design. The approach is suitable because Estonia has
not yet operated large OWFs, meaning that direct
incident data from Estonian turbine fields do not exist.
Expert interviews allow the study to identify
operational concerns, regulatory gaps and planning
needs before the first Estonian OWFs enter the
construction and operational phases. The qualitative
design is supported by thematic coding and cross-case
comparison, enabling patterns to be identified across
stakeholder groups [11], [17].
The empirical material is interpreted together with
documentary analysis of national marine pollution
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response arrangements, HELCOM response
frameworks, Estonian OWF planning materials and
selected international practices. This triangulation
strengthens the analysis by comparing expert
perceptions with regulatory, operational and scientific
evidence.
3.2 Sample and Data Collection
The empirical material consists of 24 semi-structured
interviews conducted between March and May 2025.
The sample included four target groups: Estonian
marine pollution response experts, international
experts from HELCOM member-state contexts,
response-vessel commanders and representatives of
major offshore wind developers. This composition was
selected to cover strategic planning, operational
command, vessel-level experience and developer
perspectives.
A total of 24 semi-structured expert interviews were
conducted between March 10 and May 5, 2025. The
participation rate was 92% (24 of 25 invited experts).
Interviews ranged in duration from 31 minutes to 1
hour and 25 minutes. The sample was divided into four
target groups, as presented in Table 2.
Table 2. Distribution of interviews by target group.
Target Group
Number of
Interviews
Countries/Organizations
Represented
Estonian Marine
Pollution Experts
7
Estonian Navy, State Fleet,
Environmental Board
International
Marine Pollution
Experts
7
Finland, Sweden, Latvia, Poland,
Germany, Denmark, HELCOM
Offshore Wind
Farm Developers
4
Saare Wind Energy, Enefit Green,
Utilitas Wind, Netherlands
Response Vessel
Commanders
6
ENS Kindral Kurvits, ENS Raju,
EVA-316
Total
24
Separate interview guides were developed for each
target group, organized around four thematic blocks:
(1) assessment of the current state of Estonia's pollution
response capability; (2) the impact of OWFs on
response operations; (3) cooperation and risk
management; and (4) proposals for improvement.
Interviews were conducted in Estonian or English,
recorded with participant consent, and subsequently
transcribed.
3.3 Data Analysis
The transcribed interviews were analysed using
qualitative content analysis supported by a thematic
matrix and cross-case (horizontal) comparison. The
analysis was structured around four main thematic
blocks: current response capability, operational
impacts of offshore wind farms, cooperation and
regulatory frameworks and improvement measures.
Responses were first coded according to these themes
and subsequently compared across expert groups to
identify recurring patterns, similarities and
divergences in perspectives.
The matrix-based approach enabled systematic
comparison of responses and facilitated the integration
of empirical findings into descriptive analytical
summaries. Representative quotations were used
where appropriate to illustrate key viewpoints, while
maintaining participant anonymity by referring to
interviewees using coded identifiers (e.g. Expert 1,
Expert 9).
A key limitation of the analysis is that the findings
reflect expert judgement rather than measured
operational performance within existing Estonian
offshore wind areas. Further research should therefore
complement qualitative findings with simulation-
based methods, response-time modelling and scenario-
based exercises.
4 RESULTS
4.1 Current State of Estonia's Marine Pollution Response
Capability
The majority of interviewed experts agreed that
Estonia's marine pollution response capability has
improved significantly over the past decades and is
functional under standard conditions. Most experts
highlighted the historical development trajectory,
noting that in the early 1990s Estonia had very limited
response capacity, whereas sustained investment and
close regional cooperation have enabled the
establishment of a credible baseline system.
The current response fleet, including ENS Kindral
Kurvits (equipped with approximately 100 m³
collection capacity and ice-capable skimming systems),
ENS Raju, and EVA-316 is generally considered
technically modern and adequate for small- to
medium-scale incidents. However, despite this
progress, experts consistently characterised the system
as “sufficient, but marginal” in capacity.
The interview data further indicate that Estonia’s
response capability is vulnerable to saturation in the
event of a large-scale spill or multiple simultaneous
incidents. As one expert noted, “We have capability,
but it is thin. If one large accident happens, all
resources are already occupied” (Expert 5). As a result,
the national system is structurally dependent on
international assistance, particularly within the
HELCOM cooperation framework.
A key finding is that the challenge is not solely the
absolute level of response capacity, but its alignment
with evolving operational conditions. While large
multi-purpose vessels are effective in open-water
environments, their suitability for operations within
offshore wind farm (OWF) areas remains uncertain.
Experts consistently linked future capability challenges
to spatial and operational constraints within turbine
arrays, including access corridors, manoeuvrability
limitations, equipment deployment constraints and the
need for specialised crew training.
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Table 3. Summary of expert assessments on Estonia's
current marine pollution response capability.
Aspect
Expert Assessment
Key Gaps Identified
Overall
Capability
Functional for small/medium
incidents; insufficient for
large-scale disasters without
international aid.
Limited fleet size; no
OWF-specific protocols.
Equipment
Modern and effective, but
quantitatively limited.
Challenges with heavy fuel
oil in cold waters.
Insufficient boom and
skimmer inventory for
large-scale events.
Response
Speed
Dependent on vessel location;
initial response times can be
lengthy.
No pre-positioned
equipment near
planned OWF zones.
Personnel
Highly skilled and
experienced, but limited in
number.
Risk of fatigue during
prolonged operations;
no OWF-specific
training.
HELCOM
Compliance
Approximately 53% of
recommended capacity met.
Significant investment
needed to reach
recommended levels.
4.2 Impact of Offshore Wind Farms on Response
Operations
The interview data indicate that the introduction of
offshore wind farms (OWFs) fundamentally alters the
operational environment for marine pollution
response. Experts across all target groups identified a
set of interconnected challenges related to vessel
manoeuvrability, response logistics, environmental
conditions and planning frameworks.
A primary constraint concerns restricted
manoeuvrability within turbine arrays. The presence of
wind turbines, subsea cables and maintenance
infrastructure significantly limits the operational space
available for large response vessels. Experts
emphasized that turbine spacing and physical
obstacles complicate the deployment of long boom
formations and reduce operational safety, particularly
under adverse weather conditions. As one vessel
commander noted, “In a wind farm, you should use a
smaller vessel as the lead response ship, while larger
collection vessels operate on the perimeter” (Expert
23), highlighting the need for adapted response
strategies in OWF environments.
In addition to spatial constraints, experts pointed to
the influence of OWFs on local environmental
conditions. Turbine structures may alter wind patterns,
wave dynamics and current regimes, creating a more
complex and less predictable operational environment.
These effects can influence the behaviour and
dispersion of oil spills, potentially reducing the
effectiveness of standard containment and recovery
techniques. As a result, the current fleet optimised for
open-water operations is considered less suitable for
confined OWF conditions.
Experts further highlighted the need for
decentralised and rapid first-response capabilities
within OWF areas. Several interviewees suggested that
service vessels operating within wind farms should be
equipped with basic spill-response kits, including
short absorbent booms, absorbent materials and
portable pumping systems. This would enable initial
containment measures to be implemented before the
arrival of larger response assets, thereby improving
overall response effectiveness.
A further critical issue concerns the integration of
pollution response planning into OWF development
processes. Interview data indicate that, to date,
Estonian environmental impact assessment (EIA)
procedures for offshore wind projects have focused
primarily on underwater archaeology, biodiversity
and navigational safety, while pollution response
planning has received comparatively limited attention.
As one expert observed, “The pollution response topic
was left in the background in the OWF EIA process,
while the focus was mainly on underwater
archaeology and navigational hazards” (Expert 3). This
gap appears to be partly linked to the absence of
established methodologies for pollution response in
OWF environments. While response procedures for
open-sea conditions are well developed, there is
currently no systematic operational framework
tailored specifically to turbine arrays, particularly
under Baltic-specific conditions such as seasonal ice
cover.
4.3 Cooperation and Regulatory Frameworks
The study revealed that while inter-agency
cooperation within Estonia is strong, the integration of
private OWF developers into the national crisis
management framework is currently lacking.
The 2023 Estonian Marine Pollution Response Plan
defines a clear operational structure, with the Navy
leading offshore incidents and the Rescue Board, Police
and Border Guard Board, State Fleet and
Environmental Board acting in supporting roles.
Experts consistently characterised this framework as a
functional and efficient cooperative model. As one
international expert noted, “Estonia has the advantage
of being a small country where all agencies know each
other and work closely. In larger countries, this is often
more fragmented” (Expert 9).
In contrast, the integration of offshore wind farm
(OWF) developers into the national crisis-management
framework remains limited. The interview data
indicate that there is currently no explicit legal
requirement for OWF operators to maintain dedicated
marine pollution response capabilities or detailed
contingency plans. While developers expressed a
willingness to cooperate, they highlighted the need for
clearer governmental direction regarding their
responsibilities. As one developer representative
summarised, “Tell us what we need to do, and we will
do it,” indicating that the current regulatory
framework lacks operational clarity in this area.
Experts also discussed the potential for cooperative
industry solutions, such as shared response resources
among OWF operators within the same region. For
example, jointly maintained first-response vessels or
shared equipment stockpiles were identified as
potentially cost-effective approaches to improving
preparedness. However, such arrangements would
require a clear regulatory mandate and coordination
mechanism.
The application of the “polluter pays” principle in
the context of OWFs was identified as an area requiring
further clarification. Existing national legislation
provides strong financial incentives for pollution
prevention, for example through substantial penalties
for unrecovered spills. However, interviewees debated
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whether this approach should be complemented by
more proactive mechanisms, such as mandatory
contributions to national response capacity or financial
guarantees comparable to maritime liability insurance
schemes.
Finally, effective response in OWF areas requires
well-defined communication and coordination
protocols between operators and national authorities.
Experts emphasised the need for standardised
procedures for information exchange, including
turbine shutdown protocols during incidents and the
designation of navigable access corridors within
OWFs. The absence of such predefined operational
arrangements may significantly complicate response
coordination once offshore wind farms become
operational.
4.4 Integrated Marine Pollution Response Model for
Offshore Wind Farm Areas
Based on the empirical findings of this study and
expert interviews, this article proposes an adapted
marine pollution response management model for
offshore wind farm (OWF) areas. The model expands
Estonia’s existing centralized response framework by
introducing a structured role for offshore wind farm
operators during the early and operational phases of
pollution incidents.
In the proposed model, pollution incidents within
wind farm areas may be detected not only by national
surveillance assets but also by wind farm–integrated
sensors, maintenance vessels, and operational
monitoring systems. Initial alerts are transmitted
simultaneously to the Maritime Operations Centre and
the wind farm operator, enabling parallel situational
awareness from the outset.
A critical innovation of the model is the conditional
delegation of initial operational control. If the wind
farm operator possesses sufficient first-response
capability such as trained crew, response equipment,
and designated response vessels the operator may
temporarily manage immediate containment actions
within the wind farm. This includes first-response oil
containment, source control, and deployment of
absorbent equipment under predefined conditions and
protocols.
Should the incident exceed the operator’s response
capacity, operational command is formally transferred
to the MOC, following established national
procedures. The transition is supported by pre-agreed
coordination mechanisms, ensuring continuity of
situational awareness and avoiding delays caused by
institutional boundaries. Throughout the operation,
coordination and information exchange are
maintained between state authorities, the wind farm
operator, and, where necessary, international partners.
The proposed model preserves the authority of the
national response system while enhancing response
speed and effectiveness in operationally constrained
wind farm environments. By integrating private
operators into the response architecture, the model
reflects the changing maritime risk landscape and
aligns pollution response planning with the realities of
offshore energy infrastructure.
Figure 6. Proposed operational logic of marine pollution
response in offshore wind farm areas.
4.5 Proposals for Improvement
Experts from all groups converged on a set of concrete
recommendations for strengthening Estonia's
pollution response capability in the context of OWFs.
These are summarized in Table 4.
Table 4. Summary of expert recommendations for
improving Estonia's marine pollution response in OWF
areas.
Area
Proposed measure
Priority
Regulatory
Framework
Mandate project-specific Marine Pollution
Contingency Plans (MPCPs) as a
condition of OWF building permits.
High
Fleet
Development
Invest in smaller, highly maneuverable
response vessels suited for turbine-field
operations.
High
Equipment Pre-
positioning
Establish pre-positioned pollution
response equipment caches near planned
OWF zones.
High
Public-Private
Integration
Formalize OWF operator roles in national
crisis management structures; establish
joint communication protocols.
High
Training and
Exercises
Develop OWF-specific training modules;
incorporate OWF scenarios into BALEX
DELTA and Puhas Meri exercises.
Medium
Financial
Guarantees
Explore requirements for OWF
developers to maintain liability insurance
or financial guarantees for pollution
incidents.
Medium
International
Cooperation
Initiate a HELCOM working group or
joint seminar to develop standardized
guidelines for OWF pollution response.
Medium
Drift Modelling
Implement oil spill drift modelling tools
calibrated for OWF microclimate
conditions.
Medium
A key structural output of the research is a
preliminary framework for developing OWF-specific
pollution response plans, covering three distinct
phases: the construction phase, the operational phase,
and the decommissioning phase. Each phase presents
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distinct risk profiles and requires tailored response
strategies. For example, the construction phase
involves heavy vessel traffic and the use of hydraulic
equipment, while the operational phase involves the
routine risk of transformer oil leaks and vessel
collisions. The decommissioning phase, often
overlooked, involves the removal of large structures
and the potential for disturbing seabed contaminants.
5 DISCUSSION
The findings of this study align with and extend
broader understandings of the environmental and
navigational risks associated with the expansion of
offshore wind farms (OWFs) in the Baltic Sea. The
increasing spatial interaction between OWFs and
maritime traffic introduces more complex operational
conditions and elevates the probability of incidents,
thereby requiring adaptation of existing pollution
response strategies. The study’s primary contribution
lies in its empirical grounding in the Estonian and
Baltic Sea context, offering a detailed understanding of
challenges that are not fully addressed in generalised
international frameworks.
A central finding is the structural vulnerability of
Estonia’s current response model in OWF
environments. The reliance on large, multi-purpose
vessels represents an economically rational solution for
a small state; however, constrained manoeuvring space
within turbine arrays limits the effectiveness of such
assets. This indicates a need for more decentralised and
agile response configurations. Combined with the
finding that Estonia currently meets approximately
53% of the HELCOM-recommended response capacity,
this suggests that the system operates with limited
redundancy and may face increasing pressure as OWF
development progresses.
The study identifies a governance gap in the
integration of offshore wind farm (OWF) developers
into marine pollution response planning. Current
regulatory arrangements do not clearly define the
responsibilities of developers with regard to pollution
preparedness, resulting in a structural reliance on
state-led response mechanisms. Interview findings
suggest that developers are willing to contribute to
preparedness but expect clearer institutional guidance
regarding their operational role. In this context,
project-specific contingency planning may offer a
mechanism for improving the interface between
developer capabilities and the national response
system. Such approaches would allow operators to
support early-stage response activities, resource
availability and situational awareness without altering
the overall command responsibility of the state. This
issue is closely related to the application of the
“polluter pays” principle, which provides an existing
legal basis for linking environmental responsibility
with preparedness obligations. Strengthening its
interpretation in the context of OWFs may improve the
coherence between regulatory requirements and
operational response capability.
In addition to technical and regulatory aspects, the
findings highlight the importance of the human and
organisational dimension in OWF pollution response.
Effective adaptation to turbine-field environments
requires not only new equipment and procedures, but
also changes in operational thinking. As one expert
noted, “We need a chapter in our textbooks: ‘Pollution
response in a wind farm.’ Then it will be clear that we
take this as seriously as ice conditions or storms”
(Expert 8). This reflects the need for a broader shift in
professional practice, including the systematic
integration of OWF-specific scenarios into training
programmes and operational frameworks.
The study has several limitations. The findings are
based on qualitative expert interviews and may
therefore reflect individual and organisational
perspectives. In addition, quantitative data on spill
probabilities and response performance in OWF
environments remain limited. Future research should
therefore complement qualitative insights with
simulation-based modelling and scenario testing to
evaluate response effectiveness under spatially
constrained conditions. In particular, further attention
should be given to seasonal variability, including ice-
covered conditions, which introduce additional
constraints on vessel manoeuvrability, equipment
performance and response timing in the Baltic Sea
context. Furthermore, as Estonia’s first OWF projects
progress towards construction, the regulatory and
operational environment will continue to evolve,
requiring periodic reassessment of the findings
presented in this study.
6 CONCLUSION
The planned construction of offshore wind farms in the
Estonian marine area introduces significant new
challenges for marine pollution response. While
Estonia possesses a foundational response capability
built over decades of investment and international
cooperation, it is currently not optimized for the
complex operational environment of a wind turbine
field. The study confirms that the current system
functions adequately under standard conditions but
would face critical gaps in OWF zones, particularly
regarding vessel maneuverability, equipment
availability and regulatory clarity.
The core contributions of this article are: (1) a
comprehensive empirical assessment of Estonia's
marine pollution response readiness in the context of
OWFs; (2) a comparative analysis of international
practices in OWF pollution response planning; (3) a
preliminary framework for developing wind-farm-
specific spill response plans covering construction,
operational, and decommissioning phases; and (4) a set
of policy recommendations for state authorities, OWF
developers, and regional bodies.
To mitigate the identified risks and ensure the
protection of the Baltic Sea ecosystem, the following
strategic adjustments are urgently recommended.
First, regulatory updates should mandate that OWF
developers submit comprehensive MPCPs as a
prerequisite for building permits, with risk scenarios
and mitigation measures covering all three phases of
the OWF lifecycle. Second, investment is needed in
smaller, highly maneuverable response vessels and
specialized containment equipment suited for confined
spaces, with pre-positioning of equipment near high-
risk OWF zones. Third, OWF operators must be
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formally integrated into the national crisis
management structure through institutionalized
dialogue, joint communication protocols, and public-
private cooperation agreements. Fourth, specialized
training modules focusing on pollution response
within OWFs should be developed and OWF scenarios
should be incorporated into national and international
exercises. Fifth, Estonia should advocate for the
development of standardized HELCOM guidelines for
marine pollution response in OWFs, fostering
knowledge exchange and regional preparedness across
the Baltic Sea.
By implementing these measures proactively,
before the first Estonian OWF becomes operational,
Estonia can successfully navigate the intersection of
renewable energy development and marine
environmental protection. The thesis highlights that
proactive investment in planning, regulation and
intersectoral cooperation today will reduce the long-
term environmental and economic costs of pollution
incidents tomorrow. Moreover, by taking a leadership
role in this area, Estonia has the potential to serve as a
model for other Baltic Sea states facing the same
challenge.
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