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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,