According to an analysis of the Hiiu maritime area commissioned by the Ministry of Finance, which was made public at the beginning of the year, wind farms cannot be built off the coast of Hiiumaa, mainly due to their potential impact on local birds.

In a written appeal to the Ministry of Finance, Sunly Wind said, that although the analysis was based on previous studies, a few days after its findings were made public, they were seemingly used as a convincing argument for not initiating the company's building permit procedure.

According to Sunly, the spatial analysis should be taken into account, but only alongside several other studies, which have also been conducted to determine the suitability of the Hiuu maritime area for the construction of wind farms. Its conclusions should therefore, not be used as the sole basis upon which decisions to award of planning or building rights are legally determined.

Sunly pointed out, that while no new environmental research was conducted as part of the analysis, the conclusions reached appear to contradict those of previous studies.

Sunly is also critical of the methodology used to conduct the analysis, as well as its failure to utilize all the available data, including bird surveys.

"The environmental impact of other methods of energy production have also not been considered. These can be many times more damaging to the environment and the climate, as well as to birds directly," Sunly said.

According to the spatial analysis, it would be possible to build wind farms in two areas between Hiiumaa and Saaremaa. However, Sunly considers these locations unrealistic, due to their distance from the coast. The company also pointed out, that in its network development plan, Estonia's transmission system operator for electricity and natural gas Elering, does not foresee the construction of such a large-scale offshore network over the next decade.

Furthermore, wind farms in the recommended areas would need to be constructed on floating platforms, with the technology required to do so in icy waters not yet available.

 "Even if this were the case, it would be unreasonably expensive for society. However, in practice the area is not viable, because this kind of foundation technology for icy conditions does not exist."

According to Sunly, the construction of a wind farm on the second proposed site would necessitate the construction of cable corridors crossing Hiiumaa and the sea, something it also considers unrealistic.

"It is important to emphasize here, that previous applications for planning permission in the Hiiu maritime area are mostly of the type where the developer is likely to the one willing to bear the cost of connecting to the grid, as that connection could be made directly across the sea."

Sunly went on to say, that a 2018 court decision had not ruled that wind farms could not be constructed in the Hiiumaa maritime area, but that a more thorough environmental impact assessment of the region was required.

"In 2018, the court annulled the Hiiumaa maritime planning because the state had failed to conduct a sufficiently high quality strategic environmental impact assessment. The court did not say that wind farms could not be built in the planned locations near Hiiumaa, but that the Ministry of Finance had not done its job well enough. The strategic environmental assessment report remained valid," the company said.

According to Sunly, the content of the spatial analysis is not consistent with that of the environmental impact analysis.

"The spatial analysis only omits areas where wind farms will probably never be built. In light of the shortcomings listed above, this document should certainly not be used to exclude sites or to initiate procedures for building permit applications."

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