Several building permit processes for potential offshore wind farms are currently underway for which the Ministry of Defense has provided feedback. Please describe the expectations the ministry has set for offshore wind farms.

Military defense and a functional early warning system are certainly important for us. The general marine spatial plan, which establishes where offshore wind farms can theoretically be built in Estonia, was initiated years ago. We completely ruled out the northern coastline and concluded that there are only two larger and one smaller area in Estonian waters where we could even consider discussing offshore wind turbines. These areas together account for about 4 percent of the sea area.

We are now in the phase where developers are starting to consider specific construction plans, and it is important to understand that when building on these designated areas begins, approval must also be obtained from the Ministry of Defense. As part of this approval process, we will review with experts once again whether the specific development is favorable for us. If we identify, for instance, a need for additional compensation or mitigation measures, we will certainly document and implement these in cooperation with the developers.

For example, the building permit for Saare Wind Energy is expected to be issued in the coming months, meaning the process is already underway. Last Friday, the Consumer Protection and Technical Regulatory Authority (TTJA) revealed that, so far, the Ministry of Defense has focused solely on issues related to height restrictions within the framework of building permit proceedings. From the perspective of national defense, is it also important how densely and in what configuration the turbines are located, or what kind of vibrations they generate?

If we speak entirely theoretically, then yes, the specific placement of turbines can indeed have varying effects. Therefore, every project must be coordinated with the Ministry of Defense to allow our experts to model the specific impact, provide recommendations and issue guidelines, including any additional compensation measures that may be required from developers.

I would draw a parallel to onshore wind farms, where such practices with developers are entirely common. In certain cases, we have found effective solutions by adjusting the placement of turbines slightly, making it possible to establish a farm of a suitable size.

Do I understand you correctly in that the Ministry of Defense sees its role not in the planning process, but later, when applying for the building permit?

We can provide these approvals at various stages, and naturally, it is in both our and the developer's interests to establish mitigation measures as early as possible.

Why haven't you provided input as concerns the placement and vibration levels of turbines so far?

In the context of the building permit, we have noted that mitigation measures may need to be implemented.

We are also conducting a study carried out by an international company with extensive experience in this field. They will provide us with the best input on what, if any, mitigation measures are needed. This expertise will enable us to guide developers accordingly in the future.

When will this study be completed?

The target is early 2025.

When applying for support for offshore wind farm compensation measures, Estonia promised the European Commission that in the fourth quarter of 2025, the Ministry of Defense would announce on its website that there are no height restrictions for wind farms in the Gulf of Riga and west of Saaremaa. Can you ensure this announcement is posted as promised?

We are well on schedule with our activities, so at the moment, I see no reason why such an announcement could not be made. We have made good progress in this regard.

The radars proposed as compensation measures contribute to our air defense. Please describe whether and to what extent Estonia, based on current agreements, has acquired or is in the process of acquiring additional resources related to the Defense Forces' capability to monitor activities both underwater and on the surface.

If there are specific issues regarding maritime surveillance, this will be a matter for negotiations with the developers, depending on the results of the mentioned study.

Offshore wind farms have been discussed for a very long time. Areas suitable for wind farms were designated in marine spatial plans years ago, and companies are already setting their business plans in motion. How did we arrive at a situation where the study determining how wind farms affect our maritime surveillance capabilities will only be completed in 2025?

We actually commissioned this study some time ago. For context, broader maritime surveillance was transferred from the Police and Border Guard Board to the Navy only a couple of years ago. Once we took on this responsibility, we began addressing the potential impacts in earnest. So, I believe we started at the earliest possible opportunity.

You commissioned the study years ago?

We started the process a few years ago, but I believe we commissioned this particular study from a foreign company toward the end of last year.

Has the Defense Forces (EDF) provided input to the Ministry of Defense as part of the ongoing building permit processes, highlighting the potential negative impacts of offshore wind farms on our maritime surveillance, as well as, for example, acoustic intelligence?

I can respond by saying that all planning and building permits within this area of governance are discussed with Defense Forces experts, and we take their recommendations into account. We have done this in the past and will continue to do so in the future.

Has the EDF then stated that all the risks mentioned by the Navy commander last week should be included in the feedback on the building permit application?

Yes, we have provided feedback to developers, indicating that in certain cases, additional compensation measures may be necessary.

You keep mentioning additional compensation measures. So far, taking the example of air surveillance radars, the state itself has implemented these measures. Am I understanding you correctly that these additional compensation measures would no longer be procured by the state but by the developers?

That is indeed one possible outcome of the study – that in certain areas, such measures may be necessary. Today, it cannot be stated with certainty that this will be the case, but if it is, then naturally, it will be a condition for these developments to proceed. From our perspective, we cannot allow gaps in the early warning system.

How is it possible that the Navy commander describes us as building a 20-kilometer-deep and 50-kilometer-wide wall in front of ourselves, behind which we simply cannot see, and you are saying that perhaps the study will reveal that some compensation measures might be needed?

Early warning is multi-layered. There are other means of gathering information and other platforms from which to obtain situational awareness data. So, I believe both perspectives are valid. Ultimately, we are working to ensure that early warning is not compromised. We will certainly find the solutions needed to guarantee this.

If there is a "wall" in front of coastal maritime surveillance radars and other equipment, as described by the Navy commander, do compensation measures mean that the equipment must be placed either on the other side of the offshore wind farms or within the wind farms themselves?

That could be one solution, but I wouldn't jump ahead on these questions. The results of the study should be available to us fairly soon, and then we can discuss more concretely what measures might need to be implemented, and how.

As for acoustic intelligence – what we can detect underwater – how could the vibrations caused by turbines in the water possibly be compensated for?

Unfortunately, I cannot go into detail regarding underwater surveillance.

Is the survey you commissioned meant to answer that question?

This study does not look at the underwater dimension.

How will we know then?

I cannot comment on that in more detail.

Did I understand correctly that the Ministry of Defense's position is that if these compensation measures need to be implemented, it is the responsibility of the developers?

We will certainly discuss this with the developers. Indeed, it is more likely to be a condition set by us for these parks to be established. However, we are, of course, happy to support and advise developers and work together to find the best possible solutions.

Does Estonia have any relevant experience, a developer having to purchase such equipment at their own expense? After all, the Sõnajalg brothers (developers of the Aidu wind farm – ed.) could have been required to buy those radars themselves if they were so eager to build their turbines.

When we talk about offshore wind farms, their financial scale is significantly larger than that of onshore wind farms. So, proportionally speaking, it is easier to apply such an approach in the case of offshore wind farms.

One thing is what we can see. Another is what and how we can influence. The Defense Forces say that offshore wind farms significantly interfere with the use of our anti-ship missiles. How can missiles be launched to the other side of offshore wind farms?

I think this issue might have come up a bit out of context. Anti-ship missiles are entirely relocatable. And as regards ships in motion – we see them before, and we see them after. So, I don't think this will be a significant problem. We can still influence those ships, perhaps just from a different location.

In other words, we'll just wait for the enemy to come out from behind the 50-kilometer long wall?

For example.

Isn't that taking a bit too much of a risk? It would be better if we could influence the adversary's vessels over a slightly wider area without inadvertently creating additional hiding spots for them ourselves.

I think there are also natural features and various locations where we can't always fire directly at every moment. And it's clear that Estonia is not the only country that could or should target adversary ships in a crisis situation. There are other NATO countries in the region as well, so I think this issue needs to be viewed in a somewhat broader context.

The Finns are acquiring four naval vessels for €1.3 billion, equipped with similar missile systems. Does Estonia not have such a plan?

Estonia will also start replacing its naval vessels at some point. The exact type of vessel is still under discussion. In time, we will see whether they will have such capabilities or if we will find other solutions.

The building permit process for Saare Wind Energy could conclude within the next few months. The building permit processes for the Gulf of Riga wind farms are reaching a stage where environmental impact assessment documents will be published. The Ministry of Climate hopes to announce auctions in the first half of next year to set price floors and ceilings for wind farms. The ministry expects bids by next summer. By then, developers should have clarity on the costs they will face. By when will the Ministry of Defense provide clarity on the conditions it will set for developers?

The study we are conducting will be completed in the first quarter of next year. All the information from it will be shared immediately with the Ministry of Climate and the developers. We do not see a need to revise our fundamental approvals in any way – certainly not. However, if clarifications or mitigation measures are needed, we can proceed with them in consultation with both the Ministry of Climate and the developers.

Currently, there is a regulation prohibiting the construction of solar parks with capacities exceeding 50 kilowatts within a 60-kilometer radius of the Defense Forces' radio intelligence equipment. Has the Ministry of Defense proposed easing this restriction?

Yes, we are certainly exploring ways to ease this restriction. However, this will be done in a manner that clearly demonstrates that our warning system will not be compromised as a result.

What does "clearly demonstrates" mean? A few years ago, there was talk that the Ministry of Defense would commission an analysis from TalTech on this matter. Is that analysis now complete?

The recommendations section of that analysis is complete. However, we are also looking more broadly at international practices, such as those in Finland. Naturally, this means that we must have unequivocal results from certain measurements to ensure that there is no impact on early warning systems or that such impacts do not increase.

What did the practices of Finland and Sweden tell you?

In Finland, the conditions are not as strict compared to the ones currently in effect in Estonia. We are still discussing these internally, and hopefully, we will be able to propose something similar in Estonia, allowing solar park developers to utilize a larger area.

However, it is equally important that we assess each park individually to determine whether it affects us and whether we can permit it or not.

By what time do you expect to issue the draft regulation?

I hope it will be done early next year.

The Aidu wind turbines are currently operational, but the compensation measures are not yet in place. How did it happen that, at this point, the Aidu turbines can interfere with the Defense Forces? How was such an agreement reached that allowed these turbines to start operating?

The agreement was reached by setting a deadline – July 1 of this year. Until the radars and other systems are operational on our side, we can use temporary measures. Unfortunately, I cannot go into detail about those measures, but we are aware of the situation and have responded accordingly.

Do these systems fully compensate for the shortfall? The Defense Forces say they do not.

I cannot comment on these details.

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