Protect Estonian Waters! Stop dangerous STS transfers along Estonian seashores

The lowdown

Forbid dangerous chemical & oil operations to take place right in front of the Baltic shores, putting Estonia's sea at risk of major catastrophe.

The maritime industry is performing very high risk operations called "Ship to Ship" (STS) transfers and bunkering in Estonian waters due to very loose legislation and lack of taxation. These operations often lead to leaks or accidents causing spillage of crude oil or dangerous chemicals in the sea.

Estonia's Ministry of the Environment is planning to keep on allowing them in Tallinn bay (Haabersti), at zero benefit to the Estonian people and at the expanse of nature. All experts agree these operations could cause a catastrophe in the already fragile maritime ecosystem of the Gulf of Finland.

Estonia should not be a free haven for careless ship operators. We demand STS operations be banned from Estonian waters and only take place when absolutely necessary, and only in ports, where there is equipment to do them as safely as possible.


What are Ship to Ship (STS) operations?

Ship-to-ship transfers are operations where a tanker, usually carrying crude oil, natural liquefied gas, or dangerous chemicals, transfers some or all of their cargo to another ship, while at sea. This is done by connecting a hose between the two ships, while they are in slow movement or stationary.

This is usally done when one of the ships cannot reach its final destination, for example because its draft is too high for the port's shallow waters, or because the port's waters are frozen and the ship's hull cannot break ice. Sometimes STS transfers also occur to refill oil of a ship for propulsion, in which case it's referred to as "STS bunkering".

A typical situation in Estonia would be a tanker exporting Russian crude oil during winter. An expensive ship that can break ice would leave the Russian port, then transfer its contents to a cheaper-to-operate ship, which in turn will export the oil to another country. This is done in Estonian waters because it's cheap, thanks to the lack of legislation and taxation, but it could also be done in port.

Why are Ship to Ship operations dangerous for Estonia?

Even the maritime industry acknowledges that STS transfers are very high-risk operations that can lead to ship collisions and environmental disasters. Some common causes of accidents are: adverse weather conditions, ill-trained crews, damaged equipment (e.g. ruptured or leaky hose), crew fatigue, communication issues between the two ships involved... According to an estimation from the National Technical University of Athens, 80% of STS incident are due to human error.

Slideshow from a lecture at the School of Marine Engineering of Athens highlighting common risks from STS operations

Among some recent high-profile accidents, one can cite a large oil spillage that occurred in July 2019 in South Africa, where 1600L of oil were spilled during a bunkering operation. "Even though a commercial oil spill response service provider was summoned to mitigate and contain the spread of the spill, more than 100 birds, all endangered species, were oiled. It took ~ 10 hours to recover 350L of the spilled HFO. 50L of HFO was left in the sea.". And this was just a small bunkering operation, nothing like the large STS transfers allowed in Estonia, which move 85,000 tons of crude oil, as happened in Paldiski area in January 2021.

An even more high-profile case is that of a very large oil spill which ravaged the coast of Brazil in September 2019. This was investigated by Brazilian authorities which uncovered its cause: a Greek ship performing an undocumented ship-to-ship transfer of crude oil in the Atlantic ocean. Despite the vastness of the ocean, the quantity of oil was so big that it landed on almost 300 Brazilian beaches and was deemed the country's worst environmental disaster.

Left: oil spill from a STS transfer caught on satellite images outside Iraq, 2018.
Right: a Brazilian beach damaged by oil from an STS transfer that went wrong, Sep 2019.

A leakage or spill of crude oil or other chemicals along Estonian shores would be a disaster for the sea ecosystem, human health, and the natural beauty of Estonia's coast. It already takes years and considerable effort & cost to repair the environmental damage of oil spills and leaks in open seas. It would be even slower and more deadly in the Gulf of Finland, which is a closed sea with limited currents to wash up petroleum and take away its dangerous chemicals. As Kai Künnis-Beres, a marine biologist and head of the marine ecology laboratory at the Institute of Marine Systems at Tallinn University of Technology, put it: "Should an accident occur and a large amount of oil products end up in the sea, the entire coastal sea is gone! In our climate, natural self-cleaning takes a very long time."

What is the current Estonian legislation?

Until this year, STS transfers were barely regulated in Estonia, a huge loophole which attracted tankers from the whole of the Baltic Sea to Estonian shores. After the uncovering of STS transfers taking place next to the Pakri nature reserve in January 2021, the Estonian Ministry of the Environment paused STS transfers until further analysis was performed. In March, the ministry came back with proposed legislation to keep allowing STS transfers to take place, but only in one anchorage area, the so-called "Tallinn G" area. This is right next to Tallinn, in the strait between Kakumäe beach and the nature reserve of Naissaar Island! (see map below). The risk of STS transfers is not going away, instead it's being concentrated right in the middle of Tallinn bay. As for bunkering operations (which caused the catastrophe in South Africa), they are not even covered by the law.

The Ministry's draft legislation proposed to concentrate all kinds of STS operations (crude oil, petroleum products, NLG and toxic chemicals) to take place right next to Tallinn, in the so-called "achorage area G" (left), between Kakumäe and Naissaar Island.

It's worth noting that there is little economic benefit for Estonia from this tanker activity. Almost all ships involved have foreign pavillion and employ foreign crew, they are only transiting through Estonia because of the lax regulation. In contrast, Finland's legislation (L 275/2017) allows STS in two special areas on the Finnish coast, far away from any nature reserve, and more importantly, it's disincentivised through taxing. As per this article, "a company planning to operate in Finnish territorial waters is also required to pay the waterway charges and costs associated with the readiness of ships to deal with possible pollution."

While the Ministry of the Environment says they might tax STS operations in the future, right now the draft legislation only proposes to move these operations to the Kakumäe area. There is no tax benefit and no benefit to local industry. In case of incident, our nature would be ruined and the Estonian taxpayer would bear all the costs.

What do you propose?

We propose that STS operations, transfers as well as bunkering, be banned to take place in Estonian waters. While we recognise these operations are sometimes necessary for martime opeations, they should remain exceptional and only take place in ports (e.g. Vene-Balti or Muuga in the Tallinn area, to name a few), where there is proper equipment and trained staff who can provide the necessary safety guardrails to minimise the risk of any environmental accidents. The ports union (sadamate liit) already proposed such amendment earlier this year.

We also propose that the government tax those operations so that there would be no incremental cost to the Estonian taxpayer from maintaining anti-pollution vessels and training staff, should these be necessary. The goal of the taxation is to disincentivise those operations in Estonia, and use the money as insurance should any accident occur (which should be less likely if they take place in port).

Sign our petition to ask the Estonian government to ban STS opeations from Estonian waters!

Press coverage & Further reading