Betz limit for sailboats?

In the study of sustainable energy, there is a nice result on windmills, called the Betz limit: There is a finite limit to the fraction of the kinetic energy of the wind that a windmill can absorb or exploit. The reason is often stated as: If the windmill took all of the power in the wind, the wind would stop, and then there would be no flow of energy over the windmill. I'm not sure I exactly agree with that explanation, but let's leave that here.

On my travel home today I worked on the possibility that there is an equivalent to the Betz limit for sailboats. Is there an energetic way of looking at sailing that is useful?

One paradox is that a sailboat is sailing steadily when the net force on the boat is zero (just like when a windmill is turning at constant angular velocity). In the Betz limit, the windmill is thought of as having two different torques on it, one from the wind, and one from the turbine. Sailing has no turbine. So this problem has a conceptual component to it.

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