On September 20, The Kharkiv City Council sent an appeal, addressed to Ukrainian Prime Minister Volodymyr Groisman, regarding concerns over recent actions by the European Aviation Safety Agency (EASA). Specifically, the appeal cites a draft bulletin allegedly sent by the EASA to the Ukrainian State Aviation Service (SAS), proposing restrictions upon international aviation in eastern Ukraine (City.kharkov.ua, September 20). Neither the EASA nor the SAS have released the document in question into the public domain. Though the SAS confirmed receipt of the EASA document, the Ukrainian agency has stated only that it will liaise with the Ukrainian government to adopt an official position (Avianews.com, September 20). To date, the aforementioned appeal by the Kharkiv City Council against the adoption of the EASA proposal is the sole official notification and documentation by a government body that exists in the public domain.
According to the Kharkiv City Council’s appeal, it appears that the EASA intends to restrict flights that fall within the Dnipro Air Traffic Control zone. Since the downing of Malaysian Airlines Flight 17 and the murder of all on board in mid-2014, the air space over the territories of the temporarily occupied Donbas and the area of military engagement remains closed. But if the proposed EASA restrictions on the airspace controlled by Dnipro Air Traffic Control become a reality, that would effectively block civilian air traffic over half of Ukraine—almost all airspace east of the Dnipro river in fact. Thus, in adopting such a proposal, the European aviation watchdog would effectively isolate the major Ukrainian cities and transport hubs of Dnipro, Zaporozhye and Kharkiv from civilian air travel.
This would not be the first time these airports have been cut off. In 2014, the Security Service of Ukraine (SSU) requested restrictions for a period of two weeks. And the United States’ Federal Aviation Authority (FAA) banned all flights to Crimea and Dnipro since 2014 as well. That ban lapses on October 27, 2018, unless it is renewed (Federalregister.gov, July 22, 2016).
Clearly, the proposed restrictions to be placed on the airspace controlled by Dnipro Air Traffic Control would have a negative effect upon Dnipro, Zaporozhye and Kharkiv. These major urban centers would face damaging consequences to local business, foreign investment attractiveness, employment at the airports and beyond, as well as civilian tourism and travel. Finally, by extension, such limitations on air links would undercut the newly initiated visa-free travel system between the European Union and Ukraine (EUobserver, June 12). Of course, these are not foremost considerations for the EASA, a body tasked with aviation security.
What exactly prompted the EASA to suddenly decide to tighten restrictions over eastern Ukraine? Whatever intelligence or information this international body is acting on, is clearly sensitive and perhaps explains why the EASA’s original proposal document has not been released. But at least in the public domain, there have been no recently observable dramatic increases in military operations within the temporarily occupied territory of Donbas or along the line of contact. Furthermore, there have been no civil aviation crashes or major incidents within this airspace since MH17 in 2014. If the EASA’s risk analysis has changed so dramatically, why has it and how credible is the intelligence or information upon which that new risk analysis is based?
Another important question is how will the affected airlines flying to and from eastern Ukrainian cities react? Zaporozhye airport is serviced by Rose, Motor Sich, Turkish Airlines, Anda Air, Bravo Air, Atlas Global, Atlas Jet and Ukrainian Airways (Flightstats.com, accessed September 24). Dnipro Airport sees flights from Dnipro Air, Ukrainian Airways, Ellin, Rose and Austrian Airlines (Dnk.aero, accessed September 24). Whereas, Kharkiv is an air destination for, among others, Ukraine Airways, Turkish Airways, Lot, Belavia and Pegasus (Hrk.aero, accessed September 24).
European airlines will almost certainly not be willing to ignore the EASA’s restrictions. But perhaps domestic Ukrainian airlines could continue their flights to and from the region. The complication, however, stems from the fact that—with the exception of Motor Sich, which manufactures and owns its own aircraft—almost all other Ukrainian air carriers lease their planes. It is therefore necessary to consider how the direct owners of the airplanes in question will behave. Some may insist that the EASA’s decisions be adhered to. Others may choose to ignore the Agency, but at a significant financial cost since insurance companies would no doubt insist upon raising their premiums (Globalsecurity.org, accessed September 24).
For the Ukrainian government, improving the economy and social mobility are clearly top priorities. Thus, the adoption of the EASA’s draft would be a significant blow, damaging the image of Ukraine internationally and effectively isolating half the country from accessible interstate flights. There may or may not be identified risks within the draft EASA document that Ukraine can address and thus potentially prevent the adoption of the proposed restrictions. But it is unclear how Kyiv plans to deal with this matter, especially without insight into what is driving the EASA’s change in its risk assessment.