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Russia’s Invasion of Ukraine Poses an Increasing Risk to Civil Aviation

The European Union Aviation Safety Agency (EASA) has warned that Russia’s invasion of Ukraine could result in civilian aircraft being accidentally targeted or airlines being subjected to cyber attacks.

EASA has consequently developed a safety risk portfolio to identify the 20 safety issues affecting commercial aviation which stem from or are associated with the conflict. The agency developed the portfolio in close cooperation with member state regulators and industry partners to capture new or emerging safety issues. The assessment followed surveys of EASA’s safety partners, comprising the EASA Member States’ regulators and industry. 

The first of the four safety issues identified by EASA relate directly to security. Of most concern is the increase in cyber attacks associated with the conflict. Second is the separation with unidentified aircraft. Between Finnish and Estonian territorial waters there is a narrow corridor of neutral waters providing Russia with access to the Baltic Sea and Kaliningrad. Unidentified aircraft using these routes can conflict with other traffic. EASA underlines the importance of using transponders, filing flight plans, and communicating with air traffic control (ATC). Such flights over neutral waters have increased significantly, increasing ATC workload, and imposing an effect on the flight profiles of civilian aircraft. A further security concern pertains to errors in civil aircraft identification by ground military forces and airborne assets outside the conflict zone. As shown by previous wars, misidentification is easy in confused arenas of warfare and the development of this risk is common to all combatants. Add the potential for jamming electronic aids involved with navigation or identification tools, it is easy to see the risks for innocent aircraft. In addition, GPS signals may be manipulated leading to navigation or surveillance degradation. Due to military use of electronic warfare systems, the GPS signal may be disturbed in countries adjacent to the conflict zones and affect the operation of aircraft en-route, during approach and departure and/or while operating at airports. The GPS interference may be only temporary, and EASA reminds pilots to be aware of this risk and contingency procedures should be included in flight planning.

Away from the direct security implications, EASA warns that aircraft manufacturers are unable to support their fleets in Russia, due to sanctions, and this will have an impact on the safety standards of the affected aircraft. That includes maintenance support, customer service, technical assistance, and parts. Type Certificate Holders will not receive information from Russian operators regarding failures, malfunctions, defects, or other occurrences, which cause or might cause adverse effects on the continuing airworthiness of the product. Other infrastructure risks include those stemming from mixed civil-military operations and spare parts shortages which could result in aircraft that is not airworthy.

There is also of course the risk, which has become a reality, of Ukrainian aviation infrastructure being directly targeted. In July 2021, the main airport in the port city of Odessa opened a new runway which the city’s mayor said was intended to help bring in tourists from around the world. At the end of April 2022, this runway was destroyed by a missile strike.

In terms of air traffic management, EASA says there is an increased risk of airspace infringements by military drones or aircraft spilling over from conflict zones. Military drones and aircraft operating in the conflict zone may inadvertently infringe adjacent civil airspace, leading to losses of separation and a general disruption to operations. Additionally, ad hoc requests to establish Temporary Segregated Areas (transit corridors) and the reservation of military areas outside of the normal operational hours may lead to additional workload as the requests must be coordinated with all parties involved. Another concern is that civilian traffic may unknowingly infringe prohibited/restricted airspace along the Ukrainian border that has been allocated for military operations. Further, the reduction of available airspace (due to military activity) creates a corresponding increase in traffic in the remaining available airspace. This may lead to congestion or high levels of traffic on certain routes.

The regional response to the war in Ukraine may also result in European countries experiencing an increase in unexpected military exercises, and unexpected ‘due regard’ flights (movement of military aircraft from one air base to another). This could increase risks to commercial operations in certain areas. Unusual traffic types such as formation flights, aircraft refueling, and others may increase in certain areas. Overall, this will increase sector workload.

Human performance risks include crew fatigue due to having to take longer routes to avoid conflict zones and Russian airspace. These routes may be less well known to flight crew and EASA says that working on very long flights, flights at high latitudes close or over the poles contribute to the amount of cosmic radiation that crew members are exposed to. There has also been a risk of degradation in skills and knowledge following the downturn in traffic due to the COVID-19 pandemic. This is prolonged by the war in Ukraine, which also presents a more complex operating environment. 

EASA is right to be concerned. In October 2015, a final report by the Dutch Safety Board on Malaysia Airlines flight MH17, which crashed on July 17, 2014, in Donetsk Oblast, Ukraine, concluded the Boeing was “shot down over the eastern part of Ukraine, where an armed conflict broke out in April 2014,” killing all 298 people on board. In further detail, the report noted a Russian-made Buk missile hit the front left of the plane causing other parts to break off. The report does not say who fired the missile, but says airspace over eastern Ukraine should have been closed. Russia, inevitably, disagreed with the findings of the report. We are now in a very different operating environment in 2022, and the conflict has escalated far beyond the need to be concerned solely about airspace over conflict zones. Russia’s cyber arsenal is more sophisticated than it was in 2014, and the Kremlin has made no bones about the fact it is watching Ukraine’s allies and will act in retaliation. EASA’s report has little detail on its considerations of the cyber threat but the fact that it places this risk at the very top of its list should be cause enough to ensure airlines have the very best cyber defense available without delay.

EASA will continue to monitor the safety situation and will provide further updates to the report as needed. For example, the conflict is causing an energy crisis which may impact aviation safety by curtailing financial investment in security measures.

Read the full safety risk review at EASA

Kylie Bielby
Kylie Bielby has more than 20 years' experience in reporting and editing a wide range of security topics, covering geopolitical and policy analysis to international and country-specific trends and events. Before joining GTSC's Homeland Security Today staff, she was an editor and contributor for Jane's, and a columnist and managing editor for security and counter-terror publications.

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