General Aviation

Dear EASA General Aviation community,

I am writing on behalf of a group of private pilots, student pilots and general aviation enthusiasts with Russian citizenship who reside in the European Union.

We are all affected by the EU Regulation 2022/334 (Article 3d) that was clearly intended to make flights and maintenance of commercial aircrafts operated by Russian aircarriers and private jets of Russian oligarchs impossible in the European Union:

“ It shall be prohibited for any aircraft operated by Russian air carriers, including as a marketing carrier in code-sharing or blocked-space arrangements, or for any Russian registered aircraft, or for any non-Russian-registered aircraft which is owned or chartered, or otherwise controlled by any Russian natural or legal person, entity or body, to land in, take off from or overfly the territory of the Union.”

The objectives of the restrictive measures against Russia are declared as follows:
1) weaken the Kremlin’s ability to finance the war;
2) impose clear economic and political costs on Russia’s political elite responsible for the invasion.

According to the current interpretation EASA stated in the corresponding FAQ, the ban concerns all kinds of motorized aircrafts (E-Class, Ultralights) as well as gliders and even drones. It prohibits all kinds of flying activities, including recreational flying, makes no distinction between a small two-seater airplane and a luxurious business jet and also does not differentiate between legal residents of the European Union and residents of Russian Federation.

We condemn the war. We are not oligarchs financing the war. We do not have any influence on the Kremlin’s politics. We are ordinary men and women legally residing in the EU. We believe that a legal EU resident's ability to fly an aircraft for recreational purposes within the EU territory is consistent with the objectives of the restrictive measures. We also believe this Regulation in its current interpretation has clear signs of discrimination solely on the basis of nationality.

In regard to the aforementioned we ask EASA:
1) To review the wording of the FAQ with the goal to explicitly exclude all general aviation pilots (including student pilots) who are Russian nationals legally residing in the EU and are not subject to personal sanctions from the restrictions, as stated in Article 3d:

“The competent authorities may authorize an aircraft to land in, take off from, or overfly, the territory of the Union if the competent authorities have determined that such landing, take-off or overflight is required for [...] any other purpose consistent with the objectives of this Regulation.”

2) To help us, as the most relevant Agency, to convey the feedback to the European Council and European Commission in order to amend the EU Regulation 2022/334 with the same goal as stated in 1.

Sincerely,
Ivan Kuznetsov

As a result of the work undertaken under RMT.0476, EASA is pleased to announce the publication of NPA 2022-04 on 25 May 2022, proposing amendments for a comprehensive update of the SERA IR (Regulation 923/2012) and of the related AMC and GM.

The proposals issued with this NPA:
• ensure synchronisation between the SERA regulatory framework and the originating transposed International Civil Aviation Organizaton (ICAO) provisions, especially those of ICAO Doc 4444 ‘PANS-ATM’ up to its Amendment 9, in particular in relation to new procedures on standard instrument departures (SID) and standard instrument arrivals (STAR) and other provisions identified as being of a ‘rules-of-the-air’ nature;
• introduce changes to the existing radio communication failure procedure in anticipation of a future amendment to ICAO Annex 2, thus bringing forward in time the related operational benefits;
• remove the Supplement to the Annex to the SERA IR, containing the commonly agreed differences to ICAO Standards and Recommended Practices (SARPs), and introduce regulatory references to Regulation (EU) 2018/1139 on the notification of differences;
• introduce speed restrictions to prevent supersonic flights over the territory of the EU, with the objective of protecting citizens from unacceptable sonic booms generated by supersonic transport (SST) aircraft, in order to maintain a high level of environmental protection;
• address issues in the implementation of the SERA IR as either identified by EASA through its standardisation activities or raised by stakeholders;
• satisfy a safety recommendation addressed to EASA, related to the inclusion of information on ballistic parachutes on board in the flight plan; and
• remove editorial mistakes and identified consistency issues.

This NPA is available at the following link of the EASA public website: NPA 2022-04 - Regular update of the SERA regulatory framework (IRs and AMC & GM) | EASA (europa.eu); comments may be submitted until 25 August 2022 through the Comment Response Tool (CRT) at http://hub.easa.europa.eu/crt/.