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.

Ivan Kuznetsov

Hartmut Beil

I am sure the EU had Russian airlines in mind when formulating this law. Outlawing certain activities based on nationalities, not intent is certainly not fair. I hope the EU finds an exception to this rule.

Andrii Havrylenko

Why don’t you write to the russian government due to their policies and actions, you’ve been sanctioned. If your government doesn’t care about your problems, why Europe should solve them, especially since your politicians are constantly threatening the EU with non-existence. "Fault finding algorithm" always comes down to cause but you’re wasting time on consequence...

Ivan Kuznetsov

Andrii, I understand your point. Let me briefly explain ours.

We avoid any contact with Russian authorities and press to prevent fueling state propaganda.

We appeal to the EASA, European Commission and European Council because:
1. We live under their jurisdiction. We are legal residents of the EU, some of us are EU citizens.
2. The blanket ban cannot be justified in this case considering the declared objectives. Therefore, this is not an issue of sanctions. This is an issue of human rights – core European value.

Best wishes,

Jozef Jankovic

I fully support opinion of Hartmut Beil and fully understand Ivan Kuznetsov.
I don't understand wording and opinion of Andrii Havrylenko ... for me it is even not polite enough for this forum.
We are not speaking or playing with politics here, and we are here to discuss and improve General aviation matters here on the FAIR principles, not based on the nationality - this is the basic principle of European union btw.

Paul Wheal

I’m sure that the nice pilots of the Ukraine would love to be able to partake in general aviation activities in their country. But for some inexplicable reason they are unable to do so at the moment.

Davey W

@Paul Wheal, the fact that the original post has 14 likes, and your comment has none, means it's probably a good idea to reflect on why that would be the case.

Artem Tinchurin

I don't understand the concept of collective responsibility. I can be responsible for something I have control of. I'm responsible for my passengers as PIC for example. Should I be liable for what I'm against of and have no control of? With all due respect and sympathy towards Ukrainians, Andrii, I can't agree.

Alexander Marinosyan

I agree that the ability to fly for recreational purposes is a fundamental human right.
Seriously, a competent authority may authorize those who are consistent with the objectives. It may be easier to convince your state of residence that you are good, compared to convincing the whole EU that ALL Russian citizens who fly for fun are good.

Ivan Kuznetsov


you've got a point. We do try to talk to everyone on all levels, including national authorities.

The problem is national authorities look at the EASA in this matter. And EASA has chosen a very arbitrary and a very restrictive interpretation of the regulation.

EASA FAQ is not a legally binding document, yet almost all replies of the national authorities reffer to it.…

EASA is able to encourage national authorities to access the ban on the case-by-case basis, fully within the scope of Article 3d p.3 by simply mentioning such a possibility explicitly at their FAQ. This would not solve the problem completely, but will at least give us an access to the derogation mechanism which is built into the Regulation.

Best wishes,

David Mitchell

Alexander, how wide or narrow are you specifying the fundamental rights? Is driving a private car one of these rights? If not, wouldn't you ban EU residents with Russian passports off the roads?

Alexander Marinosyan

David, possibly my judgement about these things is flawed. According to EASA recognized local authorities, performing prototype test flights is a leisure activity, and should be charged like an ordinary vacation bound oligarch flight. That made me feel for the oligarchy and ask aren't oligarchs humans too? Why discriminate and take their basic human rights?

AFAIK there aren't any other areas than aviation where all Russian citizens (living in EU) would be hit by the sanctions. If the intent was to motivate them to do something, the choice is very strange (probably less than 1% of Russian citizens living in Europe are pilots).

Alex s

With the derogation mechanism effectively inoperational, it sounds like the regulatory nature of the problem Ivan described is way more serious than it seems.

First of all, recreational flying is almost never about a hobby alone. It's an essential "building brick" of professional flight training too. Before a pilot starts working on their CPL or FI rating they must get a PPL first and build some hours as a recreational PIC. Thus, banning recreational flying effectively bans flight training and professional flying too. I can imagine this measure ruined quite some plans of young students and licensed pilots. Knowing how demanding and costly flight training and maintaining currency are, I totally understand why this issue is no joke for the people affected.

Yes, EASA has announced exemptions for those with employment guarantees from an EU company, but, respectfully, it doesn't worth a penny. Why so? Well, ask yourself: how feasible is it to get such a guarantee for any (foreign) student pilot prior to starting their training in the present realities of the aviation industry?..

Having said that, it seems like almost no Russian can fly right now, not just recreational pilots. Even those who are employed by an EU airline are on hecking thin ice. I wouldn't be surprised to learn that airlines silently ground their Russian pilots too just to play safe.

Also, with no flying possible, I don't see how to extend ratings once they expire. Does it mean that the EU/EASA effectively revoked the licenses of Russians without doing so formally? If so, that's quite an inventive way to avoid liability, I must admit.

Secondly, this matter goes beyond "just aviation" or "just Russian pilots". It's about how the EU institutions operate.

I don't want to be that devil's advocate here. What's happening in Ukraine is unacceptable and outrageous. The duty of the civilized world is to stop aggression from Putin's government and help Ukraine as much as possible. Under no circumstances the tragedy going on in Ukraine shall be undermined. But I don't want to join the shaming movement either. It's not appropriate to impose guilt on all Russian citizens simply because it's hard to distinguish between those who support the war and those who don't. Find the ways, then, don't be lazy.

I see the matter raised by Ivan as a major red flag symbolizing the deterioration and dangerous "sentimentalization" of the European (aviation) institutions. It raises a ton of questions to think about. Just a few of them:
- If in the 21st century in Europe it's still possible for the government to label some nationality as "bad" as a whole and introduce regulatory restrictions just based on this sentiment, are we well in line with the rule of law? Please keep in mind that the people concerned are also EU residents/citizens and EU taxpayers.
- What's the whole point of having the rule of law in the first place if it's unable to protect regular individuals from arbitrary political decisions or the rage of public opinion?
- How our juridical principles are doing, e.g. presumption of innocence, non-discrimination, proportionality? Are they still OK out there?
- Is a war a good enough excuse to throw them into a trash bin?
- If so, how are we better than the Russian government then?
- Why there is no transparency to how these decisions are taken?
- Why do competent regulatory bodies avoid substantial communication on this matter? Are they afraid to be held liable? If so, why? Did they do something unlawful?
- How is this even possible that hundreds of licensed EU-taxpaying pilots are grounded overnight out of spite or... what exactly? Why are they put into a position where it shall cost them several years and tens of thousands of euros to defend their rights in courts?

IMO It's important that every pilot who got affected acts to defend their hard-earned right to fly: raises the issue with the competent authorities and initiates legal action, if necessary, demanding adjustments to this measure and compensation for being grounded. The authorities shouldn't just get away with it. If it's allowed now, tomorrow we may see them taking more rights from their citizens, using a different crisis as an excuse and a different category of people as "victims".

Artem Panfilov

I can share my personal experience with local PL officials.
In short, if you hold a RU passport, you're doomed to complete any certification. Even a permanent residency isn't an exempt. On a personal level, all understands that this broad measures are tailored in rush and shouldn't be that plain.
Hope to see the EASA updates on PPL for EU residence and RU passport holders.

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