ROLES REVIEW

Vol.2（2022.9）

Diverse Faces of Security
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ROLES REVIEW Vol.2（2022.9）
1. D
 elamotte, Guibourg. “What Abe’s Death Means for Japanese Politics: Japan has Lost a
Compass and a Driving Force” ��������������������������� 2
2. N
 akai, Ryo. “Information Security and Russian Influence Operations in the Baltic States: Media,
Memory, and Minority” ������������������������������ 5
3. T
 anaka, Amane and Maria Tanaka. “China’s Security Engagement with Greater Central Asia
(GCA): The Case of Afghanistan” ������������������������� 21
4. L
 amont, Christopher K. “The Great Unraveling? Geopolitics, Emerging Technologies, and the
Future of International Civil Aviation” ����������������������� 39
5. H
 inata-Yamaguchi, Ryo. “Civil Aviation Governance in North Korea”���������� 51
6. Toyoda, Kohei. “Iran’s Energy Relations with China and Russia amid the Ukraine Invasion”

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7. K
 aji, Ichiro. “An Unequal Agreement: Revisiting the 1951 Diet Deliberations on the Japan-US
Security Treaty” �������������������������������� 72

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What Abe’s Death Means for Japanese Politics:
Japan has Lost a Compass and a Driving Force
Guibourg Delamotte
Senior Lecturer in Political Science and Japanese studies at France’s Inalco
Visiting Associate Professor at the Tokyo College; Visiting Fellow at RCAST;
Visiting Associate Professor at GraSPP, the University of Tokyo

Abe Shinzo’s political debut as prime minister, in 2006, was uninspiring. He resigned within a year and the healthexplanation provided seemed flimsy at the time. His mentor and predecessor as prime minister Koizumi Junichiro himself
expressed disappointment. Yet Abe had already laid the foundation stones of a far more substantial legacy on which he
was to build in 2012 when he regained power.
Japan has had few strong figures with vision for their country. Abe changed not only the way Japan was perceived on
the world stage, but also Japan's vision of the world. During Abe's near-decade in power, her international influence
bloomed. As early as 2007, he drew attention to the geopolitical coherence of the Indo-Pacific region. In 2016 under his
leadership Japan’s “vision for the Indo-Pacific” alerted the international community to the region’s strategic importanceand China’s increasing presence there. The US, France, Britain, the EU...soon followed with Indo-Pacific strategies of
their own. Japan’s conception of regional international security was founded on ‘soft’ development assistance to emerging
countries through better connectivity and ‘quality’ infrastructure, and also assumed a ‘harder’ direction, on maritime
security and Freedom of navigation.
Abe also opened up the possibility for industrial cooperation and the joint development of weapons systems withpartners other than the US. He developed defence dialogues with neighbouring Asian states. With South Korea, heendeavoured to defuse lingering historical issues and agreed to (again) compensate ‘comfort women’. He deepened
friendships with Australia and the US by commemorating their war deaths and prisoners-of-war and visiting Pearl Harbour.
Abe stabilised relations with China, after tensions under Koizumi and the Democratic Party's years in power from 2009 to
2012, even though Chinese incursions into Japanese waters increased (after a reduction in numbers in 2018).
Abe gave the country a strategic vision by establishing a National Security Council which brings the Defence, Police,
and Foreign Policy establishments together. The Law on the protection of sensitive information enabled greater intelligence
cooperation with the US (which the 1997 Japan-US bilateral Security guidelines had called for). Abe also undertook a vastreform of Japan’s international cooperation and defence legal system in 2015. Japan had relied on ad-hoc laws until then,most of which dealt with specific circumstances with which they expired, nonetheless establishing precedent for the next
set of measures. That way of dealing with international crises was unpredictable for Japan’s international allies as eachcrisis brought parliamentary debates and no one could foretell if and how Japan would take part in an international coalition.
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Furthermore, from 1992 when the first international cooperation-related law was adopted, citizens elected a majority party
whose head, as prime minister, then made decisions for which he held no national mandate, as indeed citizens had elected
him before the crisis and ensuing law. Worse yet, citizens might elect a premier minister while disapproving his stance on
deployments because foreign policy and deployments seemed a distant or secondary issue (Koizumi was re-elected in 2005
in spite of the people’s opposition to a deployment to Iraq). The vast 2015 reform solved those issues by characterizing
different crisis situations and pre-establishing corresponding legal frameworks, thereby laying out the government’s
options in terms of Self-Defence Forces missions.
Abe (with the Cabinet Legislation Bureau whose head he had changed) established that Japan could use collective selfdefence if an ally was attacked and Japan’s survival or the lives and freedoms of its people were thereby at risk. Japan can
now provide logistic support (excluding weapons) in crisis situations which bear an important impact on Japan’s security.
Furthermore, Japan can now cooperate with international organisations other than the UN on peace-keeping or
humanitarian missions, and undertake peace-making activities (the monitoring of a ceasefire agreement for example).
Importantly from the point of view of democratic control, in each instance, the government must seek parliamentary
approval. This new framework enabled Japan to be more effective within the boundaries of an unrevised Article 9.
Retaining power came at a cost. The opposition did not take kindly to Abe. Much of Japan’s parliamentary rules rely on
precedent and negotiation with the opposition, from when parliament sits, to the order of passage of bills. Abe roderoughshod over convention and instead asserted majority-rule disregarding the opposition’s opinion on bills. Dissolving
the Lower house in 2014 and again in 2017 before the end of the legislature, at times which suited the opposition little, hemaximized his presence in power by coaxing his party into giving him three three-year mandates as leader. Thus, heretained power for 8 years, thereby becoming the longest-serving Prime minister in Japanese history. He asserted his
control of civil servants through a 2014 law, which increases the Prime Minister’s nomination powers – breaking with thetradition of neutrality of the civil service. Political scandals in 2017 and 2018 demonstrated favouritism and use of publicfunds for the benefit of some of his support groups.
Notwithstanding what Machiavelli might have advocated as necessary to the skilful exercise of power, Abe had becomea monument of Japanese politics, one of those heavyweights whose influence endures even after leaving power.
Even though Abe had resigned his post as Prime minister in 2020, his counsel was listened to and set the pace. At theend of February 2022, he recommended that Japan discuss nuclear deterrence with the US and nuclear-sharing, and inJune, when President Biden visited South Korea and Japan, the redeployment to South Korea of strategic assets, possibly
tactical nuclear weapons, and close cabinet consultations with Japan, were agreed upon. How is Japanese policy developing
now that he has left the stage?
Current PM Kishida follows in Abe's footsteps, sealing international partnerships with partners and allies, and increasing
naval deployments in the Indo-Pacific. Japan has signalled a willingness to partake in future AUKUS technologicalcontracts – industrial cooperation with allies was made possible when Abe relaxed rules on arms exports, which are now
allowed if they will contribute to international peace or to Japan’s security and not reach a country at war or be in violationof international law (exports to third parties require the GoJ’s approval). Kishida has highlighted “economic security”, theimportance of which Abe, who had established an economic security unit in the National Security Council and pushed for23

a reform of the legal framework of foreign direct investment in Japan, had been fully aware.
There are elements of departure from the Abe line too. Abe succeeded in establishing friendly relations with all of theworld’s leaders. No other country in the world has simultaneously cordial relations with Arab countries, Israel, and Iran.
Who else managed Donald Trump better than Abe? He made friends with him while bringing to life the Comprehensive
Progressive Trans-Pacific Partnership after Trump announced the US would no longer be a member of the TPP. Abe also
negotiated a bilateral free trade agreement which would not be disadvantageous to Japan, and held off discussions on thelevel of Japan’s Host Nation contribution (Japan’s financial contribution to the costs of US bases in Japan), when Trump
wanted it increased. There was even some benefit to an American president taking on China and making overtures, albeit
without prior-ally consultation, to North Korea (though Japan was sceptical as to their outcome).
The war in Ukraine has forced Kishida to side with the G7 in adopting sanctions against Russia – Kishida’s “realism
diplomacy for a new era”. Back in 2014, when Russia invaded Crimea, Abe had withheld from adopting sanctions in thehope that Putin would return some of the lost Northern Territories.
Under Abe, defence budgets increased steadily but remained at 1% of the GNP. The ruling party has advocated their
doubling and acquisition of strike capabilities in the form of Intermediate range ballistic missiles, in view of North Korea
and China’s improving capabilities which make Japan’s missile defence system insufficient. Though the rationale remains
defensive, Japan’s acquisition of first-strike capability will mark the end of its “defensive defence policy”, the Yoshidadoctrine, which Abe for all his reforms in the field of defence, had stuck to.
On the domestic front, the Abe faction was the strongest in the LDP. It is now left leaderless. Whether or not his faction
will remain as strong and consistent in its support of the government without the pull of a charismatic leader remains to beseen, so too whether or not Kishida will know how to navigate the political scene so as to become the compass Abe has
been.

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Information Security and Russian Influence Operations in the Baltic States:
Media, Memory, and Minority *Ryo Nakai
Associate Professor, Department of Political Science, The University of Kitakyushu*Essential parts of this paper were prepared and written before the beginning of the large-scale invasion of Ukraine by
the Russian Federation on February 24, 2022. It should be noted that this is a text explaining the structural backgroundof the situation and does not necessarily reflect the latest information.

Abstract
The Baltic States—Estonia, Latvia, and Lithuania—are examples of states with advanced information
security as they have experienced long and intense influence operations from the Russian Federation.
Influence operations have been observed in conflicts over memory politics, the dissemination of fakenews, and extensive bot and troll activities. To prevent influence operations from causing domestic
divisions and eroding international cooperation, Baltic countries are working to implement measures
including stronger regulations and the creation of new information spaces.
Keywords: Information Security, Disinformation, Russia, Baltic States, Estonia, Latvia, Lithuania
1. Introduction
The Baltic States (Estonia, Latvia, and Lithuania1) are replete with advanced examples of information security. Long
before disinformation and influence operations by the Russian Federation became global topics, 2 Baltic republics
experienced and responded to them.3 SCL Group, the predecessor of Cambridge Analytica, which was at the center of theallegations of Russian election intervention in the 2016 United States presidential election, was among the earliest toundertake election intervention and public opinion operations in Latvia, where Russian influence operations today are
thriving.4 The conflict between Estonia and Russia in 2007 is sometimes mentioned as the “world’s first cyber war.”
The Baltic States joined the EU and NATO in 2004 and became part of the Western community in terms of political
economy and security system. Previously they had de facto constituted (or been occupied by) the Soviet Union.5 Now,
given their various tensions with the Russian Federation, they are on the front lines of a fracture in the international politicalorder. In this context, the Cyber Defense Cooperation Center (CCD) in Estonia and Strategic Communications Center(StratCom) in Latvia are key to countering propaganda and disinformation.6
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Although an influence operation, including disinformation with a political agenda, may not change public opinion or
create new fractures within the receiving state, it may exacerbate existing divisions. The “powerful effect” or “hypodermic
effect” theories, which claim that people’s judgement and public opinion are directly influenced by the media, have long
been rejected as lacking a robust empirical basis. Rather, what has been proven is that there is an effect whereby
information can influence an individual’s priority what social issues are important, or from what perspective certain issues
should be viewed, known as the “priming” or “framing” effect.7 Information consistent with a recipient’s pre-existing
political beliefs also has the effect of reinforcing those beliefs, known as “confirmation bias” or “motivated reasoning.”8Since public opinion tends not to desire military retaliation, even when those opinions are manipulated by disinformationfrom a third country,9 intervention in the cognitive domain through disinformation and fake news is a low-risk way to
disrupt the domestic situation of the opponent.
This paper outlines the experience of the Baltic States at the forefront of such conflicts in the cognitive domain andattempts to advance understanding of the issue through the presentation of specific cases. Influence operations are highly
context-dependent, as they are fought through the issues and frames of reference that are used to perceive an event.
Accordingly, Chapter 2 introduces the issues of confrontation and conflict between the Baltic States and Russia. Chapter
3 explains specific influence operations, attempts to manipulate information, and bot activities conducted by the RussianFederation against the Baltic States. Chapter 4 examines the influence of the Baltic States on the Russian Federation andoutlines the countermeasures taken by them.

2. Contested Issues between the Baltic States and the Russian Federation
The Russian Federation has attempted to exert influence on various issues with the Baltic States through numerous
means including economic sanctions, political pressure, media intervention, and the penetration of academic networks.10
The issues are diverse. Although the hard issues between the two countries such as border disputes and energy dependence
have been prominent, they have reduced in their intensity. Rather, the Russian Federation’s soft or sharp power exercises
have increased in scope and intensity, utilizing Russian speakers abroad and memory politics as leverage.11 For the current
regime in the Russian Federation it is difficult to directly affect regime change or border changes in the Baltic States,
particularly since all have become members of the European Union (EU) and NATO. The basis of its influence operations
is said to be the formation, maintenance, and support of pro-Kremlin networks.12 By forming a pro-Russian network
within the EU and NATO, the goal is to form a core of influence and weaken unity among the Western European countries.

Border Disputes and Energy Dependencies
Latvia and Estonia previously had border disputes with the Russian Federation. Both countries acquired territories
under a cease-fire treaty during the War of Independence following World War I. After the annexation/occupation of
Estonia and Latvia into the Soviet Union, these territories were returned to the Russian territory. The Estonian and Latvian
governments renounced their territorial claims and signed border treaties in 2005 and 2007, respectively (Estonia andRussia failed to ratify the treaty and are in the process of renegotiating it).132
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The Baltic States work on energy security issues as matters of national policy. They used to be heavily dependent on
Russia for heat and electricity supplies (especially natural gas, in which they were fully dependent on Russia). This was
spurred by the fact that Lithuania’s Ignalina nuclear power plant did not meet EU standards and had to be decommissioned.
Their efforts, such as the expansion of LNG terminals, have borne fruit, and they are approaching complete independence
from Russian gas. After the invasion of Ukraine in 2022, Lithuania achieved a total suspension of gas imports from
Russia.14 The Baltic countries jointly funded the new Visaginas nuclear power plant project in Lithuania (in partnershipwith Japan’s Hitachi). However, this project was abandoned following an advisory referendum in 2012, resulting from therapid rise of an anti-nuclear campaign.
The main issue was the concern about the rising price of electricity, and some argued that it would be cheaper to buy
electricity from Kaliningrad, where a plan to build a nuclear power plant is underway with the help of Russian capital. The
suspension of the Visaginas nuclear power plant project meant prolonged energy dependence on Russia, and the antinuclear movement was thought to be supported and influenced by Russia.15 This is the reason why the Latvian Ministerof Defense (not the Minister of Economy nor the Minister of Foreign Affairs) wrote on a social networking site that “theRussian conspiracy has won” on the same day that the referendum results were announced.16 It is important to note that
the Russian plan to build a nuclear power plant in Kaliningrad was canceled after it was confirmed that the Visaginas
project had been aborted on the Baltic side.17

Issues Regarding Russian-speaking Minorities in the Baltic
In diplomatic matters with the Russian Federation, the Russian-speaking people issue within the Baltic States has been
discussed in depth, 18 including their legal status, language rights, and minority integration in their living country. 19
According to 2011 census data, Russian speakers account for 29.6% of the population in Estonia, 37.2% in Latvia, and7.2% in Lithuania.20 In particular, the governments of Estonia and Latvia did not automatically grant citizenship to many
Russian-speaking inhabitants when they restored their independence. In the 1990s, the Council of Europe and theOrganization for Security and Co-operation in Europe (OSCE) criticized this situation; Russia took advantage of thesituation and used it as a political resource for its “humanitarian diplomacy.”
Although the situation improved considerably by the time the Baltic countries acceded to the EU in 2004, informal
discrimination remained. In this context, the Russian Federation established “Russkiy Mir” (Russian World) in 2007 withthe aim of exerting influence over Russian speakers, developing a cultural sphere and preserving the community Russianspeaking population abroad. Rhetorically Russia emphasized the protection of the Russian-speaking population as its
primary rationale for conflict with Ukraine in 2014. Following this event, the international community closely monitored
Estonia, Latvia, Lithuania out of concern that the Russian Federation would use the same rhetoric (and “intervention”) totarget the Baltic republics.
The international community’s reaction was somewhat excessive. Immediately after the Ukrainian conflict in 2014,
several news and columns claimed the Baltic countries, with a large Russian-speaking population, will be the next target.

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On the other hand, most researchers familiar with the local situation were skeptical of the “Baltics are next” argument
based solely on the fact that Ukraine and the Baltic countries have large Russian-speaking populations. The situation ineach of these countries is very different.21 The sense of national belonging among Russian-speaking residents of the Baltic
countries is best described as localized, especially among the younger generation; they perceive the Russian Federation asa foreign country.22 Economic standards are higher in the Baltic countries. Russian-speaking residents, especially along
the border, are also keenly aware that they are better off than those living in Russia, albeit with some political restrictions.23
The willingness to defend one’s own country does not differ between Russian-speaking and non-Russian-speaking
inhabitants.24
On the contrary, a large gap exists between Baltic and Russian speakers regarding the perception of the RussianFederation as a security threat. The perception of the Russian Federation as a security threat has varied widely among
ethnic groups since the restoration of independence (Figure 1). Such perception gap has not changed much since the
Ukrainian conflict in 2014.25 That is why issues over domestic integration policies and conflicts over the issue of historical
recognition, which will be discussed later, could easily be associated with security issues, as opinions are greatly divided
between Russian speakers and local Baltic residents. Division in domestic and international opinion on these issues could
lead to influence operations and intervention from the Russian Federation. Such intervention could result in the“misunderstanding” about the Baltic countries in Western countries. Therefore, Baltic government officials (especially
Estonia and Latvia, which have many Russian-speaking residents) are particularly sensitive to these issues.
Figure 1. Baltic Countries’ Perception of Russian Threat Based on Language Spoken
Question: Do you think any of these pose a real threat to peace and security in his society? Russia. (N=3119)
100
90
80
70
60
50
40
30
20
10
0

Estonian

Russianspeakers

LatvianEstonia
Big threat

Russianspeakers

LithuanianLatviaSome threat

Don't Know

Russianspeakers

Lithuania
Little threat

No threat

Source: Prepared by the author based on New Baltic Barometer 2004

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The primary diplomatic goal of the Baltic States is to prevent aggression from Russia in advance. Every possible
diplomatic effort is directed toward this goal. Baltic diplomatic and defense officials have always maintained and expressedthat aggression from the Russia Federation is not improbable. At the same time, they have concerns about discourse
declaring the “Baltic States as the next target of invasion.” Such discussion, linked to the domestic Russian-speaking
population issue, would divide domestic public opinion and, in turn, endanger the unity of opinion within NATO countries.
When the BBC produced the 2016 fictional drama, “World War 3: Inside the War Room,” and scripted “the Russianspeaking population of Latgale in eastern Latvia rose up to demand incorporation into the Russian Federation, leading toa state of war between the United States, Britain, and Russia,” Baltic government officials and StratCom authorities
expressed concern and criticized the BBC.26 This kind of discourse can be used by the Russian side. In fact, a selfproclaimed “think tank” that issued an analytical report on the threat of Russian intervention in the Baltic countries under
the guise of protecting Russian-speaking residents was in fact a fake think tank created by the Russian side.27 These
underscored the concerns of Baltic authorities who understand that this discourse could be used by Russia to measure andexploit domestic and intra-regional divisions in their countries, at worst, providing justification for a Russian intervention.

The Politics of Memory and History
The issue of memory politics between the Baltic States and the Russian Federation have appeared across the cyberdomain. The two main conflicting topics between the Baltic States and the Russian Federation are the May 9 Victory Day
against Germany, and the issue of Nazi collaborators. The discourse of “de-Nazification” used by the Russian Federation
to justify its invasion of Ukraine in 2022 has, in fact, long been projected against the Baltic States (especially Estonia andLatvia).
It is well known that the Russian Federation has, in recent years, highlighted the victories (and sacrifices) of its “Great
Patriotic War” as one of its unifying national discourses; in this respect May 9 Victory Day is an important anniversary.28
For the majority of views across the Baltic States, however, regard May 9 not as a holiday, but rather as a day of cursed
memory since it marks the resumption of the Soviet occupation of the Baltic States. Government officials of the Baltic
States tend to commemorate the end of the war on May 8, as in Western Europe (and May 9 is treated as a “EuropeanDay”). Nevertheless, May 9 is sometimes celebrated in the Baltic States, especially by Russian-speaking populations(mainly in Estonia and Latvia). It has also become a day of political mobilization for some pro-Russian minority parties.29
Some of these participants had family who lost their lives in the war against Germany, so for them there is certainly an
emotional need to honor their achievements. May 9 is a time when the division of memory in these countries becomespronounced.
What’s more, memory issues have become a cause of cyber war between Estonia and Russia. Initially it was triggeredby a mass movement of (allegedly) young residents who were protesting against the relocation of a statue of a Red Armysoldier in the center of Tallinn. This protest escalated to a small riot and was forcefully suppressed by police.30 Ultimately
this was a conflict between the historical views of the Red Army soldier statue, and whether it is “a symbol of a hero who
fought against the Nazis” or “a symbol of the reoccupation of Estonia under the guise of ‘liberation’ by the Soviet Union.”

59The Russian Federation and some Russian-speaking residents criticized the Estonian government’s action. The issue ofmemory can be directly related to the issue of security.
As a corollary to these memory issues, there is a movement countering the anti-Soviet sentiment, especially in parts ofEstonia and Latvia, to commemorate the local units that collaborated with Nazi Germany. During the German-Soviet war
during World War II, Nazi Germany established Schutzstaffel (SS) units in the Baltic region, which were comprised of
locals, who had fought against the Soviet Union. While the interpretation to see these collaborators as victims of
totalitarianism of communism (Soviet Union) and fascism (Nazis Germany) is somewhat mainstream, the RussianFederation has long criticized them (and the commemoration for them) for being Nazis. Occasionally the Western media,
in Germany and France, will take a similar stance. Past disputes have erupted over a statue of SS troops in Lihula, Estonia,
as well as a monument to SS POWs built by Latvian volunteers in Belgium.31 In particular, March 16 in Latvia is a dayof annual tension in Russian-Latvian relations when a parade is held in the center of the capital to commemorate the SS
POW unit.

3. Russian Federation’s Influence Operations in the Baltic States
Amid these political disputes and conflicts, the Russian Federation has been attempting to influence public opinion
in the Baltic States, both explicitly and implicitly. They do so through collaboration with political parties, targetingthe media in influence operations, and conducting trolling and bot activities on social media.
Official Cooperation with Political Parties
The official practice for Russia has been to establish direct cooperation in the domestic political process. United Russia,
the ruling party of the Russian Federation, established official cooperation with the Centre Party (Keskerakond) in Estonia
in 2004 and with the Harmony (Saskaņa) in Latvia. Both the Centre Party and the Harmony have strong support from theRussian-speaking population because they were active in defending the rights of the Russian-speaking population. They
often seized power in local governments in capital cities where many Russian-speaking people lived. In Lithuania, thePolish minority party, the Polish People’s Electoral Movement (LLRA), has established cooperative relations with United
Russia.
It is not clear to what extent these cooperative relations have been successful in terms of their intended use of influence.
Neither the Centre Party nor the Harmony were able to assume power at national-level politics, as their cooperation with
the United Russia parties was considered problematic in domestic politics and excluded from the coalitions. The Centre
Party finally returned to central politics in 2016 after the defeat of its long-time executive leader, the Edgar Savisaar faction,in an intra-party competition; this resulted in its cooperation with United Russia becoming virtually dormant.32 The
Harmony also dissolved its cooperation with United Russia in 2017, but its leadership, led by Nils Ušakovs and Jānis
Urbanovičs, has not changed significantly. Other Latvian political parties do not allow coalition cooperation with theHarmony. The Lithuania’s LLRA has succeeded in entering the coalition, but its influence is very small because it is anextremely small party by nature.

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An important figure is Tatjana Ždanoka, a Latvian member of the European Parliament. Tatjana Ždanoka is a memberof the “Union of Latvian Russians (LKS),” the most extreme pro-Russian force in Latvia.33 She has had a longpolitical career since the restoration of independence in the 1990s and has been a member of the European Parliament
since Latvia’s accession to the EU. It is an open secret that her party LKS has been receiving financial support fromthe Russian Federation behind the scenes, and that she has been acting as an agent to express support for the RussianFederation’s position in the European Parliament.34
Influence Operations through the MediaThe Russian Federation has asserted extensive intervention and control over the information space. Using the media,
which forms the basis for shaping public opinion, the Russian Federation has attempted to indirectly influence the Baltic
countries’ relations with Russia by disseminating information favorable to the Russian side. For some time, the RussianFederation has frequently disseminated information (as many sovereign nations do) in line with its own position on issuesof historical awareness and Russian-speaking populations. What has become increasingly common in recent years areattempts to disseminate information through the media aiming to upset the relationship between the Baltic States andWestern Europe and North America. This is sometimes done through the creation of fake news, by covering up its
management bodies.

To give an example, in 2017, news of US President Trump’s decision to end funding to the Baltic States was
published on the local news site “Rubaltic.” The US State Department described the Baltic States as “parasites,”
which made Baltic readers feel disappointed in the United States. President Trump’s decision, its representation andthe background information on the funding had been fabricated.35 This fake news and the reaction of disappointment
toward the US were reported across a large number of media outlets within a few days, and even after the sources ofthis information disappeared, disseminated of this news has not disappeared. This is just one example of an attempt
to discredit the trust between the Baltic States and the US.
These websites are generally run by news NGOs, and their funding often comes from “human rights NGOs” or“international exchange organizations.” This makes them appear to be run by neutral organizations. However, the“self-proclaimed” NGOs that support these news organizations sometimes include the Russkiy Mir Foundation,
which forms the basis of the Russian Federation’s soft power strategy. In addition, the news NGOs conduct theirinterviews through introductions from various “organizations” and “informants,” who are also funded by the Russkiy
Mir Foundation and other foundations. In other words, the people involved in the dissemination of fake news, theirsources of support, and their interviewees are all operating under the influence of organizations whose purpose is toreflect the wishes of the Russian government. The news outlets produced by these networks are quoted and referred
to in the international media as information “from local news sites.” This influences readers’ perceptions (mainly inWestern countries) of the Baltic States.

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Another news site, Baltnews, is a more roundabout example. This news site within the Baltic States is ostensibly run
by a local team but owned by a Dutch company. However, this Dutch company is controlled in terms of shares by a Russiancompany called Media Kapital. Media Kapital is also controlled by Moscovskiye Novosti, whose largest shareholder is
RIA Novosti, a Russian state-owned news agency. In a nutshell, through double and triple circumvention Russian staterun news agencies disseminate information in the Baltic region in the name of local companies.36 The editor-in-chief ofthe Estonian edition of Baltnews secretly met with the head of the Institute of the Eurasian Economic Union, a Russian
propaganda agency, and was later arrested (it should be noted that the arrest was due to tax evasion charges).37
Similar structures exist beyond online media, including in the broadcasting industry. The Baltic Media Alliance (BMA),a UK-based company with broadcasting rights for Russian-language programs in the Baltic States, was under the influenceof Moscow, made apparent through their capital ties.38 Since BMA had the rights and facilities to distribute its influential
and popular Russian-language channels in the Baltic region, the focus is now on how to regulate (or even stop) its activities
in the Baltic region, as will be discussed later section.
It should be highlighted that not all such fake news affecting the Baltic region is related to Russian activities. Some of
it is domestically motivated mainly for financial reasons.39 Further, concluding that all fake news industries are a “Russian
conspiracy” is also a shortsighted view.

Trolling and Bot Activities on SNS
The spread of (fake) news about the Baltic States across the Internet is also linked to bot and trolling activities. Internet
influence operations using trolls and bot, such as on social networking sites, are deployed in an attempt to influence public
opinion. In 2016, Sputnik opened their Baltic online platform.40 It was also during this period that so-called trolling farms
began targeting the Baltic countries.41
The reality of these automated bots has been much studied by NATO, mainly by StratCom. The bot activity is identified
by the following factors of their posting activity: non-responsiveness (bots do not reply to comments from third parties),
repetition, duplication of text (bots make copy posts), and concentration of comments on political articles. Based on thesecriteria, from March to August 2017 StratCom conducted a comprehensive review of all tweets on Twitter that contained
the word “NATO” and either “Estonia,” “Latvia,” “Lithuania,” or “Poland.” They found that 84% of Russian tweets and
46% of English tweets were found to have been posted by a bot.42 This ratio of bot activities was particularly high for
those mentioning Estonia and Latvia, with 87% of posts about Estonia and 85% of posts about Latvia actually made by abot. The contents of the bot posts were critical of these countries’ cooperation with NATO, fabricating the impression thatpublic opinion was against NATO cooperation on social networking sites. The volume has varied, with a 2015 StratCom
survey showing that of 200,000 targeted tweets, approximately 20,000 (or 10%) were attributed to bots or trolls.43 The
2021 survey showed similar figures (19% of tweets in Russian and 6% of tweets in English).44
The prominence of these bot activities in 2017 was the result of an artificial campaign, which was analyzed as being
deployed in conjunction with the timing of NATO’s large-scale military exercises.45 This indicates that the bot activities
are able to fill the majority of international political commentary on the social networking service (SNS) platform. Even812

if the large amounts of commentaries do not directly change people’s opinions, they can distort their perception of what is
the majority opinion on the SNS.
Bot activities are not only intended to measure domestic divisions within the Baltic States, but also to discredit theNATO presence and foster anti-NATO sentiment. One example is fake news about NATO soldiers committing rape in
Lithuania.46 There are also online signature campaigns (hashtag activity) criticizing the desecration of NATO soldiers.47
It’s ironic that the political participation of righteously indignant people was, in fact, the result of Russian intelligenceintervention.
StratCom is concerned about the further diversification of disinformation measures more than bot activities. The useof deep fakes is spreading beyond simple message repetition.48 During April 21-24, 2020, many Lithuanians observed acomplex fake campaign that combined a fake online article claiming that “NATO will withdraw from Lithuania in response
to Covid-19,” a fake letter to ministries and media outlets in the name of NATO Secretary General Jens Stoltenberg, andthe simultaneous appearance of commentary videos on multiple YouTube accounts under local names. Some major
Western media outlets were deceived by these videos and reported them as fact. 49 Various attempts at influencing
operations in the Baltic region through multiple information technologies are likely to continue, strengthen, and diversify
in the future.

4. The Impact on the Baltic States
Assessment of the Impact on Public Opinion
To what extent do influence operations from the Russian Federation in the Baltic States impact public opinion? NATO
StratCom, which specializes in information security, has published a report that considers the effect to be limited.50 As forterrestrial broadcasting, it has been pointed out that the consumption of Russian-language media by Russian-speaking
residents of the Baltic countries is almost exclusively limited to entertainment.51 As noted at the beginning of this paper,
the effects of media information impacting public opinion are highly contextual and limited.
On the other hand, it has often been noted that Russian speakers in the Baltic countries are more vulnerable toinformation intervention from the Russian Federation.52 The aforementioned StratCom report points out that Russian
speakers’ trust in Russian official media is somewhat higher than Baltic residents.53 In addition, they are more receptive
to alternative historical perceptions that affirm their own lives, given the instability of their domestic position.54 According
to an academic study conducted for the Ukrainian 2014 elections, exposure to Russia’s broadcasting had the effect ofincreasing votes for pro-Russian parties.55 While we should not be overly awed by this influence, we should not dismiss
it as insignificant.
A previous StratCom survey found that some correlations were found between the use of various Russian-language
media outlets and opinions on various policy topics, while others were not.56 One survey conducted in Latvia in October
2014 after the Ukrainian conflict noted that the frequency of Russian-language newspaper subscriptions had no statisticallysignificant impact on subscribers’ understanding of the Ukrainian conflict, while Russian-language SNS (VKontakte and913

Odnoklassniki) users were. This effect was also present when the respondents were limited to Latvian speakers only (Figure2). This effect was also observed after controlling the effects of respondents’ basic attributes, (i.e., mother tongue, education,
income, supporting party, etc.)57 Differences in attitudes toward the Ukrainian conflict are defined by whether they use
Russian-language SNS or not.58
Figure 2. Russian SNS Use and Security Perceptions in Latvia after the Ukrainian Conflict in 2014

"Russian Federation is a threat to the Latvia peace and security"(N=2920)

Who would be blamed for the escalation of conflict in Ukraine(N=897）
Russian-speaker,
using Russian SNS

Russian-speaker,
using Russian SNS

Russian-speaker,
not using Russian SNS

Russian-speaker,
not using Russian SNS

Latvian,using Russian SNS
Latvian,using Russian SNS

Latvian,not using Russian SNS
0%

Latvian,not using Russian SNS

0%

Strongly agree

20%

Rather agree

40%

Neither60%

Rather disagree

80%

20%

40%

60%

80%

100%

100%

Strongly disagree

Russian Federation/ Pro-Russian group

Ukraine government/ Ukraine naitonalist

NATO/ U.S.

EU/ Western European countries

OthersRefuse to answer

Source: Nakai, Ryo. 2020. “Latvia’s Political Survey 2014,” https://doi.org/10.7910/DVN/28420, Harvard Dataverse, V2.

Baltic Governments’ Countermeasures in the Discursive SpaceMedia regulation
The Baltic countries are also taking measures to counter Russian disinformation and propaganda. One domestic policy
is to suspend or cease operations of broadcasters (or operators) that are deemed to be disseminating extremely pro-Russian
content.59 While considering the dangers of imposing certain restrictions on the free flow of information within the country,
each of the Baltic countries has sought to make this possible.
In the first case of administrative action, Lithuanian authorities imposed a domestic suspension on the Swedish-based
Russian-language broadcaster RTR Planeta in 2015.60 In 2019-20, in Latvia and then again in Lithuania, RT, the Russian
national broadcaster, and BMA, the broadcasting rights holder of the major PBK channel (see above), were suspended.
Around the same time, Estonia also banned the entry of pro-Russian Western journalists. While BMA took measures toavoid sanctions by establishing local subsidiaries in the Baltic countries and appointing different representatives, theauthorities in the Baltic countries also responded with severe fines, taking advantage of various regulations. In Lithuania,
it moved to the EU court of justice (the Lithuania side won in general).61 In Estonia, two cable stations decided to suspend
Russian-language channels on February 22, 2022, just before the start of the invasion of Ukraine.62

1014

Of course, a keystone of liberal democracies is promoting free sources of information and alternative media. The
restrictions on them need to be handled with extreme caution. Both in the response to the Lithuanian authorities in 2015
and in a series of restrictive measures starting around 2019, the public and experts have opposed them as restrictions on
freedom.63 OSCE expressed concern to the Latvian government when Latvia shut down Russia’s website without judicial
oversight.64 Reporters Without Borders has issued a critical opinion,65 pointing out that the Baltic authorities are abusing
the sanctions against the Russian oligarchy adopted by the EU, interpreting them in an expansive way. While they try
respond to the disinformation originating from Russia, they must also uphold freedom and the rule of law, placing them ina situation of repeated difficult decisions. Their call for a pan-European regulation of the Russian media could be treatedas one of their strategic responses.66

Historical awareness and social integration
In counter to the Russian Federation’s influence operation the Baltic governments have long been engaged in public
diplomacy activities, in which they enthusiastically express their positions on their own historical perceptions to the outside
world. The degree to which these activities have been deployed has been determined through a process of trial and error.
The pursuit of anti-Russian sentiments has, in some respects, risked hindering the social integration of the Russianspeaking population. In Estonia, as mentioned earlier, the politics of memory over the recognition of World War II led todomestic riots and cyber warfare with Russia. In Latvia, the 2008 film “Soviet Story,”67 which was used by the right-wing
UEN group in the European Parliament to accuse Russian Federation, not only became a diplomatic issue with the RussianFederation, but also hindered domestic integration. Such content has had the effect of encouraging a conflict of historicalviews and open dialogue, especially on social networking sites,68 but one summarizes that “Due to its very emotional
focus on the Latvian victims only, Latvian history politics failed to integrate the Russian speaking population of Latvia.”69
Given these circumstances, the state-run broadcasters in Estonia and Latvia have begun to produce their own Russianlanguage programs. They actively develop strategic communication in line with their own perceptions to cultivate local
identity among the Russian-speaking population in the country,70 and to “protect the information space.”71 Those attempts
are beginning to show success in fostering national cohesion.72
In other words, recent public relations efforts to counter Russian perceptions of history continue in ways that do not
greatly divide the country. Through this process, inter-state cooperation has been observed.73 For example, the recent
attempt to ban the display of the Georgian ribbon, a symbol of Russian patriotism, may be part of this effort (it was
legislated in Ukraine in 2017.) 74 As another efforts, since the middle of 2010s, embassies and diplomats deployedcampaign protesting the media’s use of the term “former Soviet Union (ex-Soviet).”75
It is not clear from public information whether the authorities in the Baltic States are conducting influence operations
or propaganda using bot and troll activities to counter Russia. On SNS platforms, there are some accounts expressing
radical anti-Russian rhetoric, but they are likely authentic. Volunteers such as the “Elves,” an online group based in
Lithuania, detect and respond to fake-news and bot activities.76

1115

5. Conclusion
The Baltic States have long-standing diplomatic tensions with the Russian Federation. As NATO and EU member
states, they are in a strategic position in international politics, directly bordering the Russian Federation. Therefore, they
are regarded as a frontline for various influence operations, both covert and overt; on a regional level as a source of fissures
within NATO and the EU, and nationally as targets for widening domestic divisions within the Baltic States. The RussianFederation’s influence operations against the Baltic States have “centered on its own interpretation Soviet history, smearing
Baltic governments and societies as fascists and Nazis, and creating propaganda about alleged abuse of the Russianminorities,”77 utilizing soft issues as leverage in domestic disagreements. NATO and the Baltic governments have taken
countermeasures from time to time, but the situation has varied.
In the short term, it is unlikely that the Baltic States will be the target of a change in the status quo using military force,
given that the countries are members of NATO and the EU (ground forces of NATO members have been deployed there
since 2014). There have been simulations of a military intervention (the RAND report is a well-known example),78 anddiscussions on how to defend the Suwalki Gap since the Baltic States would lose their land connections to the NATO bloc
if it were seized. Long-term deterrence of attempts to change the status quo by force against the Baltic States depends, inthe first instance, on not creating forces within the country that would welcome Russian intervention.
A variety of measures have been developed to deal with the various influence tactics that have been used to foment
division within the country. Even more important is that the Western free nations of NATO maintain their will to provide
defense to the Baltic States. This depends on the political resolve of the member states, and importantly on public opinion
in member states, since this is the source of political will in democracies. Forces that do not like the current situation will
have the incentive to discourage this political will in several ways such as spreading discourse in Western countries along
the lines of “there is no moral reason to provide a defense to the Baltic States,” and “the Baltic States have no choice but
to intervene.” Public opinion needs to be vigilant against such movements and rhetoric.
In practice, influence operations and strategic communications from the Russian Federation with the above-mentioned
objectives have been, are being, and probably will be carried out in the future, necessitating counterbalancing activities on
the part of the Baltic States. As of this writing in May 2022, influence operations via political parties (LKS), the polarizationof media coverage and public opinion, and SNS activities aimed at international public opinion have begun to develop in
Latvia over the ruling party’s plans to remove the Victory Monument.
The Baltic republics are also in a period of trial and error, depending on the country and the time period, as to whether
to counter, contain, or rebut such influence operations and what means to use. The Baltic States, Estonia, Latvia, andLithuania, which have long been in rivalry with Russia, have diverse experiences in this process of trial and error. The
Baltic countries’ experiences have their own contexts, and not all of them can be easily applied to other countries, but they
are full of precedents. The Baltic experience, which has been attracting international attention in an unfortunate way since
the end of February 2022, is not just a matter of diplomatic strategy toward the Russian Federation but also of experiencein dealing with information security in general.

12
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1

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The current Republic of Estonia and the Republic of Latvia do not legally recognize that they were Soviet Union
constituent republics, and their “incorporation” in the 1940s is recognized as an “illegal occupation” by national principle.
6
Lithuania has the NATO Energy Security Centre of Excellence (ENSEC).
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For background and differences between the two governments, see Yasui, Kiyotaka and Ryo Nakai. “An Opportunity for
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168-189.
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They are not necessarily ethnic Russians. Since they are native speakers of Russian, which was the lingua franca of the Soviet
Union, this includes a considerable number of ethnic Ukrainians, Belarussian, Kazakhs and others.
19
There have been vast works regarding this. For example, see Galbreath, David J. Nation-Building and Minority Politics inPost-Socialist States: Interests, Influence and Identities in Estonia and Latvia, Stuttgart: Ibidem, 2005; Agarin, Timofey. A Cat’s
2

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Lick: Democratisation and Minority Communities in the Post-Soviet Baltic, Amsterdam/New York: Brill, 2010.
20
Lithuania has a smaller number of Russian-speaking residents. This difference is due to differences in industrial
structure among the three countries, intense partisan activity within Lithuania, geopolitical location, and so on.
21
Grigas, Agnia. “Who’s next on Putin’s list?” opendemocracy.net. March 12, 2014. Accessed May 19, 2022.
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Estonian Foreign Policy Institute Paper Series, no.21 (2015). Accessed May 19, 2022. Originally, http://www.evi.ee/wpcontent/uploads/2015/05/EVI-mottepaber21_mai15.pdf;
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“Latvia’s Russian-speakers belong to Latvia, say schoolkids,” LSM.lv. May 6, 2015. Accessed May 19, 2022.
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24
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25
For survey data taken after the 2014 Ukraine conflict, see Nakai, Ryo. “Latvia’s Political Survey 2014.” 2020.
https://doi.org/10.7910/DVN/28420, Harvard Dataverse, V2.
26
LSM. “NATO Izcilības centra šefs: BBC filma par iebrukumu Latvijā var radīt sabiedrībā bažas par drošību” LSM.lv. February
17, 2016. Accessed May 19, 2022.
https://www.lsm.lv/raksts/zinas/latvija/nato-izcilibas-centra-sefs-bbc-filma-par-iebrukumu-latvija-var-radit-sabiedriba-bazaspar-drosibu.a169476/.
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Shekhovtsov, Anton. “Center for Eurasian Strategic Intelligence, a fraudulent ‘hawkish’ think tank” Stopfake.org, December
22, 2014. Accessed May 19, 2022. https://www.stopfake.org/en/center-for-eurasian-strategic-intelligence-a-fraudulent-hawkishthink-tank/
28
Nishiyama, Yoshihisa. Rosia no Aikoku Syugi: Putin ga Susumeru Kokumin Tougou (Патриотизм в современной
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30
For background and the political calculations of the government, see Smith, David J. “‘Woe from Stones’: Commemoration,
Identity Politics and Estonia’s ‘War of Monuments.’” Journal of Baltic Studies 39, no. 4 (2008): 419-430; Ehala, Martin. “TheBronze Soldier: Identity Threat and Maintenance in Estonia,” Journal of Baltic Studies 40, no. 1 (2009): 139-158.
31
Komori, Hiromi. Esutonia no Rekishi to Seiji Ninshiki (Politics and Understanding of History in Estonia), Tokyo: Sangensha,
2009; LSM. “Latvia critical of Belgian plans to relocate war memorial” LMS.lv, December 12, 2021.
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32
The official end of cooperation is March 6, 2022, after the invasion of Ukraine occurs.
33
She was arrested on May 13, 2022. The ostensible reason for the arrest was the non-reporting of a rally. Since it was
the arrest of an incumbent MEP, there was a lot of criticism, but it is unclear to what extent this was honest public opinion
and to what extent it was the voice of bots, etc., as described below.
34
For example, see LSM. “Kremlin cash flows towards pro-Putin MEP” LSM.lv, April 13, 2015.
https://eng.lsm.lv/article/politics/politics/kremlin-cash-flows-towards-pro-putin-mep.a125270/.
35
Springe, Inga. “Small time propagandists” re:baltica.lv. April, 17, 2-17. https://en.rebaltica.lv/2017/04/small-timepropagandists/.
36
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re:baltica.lv. August 29, 2018. https://en.rebaltica.lv/2018/08/moscows-mouthpieces/.
37
Jemberga, Sanita, Mikk Salu, Šarūnas Černiauskas, and Dovidas Pancerovas. “Kremlin’s Millions” re:baltica. August 27,
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38
Jemberga, Sanita. “PBK Baltic owner enters plea bargain in EU sanctions case” re:baltica. January 25, 2021.

14
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https://en.rebaltica.lv/2021/01/pbk-baltic-owner-enters-plea-bargain-in-eu-sanctions-case/.
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40
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41
Gerdziunas, “Baltic battle Russia in online disinformation war”; Roonemaa Holger and Inga Springe. “This Is How Russian
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44
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45
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46
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47
LRT. “More fake news target NATO’s presence in Lithuania” LRT.lt, September 27, 2019. https://www.lrt.lt/en/news-inenglish/19/1101632/more-fake-news-target-nato-s-presence-in-lithuania.
48
Willemo, Jakob. Trends and Developments in the Malicious Use of Social, NATO Strategic Communications Centre of
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49
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Excellence, 2021: 30-31.
50
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Environment, Report 2016/2017, NATO Strategic Communications Centre of Excellence, 2018.
51
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Speakers, International Centre for Defense and Security, 2015.
52
Gaufman, Elizaveta. “(Re)drawing Boundaries: Russia and the Baltic States,” in Andrey Makarychev and Alexandra Yatsyk
eds. Borders in the Baltic Sea Region: Suturing the Ruptures. London: Palgrave, 2017.
53
Bērziņa et al. Russia’s Footprint, 89-90.
54
Koizumi. Geopolitics of Russia as “Empire,” 119-120.
55
Peisakhin, Leonid, and Arturas Rozenas. “Electoral Effects of Biased Media: Russian Television in Ukraine,” American
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56
Bērziņa et al. Russia’s Footprint.
57
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SSRN: https://ssrn.com/abstract=2812687.
58
It remains possible that factors that cannot be fully grasped in the survey may have determined both the form of
information contact and the attitude toward conflict in Ukraine. It is also possible that information contact did not shapeperceptions but rather that the form of information contact was based on perceptions that had already been formed. To
truly clarify the effect of information contact by Russian media sources on public cognition, it is necessary to conduct a
political psychology experiment in which security-related information stimuli are randomly given to examine subsequentchanges in attitude or to conduct an analysis using a quasi-experimental situation on the target data.
59
Kojala and Zukauskas. “Russia’s Soft Power in Lithuania”
60
The year before that, in 2014, there was a three-month ban on domestic re-broadcasting of Russian state-run (throughGazprom) channels in Lithuania (NTV Mir Lithuania). This only targeted specific programmes, not the entire channel. See
detail on “Russian TV banned” The Baltic Times, April 3-April 30, 2014 (#845), 4.
61
BNS/TBT Staff. “Dispute on Lithuanian sanctions for Russian TVs moves to EU Court of Justice,” The Baltic Times,
February 28-March 28, 2018 (#915), 19; Wang, Ya Chun. “EU court backs Lithuania in TV hate speech case” Politico.eu.
July 4, 2019. https://www.politico.eu/article/eu-court-backs-lithuania-in-tv-hate-speech-case/.
62
ERR. “Telia, Elisa to halt broadcast of Russian-language TV channels” err.ee. February 22, 2022.
https://news.err.ee/1608508637/telia-elisa-to-halt-broadcast-of-russian-language-tv-channels.
63
Girnius, Kestutis. “On the Road to Censorship?” The Baltic Times. September 4-October 1, 2014. (#850), 15; DW. “Lithuania
39

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to ban Russian TV channel for ‘warmongering’,” dw.com, April 8, 2015. https://p.dw.com/p/1F564; Cesare, Matt. “Russian
encroachment in the Baltics: The Role of Russian Media and Military,” Foreign Policy Research Institute, December 14, 2020.
https://www.fpri.org/article/2020/12/russian-encroachment-in-the-baltics-the-role-of-russian-media-and-military-2/.
64
BNS/TBT Staff. “OSCE official concerned over closing of Latvian web-site of Russia’s Sputnik news agency.” The
Baltic Times, April 7-April 20, 2016 (#875), 1.
65
RSF. “Baltic countries: Misusing EU sanctions to ban Russian TV channels is not a legitimate tool for promoting reliable
information.” rsf.org July 10, 2020.
66
McDermott, Doireann. “US and CEE Countries concerned over the Kremlin’s Europe strategy.” The Baltic Times,
October 20-November 2, 2016 (#889).
67
Although the government did not directly produce the film, the director of the film was decorated by the Latvian andEstonian governments of the time for his work.
68
Kaprāns, Mārtiņš. “Hegemonic representations of the past and digital agency: Giving meaning to “The Soviet Story”
on social networking sites” Memory Studies 9, no. 2 (2016): 156-172.
69
Wezel, Katja. “Latvia’s ‘Soviet Story’. Transitional Justice and the Politics of Commemoration.” satori.lv. October 26, 2009.
https://satori.lv/article/latvias-soviet-story-transitional-justice-and-the-politics-of-commemoration.
70
Kasekamp. “Why Narva is not Next”, 3.
71
TBT Staff. “Latvia may get Russian-language TV channel,” The Baltic Times, March 4-April 2, 2015 (#856), 3.
72
For the evaluation of Estonia’s national ETV Russian language channel, Parshukov Vitalii 2017 “Media, Memory, andMinority: The Russian Language TV Channel ETV+ and its Role in the Long-Lasting “War of Memories” in Estonia”
Master Thesis submitted to University of Tartu, Faculty of Political Science Johan Skytte Institute of Political Science. It
is known that this channel is popular not only with Russian-speaking Estonians, but also ethnic Estonians as well.
BNS/TBT Staff 2015 “New Russian channel ETV+ most popular with ethnic Estonian” The Baltic Times, October 8October 21, 2015, 2.
73
TBT Staff 2015 “LTV working on new channel for Latvia’s Russian speakers” The Baltic Times, April 2 – May 6, 2015(#857), 3.
74
Kolsto. Strategic Uses of Nationalism and Ethnic Conflict, 212.
75
While this campaign was not so clearly developed in the Japanese-speaking world, the Twitter statement by the Estonian
Embassy in Japan on February 24, 2022 (https://twitter.com/estembassyjp/status/1496798387856834561) generated many
positive and sympathetic reactions across Japanese SNS, which is a rare success story.
76
Abend, Lisa. “Meet the Lithuanian ‘Elves’ Fighting Russian Disinformation” Times, March 5, 2022.
https://time.com/6155060/lithuania-russia-fighting-disinformation-ukraine/.
77
Grigas, Agnia. Beyond Crimea: The New Russian Empire. New Haven: Yale University Publishing, 2016. 162.
78
Schlapak, David A. and Michael W. Johnson. Reinforcing Deterrence on NATO’s Eastern Flank: Wargaming the Defense of
the Baltics, RAND Corporation. 2016.

1620

China’s Security Engagement with Greater Central Asia (GCA)1:The Case of Afghanistan
Amane Tanaka*
Maria Tanaka***Project Researcher, Research Center for Advanced Science and Technology,
University of Tokyo**Specially-appointed Assistant Professor, Graduate School of International Resource Sciences,
Akita University
Abstract
In the aftermath of the 9/11 attacks, China has developed a complex legal framework and an extensive
operational infrastructure to combat terrorism. Recognizing the linkages between internal and external
security threats, Beijing has also increased counter-terrorism cooperation with its neighbors. Regarding
long-term strategic objectives, the Chinese government places emphasis on the eradication of internal(Xinjiang) and external (the Af-Pak region) terror hotbeds through economic development.
Concurrently, China acknowledges that it is a stable security environment that provides the mostfavourable conditions for sustainable economic growth, hence the salience of counter-terrorism
cooperation. The overall aim of this study is to examine China’s evolving security footprint in GCA in
relation to counter-terrorism with a particular focus on Afghanistan. The paper follows a case-study
design, with in-depth analysis of the following security mechanisms: 1) the Shanghai Cooperation
Organization’s (SCO) Regional Anti-Terrorist Structure (RATS) and the SCO-Afghanistan Contact
Group (SCO-ACG), 2) the Quadrilateral Cooperation and Coordination Mechanism (QCCM), 3) the
Sino-Russian strategic partnership, and 4) Sino-Afghan security cooperation. The paper concludes
with a discussion about security challenges China faces in connection to the Taliban’s 2021 takeoverof Afghanistan and Beijing’s efforts to adjust to a new geostrategic reality.
Keywords: Security Cooperation, Counter-terrorism, SCO-RATS, Sino-Afghan Relations, Taliban
1. Introduction
The chaotic US withdrawal from Afghanistan resulted in the collapse of the Ghani administration and the Taliban’s
return to power. On August 19, 2021, the Taliban officially declared the restoration of the Islamic Emirate of Afghanistan
and subsequently named a new government. Nine days after the Taliban’s takeover, US Defense Secretary Lloyd Austin

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told Congress that the Afghan army’s sudden collapse caught the Pentagon “by surprise.”2 But the Pentagon was not alone
as Afghanistan’s neighbors also scrambled to address the Taliban surge.
On September 8, 2021, China’s Foreign Minister Wang Yi attended (via video link) the 1st Foreign Ministers’ Meetingon the Afghan Issue Among the Neighboring Countries of Afghanistan. In the Joint Statement issued at the conclusion of
the meeting, the foreign ministers of Pakistan, China, Iran, Tajikistan, Turkmenistan and Uzbekistan recognized that “thechanges undergone in Afghanistan prove yet again that there is no military solution to this issue, and [emphasized] theimportance of an inclusive political structure in Afghanistan with participation of all ethnic groups.” The ministers also
reiterated that “terrorist organizations, such as ISIS, Al-Qaeda, ETIM, TTP, BLA, Jondollah and others should not beallowed to maintain a foothold on Afghanistan’s territory.”3 On the same day, Wang announced that China would begin
offering at least $31 million in emergency aid to Afghanistan, including coronavirus vaccines, grain, winter supplies, andmedicines.4
Meanwhile, Taliban spokesperson Zabiullah Mujahid signaled the Taliban’s desire to join the China-Pakistan Economic
Corridor (CPEC). Given the Taliban’s limited investor choices, it seemed like a logical move. Soon after, Pakistan’s Interior
Minister Sheikh Rasheed Ahmad supported the extension of the CPEC stressing the need to promote regional connectivity.5
During his visit to Kabul in March 2022, Wang reiterated that China was willing to promote the extension of the CPEC to
Afghanistan, making the country a bridge for regional connectivity.6 To date, however, these words have not been followedby action.
The above developments provide insight into China’s expectations toward the Taliban government. First and foremost,China expects the Taliban to stop the spread of Islamist militancy (including the East Turkistan Islamic Movement (ETIM))
which threatens Xinjiang’s stability and jeopardizes Belt and Road Initiative (BRI) projects in the region. In other words,
China seeks assurances that the Taliban will not allow any anti-China Islamist groups to operate under their rule. Second,
China favors an inclusive coalition government in Afghanistan that is open to ethnic and religious minorities. Third,
although China does not recognize the Taliban government, it continues to provide emergency aid to Afghanistan, keeps
its Kabul embassy open, and engages in talks on the CPEC extension. It is clear, however, that China will not make any
substantial moves until it is confident of political and security conditions.
China’s post-9/11 counter-terrorism strategy places particular emphasis on eradication of internal (Xinjiang) andexternal (the Af-Pak region) “terror-breeding hotbeds” through economic development.7 In the Chinese view, there arelinkages between the emergence of violent extremism and conditions of economic deprivation, bad governance, andprolonged conflicts. Therefore, poverty eradication, livelihood enhancement, and sustainable growth are promoted as
strategic goals. Following this line of reasoning, the broad goal of the China-Central Asia-West Asia Economic Corridor(CCAWAEC) and the CPEC is to contribute to the economic development and stability of GCA countries, which in turnshall prevent the growth of Islamist terrorism and radicalization.8 At the same time, China acknowledges that a stablesecurity environment provides the most favourable conditions for sustainable economic growth, hence the salience ofcounter-terrorism cooperation.
Existing literature on Sino-Afghan security relations can best be classified under three headings: 1) the Shanghai
Cooperation Organization (SCO), 2) the “Pakistan factor,” and 3) the “War on Terror.” The first group of studies analyzes

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Sino-Afghan security relations in the context of the SCO’s efforts to maintain regional stability and combat terrorism anddrug-trafficking, as well as the SCO’s engagement with Afghanistan.9 The “Pakistan factor” literature, on the other hand,examines China and Pakistan’s key interests in Afghanistan and their strategic cooperation to pursue them. It also shows
how Pakistan’s army, through its sponsorship of the Taliban and other militants, possesses a unique capacity to influence
how these groups behave toward China.10 The third group of texts discusses the broader strategic context in which Chinesecounter-terrorism policy operates, its links to the US “Global War on Terror,” as well as the growing trend of overseas
terrorist attacks against Chinese nationals in the GCA region.11
In contrast to the above academic literature, this study offers a comprehensive analysis of China’s regional counterterrorism strategy at every level of engagement. The overall aim of this study is to examine China’s evolving security
footprint in GCA in relation to counter-terrorism with a particular focus on Afghanistan. The paper follows a case-study
design, with in-depth analysis of the following security mechanisms: 1) the SCO’s Regional Anti-Terrorist Structure(RATS) and the SCO-Afghanistan Contact Group (SCO-ACG), 2) the Quadrilateral Cooperation and Coordination
Mechanism (QCCM), 3) the Sino-Russian strategic partnership, and 4) the Sino-Afghan security cooperation. The paper
concludes with a discussion about security challenges China faces in connection to the Taliban’s return to power in
Afghanistan and Beijing’s efforts to adjust to a new geostrategic reality.

2. Developing Regional Counter-terrorism Cooperation: The SCO and Afghanistan
In contrast to its Western counterparts, China perceives terrorism as one of the “three evils” (三股势力) together withseparatism and religious extremism - a three-headed hydra that threatens the country’s national security and regional
stability. Therefore, the rhetoric of combating the “three evils” has not only dominated China’s domestic counter-terrorism
discourse, but also become a foundational concept for China’s regional security strategy in Central Asia following theestablishment of the SCO in 2001.12
While there is little doubt that the SCO is China’s main multilateral tool to maintain stability in the region, theorganization’s security structures are nascent and lack capacity to provide an effective collective response to regional
security challenges. The Regional Anti-Terrorism Structure (RATS), however, has been relatively successful incoordinating national counter-terrorism activities and intelligence sharing among SCO members. Established in 2004,
RATS is a permanent entity of the SCO with headquarters in Tashkent. Under the framework of the Shanghai Convention
on Combating Terrorism, Separatism and Extremism (2001), and the SCO Convention on Counter-terrorism (2009), RATS
has been active in the following five spheres: 1) information sharing, 2) information integration and production (thecreation of RATS Terrorist Database), 3) joint counter-terrorism exercises, 4) cooperation in criminal matters (including
extradition mechanisms), and 5) cooperation with other IOs to combat terrorism.13
Under the first Taliban regime (1996-2001), Afghanistan was a safe haven for Central Asian and Uyghur Islamist
militants, including the Islamic Movement of Uzbekistan (IMU) and the ETIM. In the wake of US-led invasion of
Afghanistan, the fighters from these militant groups fled to Pakistan’s Tribal Areas where they blended with militants fromother groups and ultimately became dependent on Al-Qaida.14 Throughout 2014, a dozen or so militant groups around theIslamic world pledged allegiance to ISIS leader Abu Bakr al-Baghdadi (1971-2019). Among them were Afghan and323

Pakistani commanders who rejected the Taliban movement under Mullah Omar for being too moderate.15 In November
2014, al-Baghdadi created a series of wilāya (governorate) in Saudi Arabia, Egypt, Yemen, Algeria, and Libya andappointed their wāli (governor).16 Two months later, in January 2015, ISIS issued a statement announcing the creation of
the wilāya Khurāsān (which refers to a historical region comprising eastern Iran, Afghanistan, and western Pakistan) andthe appointment of the former Taliban commander Hafiz Saeed Khan as its wāli.17 In sum, there is no denying that AlQaida, ISIS-Khurāsān (ISIS-K), and allied militant groups remain present in Afghanistan. Although this has been rejectedby the Taliban as “baseless propaganda”, the ISIS-K suicide attack on Kabul Airport last August and the US drone killingof an Al-Qaida leader in Kabul this August seem to prove otherwise. Lastly, along with the Islamist terrorist threat thatemanates from the Af-Pak region, the SCO needs to address organized crime and drug trafficking, a main source of funding
for insurgency and terrorist attacks in the GCA region.18
The June 2011 announcement of the NATO plan to complete the withdrawal of troops from Afghanistan by the end of2014 revived the discussion on SCO membership expansion. The 2014 SCO Dushanbe Summit approved the legal
documents on the admission of new members, paving the way for the SCO’s expansion.19 In 2017, India and Pakistan
were officially admitted to the SCO, while Iran’s bid to become a full member was approved in 2021. Some scholars pointout that since India and Pakistan became members, the SCO has witnessed more disagreements and disputes on its security
agenda due to the enmity between the two states.20 The Chinese government, however, still seems to harbor hope that withall (bar neutral Turkmenistan) Afghan neighbors becoming full members and with India on board, the organization will
finally be able to present a unified vision of how to solve the Afghanistan conundrum.
Throughout the years, it was China who was pushing for the SCO’s engagement with Afghanistan. In 2005, Beijing
supported the establishment of the SCO-Afghanistan Contact Group (SCO-ACG), preparing the groundwork for closer
security cooperation between Afghanistan and the organization. However, contrary to widespread expectations, the Obamaadministration did not quickly pull out from Afghanistan, but instead launched the “Af-Pak strategy,” refocusing on
Pakistan’s role as a sanctuary for the Afghan Taliban and Al-Qaida, increasing US forces in Afghanistan, and moving
forward with the New Silk Road initiative. As a result, the SCO-ACG’s activities ground to a halt.
During the 2012 SCO Beijing Summit, Afghanistan was granted the status of observer, while in 2015 the country signed
a protocol on counter-terrorism with the SCO-RATS. Furthermore, during the 2015 SCO Ufa Summit, the SCO announced
the formation of the so-called “6+6+6” consultative framework consisting of the organization’s six members, six observers,
and six dialogue partners.21 In 2017, in line with the Afghan government’s newly coined policy of “multi-alignment
neutrality,” Afghanistan requested full membership in the SCO.22 In response to the Afghan government’s move, at the2017 SCO Shanghai Summit, President Xi proposed the resumption of the SCO-ACG to facilitate peace and stability in
Afghanistan. Since then, the Contact Group has been meeting annually.23
During the 3rd Meeting of the SCO-ACG held in Bishkek in April 2019, a Roadmap for Enhanced Cooperation - thefirst step toward full SCO membership - was signed. In another development, during the 4th Meeting of the Group held in
Dushanbe in July 2021, Uzbekistan proposed a Plan of Practical Measures to Promote the Socioeconomic Restoration of
Afghanistan, moving the socio-economic development of Afghanistan to the top of the agenda. Regrettably, in the wakeof the Taliban’s takeover, the SCO’s collective vision for security, stability, and the socio-economic development of

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Afghanistan seems to have disappeared. Originally, Afghanistan’s full membership in the SCO was supposed to reduce
security threats to the GCA region, enhance counter-terrorism cooperation, and help address the power vacuum left after
the US withdrawal. Instead, with the Taliban back in power, the region is back to square one, teetering on the abyss andscrambling to stave off a humanitarian crisis and economic collapse.

3. Stabilizing China’s Western Border: The Quadrilateral Cooperation and Coordination Mechanism
In addition to the SCO-RATS, China initiated the Quadrilateral Cooperation and Coordination Mechanism (QCCM), a
counter-terrorism minilateral cooperation framework composed of Afghanistan, China, Pakistan, and Tajikistan. According
to China’s 2019 Defense White Paper, the QCCM was created to provide “coordination and mutual support in situation
evaluation, evidence verification, intelligence sharing, capacity building, and training.”24 In August 2016, the chiefs ofstaff met for the first time in Urumqi to announce the formation of the mechanism and subsequently observe a Chinese
military exercise at Korla.25 During the 2nd meeting held in Dushanbe in August 2017, two agreements were signed: theAgreement on Quadrilateral Counter-Terrorism Cooperation and Coordination Mechanism, and the Protocol on
Quadrilateral Counter-terrorism Information Coordination Centre, taking the initial step toward the institutionalizationof the initiative.26
The QCCM is noteworthy for three reasons. First, it is a component of China’s new regional security framework (theso-called “New Asian Security Concept” 亚洲新安全观). This framework seeks to further China’s strategic interests
across Asia by knitting together security organizations, mechanisms, and partnerships devoid of Washington’s influence.
Second, it is a part of a larger drive to institutionalize China’s global military footprint. Thus, it cannot be ruled out that,at some point in the future, China will officially dispatch its military or paramilitary personnel on an overseas counterterrorism mission under the QCCM framework.27 Third, the QCCM marks the first time the People’s Liberation Army
(PLA) has taken a leadership role in building a multilateral cooperation framework.28
Following the withdrawal of a majority of NATO forces from Afghanistan in 2014, China has sought to build a “security
barrier” (安全屏障) in Tajikistan to prevent terrorist and extremist groups from heading north into Central Asia andXinjiang.29 To this end, the QCCM has facilitated security cooperation with Tajikistan. In October 2016, Tajikistan and
China signed a government-to-government agreement on the construction of a number of frontier posts along Tajikistan’scommon border with Afghanistan.30 Also since 2016, Chinese troops (most likely the People’s Armed Police (PAP) in
charge of counter-terrorism efforts) have been posted in the vicinity of Shaymak in Gorno-Badakshan Autonomous Region(GBAR) near the joint Afghanistan-PRC-Tajikistan border. Details are scarce, but PAP’s purpose seems to be patrol of the
GBAR and the Wakhan Corridor to prevent Islamist militants from covertly entering Tajik and Chinese soil.31
Further to the above, following a visit from Chinese Defense Minister Wei Fenghe in Dushanbe in October 2021,
Tajikistan’s lower house of parliament approved the construction of a new Chinese-funded base near the country’s borderwith Afghanistan. It was also reported that the Tajik government offered to transfer full control of an existing Chinese
military base in the country to Beijing and waive any future rent in exchange for military aid from China.32 In sum, it
appears that Tajikistan expects China to provide long-term funding to strengthen Tajik military points along the borderwith Afghanistan in exchange for Dushanbe transferring full control of the existing facility/facilities to China without

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charging any basing fees. In yet another development, in August 2021, before attending the SCO’s biannual counterterrorism military exercise in Orenburg Oblast, China and Tajikistan held a joint counter-terrorism drill in Dushanbe. The
2021 Counter-Terrorism Coordination Exercises were conducted within the QCCM framework and included (among others)
practicing drone strikes and clearing explosive devices.33
Overall, although limited in comparison with Russia’s military presence, in recent years China has enhanced counterterrorism and border cooperation with Tajikistan. Within the QCCM framework, China has deployed PAP personnel to
Tajikistan and to Afghanistan’s Wakhan Corridor and it is entirely possible that, at some point in the future, China will
decide to dispatch PAP (or even PLA) personnel on an official overseas counter-terrorism mission to the area.

4. The Dynamics of Sino-Russian Strategic Partnership in GCA
Beijing and Moscow’s interests in Central Asia overlap in three areas: 1) regional security and stability, 2) tradecomplementarities between the two economies, with Russia as a key exporter of resources and China as a key investor andprovider of consumer goods, and 3) a joint Sino-Russian front to undermine the relevance of US aid and other efforts inCentral Asia aimed at increasing American supremacy. Hence, up until recently, China and Russia have chosen toemphasize cooperation over competition in their bilateral relations, with Russia focusing on security issues and China
contributing to economic development mainly through infrastructure investments.34 Collaborative mechanisms designed
by Russia and China - the Collective Security Treaty Organization (CSTO) and the SCO on the security side, and theEurasian Economic Union (EAEU) and the Silk Road Economic Belt (SREB) in the economic sphere - have guaranteed
relative stability of the region and resulted in moderate economic growth. It has also, however, contributed to a
consolidation of Central Asian semi-authoritarian regimes.
Since the West imposed sanctions on Russia in response to its 2014 annexation of Crimea, the country has accelerated
its “turn to the East” in an attempt to offset its loss of access to Western financial markets and advanced technologies. As
a result, the Sino-Russian military and economic cooperation has progressed a great deal and the two countries havecollaborated on a host of global and regional governance issues. In May 2015, during a meeting between Xi and Putin in
Moscow, Russia endorsed the idea of making the SCO a platform for EAEU-SREB cooperation and the two sides signeda Joint Declaration on Aligning the Silk Road Economic Belt with the Eurasian Economic Union. During the visit,
President Xi also signed a series of infrastructure agreements worth $25 billion with Belarus, Kazakhstan, and Russia onhigh speed rail, energy infrastructure and aerospace, as well as industrial parks.35 At the beginning of 2017, the EAEU
Economic Commission announced a list of priority projects to be implemented under the SREB-EAEU alignment,
highlighting the potential of transport infrastructure projects for enhancing Eurasian trade and connectivity.36 Overall,while the envisaged cooperation between the SREB and the EAEU adds to the perceived legitimacy of both initiatives,
Russia has used the EAEU to retain an institutional leverage over China’s economic encroachment into post-Soviet space.
In the realm of security cooperation, in 2019 the two countries upgraded their relations to the highest level of partnershipwithin the hierarchy of diplomatic ties in China’s partnership framework - a “comprehensive strategic partnership of
coordination for the new era” (新时代全面战略协作伙伴关系). This partnership is characterised by cooperation on all
issues, including international affairs, as well as military and technological development.37 Under the agreement, China

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and Russia have institutionalized a comprehensive mechanism for military consultation, expanded military-technicalcooperation, and increased joint military exercises. In November 2021, the two sides signed a Road Map for Military Cooperation for 2021-2025, a document that guides collaboration in the realms of joint military exercises, intelligence sharing,and joint development of weapons system.38
Cybersecurity is another area of cooperation between China and Russia. In 2015, the two sides signed an Agreement on
Cooperation in Ensuring International Information Security, with the overarching aim of combating “threats in the fieldof international information security” including cyberterrorism.39 Interestingly, in the same year under the SCO umbrella,an International Code of Conduct for State Behaviour in Cyberspace was promulgated, placing the Central Asian states
within the “Sino-Russian cyber-security bloc” sphere of influence.40 Also in 2015, the first SCO anti-cyberterrorism joint
drill was held in Xiamen, which was based on the scenario of an international terrorist group infiltrating the member
country’s network.41
In July 2021, the deteriorating security environment in Afghanistan prompted China and Russia’s defense ministers tomeet in Dushanbe to discuss the strengthening of the military and counter-terrorism cooperation in the GCA region. A
month later, a massive (10,000 soldiers) joint anti-terrorism military exercise was held in Ningxia Autonomous Region,
followed by another large-scale (4,000 soldiers) joint exercise in Orenburg in September.42 Meanwhile, at the beginningof August, the Russian army completed joint military exercises with Tajik and Uzbek troops near the border with
Afghanistan.43 In another set of exercises, during September 7-9 in Kyrgyzstan, the CSTO Collective Forces of Rapid
Deployment conducted a joint counter-terrorism operation focused on a scenario in which an irregular military invaded
the territory of one of the CSTO members.44
Overall, from a military standpoint, Russia (via the CSTO) has remained the regionally dominant power, and this is
acceptable both to China and Central Asian countries, which instead focus on fighting the “three evils” on the local level.
In December 2021, Xi discussed with Putin the possibility of China participating in a joint peacekeeping mission with the
CSTO in a buffer zone at the Tajikistan-Afghanistan border.45 At that point, Central Asian countries still looked to Russia
as a security guarantor able to protect the region from incursions by Islamist militants. But the subsequent Russian invasionof Ukraine made both China and its Central Asian partners rethink their positions.
First, Putin’s justification for the invasion (the liberation of areas with majority ethnic Russian populations) could justas easily apply to Kazakhstan as it could to Ukraine. Thus, this is not surprising that both President Toqaev andUzbekistan’s then-Foreign Minister Komilov made it abundantly clear that they would not recognize the Donetsk andLuhansk regions as independent entities.46 Second, the conflict has been a major blow to the regional economy. Close
trade and payment-system links with Russia are curbing trade, remittances, and tourism, adversely affecting economic
growth, inflation, and countries’ abilities to repay external debts. Rising prices raise social tensions thus contributing tofurther societal destabilization. Third, any faith Central Asian governments and China had in Russian military power has
no doubt been shaken by its failures in Ukraine. Consequently, there are growing concerns about what sort of guarantees
and military help Moscow can really offer.

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To sum up, although Russia’s military and economic interests remain firmly entrenched in Central Asia, political fallout
from the Ukraine war could lead to Beijing becoming an even more sought-after partner in the region, at the same time
placing an even greater burden on its shoulders in enforcing the SCO’s counter-terrorism mandate.

5. The Missing Link: The Sino-Afghan Security Cooperation
China’s modus operandi in Afghanistan can be described as cautious engagement. When the necessity arises, China (via
the good offices of Pakistan’s Inter-Services Intelligence Directorate (ISI)) engages with the Taliban. 47 When theopportunity arrives, China expands its economic footprint in Afghanistan, while assisting the consecutive republican
governments in building resilience against terrorism.48
Between 1980 and 1985, in response to the Soviet invasion of Afghanistan, China funnelled money and arms to thegrowing Mujahedeen movement via the Peshawar route. It is estimated that by 1985 China had supplied the Afghan
opposition with as much as $400 million.49 Around the same time, following China’s opening-up and the Party’s relatively
liberal religious policy, Uyghurs were allowed to travel to Pakistan to study Islam in local madrasas. Some of thesemadrasas, however, promoted radical Islamist ideologies, instilling in Uyghur students a radical Islamic identity. The
madrasas also served as a recruiting site for Afghan wars.50
In Xinjiang in the late 1980s, on the other hand, the East Turkistan Islamic Movement (ETIM) was revived advocating
a greater political and social role for Islam in Xinjiang and the establishment of an independent East Turkistan.51 Following
the Baren rebellion (1990), the Yining insurrection (1997), and the subsequent retaliatory “strike hard” (反恐严打)
campaigns, the ETIM militants fled to Afghanistan, where they pledged allegiance to the Taliban leader Mullah Omar andunder his protection managed to establish bases for Uyghur militants in Kabul and along the Afghanistan-Pakistan border.
In the aftermath of the US-led invasion of Afghanistan, ETIM fled to Pakistan’s Tribal Areas where it blended withmilitants from other groups and ultimately became dependent on Al-Qaida.52
Aware of the situation, Beijing, through the good offices of the ISI, began to cautiously establish contact with the Taliban
around 1999. In December 2000, the PRC’s ambassador to Pakistan, Lu Shulin, met with Mullah Omar in Kandahar.
Mullah Omar assured the ambassador that the Taliban would not permit militants seeking to harm China to operate inAfghanistan. In exchange, Beijing was asked to diplomatically recognize the Taliban government and protect it from UN
sanctions.53 While both parties were waiting for the other to make the first move, the 9/11 attacks and the subsequent USled invasion derailed the relationship.
Following the 2011 announcement of the International Security Assistance Force’s (ISAF) withdrawal plan, China
became a more visible player in Afghanistan. In 2012, a member of the Politburo Standing Committee, Zhou Yongkang,visited Kabul - the first high-level trip to Afghanistan since 1966.54 In the same year, China and Afghanistan decided to
upgrade their ties to the level of a “strategic cooperative partnership” (战略合作伙伴关系). As a part of the agreement,
China offered to train around 300 Afghan police officers.55 Regarding China’s mediation efforts, in 2014, China hosted
the 4th Ministerial Conference of the Heart of Asia-Istanbul Process (HoA-IP), an initiative that brings regional countries
together to support peace and stability in Afghanistan. Between 2015 and 2017, China (together with Afghanistan, Pakistan,and the US) participated in the Quadrilateral Coordination Group on the Afghan Peace and Reconciliation (QCGAPR), a

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forum to enhance mutual trust between Afghanistan and Pakistan and broaden political, security, and economic
cooperation.56 Lastly, as discussed in the previous sections, since around 2016, PAP personnel have conducted joint patrols
with Tajik and Afghan forces in GBAR and the Wakhan Corridor. Since 2015, Beijing has also consistently supported
Afghanistan’s bid for full SCO membership.
In light of the above, it is clear that Beijing has been highly pragmatic in its dealings with Afghanistan, willing tocultivate contacts both with the republican governments and the Taliban. Throughout the years, China (via the good officesof the ISI) has quietly maintained a relationship with the Taliban while forging a good working relationship with the Karzai
and Ghani governments. On the eve of the withdrawal of NATO troops, China adopted a more proactive approach toAfghanistan, beefing up security and economic cooperation and actively engaging in mediation efforts.
In the 1990s only three states (Pakistan, Saudi Arabia, and the UAE) recognised the first Taliban regime. This timearound China acknowledges that it has vital interests in cooperating with the Taliban, particularly on counter-terrorism,
counter-narcotics, border security, and economic development (such as land transport infrastructure and resource extractionindustry). China, however, will not take the lead in recognising the Taliban government and will only do so in a concerted
move with Pakistan, Russia, and Iran. One full year into Taliban rule, China has taken a “wait-and-see” approach, seeking
assurances that the Taliban will not allow any anti-China Islamist group to operate under their rule, while providing
humanitarian aid and engaging in talks on CPEC extension. It is certainly possible that, at some point in the future, China
will take a more hands-on role in Taliban-led Afghanistan. For the time being, however, China is still weighing the risk
and reward any such move would entail.

6. China’s Security Footprint in GCA: Adjusting to a New Reality
In the aftermath of the 9/11 attacks, China developed a complex legal framework and an extensive operational
infrastructure to combat terrorism. Regarding long-term strategic objectives, Beijing places emphasis on the eradicationof internal (Xinjiang) and external (the Af-Pak region) terror hotbeds through economic development. Therefore, the broadgoal of the SREB’s economic corridors (the CCAWAEC and CPEC) is to contribute to the economic development andstability of GCA states, which in turn shall prevent the growth of Islamist terrorism and radicalization. Concurrently, China
acknowledges that a stable security environment provides the most favourable conditions for sustainable economic growth,hence the salience of counter-terrorism cooperation in the region.
Throughout the years, China has developed a four-pronged model of counter-terrorism cooperation in the GCA region.
At the regional level, the SCO-RATS has been relatively successful in coordinating national counter-terrorism activities
and intelligence sharing among members. To forge closer security ties with Afghanistan, Beijing facilitated theestablishment of the SCO-Afghanistan Contact Group, expressed support for granting Afghanistan observer status, andpromoted its subsequent bid for full SCO membership. At the minilateral level, within the QCCM framework, China hasenhanced counter-terrorism and border cooperation with Tajikistan and Afghanistan as well as deployed PAP personnel
near the Afghanistan-PRC-Tajikistan border to ensure that terrorists are prevented from entering Chinese soil. In the realmof bilateral cooperation, China attaches particular importance to the Sino-Russian strategic partnership. In recent years,
the two countries have institutionalized a comprehensive mechanism for military consultation, expanded military-technical929

cooperation, increased joint exercises, and signed an agreement on cybersecurity cooperation. As for Sino-Afghan security
ties, China forged a good working relationship with the Karzai and Ghani administrations, while quietly maintaining a
relationship with the Taliban. In the aftermath of NATO forces withdrawal, China stepped up mediation efforts to broker
peace between the republican government and the Taliban, as well as actively encouraged Afghanistan and Pakistan tobuild mutual trust and broaden security cooperation through the QCCM and QCGAPR.
The Taliban’s recent return to power, in conjunction with Russia’s invasion of Ukraine, has thrown the regional counterterrorism architecture into disarray. One year into Taliban rule, China faces a dilemma about its counter-terrorism strategy
at every level of engagement. At the regional level, the SCO’s collective vision for security, stability, and socio-economic
development in Afghanistan must be shelved for the time being. At the minilateral level, China has been left to navigate
increasingly strained ties between the Tajik government and the Taliban, as well as foot the bill for upgrading Tajik borderfacilities. In the realm of bilateral cooperation, although the Sino-Russian strategic partnership remains intact for the
moment, the Russian invasion of Ukraine and subsequent Western sanctions have dealt a major blow to the regional
economy, threatening further societal destabilization. Moreover, in light of Russia’s military failures, there are growing
concerns about what guarantees and military help Moscow can really offer. The fall of the Ghani government, on the other
hand, left China scrambling to repurpose its counter-terrorism, counter-narcotics, and border management strategies
against the backdrop of a humanitarian crisis and economic collapse in Afghanistan.
Beijing is currently in the process of mapping out how to deal with a post-American Afghanistan, and, by extension,
how to revamp the regional counter-terrorism architecture. China has outlined conditions for possible Sino-Afghan
cooperation, including the Taliban’s strict stance against Uyghur militants, Al-Qaeda, and ISIS-K; forming an inclusive
government; and moderating their domestic policies. While still weighing the risk and reward, China recognises that failure
to engage with the Taliban would result in Afghanistan once again descending into chaos and relapsing into a hotbed ofinternational terrorism. Should China succeed in engaging the Taliban and stabilizing the country, it will reap a handsome
reward - proof that the Chinese model of “developmental peace” constitutes a viable alternative to the standard Westernmodel of state-building that failed so miserably in Afghanistan.

Acknowledgements
This work was supported by JSPS KAKENHI Grant Number JP21K01344.
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1

S. Frederick Starr defines “Greater Central Asia (GCA)” as a cultural zone of which the five former Soviet republics area part, along with Afghanistan, the Chinese province of Xinjiang, Mongolia, the Khorasan Province of Iran, and thenorthern part of Pakistan. Starr’s argument is that centuries of economic and social interactions within the Turko-Persian
Islamicate cultural complex is more relevant than the Soviet-induced factors that keep the area divided today (S. FrederickStarr, “In Defense of Greater Central Asia,” CACI Policy Paper, September 2008: 2-4). Although scholars from Central
Asia were initially negative about Starr’s proposal, the analysis of the region through the “Greater Central Asia” lens has
been gaining traction among Western, Indian, and Chinese experts.
2
Lloyd J. Austin, “Secretary of Defense Lloyd J. Austin III Remarks Before the Senate Armed Services Committee,” U.S.
September
28,
2021,
Department
ofDefense,https://www.defense.gov/News/Speeches/Speech/Article/2791954/secretary-of-defense-lloyd-j-austin-iii-remarksbefore-the-senate-armed-service/.
3
Ministry of Foreign Affairs, “Joint Statement Issued at the Conclusion of the Foreign Ministers’ Meeting on the Afghan
Issue Among the Neighbouring Countries of Afghanistan,” Government of Pakistan, September 8, 2021,
https://mofa.gov.pk/joint-statement-issued-at-the-conclusion-of-the-foreign-ministers-meeting-on-the-afghan-issueamong-the-neighbouring-countries-of-afghanistan-8-september-2021/.
4
Al Jazeera, “China Extends $31m in Emergency Aid to Afghanistan,” Al Jazeera, September 9, 2021,
https://www.aljazeera.com/news/2021/9/9/china-offers-31m-in-aid-3-million-covid-shots-to-afghanistan.
5
Adnan Aamir, “Taliban Rolls Out Red Carpet to Belt and Road Initiative,” Nikkei Asia, September 12, 2021,
https://asia.nikkei.com/Politics/International-relations/Afghanistan-turmoil/Taliban-rolls-out-red-carpet-to-China-s-Beltand-Road-Initiative.
6
Dawn, “China Says Willing to Extend CPEC to Afghanistan,” Dawn, March 25, 2022,
https://www.dawn.com/news/1681738.
7
Zhen Wang, “China’s Counterterrorism Experience,” China - US Focus, June 30, 2022,
https://www.chinausfocus.com/peace-security/chinas-counterterrorism-experience.
8
For a detailed analysis of China’s version of security-development nexus, see Amane Tanaka, “Chugoku-Chuoajia Kankeini Miru Anzen Hosho-Keizai Kaihatsu no Nekusasu,” in Yurashia ni okeru Ido Koryu to Shakai Bunka Henyo, ed. Yasushi
Shinmen (Tokyo: Chuo Daigaku Shuppan, 2021), 23-38.
9See, for example, Huasheng Zhao, “Shanghai Hezuo Zuzhide Jiyu he Tiaozhan,” Guoji Wenti Yanjiu, no. 6 (2007): 3947; Joseph Y. S. Cheng, “The Afghanistan Situation and China’s New Approach to the SCO,” Asian Survey 55, no. 2(2015): 346-370; and Xiaotian Li, “Shanghai Hezuo Zuzhi Kuoyuanhoude Diqu Diwei yu Hezuo Geju,” Guoji Zhanwang,
no. 3 (2021): 96-118.
10
Examples include, Andrew Small, “China and Counter-Terrorism: Beyond Pakistan?” in Terrorism and Counterterrorism in China: Domestic and Foreign Policy Dimensions, ed. Michael Clarke (Oxford: Oxford University Press,
2018), 129-140; and Ghulam Ali, “China-Pakistan Cooperation on Afghanistan: Assessing Key Interests and Implementing
Strategies,” The Pacific Review 35, no. 3 (2022): 506-528.
11See, for example, Russell Ong, “China and the U.S. War on Terror,” Korean Journal of Defense Analysis 18, no. 2 (2009):
95-116; Mathieu Duchatel, “Terror Overseas: Understanding China’s Evolving Counter-Terror Strategy,” European
Councilof
Foreign
Relations,
October
2016,
https://ecfr.eu/wp-content/uploads/ECFR_193_-

1535

_TERROR_OVERSEAS_UNDERSTANDING_CHINAS_EVOLVING_COUNTER_TERROR_STRATEGY.pdf; andAlessandro Arduino, “China’s Private Security Companies: the Evolution of a New Security Actor,” in Securing the Beltand Road Initiative: China’s Evolving Military Engagement along the Silk Road, ed. by Nadege Roland, (Seattle: The
National Bureau of Asian Research, 2019), 91-103.
12Zhenhong Wei, ed., Shanghai Hezuo Zuzhi Huimou yu Qianzhan (2001-2018) (Beijing: Shijie Zhishi Chubanshe, 2018),
7-9.
13
Aleksandra Maria Kolodziejczyk-Tanaka and Amane Tanaka, “The Structure and Content of China’s Counterterrorism
Policy: The Case of Uyghur Islamist Terrorism,” in Proceedings: International Conference on Xinjiang in the Context ofCentral Eurasian Transformations (Tokyo: University of Tokyo, 2015), 286-387.
Since its inception, RATS has been tasked with the coordination of the SCO anti-terrorism drills, including annual Joint
Anti-Terrorism Exercises (JATEs) and cybersecurity drills. The practice was institutionalized in the 2008 Agreement on
the Procedure for Organizing and Conducting Joint Anti-Terrorism Exercises. Regarding the cooperation in criminal
matters, under the simplified extradition procedure (Article 23 of the SCO Convention against Terrorism), the vast majorityof cases involve extradition of Uyghurs to China. As for cooperation with other IOs, RATS signed protocols of cooperation
with the CARICC, CIS, CSTO, as well as a MoU with the UNODOC.
14
Jacob Zenn, “On the Eve of 2014: Islamism in Central Asia,” Current Trends in Islamist Ideology, vol. 15 (2013): 75-76,
https://www.hudson.org/content/researchattachments/attachment/1378/zenn_vol15.pdf.
15
It appears that around that time IMU pledged alliance to ISIS, whereas ETIM remained loyal to Al-Qaida (RaffaelloPantucci, “Uyghur Terrorism in a Fractured Middle East,” in Terrorism and Counter-Terrorism in China: Domestic andForeign Policy Dimensions, ed. Michael Clarke (Oxford: Oxford University Press, 2018), 166-169).
16
The term “wilāya” was used by the Ottoman Empire to describe semi-autonomous provinces under loyal but independent
rulers.
17
Jason Burke, The New Threat: The Past, Present and Future of Islamic Militancy (New York: The New Press, 2015),
146.
18
For a detailed analysis, see Mariya Omelicheva, “Eurasia’s CSTO and SCO: A Failure to Address the
Trafficking/Terrorism Nexus,” Ponars Eurasia, January 21, 2017, https://www.ponarseurasia.org/eurasia-s-csto-and-scoa-failure-to-address-the-trafficking-terrorism-nexus/.
19
Shanghai Cooperation Organization, “Dushanbe Declaration by the Heads of the Member States of the Shanghai
Cooperation Organization,” Shanghai Cooperation Organization, September 12, 2014, http://eng.sectsco.org/documents/.
20
For a detailed analysis, see Jinfeng Li, Shanghai Hezuo Zuzhi 20 Nian: Chengjiu, Tiaozhan yu Qianjing (Beijing: Shehui
Kexue Wenxian Chubanshe, 2021), 135-137; and Jin Wang and Dehang Kong, “Counter-Terrorism Cooperation between
China and Central Asia States in the SCO,” China Quarterly of International Strategic Studies 5, no. 1 (2019): 75-76.
21
Ziguo Li, “Shanghai Hezuo Zuzhi de Kuoyuan yu Mingyun Gongtongti Jianshe,” Eluosi Dong’ou Zhongya Yanjiu, no.
4 (2021): 9.
22
Atlantic Council South Asia Center. 2020. “Will Ghani’s Plan for Peace in Afghanistan Work?” Atlantic Council, June18, 2020, https://www.atlanticcouncil.org/blogs/new-atlanticist/will-ghanis-plan-for-peace-in-afghanistan-work/.
23
The 1st meeting was held in Moscow on October 11, 2017; the 2nd meeting was held in Beijing on May 28, 2018; the 3rd
meeting was held in Bishkek on April 19, 2019; and the 4th meeting was held in Dushanbe on July 14, 2021.
24
Zhonghua Renmin Gongheguo Zhongyang Renmin Zhengfu, Xin Shidai de Zhongguo Guofang, Zhongguo Zhengfu
Wang, July 24, 2019, http://www.gov.cn/zhengce/2019-07/24/content_5414325.htm.
25
Renmin Wang, “Shoujie AZhongBaTa Siguo Jundui Fankong Hezuo Xietiao Jizhi Gaoji Lingdaoren Huiyi Juxing,”
Renminwang, August 4, 2016, http://military.people.com.cn/n1/2016/0804/c1011-28610676.html.
26
Yongzheng Chu, “Zhongguo Junshi Waijiaode Xin Linian Xin Bianhua,” Guoji Yanjiu Cankao, no. 8 (2018): 36.
27
Article 71 of the Counter-terrorism Law of the People’s Republic of China states in part that “the Chinese People’s
Liberation Army and Chinese People’s Armed Police forces may assign personnel to leave the country on counter-terrorism
missions as approved by the Central Military Commission.”
28
Mathieu Duchatel, “Overseas Military Operations in Belt and Road Countries: The Normative Constraints and Legal
Framework,” in Securing the Belt and Road Initiative: China’s Evolving Military Engagement along the Silk Road, ed.
Nadege Roland (Seattle: The National Bureau of Asian Research, 2019), 13.
29
Bin Yue, “Zhongguo Zhu Tajikesitan Dashi: ZhongTa Gongtong Tuidong Shanghe Zuzhi Qude Xin Fazhan,” China News,
June 7, 2018, https://www.chinanews.com.cn/m/gn/2018/06-07/8532527.shtml.
30
Asia-Plus, “Beijing Expected to Build 10 Frontier Outposts along Tajikistan’s Common Border with Afghanistan,” Asia-

1636

Plus, November 14, 2016, https://www.asiaplustj.info/en/news/tajikistan/security/20161114/233190.
31
Dirk Van der Kley, “China’s Security Activities in Tajikistan and Afghanistan’s Wakhan Corridor,” in Securing the Beltand Road Initiative: China’s Evolving Military Engagement along the Silk Road, ed. Nadege Roland (Seattle: The National
Bureau of Asian Research, 2019), 85.
32
Reid Standish, “Tajikistan Approves Construction of New Chinese-Funded Base as Beijing’s Security Presence inCentral Asia Grows,” Radio Free Europe, October 27, 2021, https://www.rferl.org/a/tajikistan-approves-chinesebase/31532078.html.
33
Laura Zhou, “China Conducts Anti-terror Drill with Tajikistan, as Afghan Spillover Worries Grip Central Asia,” South
China Morning Post, August 18, 2021, https://www.scmp.com/news/china/diplomacy/article/3145532/china-conductsanti-terror-drill-tajikistan-afghan-spillover.
34
For a critique of the dominant narrative of a functional division of labor between Russia and China in Central Asia, seeJeanne L. Wilson, “Russia and China in Central Asia: Deepening Tensions in the Relationship,” Acta Via Serica 6, no. 1(June 2021): 55-90.
35
China-Britain Business Council, “One Belt One Road: A Role for UK Companies in Developing China’s New Initiative,”
China
Go
Abroad,September
15,2015,
http://files.chinagoabroad.com/Public/uploads/v2/uploaded/attachments/1509/OBOR-1-New-Opportunities-in-Chinaand-Beyond.pdf.
36
Eurasian Economic Commission, “Pairing of the EAEU and SREB Acquires Real Outlines: The List of Infrastructure
Projects
Has
Been
Agreed,”Eurasian
Economic
Commission,
March
1,
2017,
http://www.eurasiancommission.org/en/nae/news/Pages/2-03-2017-1.aspx.
37
Shantao Shi, “Xin Shidai Zhonge Quanmian Zhanlue Xiezuo Huoban Guanxide Xin Mubiao yu Xin Zuowei,” Dangdai
Shijie, no. 10 (2019): 53-54.
38
Ricardo Barrios and Andrew Bowen, “China-Russia Relations,” Congressional Research Service, May 2, 2022,
https://crsreports.congress.gov/product/pdf/IF/IF12100.
39
Zhonghua Renmin Gongheguo Waijiaobu, “Zhonge Qianshu Guoji Xinxi Anquan Hezuo Xieding,” Zhongguo Zhengfu
May
12,
2015,
Wang,
https://www.fmprc.gov.cn/web/wjb_673085/zzjg_673183/jks_674633/jksxwlb_674635/201505/t20150512_7666762.sht
ml.
40
For a detailed analysis, see Nikola Pijovic, “The Cyberspace ‘Great Game’: The Five Eyes, the Sino-Russian Bloc and
the Growing Competition to shape Global Cyberspace Norms,” in 13th International Conference on Cyber Conflict: Going
Viral,
ed.
T.
Jancarkova(Tallin:
NATO
CCDCOE
Publications,2021),
https://ccdcoe.org/uploads/2021/05/CyCon_2021_Pijovic.pdf.
41
Zhonghua Renmin Gongheguo Zhongyang Renmin Zhengfu, “Shanghe Zuzhi Shouci Wangluo Fankong Yanxi zai
Xiamen Chenggong Juxing,” Zhongguo Zhengfu Wang, October 14, 2015, http://www.gov.cn/xinwen/201510/14/content_2946854.htm.
42Dimitri Simes, “China and Russia Show Unity as Taliban Bang on Central Asia’s Door,” Nikkei Asia, August 12, 2021,
https://asia.nikkei.com/Politics/International-relations/China-and-Russia-show-unity-as-Taliban-bang-on-Central-Asia-sdoor.
43
Radio Free Europe, “Russia Wraps up Drills with Uzbek and Tajik Troops Near Afghan Border.” Radio Free Europe,
August 11, 2021, https://www.rferl.org/a/russia-tajikistan-uzbekistan-military-drills-afghanistan-/31403841.html.
44
Kabar, “Rubezh-2021 Exercise Completed in Kyrgyzstan,” Kabar, September 9, 2021, http://en.kabar.kg/news/rubezh2021-exercise-completed-in-kyrgyzstan/.
45
Gaye Christoffersen, “Russian Thinking about CSTO Peacekeeping: Central Asia, China, and the Ukraine War,” The
Asan Forum, May 11, 2022, https://theasanforum.org/russian-thinking-about-csto-peacekeeping-central-asia-china-andthe-ukraine-war/.
46
Radio Free Europe, “With All Eyes on Ukraine, Toqaev Navigates New Fault Lines between Russia and Kazakhstan,”
Radio Free Europe, June 21, 2022, https://www.rferl.org/a/ukraine-war-kazakhstan-russia-toqaev/31908810.html; andRadio Free Europe, “In Break with Moscow, Uzbeks won’t Recognize Separatist ‘Republics’ in Ukraine,” Radio Free
Europe, March 17, 2022, https://www.rferl.org/a/uzbekistan-ukraine-separatists-not-recognized/31757881.html.
47
It is no secret that the ISI has backed the Taliban since the group’s origin in the mid-1990s, offering them safe haven in
the borderlands, providing training, arms and advisers for their military, and fundraising. For a detailed analysis, see, Chris
Alexander, “Ending Pakistan’s Proxy War in Afghanistan, ” Macdonald-Laurier Institute, March 3, 2021,

1737

https://macdonaldlaurier.ca/ending-pakistans-proxy-war-afghanistan-new-paper-chris-alexander/.
48
The term “republican governments” refers to the Karzai (2001-2014) and Ghani (2014-2021) administrations.
49
A. Z. Hilali, “China’s Response to the Soviet Invasion of Afghanistan,” Central Asian Survey 20, no. 3 (2001): 335.
50
Zaid Haider, “Sino-Pakistan Relations and Xinjiang’s Uyghur: Politics, Trade, and Islam along the Karakoram Highway,”
Asian Survey 45, no. 4 (2005): 529-530.
51
For a detailed analysis, see Michael Dillon, Xinjiang: China’s Muslim Far Northwest (London: Routledge, 2004),
Chapter 6.
52
Todd J. Reed and Diana Raschke, The ETIM: China’s Islamic Militants and the Global Terrorist Threat (Santa Barbara(CA): Praeger, 2010), 76-77.
53
Andrew Small, “Why is China Talking to the Taliban?” Foreign Policy, June 21, 2013,https://foreignpolicy.com/2013/06/21/why-is-china-talking-to-the-taliban/.
54
Ghulam Ali, “China-Pakistan Cooperation on Afghanistan: Assessing Key Interests and Implementing Strategies,” The
Pacific Review 35, no. 3 (2022): 510.
55
An Zhang, “Zhonga Guanxi 70 Nian: Licheng yu Jingyan,” Bianjie yu Haiyang Yanjiu 5, no. 2 (2020): 83.
56
Embassy of Islamic Republic of Pakistan in Washington D.C., “Joint Press Statement First Meeting of the Quadrilateral
Coordination Group on Afghan Peace and Reconciliation Process,” Embassy of Pakistan USA, January 11, 2016,
https://embassyofpakistanusa.org/press-releases-01-11-2016/.

18
38

The Great Unraveling? Geopolitics, Emerging Technologies,
and the Future of International Civil Aviation
Christopher K. Lamont, PhD1
Associate Professor of International Relations, Tokyo International University
Visiting Researcher, ROLES, University of Tokyo
Abstract
The 1944 Chicago Convention established an international civil aviation regime that propelled thegrowth of air travel during the latter half of the 20th century and early 21st century. Functioning as amodel international regime providing a public good of efficient and safe civil air travel, theInternational Civil Aviation Organization (ICAO) has, until the last decade, rarely relied on its disputesettlement mechanism to uphold compliance with the Chicago Convention and its annexes. However,as this article will illustrate, the mid-20th century consensus embodied in the Chicago Convention that
undergirds global civil aviation connectivity and safety is under increasing strain. Developments
including unilateral measures to avoid sanctions, the unlawful disruption of civil aviation on the partof states, increasingly onerous Air Defense Identification Zone (ADIZ) reporting restrictions, and an
urgent need to regulate emerging technologies each highlight how the Chicago Convention consensus
is encountering significant stresses. Indeed, as will be argued here, emerging technologies also offer
an opportunity in the coming years to forge a new international consensus that may serve as afoundation for a more robust international civil aviation regime.
Keywords: Global Governance, International Organizations, Civil Aviation, International Cooperation, Emerging
Technology
1. Introduction
In March 2022, Russia reflagged foreign owned aircraft operated by Russia’s airlines. In an attempt to circumvent
sanctions imposed in response to Moscow’s invasion of Ukraine on February 24, 2022, Moscow’s reflagging of foreign
owned aircraft exposed a growing friction between the International Civil Aviation Organization (ICAO) and states acting
to challenge the liberal consensus that made safe international air travel possible for passengers across the world over the
past decades.2 To be sure, the impact of sanctions on Russia’s aviation sector has been debilitating.3 Russian aircraft werebanned from entering airspace and landing at airports in the European Union, the United Kingdom, the United States, andCanada, among others. The provision of insurance or maintenance of aircraft and aviation technologies for Russian
operated aircraft was also prohibited across many jurisdictions. Indeed, sanctions imposed by the EU, UK, US, and Canada
139alone impacted 75 percent of Russia’s civil aviation fleet, which was largely comprised of Airbus, Boeing, and otherwestern manufactured aircraft. The immediate effect of these sanctions was that most commercial aircraft operating in
Russia were left cut off from parts, equipment, maintenance, or technical inspections.4
Almost a year prior to Russia’s invasion of Ukraine, an alleged act of state sponsored air piracy further illustrated theunraveling of an international consensus that sustained the remarkable growth in civil aviation after the adoption of the
Chicago Convention in 1944.5 In May 2021, Belarus’ Department of Aviation notified Ryanair Flight 4978, a regularlyscheduled commercial flight from Athens, Greece to Vilnius, Lithuania, of an explosive device on the aircraft and diverted
the flight to Minsk. On board Flight 4978 was Roman Protasevich, a Belarusian opposition activist. Upon landing in Minsk,
Protasevich was detained by Belarusian authorities. Despite an ICAO fact finding mission that determined the Belarusianclaims of a bomb on board the aircraft were false, the ICAO report stopped short of accusing Belarus of an unlawful act,
testing the limits of the ICAO’s longstanding practice of not explicitly holding a state to be in non-compliance with Chicago
Convention obligations. Notwithstanding the failure to sanction Belarus on the part of the ICAO when it was clear that
Flight 4978 was targeted by Belarusian authorities due to Protasevich’s presence on board, the presence of US citizens on
Flight 4978 allowed the US to charge four Belarusian officials with aircraft piracy.6
For seven decades, international civil aviation has functioned as a model international regime, a system of internationalrules maintained by member states to provide a common good.7 This regime necessitated compliance among participatingstates to ensure the high level of safety in civil aviation that is taken for granted by the traveling public. As a regulatory
regime that makes seamless international civil aviation possible, the Chicago Convention and the ICAO carry out anessential regulatory and oversight function. However, as the two incidents described above illustrate, civil aviation isentering a period of increasing turbulence. This article will highlight how the state consensus that undergirded the Chicago
Convention has come under increasing stress in recent years.
The ‘rules of the air’ established by the Chicago Convention are faced with a growing fragmentation of civil aviation
actors. For example, new actors, principally China, have emerged with preferences that challenge liberal principles
embedded in the existing regime.8 Moreover, not only do Russia and Belarus highlight how state non-compliance raises
troubling questions for the future of international civil aviation, but also the 2017 Qatar air blockade and more expansive
reporting obligations imposed by Air Defense Identification Zones (ADIZs) highlight the extent to which a once global
civil aviation regime is confronted with the prospect of deepening fragmentation.
In order to explore these challenges, this article will first introduce the international civil aviation regime and its
limitations. Next, this article will turn to an analysis of how the once taken-for-granted consensus of liberalizing
international civil aviation has been increasingly challenged by member states acting to undermine some of the Chicago
Convention’s core tenets. These divisions also come at a time of rapid technological innovation in civil aviation. As oneof the principal functions of the ICAO has been to provide a set of common standards and safety procedures, the article
will then turn to the challenge of governing emerging technologies such as artificial intelligence (AI) and machine learning(ML) tools. In conclusion, it will be argued that for the ICAO to continue to carry out its mission, to facilitate safe andefficient international civil aviation, member states must explore strengthening mechanisms to counter deepening divisions
among member states and a fragmentation of civil aviation that would make international air travel less safe and less240

predictable.

2. International Civil Aviation - A Model Regime
Unlike rules governing maritime transport, the international regime governing aviation is relatively young given the20th century origins of civil aviation.9 To be sure, when the Chicago Convention was adopted, the Convention reflecteda strong consensus among signatory states to open the skies for civil aviation. Because the ICAO was initially limited inmembership to states that had aligned with the United States in the context of an emerging Cold War, the organizationreflected Washington’s preferences for a global interconnected civil aviation market and aligned with technical standards
largely endorsed by the US. Eventually, the Soviet Union and other communist bloc states would join the ICAO; however,this did not serve to challenge the overall liberal character or the organization.10
The core principles for international civil aviation set out in the Chicago Convention included a recognition of statesovereignty in airspace over a state’s territorial landmass and territorial waters.11 However, rather than having the effectof fragmenting international civil aviation along territorial borders, this recognition was complemented by a commitment
to non-discrimination among contracting states and by a system of rules and procedures that created a legal basis forinternational air transit.12 Indeed, ever since 1944, the Convention has undergirded the liberalization of civil aviation
through the provision of air service agreements (ASAs) between states and through a consistent air safety regime underthe ICAO, both of which made possible the dramatic growth in international air travel during the second half of the 20th
century. However, it has also been noted that 21st challenges require a substantial updating of the Convention, or perhaps,a new regime altogether.13
The Convention also established a specialized international organization tasked with facilitating international civil
aviation, the ICAO. One of the Chicago Convention’s principal features is that it has provided a longstanding public good
through regulatory and technical oversight mechanisms that have helped civil aviation become both widely accessible andone of the safest modes of public transport. However, the effectiveness of the Chicago Convention in maintaining aseamless governance and regulatory regime for international civil aviation was largely maintained because major disputes
among member states within the ICAO were rare. The dispute settlement provisions of the Chicago Convention left any
dispute related to the Convention and its annexes, which could not be settled among the relevant parties to the Convention,
to a decision of the ICAO Council, a non-judicial body.14 Since 1947, there have been only five disputes addressed to the
ICAO Council.15

341

Table 1. The ICAOThe ICAO’s Main Bodies

Description

The ICAO Council

Functions

Comprised of 36 member stateselected by ICAO AssemblyElected on basis of importanceto air transport, contribution offacilities for international civil
air navigation, and geographic
representation










The ICAO AssemblyThe ICAO SecretariatComprised of all 193 ICAO
member states
Meets once every three years
Can convene extraordinary
sessions at the request of the
ICAO Council, or a majorityof member states in the
Assembly
Led by ICAO SecretaryGeneral
Head Office in Montreal,
CanadaMaintains seven regional
offices in Bangkok, Cairo,
Dakar, Lima, Mexico City,
Nairobi, and Paris, plus one
subregional office in Beijing








Provides regular direction to
the work of the ICAO
Settles disputes among
member states
Sanctions non-compliance onbehalf of states or airlines
Adopts Standards andRecommended Practices(SARPs)Submits annual reports to the
ICAO Assembly
Administers finances
Appoints and defines duties ofcommittees
Appoints Secretary-General
Elects members of the ICAO
Council
Reviews and takes actions
recommended by the ICAO
CouncilApproves ICAO budget
Can amend the Convention,subject to ratification ofamendments by member states
Carries out day-to-day
operations of the ICAOWhen it comes to imposing punishments for non-compliance, the ICAO Council can take measures against both airlines
and states. In relation to airlines, ICAO member states are expected to ban airlines that have been found to be in noncompliance with ICAO obligations within their airspace. In relation to states, a member state can have its voting power in
the ICAO Assembly suspended by the ICAO Council for non-compliance. However, the ICAO Council has never imposed
sanctions on any member state. Furthermore, as a non-judicial body the ICAO Council is reluctant to decide state noncompliance with Chicago Convention obligations, even in cases where violations appear to be flagrant, and has instead
opted for more conciliatory declarations.16

If such a judgment were to be made, it would likely be perceived as more ofa political rather than a judicial finding.

4423. An Unraveling Consensus - Chicago and the Specter of a Weakening Regime
To illustrate the limitations of the international civil aviation regime’s existing institutional design, this section will now
turn to three examples of recent disputes where the ICAO has proven unable to address substantial disputes among member
states, leading to either disruptions in civil aviation or resulting in growing risks to civil aviation safety. The first is the
dispute between Qatar and Arab Gulf states that resulted in a land and air blockade of Qatar that began in 2017. The second
relates to Russia’s response to sanctions following Moscow’s 2022 invasion of Ukraine. The third relates to the intrusionof security practices into air space governance in the form of hardening Air Defense Identification Zones (ADIZs).

Qatari Blockade and ICAO Dispute Settlement Mechanis
The 2017 dispute between Qatar and neighboring Arab Gulf states over denying Qatari flights access to airspace
illustrates weaknesses in the ICAO’s dispute settlement mechanism. On June 5, 2017, Bahrain, Egypt, Saudi Arabia, andthe United Arab Emirates severed diplomatic relations with Qatar and subsequently closed their airspace to Qatariregistered civil aircraft. As a result of this air blockade imposed on Qatar, Qatari flights to destinations beyond the Gulf
had to be rerouted through Iranian airspace.17 This dispute was significant because the closure of airspace to Qatari aircraft
included airspace above international waters, violating the principle of freedom of navigation in the skies above
international waters, and subsequently violating the principle of non-discrimination of civil aircraft as only Qatari aircraft
were subjected to this ban.
The 2017 closure of airspace on the part of Bahrain, Egypt, Saudi Arabia, and the United Arab Emirates resulted in
Qatar filing two complaints before the ICAO Council. However, because Bahrain, Egypt, Saudi Arabia, and the United
Arab Emirates objected to the ICAO Council consenting to hear Qatar’s complaints, these states appealed to theInternational Court of Justice (ICJ) to contest the legality of the ICAO Council’s decision to accept Qatar’s complaints
before the body. By filing a case before the ICJ, Bahrain, Egypt, Saudi Arabia and the United Arab Emirates sought tocontest the ICAO Council’s jurisdiction over this dispute. However, in July 2020 ICJ rejected their appeal to the Court by
concluding the ICAO Council did indeed enjoy jurisdiction over this matter. 18 However, the January 2021 Al-Ula
declaration, agreed between Qatar and the Gulf Cooperation Council (GCC) countries and Egypt, brought an end to theblockade, and Qatar’s complaint was withdrawn before the ICAO Council leaving the matter unadjudicated.19
Despite the immediate end to the dispute, the ICAO’s inability to deal swiftly with one of the most significant civil
aviation disputes to erupt in the 21st century—critically disrupting a member state’s civil aviation—highlighted the extent
to which states could push the boundaries of the Chicago consensus without suffering repercussions within the ICAO.

Russia-Ukraine and Civil Aviation GovernanceWith a weak dispute settlement mechanism and untested sanctions measures, the ICAO is ill-suited to navigate tensions
in civil aviation governance among member states. While the ICAO Council avoided having to adjudicate the Qatar air

543blockade complaint, growing tensions between the founding members of the ICAO, largely in the West, and Russia andChina mark a second focal point of stress that will test the ICAO’s ability to maintain a global civil aviation regulatory
regime in the coming years. Indeed, tensions in civil aviation have already intensified in the aftermath of Russia’s invasionof Ukraine in 2022. At the same time, as a specialized agency of the United Nations, the ICAO enjoys a powerful mandate
to promote international civil aviation safety and connectivity.
Russia’s invasion of Ukraine on February 24, 2022 signaled the opening of a new era of risk for civil aviation. As aresult of a tightening sanctions targeting Russia and Belarus, Russia’s civil aviation authorities announced the unilateralreflagging of foreign leased aircraft operated by Russian airlines to the Russian Federation. While this had the effect ofseizing foreign owned aircraft, the inability to import component aircraft parts has resulted in Russian operated Airbus or
Boeing aircraft being barred from entering the airspace of a growing number of countries.
After March 10th, Russian airlines also stopped making payments to leasing companies for leased aircraft. Article 18 of
the Chicago Convention prohibits the registration of aircraft in more than one country because it creates uncertainty as tothe aircraft’s safety and airworthiness. Despite the ICAO warning Russia of its violation of its Chicago Convention
obligations, Moscow has sought to unilaterally revoke the foreign registration of leased aircraft in the possession of Russian
airlines.
While the ICAO was confronted with a challenge to the Chicago Convention’s core aviation safety obligations, theInternational Air Transport Association (IATA), a trade association of airlines, voiced opposition to sanctions imposed on
Russian civil aviation. The IATA noted:
IATA has a long-standing policy of opposing sanctions that could see a degradation of aviation
safety, such as bans on the export of spare parts for aircraft. Banning the export of these items
could impact aviation safety for all aircraft operating into or transiting over or near Russian
airspace. This includes, for example, aircraft that may need to divert to Russian airports in an
emergency.20
To be sure, while services and technology for civil aviation safety were granted an exemption in relation to Russianmade civil aircraft operating outside Russia,21 in the context of this limited exception the impact of sanctions on civil
aviation within Russia remained severe.22 Moreover, the closure of Russian airspace to European and some East Asian
airlines had the short-term effect of causing significant disruption to East Asian-European air connectivity, and resulted inairlines adapting to new routes that will increase both travel times and demands for fuel efficiency.23 Related to the closureof airspace is the increasing encroachment of the state practice of Air Defense Identification Zones (ADIZs) on the ICAO’s
Flight Information Regions (FIRs), which will be discussed below.

Air Defense Identification Zones and Sovereignty in the Skies
China’s declaration of its East China Sea ADIZ in November 2013, brought into focus a security practice which had
previously been considered benign in terms of its impact on international civil aviation.24 ADIZs are defined as “special
designated airspace of defined dimensions within which aircraft are required to comply with special identification and/or

644

reporting procedures additional to those related to the provision of air traffic services.” Annexes 4 and 15 to the Chicago
Convention set out standards for the publication of information on an ADIZ on the part of states, the Aeronautical
Information Publication (AIP), and in charts. However, although the term ADIZ is listed and defined in ICAO
documentation, there are no Standards and Recommended Practices (SARPS) or procedures written for the establishment
and operation of an ADIZ. In 1950 the United States declared the world’s first ADIZ; it did not impose reporting obligations
on aircraft not intending to enter US territorial airspace, and also did not recognize the right of coastal states to impose
reporting restrictions on aircraft not intending to enter territorial airspace.25
As a result, by the 2020s ADIZ reporting obligations can be seen as increasingly interfering with civil aviation, creatinga gap in the international regulatory framework. 26 This gap could serve as a basis for imposing otherwise illegal
restrictions on international civil aviation. Indeed, as ADIZs often extend far beyond a country’s territorial airspace, there
is no legal basis for establishing reporting regimes for civil aircraft transiting international airspace. However, the ICAO
has been hesitant to involve itself in clarifying the extent to which states can impose restrictions on non-territorial
airspace.27
One salient characteristic of the Qatar air blockade, Russia’s response to sanctions, and ADIZs is the reluctance of the
ICAO Council to address major disputes among member states. While this is in large part due to institutional design—the
ICAO has no compulsory adjudication process through which disputes can be settled by a judicial body—this also reflects
a lack of consensus among member states regarding what have hitherto been regarded as core principles of international
air law. Next, this article will turn to the question of emerging technologies. This is because rapid technological innovationis creating risks that necessitate regulation, and consensus building among ICAO member states.

4. Regulating Emerging Technologies: Risks and Opportunities
Disruptive emerging technologies have the potential to radically transform civil aviation in the next decade. While muchattention has been paid to debates concerning emerging technologies in the context of armed conflict,28 there has been
comparatively little interest paid to the impact of emerging technologies on non-military civil aviation. Many of thedivisions that have plagued efforts to find an international consensus on AI and ML uses for military purposes will likely
manifest themselves in the context of a rapid move towards increased automation of civil aviation.29 Moreover, significant
differences among ICAO states regarding questions of data privacy will result in notable variations in the kinds oftechnologies deployed in different jurisdictions.

Emerging Technologies
During the ICAO Assembly’s 40th session, held in 2019, Resolution A40-27 on Innovation in Aviation was adopted bymember states. This resolution recognized emerging technologies had the potential to improve aviation safety, efficiency,
security, operations, sustainability, and economic development. Innovations can also lead to more efficient and streamlined
aviation regulatory processes.
The principal challenges posed by emerging technologies for international civil aviation are:1.

Regulatory consistency across member state jurisdictions.

7
45

2.

Proliferation of private Unmanned Aircraft Systems (UAS) for domestic and international
travel.

3.

Dependence on AI and ML systems, or automation, for almost every aspect of ground andflight operations.

To tackle these challenges new regulatory frameworks and practices will be necessary. There is however an additional
challenge present within the ICAO today and that is that these new challenges are bringing a much wider range of actors
into the regulatory process than the ICAO has interacted with in the past. When the post-Second World War civil aviationindustry experienced rapid growth due to jet engine technology, the manufacturers of widely used jet aircraft wereconcentrated in Western Europe and North America. On the other hand, aircraft made in the Soviet Union were widelyused in the Soviet bloc. Unlike the tech industry, where innovation is driven by a large number of small startups which are
now providing civil aviation manufacturers with AI and ML systems, the civil aviation industry has traditionally been
dominated by a few large actors who dominated the industry in their respective countries. This created a comparatively
narrow range of industry actors which the ICAO interacted with to establish and maintain safety standards and practices.
As of 2022, there is a broader range of actors in the civil aviation industry, that also includes civil aircraft manufacturers
and tech firms in China and Russia that aim to increase their share of the civil aviation market. As sanctions against Russia
crippled Russia’s civil aviation sector in 2022, both Russia and China will continue to accelerate efforts to establish theirown sanctions-proof civil aviation industries. This can be expected to compound difficulties in establishing uniform safety
standards for emerging technologies as supply chains and state-sponsored producers in non-democratic states seek tosecure a larger share of civil aviation markets.
Thus, while technological innovation is improving the performance of civil aircraft, the fissures brought about by
Russia’s invasion of Ukraine may see a long-term diversification of civil aircraft manufacturers as some states seek toreduce their domestic civil aviation industry’s vulnerability to sanctions. Russia’s United Aircraft Corporation (UAC),
established in 2006, brought together Russia’s military and civil aircraft manufacturers into a single entity.30 Following
Sukhoi’s merger with UAC in 2022, UAC continues to expand its civil and military operations.31
In the 2020s, China also aspires to assume a growing stake in global civil aviation markets. The Commercial Aircraft
Corporation of China, Ltd. (COMAC) is a Chinese state-owned aerospace manufacturer established in 2008. Already
COMAC is seeing commercial success after its ARJ21 entered service with Chengdu Airlines in 2016. The larger C919
now has about 1,000 orders.32 There is also a Sino-Russian joint venture (CRAIC),33 however, the long-term viability ofthis venture in the face of sanctions arrayed against Russia in 2022 remains in question.
Yet, while the diversity of actors and geopolitical tensions will make building a consensus on emerging technologies incivil aviation challenging, such as technological standards for governing AI and ML in flight and ground operations, thesestandards remain technical and focused on providing the international public good of safe civil aviation. This opens a
prospect for technical standards focused processes that could skirt some of the more intractable divisions that have been
noted earlier.

846

5. Conclusion
In 2022, civil aviation was confronted with multiple geopolitical sources of stress that threaten to unravel the complex
regime governing civil aviation, potentially introducing new risks for civil aviation in the future. Absent strong disputesettlement mechanisms, states may continue to pursue unilateral measures that undermine international civil aviation safety.
At the same time, it must be acknowledged that there is little prospect for major amendments to the Chicago Convention,or even a new convention, that would contain stronger dispute settlement and compliance provisions that would bind states
to principles of freedom of navigation found in the Chicago Convention.
Indeed, geopolitical tensions fueled by Russia’s invasion of Ukraine have brought about a new set of challenges,
including the closure of territorial airspace over the Russian Federation to air carriers from a large number of countries
and the disruption of air connectivity between East Asia and Europe. Yet, while airlines can adapt to these changes, thelong-term effect of Russia’s reflagging of foreign leased aircraft, and of sanctions, will likely result in an increasing
diversity of civil aviation manufactures and emergent regulatory challenges. The extent to which the ICAO will challenge
Moscow’s breach of its Chicago Convention obligations will underline the limitations of the existing civil aviation regime
to deal with states that openly challenge core principles of international air law. To be sure, as we have seen with China’s
East China Sea Air Defense Identification Zone, states have begun to impose unilateral reporting obligations on aircraft
far removed from territorial airspace, and also in airspace already administered through the ICAO’s FIRs. If civil aviation
were to further fracture, the era of global air connectivity that marked the late 20th and early 21st century could come toan end as the cost and risk of civil air travel increase. These risks will only escalate with rapid developments intechnological innovation that are making existing regulatory frameworks obsolete, making the need for consensus within
the ICAO ever greater.
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Arbec, Debra. “Montreal-Based UN Aviation Agency Tried to Cover up 2016 Cyberattack, Documents Show.” CBC News,
February 27, 2019. https://www.cbc.ca/news/canada/montreal/montreal-based-un-aviation-agency-tried-to-cover-up2016-cyberattack-documents-show-1.5033733.
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1, 2011): 188–215.
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Lamont, Christopher K. “Conflict in the Skies: The Law of Air Defence Identification Zones.” Air & Space Law 39, no. 3(June 1, 2014): 187–202.
Lampert, Allison. “U.S. Withholds U.N. Aviation Dues, Calls for Immediate Whistleblower Protections.” Reuters. October
2, 2019. https://www.reuters.com/article/us-un-aviation-us-idUSKBN1WH2C1.
Lee, Jae Woon and Xiongfang Li. “Ongoing Tension in the Air: The Need for ICJ’s Advisory Opinion on Air Defense
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Newcomb, Tim. “As Russia’s Commercial Airplanes Fall Apart, It May Turn to Military Planes for Civilian Transport.”
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Schaefer, Brett and Dan Pletka. “International Civil Aviation Organization: United States Should Repair Chinese Damage
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For Diverting Ryanair Flight 4978 To Arrest Dissident Journalist In May 2021.” United States Department of Justice,
January 20, 2022. https://www.justice.gov/usao-sdny/pr/belarusian-government-officials-charged-aircraft-piracydiverting-ryanair-flight-4978.
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Fight.” The Washington Post. July 12, 2022. https://www.washingtonpost.com/business/2022/07/12/russia-aircraftseizure-sri-lanka/.
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1This work was supported by JSPS KAKENHI Grant Number 22H00814.
For more on the tension between state sovereignty and civil aviation see Dobson, A History of International Civil
Aviation: From Its Origins through Transformative Evolution.
3
Newcomb, “As Russia’s Commercial Airplanes Fall Apart, It May Turn to Military Planes for Civilian Transport.”
4“EU Sanctions against Russia Explained.”5
Abeyratne, “Legalities Concerning the Belarus Affair and Interference with Civil Aviation”; Hinder and Pooja,“Threatening Aviation Safety: Case of Study from the Ryanair Flight 4978 Incident.”
6
U.S. Attorney’s Office, Southern District of New York, “Belarusian Government Officials Charged With Aircraft Piracy
For Diverting Ryanair Flight 4978 To Arrest Dissident Journalist In May 2021.”
7
MacKenzie, ICAO: A History of the International Civil Aviation Organization; Nayar, “Regimes, Power, andInternational Aviation.”
2

11
49

8

Schaefer and Pletka, “International Civil Aviation Organization: United States Should Repair Chinese Damage andFocus the Organization on Its Core Mission.”
9
Nayar, “Regimes, Power, and International Aviation.”
10
The USSR joined the ICAO in 1970. MacKenzie, ICAO: A History of the International Civil Aviation Organization.
11
Milde, International Air Law and ICAO.
12
Lykotrafiti, “Liberalisation of International Civil Aviation: Charting the Legal Flightpath.”
13
Havel and Sanchez, “Do We Need a New Chicago Convention”; Guillaume, “ICAO at the Beginning of the 21stCentury.”
14
Havel and Sanchez, “Do We Need a New Chicago Convention”; Sanchez, “The Impotence of the Chicago Convention’s
Dispute Settlement Provisions.”
15
Bartsch, “Does the UN Aviation Body Have the Power to Punish Russia for the MH17 Downing? An Aviation Law
Expert Explains.”
16
Bae, “Review of the Dispute Settlement Mechanism Under the International Civil Aviation Organization: Contradictionof Political Body Adjudication.”
17
Al Jazeera, “Gulf Blockade Disrupts Qatar Airways Flights.”
18“Appeal Relating to the Jurisdiction of the ICAO Council under Article 84 of the Convention on International Civil
Aviation (Bahrain, Egypt, Saudi Arabia and United Arab Emirates v. Qatar).”19“ICAO Council Concludes 222nd Session with Important New Progress for International Aviation.”
20“War in Ukraine and Air Transport.”
21
Kaminski-Morrow, “US Treasury Exempts Civil Aviation Safety Measures from United Aircraft Sanctions.”
22
Whalen, Nakashima, and Farisz, “Russia Holding 400 Passenger Jets Hostage in Global Sanctions Fight.”
23
Ganesh, “Interview: How Finnair Circumvents Russia’s Airspace Closure.”24
Lamont, “Conflict in the Skies: The Law of Air Defence Identification Zones.”25
Lamont.
26
Lee and Li, “Ongoing Tension in the Air: The Need for ICJ’s Advisory Opinion on Air Defense Identification Zone
(ADIZ).”
27
Papp, “Air Defense Identification Zone (ADIZ) in the Light of Public International Law.”
28
Gregory, “From a View to a Kill: Drones and Late Modern War”; Jenks, “Law from above: Unmanned Aerial Systems,
Use of Force, and the Law of Armed Conflict.”29
Horowitz, “When Speed Kills: Lethal Autonomous Weapon Systems, Deterrence and Stability.”
30
Matthews and Lozano, “The Mercurial Development of Russia’s United Aircraft Corporation.”
31
TASS, “Sukhoi, MiG Merged with United Aircraft Corporation — Press Service.”
32
Zhang, “C919 Raises Hopes for Domestic Airlines.”
33
CRAIC is a joint venture between China’s COMAC and Russia’s United Aircraft Corporation (UAC).

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Civil Aviation Governance in North Korea
Ryo Hinata-Yamaguchi1
Project Assistant Professor, Research Center for Advanced Science and Technology,
University of Tokyo
Adjunct Fellow, Pacific Forum
Abstract
Civil aviation plays a vital role for many states as the most expeditious means of both passenger andfreight transportation. However, the nature of the civil aviation sector, its operations and governance,
and its overall impact, varies according to a state’s political, economic, societal, environmental, andsecurity structures, processes, and circumstances. Moreover, it is critical to look at how governance ofthe state and civil aviation, as well as security policies and strategies, impact safety and security. This
paper examines the developments in, and nature of civil aviation governance in North Korea tounderstand how the airline sector is governed, its significance to the state, and implications on safety
and security.
Keywords: Civil Aviation, North Korea, Transport Security, International Security
1. Introduction
Despite being the youngest form of transportation, civil aviation plays a vital role in today’s world. Although it has
limited mass capacity, civil aviation has been the answer to demands for faster means of transportation and logistics.
However, the sector’s nature, operations and governance varies according to a state’s political, economic, societal,
environmental, and security structures, processes, and circumstances. The Democratic People’s Republic of Korea (DPRK,North Korea) presents an interesting case, where like the state itself, the regime maintains an extremely centralized andpoliticized form of governance over the civil aviation sector that has led to various direct and indirect effects on airline
management and operations, but also state affairs, safety and security broadly.
This study purports to provide an overview of North Korea’s civil aviation sector governance and its implications on
security. The paper begins with a brief overview of the literature on North Korea’s civil aviation. The second section will
provide an overview of the developments in the North Korean civil aviation sector. In the third section, the paper will
discuss the role and significance of civil aviation in North Korea’s development. The fourth section will then look at the
implications that North Korea’s civil aviation sector has on both transport and regional security. The paper concludes that
despite its potential, civil aviation is limited in North Korea given the regime’s totalitarian governance. More importantly,
these limitations have created serious issues in safety and security due to the state of fleets and infrastructure, militarizationof airspace, weapons tests, and utilization for the armed forces.

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2. Studies on North Korea’s Civil Aviation
Various scholars have looked at the topic of transport governance from a variety of viewpoints ranging from political
economy to socio-economic approaches. When it comes to policy, Berg, Deichmann, Liu, and Selod argue that broadly
there are three types of policies: direct transport infrastructure investments, price instruments, and regulations in thetransport sector.2 The multifaceted aspect of transport policy opens many opportunities to study this topic on a case-bycase basis. Just like how each government pursues its own ways of developing its state, the same applies to the transport
sector. Therefore, it is critical to understand the state-specific processes and output in developing the transport sector, as
well as the positive and negative dynamics.
Numerous studies have sought to examine the circumstances and prospects in North Korea’s transport sector.3 Ahn
provides a comprehensive synopsis of the transport sector in North Korea, as well as its international and inter-Koreanconnections. 4 Using personal observations and interviews, Lankov provides an “on-the-ground” overview of thetransportation systems in North Korea. 5 While general, such studies offer starting points to grasp the sector’s broaddevelopments and condition, and are valuable given the little information available about North Korea.
More detailed descriptive and prescriptive studies—particularly in South Korea—have looked at economic, industrial,
spatial, and sector-specific technical issues relating to the transport sector in North Korea. A number of scholars have also
argued for the importance of the transport infrastructure in North Korea to reconnect the missing link in regional
integration.6 Scholars have also recognized the significance of the transportation sector when examining the political
economic, or socio-economic developments in North Korea. Assessing the socio-economic underpinnings of urban
development in Pyongyang, Jeong, Lee, and Ban claimed the pivotal roles of the roadways and railroads in access andindustrial growth.7 Furthermore, many of the studies are conducted in the context of inter-Korean relations and unification,
including the trans-Korean and trans-Eurasian links. For instance, Yoo and Kim evaluated the prospects of regular air
services between Seoul and Pyongyang.8
Still, scholarship on the transportation sector in North Korea remains extremely limited in its scope, and numerous
challenges exist in conceptualizing the impact of the developments in the transport sector and state development. The
development of civil aviation networks is often viewed as an indicator of development, as demonstrated by the significant
strides in East Asia’s aviation industry.9 Despite the trends in the region, North Korea’s civil aviation industry remains
unchanged.

3. Overview of North Korea’s Civil Aviation Sector
Since its formative years, North Korea has stressed the significance of the transport sector in its economic development.
Establishment of the Sinuiju Air Unit (SAU) in October 1945 served as the ancestral apparatus of the Korean People’s
Army (KPA) Air Force. Originally established as a training organization, the SAU later developed into the Air Squadronof the Security Officer Training Command, which was then integrated into the armed forces in February 1948.10 The
USSR and North Korea then set up a joint civilian aviation body known as the Soviet-Korean Aviation Organization(SOKAO) in 1950 to operate flights between Pyongyang and Moscow.

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After a period of hiatus due to the Korean War, SOKAO was later reestablished on September 21, 1955 as North Korea’s
national organization known as the Civil Aviation Administration of Korea (CAAK). The CAAK mirrored thedevelopments in other socialist states such as the Civil Aviation Administration of China (CAAC), whereby the government
directly governs civil aviation administration and infrastructure, as well as airline operations. For the first couple of decades,
CAAK flew turboprop aircraft including the Antonov An-2, Antonov An-24, Ilyushin Il-12, Ilyushin Il-14, Ilyushin Il-18s,
and Lisunov Li-2. In the late 1970s, the CAAK acquired jet aircraft including the Tupolev Tu-134, Tupolev Tu-154, andIlyushin Il-62. Moreover, CAAK also joined the International Air Transport Association (IATA) and International Civil
Aviation Organization (ICAO) in 1977.
In 1992, the CAAK was divided into two divisions: one for the administration of civil aviation11 and the other forcommercial airline operations, the latter being renamed Air Koryo. Due to the collapse of the Soviet bloc and North Korea’s
increasingly isolationist policies, the number of scheduled flights significantly decreased and became limited to those to
and from China and Russia, as well as some irregular charted flights. Air Koryo also modernized its fleet by acquiring the
Ilyushin Il-76 and Tupolev Tu-204. While the scheduled services remained essentially limited to only a handful of routes
to China and Russia, Air Koryo continued to serve as the essential means of fast access to North Korea.
Despite some developments, the civil aviation sector in North Korea remains small. Even in the pre-COVID 19 days,
international flights were limited to those to and from Beijing, Shenyang, Vladivostok, and Macau, and with the exceptionof occasional charter services, Air China has virtually been the only foreign airline that operated scheduled flights to North
Korea. Domestic flights were limited to on-demand charter services, although Air Koryo began weekly scheduled services
between Pyongyang and Samjiyon, Orang, Hamhung, and Wonsan.12 Regarding infrastructure, while North Korea hasover 40 airports and airfields, most of them are exclusively for military use and only a handful are registered with IATA
and ICAO. Sunan International Airport near the capital city Pyongyang is by far the largest and essentially the only airport
for international flights. Although the terminal at Sunan International Airport underwent major renovations in the mid2010s, both the domestic and international terminals have the capacity for less than ten aircraft. Kalma International Airport
in Wonsan has also been renovated and is arguably the second largest airport in the country, but its capacity is roughly halfof Sunan International Airport.

4. Characteristics of North Korea’s Civil Aviation GovernanceNorth Korea has taken an extremely centralized and politicized approach to transport sector management. The entire
transportation sector is exclusively affiliated to a ministry or the military, all platforms and infrastructure are government
property, and the personnel are state employees. Of course, such features are not uncommon. In the past, many airlines
even in well-developed democratic states were either originally state-owned but later privatized or restructured as public
corporations, and there are still numerous states with government-owned airlines. Yet North Korea's case is unique in theextent of the government’s control, and the tailoring of the transport infrastructure to the government’s needs, not the needsof society.
To a great extent, keeping Air Koryo as a total state-owned enterprise reflects the dictatorial nature of the North Korean
regime itself. At the same time, North Korea’s centralized governance over the airline sector has also been a way to avert

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the troubles and risks that come with decentralization and corporatization. North Korea witnessed the crisis faced by
Aeroflot after the collapse of the USSR, as well as China’s challenges in decentralizing and corporatizing CAAC. 13
However, the bigger point is that North Korea simply did not need to undergo such procedures. Above all, the size of North
Korea’s civil aviation sector and its operation pale in comparison to those of China and Russia. Moreover, North Korea
has never undertaken full reform—at least akin to the reform in other socialist states—making corporatization impossible
for the government.
For Pyongyang, the incentives for decentralization and corporatization and the risks of sustaining a centralized form ofgovernance over the civil aviation sector are minimal. Decentralization of civil aviation was not necessary given the small
nature of the market and its operations, but also unwanted because it would introduce new complexities and potential risks.
One important outcome of centralized command and control over civil aviation is seen in Pyongyang’s strategy to keep
the sector small. Indeed, the North Korean civil aviation sector was small from the outset, but this allowed the government
to exercise centralized command and control without encountering any significant ramifications. Aside from the occasional
propagandistic vaunts, North Korea never seemed to have the ambition to grow Air Koryo into a mega-carrier or establish
a hub airport. Instead, North Korea has opted to manage a civil aviation sector that is too small to fail, thereby saving itfrom overwhelming crisis should it go bankrupt.
Another aspect of North Korea’s civil aviation governance is how it has not been demilitarized. To this day, Air Koryo
continues to be commandeered by the military sector not only because of its importance to the KPA but possibly because
the airline is too weak to stand on its own. The small bureaucratic and political stature of civil aviation is evident in theheavy militarization of North Korea’s airspace both in the forms of aircraft, air defense systems, as well as missile tests.
Moreover, given the small stature of North Korea’s civil aviation market, any conflict of interest or “turf wars” between
the civilian and military sectors is limited.
Indeed, Pyongyang’s strategy of maintaining a hyper-centralized and compact civil aviation sector denies growth
opportunities. That said, the lack of competition allows Air Koryo to monopolize the market. Even though some foreign
carriers such as Aeroflot and CAAC (during the Cold War), Air China, and some other airlines have operated scheduled
flights into North Korea in the past, Air Koryo and its predecessor CAAK have been dominant. Despite the small market
in North Korea and the modest-sized fleet, Air Koryo’s monopolization has allowed it to maximize its profit margin not
only by controlling its fares but also by minimizing its operational costs. Although the minimization of operational costs
is largely due to the state’s economic troubles, Air Koryo’s monopolization has nonetheless cushioned the effects on theairline’s position in its market.
At the same time, North Korea’s civil aviation governance has also been affected by international sanctions placed
against Pyongyang. The prohibition of exporting aviation fuel to North Korea under the current sanctions affects theoperation of Air Koryo flights by forcing the airline to only fuel in airports abroad. Sanctions further constrain fleet
modernization by restricting the sale of aircraft and equipment. Moreover, United Nations Security Council Resolutions
Resolution 2270 has led countries to halt Air Koryo flights altogether, with countries such as Malaysia, Kuwait, Pakistan,
and Thailand no longer allowing Air Koryo flights out of concerns over the proliferation of weapons.

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5. Impact of Civil Aviation Sector on State Development
Given the poor state of the economy, there are questions over whether civil aviation has the potential to bring growth toNorth Korea. While the exact impact differs according to individual countries on a case-by-case basis, civil aviation cantheoretically advance national development by providing the fastest means of international and domestic transportation,
thereby stimulating growth. In the case of North Korea, while rail and road will indeed remain the central modes ofdomestic logistics, the construction and reconstruction of infrastructure will require significant investments of capital andtime. Given the existing aerodromes operating in key North Korean locations, air transport is plausible in the short-term.
Moreover, the significant developments in private markets and the rise of entrepreneurs in recent years suggest that civil
aviation could help expand businesses across the state and bridge communication and knowledge gaps within North Korea.
Still, the most important question is not what needs to be done to upgrade the civil aviation sector to serve such roles, but
about the demands for the sector.
The problem, however, is not the role and impact of North Korea’s civil aviation pivot on the development andgovernance of the sector itself, but national governance. Above all, the benefits of civil aviation would only come tofruition under the right political economic, socio-political, and socio-economic conditions. 14 The North Korean
population’s high level of social exclusion, combined with generally low income and heavy restrictions on movement,
mean that accessibility to the civil aviation sector is low. For North Koreans, civil aviation is accessible to government
officials and those who have gained permission from the government. Travel is restricted for foreign nationals as well;even the occasional charter flight would have little impact on improving socio-economic conditions in the Stalinist state.
Another critical problem in North Korea is the underdeveloped condition of cities and regions outside of Pyongyang.
Compared to Pyongyang, which has a population of over three million, the population of other major cities such as
Hamhung, Nampho, Sunchon, Hungnam, Kaesong, Wonsan, Chongjin, Sariwon, and Sinuiju are between 300 and 560
thousand. Moreover, while the other major cities have their economic and industrial importance, the level of urban
development and socio-economic conditions are significantly lower than the capital city. Unless North Korea embarks on
projects to spearhead or facilitate significant developments in these areas, the demand for domestic travel to and from
Pyongyang will remain limited.
There are also problems in the overall capacity of North Korea’s transport sector. While the most visible constraints may
be the small size and poor state of North Korea’s civil aviation fleet and infrastructure, there are also real problems withthe lack of intermodal systems. Indeed, the key airports in North Korea are within proximity of road and railroad
infrastructures. However, the problem is that many of the land transport infrastructures suffer from serious maintenanceproblems that have undermined smooth passenger and cargo operations.15 Hence even if civil aviation operations are
increased, there would be major bottlenecks in the ground transportation operations to and from flights.
Against this backdrop, as long as the North Korean regime maintains its hyper-centralized control over the state andleaves the myriad transport infrastructure problems unaddressed, developments in and operation of the civil aviation sector
will be limited. The self-inflicted low consumer demand, coupled with unsuitable conditions for civil aviation operations,prevent North Korea from seeing the benefits of developing the civil aviation sector, especially with high operational costs
being exacerbated by the chronic shortage of fuel. North Korea may occasionally boast about its civil aviation sector, but

555

it is unlikely to treat it as a vital player in the state’s economy and logistics for the foreseeable future.

6. Problems in Safety and Security
As signatories, North Korea and Air Koryo are obliged to follow the laws and Standards and Recommended Practices(SARPs) set by the ICAO, which are codified in the state’s Civil Aviation Laws. The problem, however, lies in how thestate’s totalitarian form of governance and limited capacity undermine its ability and will to operate according tointernational regulatory standards and customs. To some extent, the possession and operation of a small fleet and limited
infrastructure, combined with the heavy-handed actions by the government, could make it easier to enforce SARPs.16 Still,
North Korea’s civil aviation practices have been substandard, not because of the regulatory framework per se, but rather
due to implementation, execution, and control.
Over the years, the North Korean civil aviation sector has had its share of problems in safety management, occasionallyleading to catastrophic consequences. In July 1983, a CAAK flight from Pyongyang bound for Conakry crashed in Guinea
killing all 23 crew and passengers on board. Additionally, there are unconfirmed reports of at least three crashes in the
1970s and 1980s.17 While the actual number of accidents may not be high, the percentage of crashes is higher on averagecompared to many other airlines given the significantly fewer services operated by the North Korean flag carrier.
The key problems in North Korea’s civil aviation safety management and substandard airworthiness are two-fold:outdated aircraft and poor safety practices. Such features have consequently affected Air Koryo’s ability to operate outsideof its territory. In 2006, Air Koryo was banned by the European Commission from flying into the European Union’s
airspace after failing to meet ICAO SARPs. The European Commission partially lifted the ban in March 2010, but still
disallows Air Koryo from flying any aircraft older than the Tu-204. Even China—North Korea’s ally—has limited Air
Koryo’s operations in Chinese airspace after one of its flights bound for Beijing made an emergency landing in Shenyang
in July 2016.18
Problems are also seen in how North Korea governs transport safety and security. The central underlying problem is theNorth Korean leadership’s obsession with regime survival, compelling it to focus more on internal security threats against
the regime than public safety. While the above does not mean North Korea cares little about incidents and accidents, itdoes mean that more attention is invested in detecting and preventing threats to the regime or other negative political
implications, consequently leading to the neglect of broader safety and security risks. Examples are seen in the railway
sector where there have been reported cases of overcrowded trains running on unsafe railroads, or cases of assault by
military and law enforcement personnel against civilians.19 Indeed, given the obligations to follow ICAO SARPs andpossible international ramifications, one could argue that North Korea has become more serious about the safety andsecurity of the civil aviation sector and its operations. Nevertheless North Korea and Air Koryo’s track record to dateindicate that the safety and security risks are still exceedingly high.
There are also civil aviation security problems caused by North Korea itself. The location of North Korea makes its
airspace attractive for many airlines to fly to China and the Eurasian continent; Pyongyang reportedly lifted the restrictions
on flights through its airspace in the late 1990s in an attempt to gain revenue through overflight fees. Despite North Korea’s
measures, however, most airlines have veered away from North Korean airspace not simply to prevent the regime from

656

accruing profits (particularly when international sanctions are in place), but out of concern for security risks associatedwith flying near North Korea.
First, there are risks in North Korean airspace due to the anti-access arrangements allowing possible attacks against orforced landing of civilian aircraft. History provides numerous cases of state and non-state actors attacking civilian flights.
Two recent examples include when Malaysia Airlines Flight 17 was shot down by pro-Russian forces in eastern Ukraineon July 17, 2014, and most recently when Ukraine International Airlines Flight 752 was shot down by the Iranian Islamic
Revolutionary Guards Corps on January 8, 2020. South Korea’s Korean Air Lines also had its share of catastrophic events
caused by geopolitical issues, such as the shootdown and forced landing of Flight 902 by Soviet fighters on April 20, 1978;the shootdown of Flight 007 by the USSR on September 1, 1983; and the bombing of Flight 858 by North Korean agentson November 28, 1987.
The second risk comes from the frequent testing of ballistic missiles that often takes place without prior warning. Even
though the probability of a ballistic missile hitting a flying aircraft is seemingly low, it deters most airlines from flying
through or near North Korea. There have been some close calls in the past, such as on March 4, 2014 when a China
Southern Airlines flight enroute from Narita, Japan bound for Shenyang, China passed through an area where a North
Korean missile flew a few minutes later. In another case, an Air France flight from Narita bound for Paris on July 28, 2018flew past a location in the Sea of Japan where a North Korean intercontinental ballistic missile landed ten minutes later.
Even if North Korea minimized the risks of hitting civilian airliners when they conduct missile tests, there are risks
nonetheless, on account of technical malfunctions, debris from in-flight explosions, and miscommunication.
There are also security implications that come from further developments in North Korea’s civil aviation sector that
benefit the North Korean armed forces. Given that Air Koryo is essentially part of the KPA, improvements in the airline’s
operational capacity would lead to enhancements in the military’s supply chain logistics. Cases could include: quicker
transportation of personnel, replenishment of supplies, and weapons from factories and rear support units to combatantunits; augmented and diversified means of airborne special forces operations; conversion and deployment of aircraft for
intelligence, surveillance, and reconnaissance operations; and dropping of conventional, chemical, biological, and nuclear
weapons. Attaining such capacity would require a considerable amount of effort and resources, and even if accomplishedit would still raise questions over whether the KPA will have the adequate readiness for sustained combat operations.

7. Conclusion
North Korea’s hyper-centralized and heavily politicized form of state governance has found application in the country’s
civil aviation sector. Simply put, the development and management of North Korea’s civil aviation sector are firmly fixatedon the regime’s political, industrial, and security demands, as opposed to servicing the populace. However, given the sizeof the civil aviation sector in North Korea, the problems in civil aviation are not directly caused by Pyongyang’s
governance of the sector per se. Rather, it is the internal and external conditions, triggered by the regime’s policies andactions, that have consequently affected civil aviation. Considering the myriad issues in North Korea, as well as chronic
shortages in fuel and international sanctions, the civil aviation sector in the Stalinist state will continue to face problems
for the foreseeable future. Hence while North Korea’s geography provides it with appeal as a civil aviation hub, the757

combination of limited capacity, stringent policies, and sanctions prevent the realization of such prospects. Moreover, as
this paper has discussed, North Korea’s civil aviation governance and militarist adventurism raise various concerns in thecontext of both civil aviation safety and security, as well as regional security.
Finding solutions to the various problems concerning North Korea’s civil aviation sector is challenging, not to mention
the implications on transport and regional security. With regards to developing the civil aviation sector, much would pivot
on attaining better capacity to effectively carry out more consistent and expansive operations, as well as creating the right
political economic, socio-political, and socio-economic conditions—mandating the implementation of major reforms. As
for civil aviation safety and security, the various problems coming from proper safety management and practices, themilitarization of airspace, weapons tests, and logistics for the KPA create serious issues. Dealing with such problems comes
down to urging and forcing North Korea to comply with proper safety and security measures, as well as refraining from
activities that harm civil aviation. The crux of the matter, however, is that doing so would require a good balance ofenforcing security measures against North Korea while providing capacity-building assistance, one that is hard to strike
under current geopolitical conditions.

1

This work was supported by JSPS KAKENHI Grant Number 22H00814.
Claudia N. Berg, Uwe Deichmann, Yishen Liu, and Harris Selod, Transport Policies and Development, Policy ResearchWorking Paper (World Bank Group, 2015). p.3.
3
Ryo Hinata-Yamaguchi, “North Korea’s Transport Policies: Current Status and Problems,” Journal of International
Relations 19, no. 2 (2016).
4
Byung-min Ahn, gyogwaseoe annaoneun bukhaneui gyotong iyagi (North Korea’s Transport not Discussed in
Textbooks) (Seoul: Institution for Unification Education, 2014).
5
Andrei N. Lankov, North of the DMZ: Essays on Daily Life in North Korea (Jefferson, NC: McFarland & Company,2007).
6
Madan B. Regmia and Shinya Hanaoka, “Assessment of Intermodal Transport Corridors: Cases from North-East andCentral Asia,” Research in Transportation Business & Management 5 (December 2012).
7
Sang-kyu Jeong , Tae-ho Lee, and Yong -un Ban, “Characteristics of Spatial Configurations in Pyongyang, North Korea,”
Habitat International 47 (June 2015).
8
Kwang-eui Yoo and Maeng-sern Kim, “A Feasibility Study on Scheduled Commercial Air Service between Capital
Cities in South and North Korea,” Transport Policy 14, no. 2 (2007).
9
James J. Wang and Timo H. Heinonen, “Aeropolitics in East Asia: An Institutional Approach to Air Transport
Liberalisation,” Journal of Air Transport Management 42 (2015).
10
Gordon L. Rottman, Korean War Order of Battle: United States, United Nations, and Communist Ground, Naval, and
Air Forces, 1950-1953 (Westport, CT: Praeger, 2002). p.169.
11
Air Koryo Administration of DPRK was renamed as the National Aviation Administration of DPRK on 30 September
2021.
12
Lankov argues that scheduled domestic flights are non-existent in North Korea. See: Lankov, North of the DMZ: Essays
on Daily Life in North Korea. p.154.; Jun-hoe Koo, “NK Introduces Domestic Air Travel,” Daily NK (25 September2014), http://www.dailynk.com/english/read.php?cataId=nk00100&num=12340.
13
See: Clinton D. Howie, “(Re)Learning to Fly: Russian Aviation in the Post-Soviet Era,” Journal of Air Law andCommerce 61, no. 2 (1995).; Jae-ho Chung, “The Political Economy of Industrial Restructuring in China: The Case ofCivil Aviation,” The China Journal, no. 50 (2003).
14
For more on political, economic, and social aspects of transport, see: Peter R. Stopher and John Stanley, Introduction
to Transport Policy: A Public Policy View, ed. John M. Phil Stanley (Cheltenham, UK: Edward Elgar Publishing Limited,2014). pp.116-131.
2

8
58

15

See: Ahn, gyogwaseoe annaoneun bukhaneui gyotong iyagi (North Korea’s Transport not Discussed in Textbooks).;
Hinata-Yamaguchi, “North Korea’s Transport Policies: Current Status and Problems.”
16
For instance, many less developed states failed to implement and enforce norms and regulations because thegovernments’ efforts could not keep pace with the growth and large-scale operations of the civil aviation sector such as in
the case of Indonesia.
17
Ibid.
18
See: Chun Han Wong, “China Chides North Korean Airline on Safety,” The Wall Street Journal (17 August 2016),
http://www.wsj.com/articles/china-demands-north-korean-airline-elevate-its-training-and-upkeep-1471436917.
19
See: “bukhaneui daehyeong sago ilji (Record of North Korea’s Major Incidents),”
NK Chosun (23 April 2004),
http://nk.chosun.com/bbs/list.html?table=bbs_16&idxno=1342&page=79&total=1864&sc_area=&sc_word=.; Song-min
Choi, “buk gunin jumin eui ’gongong eui jeok’ gun bowisodaewon hoingpo geuksim (The “public enemy” of North Korean
Residents - Severe Tyranny by State Security Department Personnel),”Daily NK (24 March 2015),
http://www.dailynk.com/korean/read.php?cataId=nk04500&num=105742.; Jung-a Choi, “buk gunindeul, yeolcha jeongi
ggeungimyeon yeo seungmuwon seongpokhaeng (North Korean Soldiers Turn Off Lights in Trains to Sexually Assault
Female Attendants),” Dong-A Ilbo (7 March 2016), http://news.donga.com/BestClick/3/all/20160307/76866091/1?

959

Iran’s Energy Relations with China and Russia
amid the Ukraine Invasion
Kohei Toyoda
Cooperative Researcher, Research Center for Advanced Science and Technology,
University of Tokyo
Energy Research Division, Research Department, Japan Oil, Gas and Metals National
Corporation (JOGMEC)
Abstract
Cooperation and competition in the oil and gas sector are among the most important elements in Iran’s
multifaceted relations with China and Russia. Iran has established cooperative relations with China
and competitive relations with Russia, not only in the oil and gas market but also in Iran’s oil and gas
industry. However, Russia’s invasion of Ukraine in February 2022 and the subsequent emergence of
new oil flows are significantly altering these existing relationships through the supply mix of theChinese crude oil market. This paper examines how Iran's relations with China and Russia are changing
amid Russia’s invasion of Ukraine.
Keywords: Oil, Iran-China Relations, Iran-Russia Relations, National Oil Company, Energy Politics
1. Introduction
The Islamic Republic of Iran has strengthened its cooperation with China and Russia since its establishment in 1979 ina wide range of political, economic, and military areas as the anti-West “Triple Axis.”1 Energy, as well as its anti-Westernorientation, is at the core of this tripartite relationship. China, the world’s second-largest oil consumer, and Iran and Russia,
the world’s leading oil and gas producers, have all had a significant presence in the international energy market for over
30 years. However, Russia’s invasion of Ukraine on February 24, 2022 has imposed a major challenge in the market.
Energy prices have skyrocketed and the focus of European countries has temporarily shifted from “decarbonization” to“de-Russianization” of energy. This global shift has resulted in changes in Iran’s energy relations with China and Russia,
from the international oil and gas market to the Iranian oil and gas industry.
This paper examines the changes in Iran’s relations with China and Russia amid the invasion of Ukraine, particularly inthe oil and gas sector. The first section provides an overview of the existing debates on Iran’s energy relations with China
and Russia. The second section identifies differences in the openness of the Chinese and Russian governments, and theirrespective national oil companies (NOCs), to participate in oil and gas projects in Iran. The third section analyzes thechanges in the oil market due to the invasion of Ukraine, particularly the change in the supply mix of the Chinese oil
160market. The fourth section discusses how the energy situation created by the invasion of Ukraine is changing Iran’s
relations with China and Russia. The paper concludes that while Iran’s interests are diverging from Chinese ones in theinternational oil market, Iran could pave the way for cooperation with Russia to develop the Iranian oil and gas industry,
despite their ongoing competition in the oil market.

2. Debates on Iran-China and Iran-Russia Energy Relations
Numerous studies have attempted to elucidate the relationship between Iran and China in the oil trade and industry.
Since China turned into a net oil importer in 1993, it has pursued crude oil from abroad, including Iran. Garver described
the relationship between China and Iran as complementary, where the former is an importer and the latter an exporter inthe oil trade.2 He detailed the historical development of how Iran began supplying crude oil to China in the 1990s, after
the Iran-Iraq war, in exchange for material support for its postwar reconstruction. Lee and Shalmon point out that in China’s“going out” strategy, which it pursued globally to secure “equity oil” that could be freely transported to China, Iran’s status
as a “rogue state” made it easy for Chinese NOCs to enter the oil and gas projects in Iran because many international oil
companies (IOCs) were not interested.3 Furthermore, Kozhanov and Calabrese show that Chinese state-owned companies
were continuously involved in the Iranian oil industry at least until the sanctions were tightened around 2010.4
Some studies refer to Iran-Russia energy relations in terms of competition in the gas market, even though such market
competition between Iran and Russia has never been realized mainly due to sanctions against Iran’s energy sector. Although
Russia also exports oil and gas to East Asia, especially China, through pipelines and by sea, Europe has always accounted
for more than half of Russian oil and gas exports through a complex network of pipelines. Without economic sanctions on
its energy sector, Iran, a major gas producer close to Europe, could have the potential to export gas to Europe. Kalehsar
and Telli and Shaffer, for example, argue that competition between the two countries in Europe will not occur in the shortterm due to the lack of pipelines and liquefied natural gas (LNG) facilities in Iran and the high cost of its sold gas comparedto Russia.5
In summary, Iran and China have cooperated in the oil market and the Iranian oil and gas industry, while Iran and Russia
have competed in the European gas market. However, to discuss the impact of Russia’s invasion of Ukraine on Iran’senergy relations with China and Russia, it is necessary to analyze why China and Russia, both of whom are importantpartners in Iran’s oil and gas sector, continue to be involved in Iran’s upstream oil and gas projects. This point is notdiscussed in detail in either the study of Iran-China and Iran-Russia relations. Esfandiary and Tabatabai make a mentionof this when discussing Iran’s relations with China and Russia in the Iranian oil and gas sector, but no detailed comparisonof these relations is made.6 As a prerequisite to discussing the changes resulting from Russia’s invasion of Ukraine, thispaper will expand on that discussion and identify the differences in motivations between China and Russia in their
participation in the Iranian oil and gas projects.

3. China and Russia in the Iranian Oil and Gas Sector
In Iran, the National Iranian Oil Company (NIOC) and its subsidiaries are responsible for its oil and gas development.
Like many NOCs, they have not been able to explore and develop their fields only by themselves due to their economic

2
61

inefficiencies and lack of technical expertise. In particular, they do not have techniques for enhanced oil recovery (EOR)
to produce additional oil from developed oil fields and LNG production to export gas globally. It is essential for foreigncompanies to enter the Iranian oil and gas sector for to extract these resources.
While IOCs have been reluctant to enter the Iranian oil and gas sector for fear of being damaged by economic sanctions
on Iran, China and Russia have actively attempted to fill the void. Internationally isolated and unable to choose otherpartners, Iran welcomed China and Russia, despite doubts about the technological capabilities of both countries’ NOCs.
What motivated China and Russia to become deeply involved in Iran’s oil and gas sector? This chapter compares thedifferent intentions of China National Petroleum Corporation (CNPC) and Gazprom, the respective Chinese and Russian
NOCs that are leading partners in Iran’s upstream oil and gas projects.

CNPC in the Iranian Oil and Gas Sector
Chinese NOCs began to consider investing in Iran’s oil and gas sector in the 2000s. While Western countries withdrew
due to economic sanctions, CNPC has continued its activities in Iran. In 2009, CNPC signed a contract with NIOC todevelop the North and South Azadegan oil field, some of the largest reserves in the world. In 2017, CNPC and France’s
Total (now TotalEnergies) also signed a contract with their Iranian counterpart to jointly develop the South Pars gas field,
the world’s largest gas field in Iran, shared with Qatar.
Since China began expanding overseas, CNPC has played a central role in its foreign operations, including several oil
and gas projects in Iran. In the mid-2000s the company acquired shares in the oil and gas fields of 26 countries in Africa,
the Asia Pacific, Central Asia, Russia, the Middle East, and South America.7 Despite the government initially branding
its initiative as the “going out” strategy, Jiang points out that CNPC’s overseas expansion in the mid-2000s was notencouraged by the Chinese government, but was driven by CNPC seeking business opportunities.8 CNPC’s overseas
operations are described in its annual report as “to promote international cooperation, particularly along the Belt and Road
route based on the optimized investment structure and regional footprint.”9 CNPC portrays its projects in the Middle East,
among China’s main sources of crude oil, as pursuing business interests, not necessarily as aligning with energy policy
initiatives.
Even after 2010, when sanctions against Iran were tightened, CNPC has shown a willingness to continuously operate
oil and gas projects in Iran, although it was eventually forced to withdraw from most projects due to lack of technology
and work delays. Maintaining a presence in large oil and gas fields in Iran could lead to both China’s energy security and
CNPC’s future profits, once sanctions against Iran’s energy sector are eased in the future. Regardless of whether it is agovernment or corporate initiative, China has continued to benefit from and participate in the progress of Iranian oil andgas projects. As with the supply-demand relationship in the oil market, Iran and China have developed cooperation in
Iran’s upstream oil and gas development.

Gazprom in the Iranian Oil and Gas Sector

362

Russia, like China, has also sought cooperation in the Iranian oil and gas sector since the 1990s. In 1997, Gazprom,
along with France’s Total and Iran’s Petropars, participated in Phase two and three developments of the South Pars gas
field. In 2018, Russian state-owned Zarubezhneft signed the Iranian Petroleum Contract (IPC) to re-develop the Avan andWest Paydar oil fields. It is important to focus on the non-contractual efforts by Russian companies since the Iran nuclear
deal in 2015. Of the 25 MOUs and contracts, 11 MOUs and one contract have been signed by Russian companies (four by
Gazprom, three by Zarubezhneft, and five by other companies), while only one contract was secured by a Chinese company,
according to the S&P Global database and Jalilvand.10 Although the degree of involvement was much lower than that ofChina until the 2000s, it is clear that Russia’s willingness to participate in the Iranian upstream oil and gas sector has
rapidly increased since the nuclear agreement was reached.
Gazprom, the most active Russian NOC in Iran, is responsible for implementing Russia’s policy on gas supply, which
is a major source of government revenue and geopolitical power for Russia. Given Russia’s abundant reserves of oil andgas, Gazprom’s overseas operations are not of great importance. Victor and Sayfer suggest that Gazprom’s overseas
operations are intended to give the company more control over demand and supply in the European gas market, citing
Gazprom’s acquisition of some European gas distribution companies as an example. 11 In other words, Gazprom’s
investments in the overseas oil and gas sector are likely aimed at strengthening Russia’s control over gas supplies toEuropean countries. Figure 1 shows the countries in which Gazprom operated energy-related projects in 2020. With some
exceptions, this map indicates that most of these countries are either countries to which Russia supplies gas, or countries
that supply gas to Europe.
Figure 1. Countries in which Gazprom has operations

Source: Gazprom Annual Report 2020

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There are also some examples of broader Russian involvement in the Iranian projects in which Gazprom has participatedto increase its control over gas supplies. Shaffer points to Gazprom’s acquisition of the Iran-Armenia pipeline in 2006 as
an attempt to prevent Iran from entering the European gas market.12 Gazprom pressed Armenia to halve the pipeline’s
circumference from its original design to prevent Iran from supplying large volumes of gas to the southern European
markets through Armenia. In light of this policy, Gazprom’s attempt to enter the Iranian oil and gas sector after the 2015
Iran nuclear deal seems to have been driven by the intention to control Iran’s gas production and export. Sanctions relief
created the possibility of connecting gas pipelines to Europe and exporting LNG, and an actual competitive relationshipbetween Iran and Russia in the European market became likely to emerge. Therefore, it is possible that Gazprom and theRussian government, through their participation in Iranian oil and gas projects, were considering either applying a certain
degree of control over the gas supply from Iran to Europe, or adopting an obstructionist approach to the Iranian projects
themselves. Based on competition in the gas market, Russia seemed ready to attempt a hostile intervention in Iran’s oil
and gas industry.

Comparing Chinese and Russian Companies
Comparing CNPC’s and Gazprom’s policies toward their overseas operations and their involvement in Iranian oil andgas projects, it can be inferred based on Iran-China cooperation and Iran-Russia competition in the oil and gas market thatthe companies held markedly different intentions in engaging with Iran. CNPC’s participation in the Iranian oil and gas
projects was driven initially by the government’s encouragement to acquire foreign oil, and later, by the company’scommercial interests. On the other hand, Gazprom’s participation in the Iranian projects may have been based on the
Russian government’s gas supply policy to control or prevent Iranian gas from flowing to the European market. In otherwords, CNPC perceived the progress of oil and gas development in Iran as favorable, whereas Gazprom perceived the lackof progress as favorable. Thus, while both Chinese and Russian NOCs’ participation in Iran’s oil and gas projects
seemingly proceeds in the same direction of cooperation with Iran, in reality their intentions are opposed.

4. Changes in the Chinese Oil Market before and after the Invasion of Ukraine
Around the time of Russia’s invasion of Ukraine, two important developments occurred in the Chinese crude oil market.
One was a decrease in imports of Iranian crude oil and the other was an increase in imports of Russian crude oil. The
former is not directly related to the invasion of Ukraine, but the overlap of the two movements has led to changes in Iran’s
relations with China and Russia, which will be discussed in the next section.
Before the invasion of Ukraine, China’s imports of Iranian crude oil showed a downward trend. Although not represented
by China Customs Statistics,13 Chinese imports of Iranian crude oil, which were estimated by tanker tracking companies
to be around 700,000 barrels per day in January, were estimated at 400,000-600,000 barrels per day in May, according todata firms Kpler and Vortexa Analytics.14 It should be noted here that this decline in Iranian crude oil imports beganaround February as independent Chinese refineries reduced their processing capacity,15 and was not caused by Russia’s
invasion of Ukraine.

564

On the other hand, China’s imports of Russian crude oil have been gradually increasing, triggered by the “deRussianization” trend of the European energy market since the invasion of Ukraine. In March 2022, the European
Commission announced a plan named “REPowerEU” to end dependence on Russian fossil fuels before 2030. The plan
anticipates a reduction of approximately two-thirds of natural gas imports from Russia by 2022, through diversification of
supply sources and reduction of fossil fuel use.16 Additionally in June, as part of the sixth package of restrictive measuresagainst Russia, a decision was reached to phase bans on all imports of Russian seaborne crude oil and petroleum products.17
With the above “de-Russianization” trend in the energy market, Russia is increasingly likely to lose access to theEuropean market to which it has exported 54% of its oil and 76% of its gas. This has led to a massive influx of Russiancrude oil into Asian markets as an alternative for Russia, and increased imports of Russian crude oil in China, Iran’s mainmarket. Although Chinese companies are said to have refrained from purchasing Russian crude oil in February, fearing
reputational risk, imports from Russia have increased steadily since then, reaching a record high of 1.98 million barrels
per day in May (Figure 2).
Figure 2. Imports of Russian crude oil by China (million barrels per day)

Source: China Customs Statistics

5. Impact of the Invasion on Iran-China and Iran-Russia Energy Relations
How will these mutually independent changes in the volume of Russian and Iranian oil imports in the Chinese oil market
affect the relations between Iran and China and between Iran and Russia? Despite what was presented previously, thehistorical relationships between Iran, China and Russia are in flux. Amidst the uncertainty of Russia’s invasion of Ukraine,

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Iran-China cooperation is becoming unsettled and Iran-Russia competition is beginning to move in the opposite direction.
The two changes in the Chinese oil market discussed in the previous section, the trend of declining imports of Iraniancrude oil and increasing imports of Russian crude oil, have upset the energy supply-demand relationship that China andIran have long established. In addition to the decline in imports due to processing capacity since February, it is rumoredthat independent refineries in Shandong Province—located in the eastern coastal area of China and historically the mainbuyers of Iranian crude oil—have begun to voluntarily refrain from buying Iranian crude oil due to stronger US sanctions
against Iran.18 In late May, the US Treasury Department’s Office of Foreign Assets Control (OFAC) sanctioned the Iranianoil smuggling network led by Iran’s Revolutionary Guard Corps for the sale of Iranian oil.19 Several Chinese companies
that had purchased millions of barrels of Iranian oil were included in these sanctions, so Chinese refineries started to moveaway from purchasing Iranian crude oil.
Russian crude oil will fill this void. As mentioned above, the sanctions against Russia have reduced the number of oil
suppliers in the international market, and Russian crude oil has been heavily discounted and redirected toward the Asianmarket. Refineries in Shandong are comparing prices with Iranian crude oil and considering replacing it with Russian
supplies. To compete with cheaper Russian crude oil, it was reported that Iran is further discounting its crude oil by aroundfive US dollars per barrel, which is normally sold at a discount of around five dollars per barrel from the Brent price. What
has resulted is the outbreak of a “discount war” between Iran and Russia.20 Thus, shrewd business decisions by Chinese
refineries have reduced the importance of Iranian crude oil in the Chinese market. It can be said that the supply-demand
relationship that has been the foundation of energy cooperation between China and Iran is weakening as the effects of theinvasion of Ukraine have spilled over.
On the other hand, relations between Iran and Russia, which have historically had competitive relations in energy
markets, are showing signs of getting closer as sanctions against Russia are being announced gradually. In response toWestern countries’ phased sanctions against Russia’s energy sector since the invasion of Ukraine, Russia has begun
exploring how it can circumvent sanctions to continue its oil and gas exports. Iran is the most adept at sanctions evasion
methods, knowledge which is of immense value to Russia at present. Having endured years of economic sanctions on its
energy sector, Iran has been seeking ways to bypass the sanctions and conduct seaborne oil transactions (Table 1). As aresult, several ministers have praised the performance of the National Iranian Tanker Company (NITC), claiming that oil
shipments by the company have doubled since the Ebrahim Raisi administration took office.21
Table 1. Methods to circumvent various sanctions by Iran

SectorOil and gas
sectorFinance sector







MethodUtilizing ship-to-ship transshipment (STS)
Navigation with AIS transponders (Automatic Identification System for
Ships) deactivatedDisguising the origin of crude oil by transportation via a third country
Establishment of payment systems in local currencies to replace SWIFT
Barter transactions, such as oil and gas swap deals

Since February, Russia has held a series of inter-ministerial meetings with Iran to discuss ways to avoid sanctions. At a766

meeting of foreign ministers in March, they reportedly discussed economic policies to neutralize the negative effects ofWestern sanctions against Russia, as well as issues related to the nuclear negotiations.22 During the meeting between
Iranian Oil Minister Javad Owji and Russian Deputy Prime Minister Alexander Novak in May, they agreed to use theirnational currencies for settlements of trade and energy payments and indicated that they would continue discussions toconnect an alternative system to SWIFT.23 While discussions on avoiding sanctions in the energy sector have not been
disclosed, some progress has been made in discussions on countering sanctions in the financial sector.
However, this exchange has a potential ramification for Iran. By sharing the methods it uses to avoid sanctions with
Russia, this could lead to more Russian flows into the Chinese oil market, placing Iran at a further disadvantage in its
market competition with Russia. In light of this and to Iran’s benefit, the two countries are concurrently stepping up
cooperation in the Iranian oil and gas sector: in conjunction with President Putin’s visit to Tehran in July 2022, an MOUof up to 40 billion US dollars was signed between Iran’s NIOC and Russia’s Gazprom for oil and gas projects (Table 2).
Table 2. Announced Details of the MOU between NIOC and Gazprom

SourceIran Media
Gazprom

Detail of Cooperation
Development of Kish gas field, North Pars gas field, and six other oil fields
Efforts to increase reservoir pressure in the South Pars gas fieldSwap transactions for natural gas and petroleum products
LNG projects and construction of a natural gas pipeline
Other technological exchange

The MOU aims to bring foreign companies into Iran’s oil and gas projects, which have not been realized since 2018.
The cooperation includes, in particular, increasing gas production and exports, which is exactly what Iran has been longing
for, as it has been unable to export its gas due to the inability to cover investment and technological capacity on its own.
This possible cooperation is completely different in nature from Russia’s previous participation in Iran’s oil and gas
projects. As noted earlier, the Russian acquisition of the Iran-Armenia gas pipeline in 2006 and its willingness to enter the
Iranian oil and gas business from 2016 to 2018 can be considered ostensible cooperation to control gas supplies from Iranto Europe. This may be since the former case occurred before the tightening of US economic sanctions against Iran in
2010, while the latter case occurred immediately after the signing of the Iranian nuclear agreement, so there was a highpossibility of Iranian gas supply to Europe. On the other hand, the current cooperation arises in a situation where thenuclear negotiations are reportedly “in danger,”24 and the export of gas from Iran to Europe is unlikely. Therefore, theMOU between NIOC and Gazprom can be viewed as a way for Iran and Russia to reduce distrust in order to counter
economic sanctions together and gain mutual benefits.25

7. Conclusion
This paper has discussed how Iran’s relationship with China and Russia has changed with Russia’s invasion of Ukraine.
Simply put, the effects of the invasion have weakened Iran-China cooperation, historically based on a pragmatic supplydemand relationship, while Iran and Russia’s competitive relationship is on the cusp of transforming into genuine
867cooperation. China has long had a cooperative relationship with Iran in the oil and gas sector based on aligned interests inthe oil market. After the invasion of Ukraine, the influx of Russian oil from Europe to Asia has led independent Chinese
refineries to move away from Iranian oil. This move could destabilize Iran-China cooperation in the oil and gas sector. On
the other hand, Russia and Iran have had a competitive relationship in the oil and gas sector based on potential rivalry in
the European gas market. Russia’s involvement in the Iranian oil and gas sector to date has been considered superficial
cooperation aimed at controlling gas flows from Iran. However, the invasion of Ukraine has raised the possibility that
Russia, which has been subject to strong sanctions from the West, may pursue genuine cooperation in the oil and gas sector
with Iran in order to avoid sanctions. This trilateral relationship is now at a turning point.
Esfandiary and Tabatabai described the relationship between the three countries as a “pragmatic relationship based on
mutual interests and necessities.”26 China, which has been building a mutually beneficial relationship with Iran, is now
temporarily turning away due to low-priced Russian crude oil, potentially jeopardizing the potential for cooperation in thelong-term. Russia, which had previously checked Iran in fear of losing a significant portion of its energy market, is now
ready to cooperate in many areas with Iran. The above expression by two Iranian experts captures the current situation.
Lacking stronger principles to reinforce their momentary alignment, future relations between the three countries will be
guided by the interests and necessities of each country, placing their relationships at the mercy of new and unforeseeable
challenges.
References
Aizhu, Chen, and Bozorgmehr Sharafedin. “China’s Iranian oil imports ease on poor margins, lure of Russian oil.” Reuters,
May 9, 2022. https://www.reuters.com/business/energy/chinas-iranian-oil-imports-ease-poor-margins-lure-russianoil-2022-05-09/.
Calabrese, John. “China’s “One Belt, One Road” (OBOR) Initiative: Envisioning Iran’s Role.” In China’s Presence in the
Middle East, edited by Anoushiravan Ehteshami and Niv Horesh, 174-91. New York: Routledge, 2018.
“China Customs Statistics.” General Administration of Customs of the People's Republic of China, accessed July 31, 2022.
http://english.customs.gov.cn/statics/report/preliminary.html.
China

National

Petroleum

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https://www.cnpc.com.cn/en/2020enbvfgrme/202107/fc4d937740b146ed9999fadcc26273b4/files/61c4314b392243
1caa93dcf48f02ab20.pdf.
Cho, Sharon, and Sarah Chen. “Iran Slashes Cost of Its Oil to Compete with Russia in China.” Bloomberg, July 4, 2022.
https://www.bloomberg.com/news/articles/2022-07-03/iran-slashes-the-cost-of-its-oil-to-compete-with-russia-inchina.
Demongeot, Maryelle. “Chinese Refiners Double Down on Discounted Russian, Iranian Barrels.” International Oil Daily,
June 21, 2022. https://www.energyintel.com/00000181-8555-d35b-a7eb-a75fcd260000.
Esfandiary, Dina, and Ariane Tabatabai. Triple Axis: Iran’s Relations with China and Russia. London: I.B. Tauris, 2018.
Foy, Henry, Felicia Schwartz, and Najmeh Bozorgmehr. “Iran’s Nuclear Deal ‘in Danger’, Says EU Chief Negotiator.”
Financial Times, September 6, 2022. https://www.ft.com/content/004f0d5a-0eca-4ea0-a423-0184481d033c.

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Garver, John. China and Iran: Ancient Partners in a Post-Imperial World. Seattle: University of Washington Press, 2006.
Gazprom.

Gazprom

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2020.

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2021,

https://www.annualreports.com/HostedData/AnnualReports/PDF/LSE_OGZD_2020.pdf.
“Iran,

RussiaSign

Energy,Banking

MoUs.”

TasnimNews

Agency,

May

26,

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https://www.tasnimnews.com/en/news/2022/05/26/2717165/iran-russia-sign-energy-banking-mous.
“Iran Turns up the Heat on Chinese State Energy Giants.” MEES, May 9, 2014. https://www.mees.com/2014/5/9/oilgas/iran-turns-up-the-heat-on-chinese-state-energy-giants/e6420480-4932-11e7-9166-e39aea53dae5.
Jalilvand, David Ramin. “The Iranian Energy: A Comeback with Hurdles.” Oxford Institute for Energy Studies (January2017).
Jiang, BinBin. “China National Petroleum Corporation (CNPC): a Balancing Act between Enterprise and Government.”
In Oil and Governance: State-Owned Enterprises and the World Energy Supply, edited by David G. Victor, et al.,379-417. Cambridge: Cambridge University Press, 2012.
Kalehsar, Omid Shokri, and Azime Telli. “The Future of Iran-Russia Energy Relations Post Sanctions.” Middle East Policy
24, no. 3 (Fall, 2017): 163-170.
Klaus, Oliver, and Phil Chaffee. “Iran’s Exports Hit by Discounted Russian Crude.” International Oil Daily, June 9, 2022,
https://www.energyintel.com/00000181-492b-d578-a1dd-eb7f2b250000.
Kortunova, Marina. “Iranian, Russian FMs discuss how to neutralize sanctions.” Press TV, March 15, 2022,
https://www.presstv.co.uk/Detail/2022/03/15/678625/Russia-favor-quick-JCPOA-revival.
Kozhanov, Nikolay. “Iran and East Asian Countries: The Economic Dialogue and Its Strategic Implications.” In Security
Dynamics of East Asia in the Gulf Region, edited by Tim Niblock and Yang Guang, 113-135. Berlin: Gerlach Press,
2014.
Lee, Henry, and Dan A. Shalmon. “Searching for Oil: China's Oil Initiatives in the Middle East,” ENRP Discussion Paper(BCSIA) and KSG Faculty Research Working Paper Series RWP07-017 (March 2007).
Oceana, Zhou, and Sambit Mohanty, with staff reports. “New Iran Sanctions Prompt China Independent Refiners to Focus
on Russian Crude,” Platts Oilgram News, June 1, 2022.
“Oil

Shipment

by

NITC

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TehranTimes,

May

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https://www.tehrantimes.com/news/472683/Oil-shipment-by-NITC-fleet-doubled-minister.
Reese, Chris. “Russia and Iran Discuss Swapping Supplies for Oil and Gas, Goods Logistics.” Reuters, May 26, 2022.
https://www.reuters.com/business/energy/russia-iran-discuss-swapping-supplies-oil-gas-goods-logistics-2022-0525/.
“REPowerEU: Joint European action for more affordable, secure and sustainable energy.” European Commission, March
8, 2022. https://ec.europa.eu/commission/presscorner/detail/en/ip_22_1511“Russia's war on Ukraine: EU adopts sixth package of sanctions against Russia.” European Commission, June 3, 2022.
https://ec.europa.eu/commission/presscorner/detail/en/ip_22_2802.
Shaffer, Brenda. Energy Politics. Philadelphia: University of Pennsylvania Press, 2009.
Sharafedin, Bozorgmehr. “Iran and Russia's Gazprom sign primary deal for energy cooperation.” Reuters, July 19, 2022.

1069https://www.reuters.com/business/energy/iran-russias-gazprom-sign-primary-deal-energy-cooperation-2022-07-19/.
“Treasury Targets Oil Smuggling Network Generating Hundreds of Millions of Dollars for Qods Force and Hizballah.”
US Department of the Treasury, May 25, 2022. https://home.treasury.gov/news/press-releases/jy0799.
“Upstream

Companies

andTransactions.”

S&P

Global,accessed

July

31,

2022.

https://connect.ihsmarkit.com/upstream/companies-transactions/.
Victor, Nadejda, and Inna Sayfer. “Gazprom: The Struggle for Power.” In Oil and Governance: State-Owned Enterprises
and the World Energy Supply, edited by David G. Victor, et al., 655-700. Cambridge: Cambridge University Press,
2012.

1

Dina Esfandiary, and Ariane Tabatabai, Triple Axis: Iran’s Relations with China and Russia (London: I.B. Tauris, 2018).
John Garver, China, and Iran: Ancient Partners in a Post-Imperial World (Seattle: University of Washington Press,
2006), 237-280.
3
Henry Lee, and Dan A Shalmon, "Searching for Oil: China's Oil Initiatives in the Middle East," ENRP Discussion Paper(BCSIA) and KSG Faculty Research Working Paper Series RWP07-017 (March 2007).
4
Nikolay Kozhanov, “Iran and East Asian Countries: The Economic Dialogue and Its Strategic Implications,” in Security
Dynamics of East Asia in the Gulf Region, eds. Tim Niblock and Yang Guang (Gerlach Press, 2014): 124-128; John
Calabrese, “China’s "One Belt, One Road" (OBOR) Initiative: Envisioning Iran’s Role,” in China’s Presence in the Middle
East, eds. Anoushiravan Ehteshami and Niv Horesh, (Routledge, 2018): 178.
5
Omid Shokri Kalehsar, and Azime Telli, “The Future of Iran-Russia Energy Relations Post Sanctions,” Middle East
Policy 24, no. 3 (Fall 2017): 163-170; Brenda Shaffer, Energy Politics (Philadelphia: University of Pennsylvania Press,2009), 114-127.
6
Esfandiary and Tabatabai, op.cit., 98-103.
7
BinBin Jiang, “China National Petroleum Corporation (CNPC): a Balancing Act between Enterprise and Government,”in Oil and Governance: State-Owned Enterprises and the World Energy Supply, ed. David G. Victor, et al. (Cambridge:
Cambridge University Press, 2012): 403.
8
Jiang, op. cit., 403-404.
9
China National Petroleum Corporation, 2020 Annual Report (July 2021), 51.
10“Upstream
Companies
andTransactions,”
S&P
Global,accessed
July
31,
2022,
https://connect.ihsmarkit.com/upstream/companies-transactions/; David Ramin Jalilvand, “The Iranian Energy: A
Comeback with Hurdles,” Oxford Institute for Energy Studies (January 2017).
11
Nadejda Victor and Inna Sayfer, “Gazprom: The Struggle for Power,” in Oil and Governance, ed. Victor et al., 656.
12
Shaffer, op. cit., 125-126.
13
Crude oil smuggling from Iran and imports of falsified origin through transshipment at ports in the Middle East andMalaysia are said to exist on a substantial scale.
14
Oliver Klaus and Phil Chafee, “Iran’s Exports Hit by Discounted Russian Crude,” International Oil Daily, June 9, 2022,
https://www.energyintel.com/00000181-492b-d578-a1dd-eb7f2b250000; Maryelle Demongeot, “Chinese Refiners
Double Down on Discounted Russian, Iranian Barrels,” International Oil Daily, June 21, 2022,
https://www.energyintel.com/00000181-8555-d35b-a7eb-a75fcd260000.
15
Chen Aizhu and Bozorgmehr Sharafedin, “China's The Iranian oil imports ease on poor margins, lure of Russian oil,”
Reuters, May 9, 2022, https://www.reuters.com/business/energy/chinas-iranian-oil-imports-ease-poor-margins-lurerussian-oil-2022-05-09/.
16“REPowerEU: Joint European action for more affordable, secure and sustainable energy.” European Commission,
March 8, 2022, https://ec.europa.eu/commission/presscorner/detail/en/ip_22_1511.
17“Russia's war on Ukraine: EU adopts sixth package of sanctions against Russia,” European Commission, June 3, 2022,
https://ec.europa.eu/commission/presscorner/detail/en/ip_22_2802.
18
Zhou Oceana and Sambit Mohanty, with staff reports, “New Iran Sanctions Prompt China Independent Refiners to
Focus on Russian Crude,” Platts Oilgram News, June 1, 2022.
2

11
70

19

“Treasury Targets Oil Smuggling Network Generating Hundreds of Millions of Dollars for Qods Force and Hizballah.”
US Department of the Treasury, May 25, 2022, https://home.treasury.gov/news/press-releases/jy0799.
20
Sharon Cho and Sarah Chen, “Iran Slashes Cost of Its Oil to Compete with Russia in China,” Bloomberg, July 4, 2022,
https://www.bloomberg.com/news/articles/2022-07-03/iran-slashes-the-cost-of-its-oil-to-compete-with-russia-in-china.
21
Marina Kortunova, “Iranian, Russian FMs discuss how to neutralize sanctions.” Press TV, March 15, 2022,
https://www.presstv.co.uk/Detail/2022/03/15/678625/Russia-favor-quick-JCPOA-revival.
22“Oil
Shipment
by
NITC
Fleet
Doubled:
Minister,”
TehranTimes,
May
17,
2022,
https://www.tehrantimes.com/news/472683/Oil-shipment-by-NITC-fleet-doubled-minister.
23“Iran, Russia Sign Energy, Banking MoUs,” Tasnim News Agency, May 26, 2022,
https://www.tasnimnews.com/en/news/2022/05/26/2717165/iran-russia-sign-energy-banking-mous.
24
Henry Foy, Felicia Schwartz and Najmeh Bozorgmehr, “Iran Nuclear Deal ‘in Danger’, Says EU Chief Negotiator,”
Financial Times, September 6, 2022, https://www.ft.com/content/004f0d5a-0eca-4ea0-a423-0184481d033c.
25
Bozorgmehr Sharafedin, “Iran and Russia's Gazprom sign primary deal for energy cooperation,” Reuters, July 19, 2022,
https://www.reuters.com/business/energy/iran-russias-gazprom-sign-primary-deal-energy-cooperation-2022-07-19/.
26
Esfandiary and Tabatabai, op. cit., 191.

1271

An Unequal Agreement: Revisiting the 1951 Diet Deliberations
on the Japan-US Security Treaty
Ichiro Kaji
Project Researcher, Research Center for Advanced Science and Technology,
University of Tokyo
Abstract
The 1951 Japan-US Security Treaty had many shortcomings, most critical being the absence of a US
commitment to defend Japan, making it an "unequal" treaty for Japan. To gain the Diet's approval, theShigeru Yoshida Administration had to present the treaty as a fair agreement. How they achieved this is
explained in the memoirs of former key officials, who stated that effective interpretation of the treaty
obligated the US to defend Japan. However, these memoirs fall short in providing detailed explanations of
this interpretation within the treaty’s clauses. This paper clarifies the government's logic by revisiting theDiet minutes chronicling the deliberations. A review of the Diet minutes reveals that in addition to evoking
the treaty's spirit, officials used precedents such as the North Atlantic Treaty to argue for its fairness.
However, even among ruling party members, the treaty text was considered too problematic to justify anequal agreement. Despite stating that the Security Treaty was the "key" to Japan's entry into the communityof equal sovereign nations, Prime Minister Shigeru Yoshida failed to convince Diet members of the treaty’s
equality.

Keywords: Japan-US Security Treaty, Diet, Shigeru Yoshida, Japanese Politics, Diplomacy
1. Introduction
The 1951 Japan-United States Security Treaty was an "unequal treaty" for Japan. This view has been widely held inJapan’s collective consciousness since the 1950s. For example, Mamoru Shigemitsu, President of the conservative
opposition, Kaishin To (the Reformist Party), called for a revision of the “unequal treaty” on November 24, 1952.1 The
Social Democratic Party of Japan also insisted that the "unequal treaty" should be revised and abolished.2 Diplomatic
historian Kazuya Sakamoto stated in his book, "The security treaty, to be fair, fulfilled a huge role for nine years in ensuring
Japanese national security. It occasioned immense dissatisfaction, however, in the Japanese government and in the Japanese
populace."3What part of the Security Treaty is unequal? Takezo Shimoda, who served as Director General of the Treaties Bureauof the Ministry of Foreign Affairs after the Security Treaty came into effect, summarized its flaws in the following six
areas: lack of US commitments to defend Japan; ambiguous treaty duration; unclear relationship with the UN Charter;
172

absence of Japanese checks on the actions of US forces in Japan (no prior consultation system); allowance of US forces to
respond to riots and disturbances in Japan at the request of the Japanese government; stipulation of prior US consent when
Japan grants bases and other rights to third countries. 4 Other issues included the Constitution, the Administrative
Agreement, and the Okinawa/Ogasawara Islands.5 These shortcomings prompted many criticize the 1951 Security Treaty
as a mere stationing agreement permitting the US presence in Japan.
Japanese negotiators from the administration of Prime Minister Shigeru Yoshida also viewed the Security Treaty as
problematic. They had been forced to make many compromises during negotiations with the US. However, the Yoshidaadministration needed its parliament, the National Diet, to ratify the imperfect treaty. This required cunning logic to convey
the treaty’s equal nature. Explanations of how this was achieved in the Diet were summarized in the memoirs of Prime
Minister Yoshida and Kumao Nishimura, Director General of the Treaties Bureau of the Ministry of Foreign Affairs.
However, their memoirs do not fully explain all the provisions: they concentrated on the issues of US defense obligations
to Japan and US forces in Japan. They defended the Security Treaty by saying that although the treaty lacked a US defense
commitment to Japan, given its spirit, a de facto commitment did exist. How did they defend the other clauses? Did their
explanations convince the members of the Diet? It is well known that opposition party members opposed the Security
Treaty, but did the ruling party members wholeheartedly agree to the treaty? Few studies have examined these Diet
deliberations in such detail.
This paper focuses on the provisions of the Security Treaty deemed unequal and examines how the government
addressed them by examining the Diet deliberations. This paper does not add any new facts or perspectives to the study of
the Japan-US Security Treaty. Instead, it examines how the government defended the treaty during the Diet deliberations,
picks up on overlooked facts, and reaffirms the strength of postwar Japan’s political energy to revise the Security Treaty.

2. Japan-US Negotiations
How did the 1951 Japan-US Security Treaty become unequal? In a nutshell, the reason was that Japan was not capableor prepared to create an equal relationship with the United States. When negotiating the Security Treaty, the Japanese
government held the policy that "Japan will ensure internal security by itself," and "As regards external security, thecooperation of the United Nations and, especially of the United States, is desired, through appropriate means."6 These“appropriate means” meant Japan-US defense cooperation in Japan, including the stationing of US forces in Japan. As forJapan's defensive power, Shigeru Yoshida intended to rearm gradually. At the meeting with his advisory group on October
5, 1950, Yoshida stated, "In fact, we’ll rearm, but before a treaty is concluded, we’ll take the position that we don't want
to rearm.”7 In his memoirs, he cited three reasons for slow rearmament: (1) Japan's low economic power, (2) the Japanesepeople's aversion to armaments, and (3) the problems resulting from the war’s ongoing resolutions. 8 The Japanese
government considered creating a security cooperation relationship with the US under Article 51 of the UN, offeringresources including bases, Japanese productive power, and police forces to the US and liberal states in exchange for US
military power.9
The US government considered the Japanese government’s position to be an insufficient contribution to the liberal order.

273

Although Washington considered security cooperation with Japan necessary for its own national security and the securityof East Asia, they found it difficult to conclude a treaty with Japan as an equal partner until Japan had sufficient defense
forces as defined by the US Senate’s Vandenberg Resolution, which stipulated security cooperation only with states thatprovide continuous and effective self-help and mutual aid. John F. Dulles, Special Representative in the peace treaty
negotiations, and who visited Japan in January 1951 to negotiate with Yoshida, stated the following at a meeting with his
staff on February 5, 1951:
Ambassador Dulles agreed that it probably would be desirable to retain Chapter VIII in someform. He went on to say that when Japan, following amendment of its Constitution, is in a position
to make precise commitments such as we are trying to obtain from European countries,
commitments to contribute a certain number of divisions by a certain date, then we will be in aposition to make more concrete commitments ourselves. Until then we must maintain a flexible
position.10
In negotiations, the US demanded rights to station US forces in Japan but did not make clear its commitments to defend
Japan. This is the primary reason why the Security Treaty became an unequal treaty for Japan.11 Director General Kumao
Nishimura recalled three limiting factors that prevented equal security cooperation between the United States and Japan:(1) Article 9 of the Japanese Constitution, (2) Japan’s lack of sufficient military power, and (3) the US attitude as theoccupying power of Japan.12 As a result of a change in (3) over time, and in US policies toward (1) and (2),13 the Security
Treaty was revised in 1960 when a new, more equal “Treaty of Mutual Cooperation and Security between the United States
and Japan” was concluded between the two countries.14
In brief, since Japan did not have sufficient capabilities, the US did not regard Japan as a full-fledged ally and refusedto accept an “equal” treaty.

3. Diet Deliberations
It is well known that the Diet deliberations on the revised Security Treaty in 1960 were heated and prompted large-scaleprotests around Japan (Anpo Sodo). But various issues were also discussed in 1951 when the “unequal” treaty was initiallydeliberated. How was the discourse in the Diet framed at that time?
To discuss and ratify the Security Treaty, Japan's Diet established the Peace Treaty of San Francisco and Japan-US
Security Treaty Special Committees in the House of Representatives and the House of Councilors after Prime Minister
Yoshida signed the Peace Treaty of San Francisco on September 8, 1951. The Special Committee deliberations began in
the House of Representatives on October 11, 1951, where Man-itsu Tanaka, a member of the ruling Liberal Party, chaired
the committee. In the House of Councilors, Nobuyuki Okuma, a grandson of former Prime Minister Shigenobu Okuma,
chaired the committee that began on October 18. The committees in both Houses were composed of representatives of thesix leading parties: the three conservative parties were the ruling Liberal Party, the opposition National Democratic Party,
and the opposition Ryokufu Kai; the three opposition reformist parties were the Right Socialist, the Left Socialist, and theJapanese Communist Party. Key members leading the deliberations were Hitoshi Ashida,15 Yasuhiro Nakasone,16 Eiichi
Nishimura,17 Takeo Miki,18 and Eki Sone.19 Other leading and minority party members were also involved.20

374

In addition to focusing on the contents of the Security Treaty, the deliberations sought to clarify a number of issues
including the relationship between the Constitution and the Security Treaty, the Administrative Agreement undernegotiations between Japan and the US, and the Acheson-Yoshida Notes, which concluded Japan’s assistance to UN forcesin the Korea War. As noted in the Introduction, this paper will focus primarily on the issues of inequality arising from the
Security Treaty articles, particularly the six areas mentioned by Shimoda. What parts of the treaty did these Diet members
take issue with, and how did government officials respond to them?

4. Lack of US Defense Commitments toward Japan
Most members of the Committees of both Houses criticized the lack of US defense commitments to Japan. Article I
provided that US forces may be utilized to contribute to any external attacks on Japan, or suppression of large-scale internal
riots and disturbances at the express request of the Japanese government. This led to criticisms by Diet members from both
the ruling and opposition parties—conservatives and reformists—that the US defense commitments to Japan were notassured. Eiichi Nishimura stated, “What I find most puzzling about the Japan-US Security Treaty is that there is noprovision for US commitments for the defense of Japan.”21 Eki Sone characterized it as a stationing agreement rather thanan ordinary security treaty.22
These concerns were shared not only by opposition party members but also by the ruling party members. In his
supportive speech on the Security Treaty, Goro Morishima, representing the Liberal Party, expressed his concerns about
the absence of mutuality in the treaty:
However, as long as the Vandenberg Resolution exists, there is no choice. When we can’t obtain
the best, we must choose the next best. This treaty is the next best. Moreover, this treaty isprovisional.23
Naoyoshi Kitazawa also stressed that the treaty was provisional and stated that the Japanese people had not only hope
but also concerns, worries, and doubts about the treaties, including the Peace Treaty.24
Government officials understood these criticisms. Yoshida recalled, "the most important of the points we wanted fromthe US was to clearly state in the agreements the US responsibility for Japan's security.”25 Japanese foreign affairs officials
were eager for US commitments during several negotiations with the US but were unable to secure US assurances.26 These
officials were left in a bind: they failed in their negotiations with the US, however, they could not announce to the public
and the Diet that there were no mutual defense commitments. Their response to critiques that they failed to secure a clear
US defense commitment has been well-documented: they developed the logic that there was a de facto commitment. As
stated in his memoirs, Yoshida said that the US would not be able to sit idly by if any invasion were to occur against Japan
while hosting US forces.27 Kumao Nishimura said that the US would exercise its right of individual self-defense in sucha situation.28
They gave the same answers to the committee's deliberations as they had in their memoirs. In response to Eiichi
Nishimura, Prime Minister Shigeru Yoshida countered:
When Japan's security is violated, it is not realistic to expect the US forces in Japan to stand idly
by and watch as US soldiers are killed because there are no obligations, so such a commitment

475

naturally arises.
Yoshida reiterated that what was essential was the treaty's spirit and that the lack of commitment provisions did notmean that the US would stand by and watch aggression against Japan.29
The government explained to the Diet that substance, not form, matters. The Diet members, however, considered form
to be more critical because the condition in which the US had rights but no obligations to Japan was a matter of self-dignity
for the Japanese people. Yoshida later denounced these positions by Diet members as Sanbyaku Daigen (sophomoricinterpretations).30 However, the lack of commitments, which even government officials considered problematic, remained
a critical issue for Japan until the treaty was revised in 1960.

5. US Assistance for Japan’s Internal Security
Along with the lack of US defense commitments to Japan, many Diet members regarded the clause allowing the US to“put down large-scale internal riots and disturbances in Japan” at the express request of the Japanese government as
dishonorable. The government, however, needed US assistance to maintain domestic stability in Japan due to Japan's weakpolice force.31 On the other hand, they also wanted to avoid expressions that would upset the feelings of the Japanesepeople.32 Finally, the internal security that the US could assist with was limited to cases "caused through instigation orintervention by an outside power or powers."
During the deliberations, most major parties, except the ruling party, opposed this provision. Hitoshi Ashida, a former
prime minister, strongly opposed dependence on the US, even for internal security. He said:
The government requested this approach from the US because it was not confident in its ability
to maintain Internal security. It is a severe problem that Japan must rely on foreign military forces
to maintain Internal security. If that is true, Japan is in nature a protectorate, even though it appears
to be an independent country.33
Takeo Miki also criticized this provision. He stated that Japan should be responsible for maintaining its internal
security.34 In the House of Councilors, Soji Okada denounced it, saying that it would allow the US to interfere in Japan’sinternal affairs.35
How did government officials respond to these concerns? In the Diet, they argued that this provision was not unique.
Kumao Nishimura defended the provision, saying that the North Atlantic Treaty Organization had similar commitments.
He referenced US Secretary of State Dean Acheson’s statement regarding Article Ⅴ of the North Atlantic Treaty, which
provides for joint defense against an armed attack, that “Purely internal revolutionary activity would not be regarded as anarmed attack; a revolutionary activity inspired, armed directed from the outside, however, [is] a different matter.” 36
Nishimura, therefore, pointed out that US assistance is limited to cases "caused through instigation or intervention by anoutside power or powers" and countered that because the situation was the same as in NATO, the provision was not unequal
for Japan.
In response to Nishimura's rebuttal, Okada suggested the difference between the North Atlantic Treaty and the JapanUS Security Treaty was that the latter specified US assistance in internal disturbances in its text, whereas the North Atlantic
Treaty did so by interpretation, and this difference was significant. Nishimura's argument was legal and not politically

576appropriate: there was no precedent other than the Security Treaty for specifying it in the article, as Okada pointed out.
Nishimura himself stated, "I can't say we've set a good precedent."37
Yoshida did not give a positive answer on this issue. When Ashida or Okada asked him for an answer, he would either
say it was a necessary clause or leave the response to Kumao Nishimura. Yoshida, unlike Nishimura, did not actively
defend this provision by providing examples from the North Atlantic Treaty or others.

6. The Stationing of US Forces in Japan
Members of the reformist opposition parties, the Right and Left Socialists, and the Communists were particularly
opposed to the stationing of US forces in Japan. They argued that the US presence was an infringement on Japan's nationalsovereignty and that it could lead Japan into war. Communist Itaru Yonehara compared one protocol with the Security
Treaty. It was the Japan-Manchukuo Protocol stipulating that Japanese troops be stationed in Manchukuo. He argued thatJapan would also become a US colony by mentioning that Manchukuo was, in effect, a Japanese colony.38 Masanosuke
Ikeda also stated that the public was mulling it over even if it was unavoidable.39
This issue was more of a policy issue than one of equality. In response to this most controversial issue in postwar
Japanese politics, Yoshida cited the US troops stationed in Western European countries as an example and stated that thecurrent era was one of joint defense.40 Ryuen Kusaba, Parliamentary Vice-Minister of Foreign Affairs, also refuted Ikeda
by giving specific numbers of divisions stationed in Western European countries.
The problem of equality related to the US forces in Japan was the lack of a prior consultation system. Shiro Kiuchi was
one of the politicians who discussed the issue of prior consultation during the Special Committee deliberations. Hisargument arose from the relationship between actions of US forces in Japan and security for Japan. He questioned whether
bases would be attacked when US forces in Japan were deployed to other areas without prior consultation with Japan. In
response to Kiuchi’s question, Nishimura explained that prior consultation would naturally occur given the treaty’s spirit.41
Yoshida let Nishimura’s answer stand and did not clarify his stance on the issue. However, the United States and Japanese
governments did not make arrangements for prior consultation. It was during the mid-1950s that discussions on priorconsultation began in earnest.42

7. Other Issues
Article II stipulated that "Japan will not grant, without the prior consent of the United States of America, any bases or
any rights, powers or authority whatsoever, in or relating to bases or the right of the garrison or of maneuver, or transit ofground, air or naval forces to any third power." Eki Sone pointed out in the House of Councilors that this provision, which
stipulated the prior consent of the US, represented the unequal relationship between the US and Japan.
There was a clear rebuttal to this criticism. Nishimura demonstrably countered that Article VIII of the North Atlantic
Treaty contained a similar provision: Article VIII stipulated, “Each Party declares that none of the international
engagements now in force between it and any other of the Parties or any third State is in conflict with the provisions of
this Treaty, and undertakes not to enter into any international engagement in conflict with this Treaty.”43 Nishimura himself,
however, recognized that this clause was one that the Japanese government did not like.44 Yoshida's reaction to this issue

677

is unknown since he was absent from the meeting.
Another problem was that the treaty’s duration was de facto indefinite. Article Ⅳ, which defines the term of validity ofthe treaty, stipulates the intent that the treaty will continue unless the US and Japanese governments agree otherwise. It
was not so much this provision that the Diet members took issue with, but rather the consequences of this provision. They
feared that the unequal provisions, as discussed in this paper, would be rendered permanent by the treaty's indeterminate
duration. Therefore, Hitoshi Ashida and Eki Sone were concerned that Article IV would fix the provision of US assistanceto Japan's internal security and the stationing of US forces, respectively.45
To these complaints, the government reiterated that the treaty was provisional. What were the conditions for revision of
the treaty if it is provisional? One was for Japan to rebuild enough military power to make a new treaty with the US on
equal terms. To aim to create an "equal" treaty with the US, Yasuhiro Nakasone pressed Yoshida to state his determinationfor "continuous and effective self-help and mutual aid," as described in the Vandenberg Resolution. Yoshida, however,maintained the principle that the Security Treaty was a treaty of equality, replying that it was not a one-sided treaty. In
response to Nakasone's insistence, Yoshida replied coldly, "I will consider your opinion."46

8. Conclusion
In response to criticisms from members of the National Diet that the Japan-US Security Treaty is "unequal," thegovernment asserted the treaty's equality in two ways: evoking the spirit of the Security Treaty and the precedents of othertreaties, notably the North Atlantic Treaty. Yoshida and his government strived to prove that the Security Treaty was anequal agreement in all its provisions.
Despite the logic used to counter arguments criticizing its inequality and the impossibility of gaining US concessions
on mutual defense, the Security Treaty was not valued as the "next best" treaty even by the ruling party members. One
reason, as many Diet members pointed out, is that the text of the treaty itself was problematic. But also important to thetreaty’s lack of acceptance was the attitude of Shigeru Yoshida. As discussed in this paper, Yoshida did not respond actively
to issues shared by the ruling and opposition parties; on the contrary, he recognized no significant controversy in the Diet.
He relied on Kumao Nishimura for most of his responses.
Yoshida also showed a dismissive attitude toward the Diet members in his memoirs. Yoshida stated, "A political treaty
like the Security Treaty is not qualified to be discussed together unless you read not only the words on paper but also theimplications between the lines."47 He recalled those days as follows:
There was considerable opposition to the security treaty. In the end, however, this was not asignificant issue, and the newspapers were only lively in reporting the discussions between
Hitoshi Ashida and me.48
Not only was there a gap between the rights and obligations of the US and Japan, but there also existed a perception gap
between the Prime Minister and Diet members, which further exacerbated the people's image of the 1951 Security Treaty.
Masataka Kosaka, a political scientist, in his classic biography of Prime Minister Yoshida assessed that public opinion had
turned away from Yoshida because he could not successfully accommodate the people's independent spirit.49 Yoshida did
not take the issue of Japan's dignity seriously, as Diet members insisted. Kumao Nishimura was not qualified to address

7
78

this issue because he was a bureaucrat.
In a brief speech on the day the Security Treaty was signed, Yoshida said, “That treaty gives Japan the key for re-entering
the community of nations as a sovereign equal.”50 However, as this paper has confirmed, the treaty, perceived as unequalby the reformist and conservative opposition parties and the ruling Liberal Party, could not be called the "key" to equality.
The Japanese had to wait until the 1960 revision to get this “key.”
References

・Primary sources
Foreign Relations of the United States: 1951, Asia and the Pacific, Volume VI, Part 1.
“Iwayuru Mitsuyaku Mondai ni Kansuru Yushikisha Iinkai Hokokusho,”: Ministry of Foreign Affairs of Japan, 2010.
accessed on July 20. https://www.mofa.go.jp/mofaj/gaiko/mitsuyaku/pdfs/hokoku_yushiki.pdf
Ministry of Foreign Affairs of Japan, Heiwa Joyaku no Teiketsu ni Kansuru Chosho Daiisatsu [Records Related to theconclusion of the Peace Treaty vol.1]: Diplomatic Archives of the Ministry of Foreign Affairs of Japan, 2001.
accessed on July 20, 2022,
https://www.mofa.go.jp/mofaj/annai/honsho/shiryo/archives/pdfs/heiwajouyaku1_16.pdf
Ministry of Foreign Affairs of Japan, Heiwa Joyaku no Teiketsu ni Kansuru Chosho Dainisatsu [vol.2]: Diplomatic
Archives of the Ministry of Foreign Affairs of Japan, 2001. accessed on July 20, 2022,
https://www.mofa.go.jp/mofaj/annai/honsho/shiryo/archives/pdfs/heiwajouyaku2_05.pdf
Ministry of Foreign Affairs of Japan, Heiwa Joyaku no Teiketsu ni Kansuru Chosho Daiyonsatsu [vol.4]: Diplomatic
Archives of the Ministry of Foreign Affairs of Japan, 2001. accessed on July 20, 2022,
https://www.mofa.go.jp/mofaj/annai/honsho/shiryo/archives/pdfs/heiwajouyaku4_08.pdf
National Diet Proceedings Search System, accessed on July 20, 2022, https://kokkai.ndl.go.jp

・Books and Papers
Fujita, Goro. “Ashida Shokan no Saikento [Reconsidering the Ashida Memorandum: The Relationship Between the Planof Emergency Stationing of US Forces and the Police Reform of 1947],” Kokusai Seiji [International Relations],
vol.207 (2022): pp.130-145.
Hara, Yoshihisa. Sengo Nihon to Kokusai Seiji: Chuokoron, 1988.
Hara, Yoshihisa. Nichibei Kankei no Kozu: NHK Books, 1991.
Igarashi, Takeshi. Sengo Nichibei Kankei no Keisei: Kodansha, 1995.
Ishii, Osamu. Reisen to Nichibei Kankei: Partnership no Keisei: Japan Times, 1989.
Kaji, Ichiro. “Anpo Joyaku no Joyaku Kigen ni Kansuru Kosatstu [A Study on the Duration Provision of the US-Japan
Security Treaty].” Handai Hogaku, vol.69, no.5 (2020): pp.55-82.
Kosaka, Masataka. Saisho Yoshida Shigeru,: Chuokoron, 1968.
Kumao, Nishimura. San Franshisuko Heiwa Joyaku: Nichibei Anpo Joyaku [ The San Francisco Peace Treaty: The JapanUS Security Treaty]: Chuokoron, 1999.
Kusunoki, Ayako. Yoshida Shigeru to Anzenhosho Seisaku no Keisei: Minerva Shobo, 2009.
Nakasone, Yasuhiro. Nakasone Yasuhiro ga Kataru Sengo Nihon Gaiko [Japanese Foreign Policy since 1945: Yasuhiro
Nakasone Oral History]: Shinchosha, 2012.
Sakamoto, Kazuya. Nichibei Domei no Kizuna: Yuhikaku, 2000; enlarged edition, 2020; English edition, The Bonds of the

879Japan-US Alliance: the Japan-US Security Treaty and the search for Mutuality: Japan Publishing Industry Foundation
for Culture, 2022.
Shimoda, Takezo. Sengo Nihon Gaiko no Sho-gen: Gyosei Mondai Kenkyujo, 1985.
Shinobu, Takashi. Nichibei Anpo to Jizen Kyogiseido [The US-Japan Security Treaty and Prior Consultation]: Kobundo,
2014.
Sugihara, Takane. Kokusaihogaku Kogi Dainihan [Lectures on International Law 2nd edition]: Yuhikaku, 2013.
Tanaka, Akihiko. Anzenhosho: Yomiuri Shimbun, 1997.
Toyoshita, Narahiko. Nichibei Anpo Joyaku no Seiritsu: Iwanami Shoten,1996.
Yajima, Akira. Ashida Hitoshi to Nihon Gaiko: Renmei Gaiko kara Nichibei Domei he: Yoshikawa-kobunkan, 2019.
Yoshida, Shigeru. Sekai to Nihon: Chuokoron, 1992.
Yoshida, Shigeru. Kaiso Junen 1-4 [A 10 Years Memoir vol.1-4]: Chuokoron, 1998.
Yoshida, Shingo. Nichibei Domei no Seidoka: The University of Nagoya Press, 2012.

・Periodicals
Asahi Shimbun
The New York Times

1

Asahi Shimbun, November 25, 1952, morning edition.
Asahi Shimbun, January 22, 1957, morning edition.
3
Kazuya Sakamoto, The Bonds of the Japan-US Alliance: the Japan-US Security Treaty and the search for Mutuality(Japan Publishing Industry Foundation for Culture, 2022) English edition; Kazuya Sakamoto, Nichibei Domei no Kizuna(Yuhikaku, 2000) Japanese edition; enlarged edition, 2020.
4
Takezo Shimoda, Sengo Nihon Gaiko no Sho-gen (Gyosei Mondai Kenkyujo, 1985) pp.28-29.
5Kumao Nishimura, San Franshisuko Heiwa Joyaku: Nichibei Anpo Joyaku [ The San Francisco Peace Treaty: The
Japan-US Security Treaty], (Chuokoron, 1999) pp. 52-58.
6
Ministry of Foreign Affairs of Japan, Heiwa Joyaku no Teiketsu ni Kansuru Chosho Dainisatsu [Records Related to theconclusion of the Peace Treaty vol.2], Diplomatic Archives of the Ministry of Foreign Affairs of Japan (2001) p.150.
accessed on July 20, 2022, https://www.mofa.go.jp/mofaj/annai/honsho/shiryo/archives/pdfs/heiwajouyaku2_05.pdf
7Ministry of Foreign Affairs of Japan, Heiwa Joyaku no Teiketsu ni Kansuru Chosho Daiisatsu [vol.1], Diplomatic
Archives of the Ministry of Foreign Affairs of Japan (2001) p.680. accessed on July 20, 2022,
https://www.mofa.go.jp/mofaj/annai/honsho/shiryo/archives/pdfs/heiwajouyaku1_16.pdf
8
Shigeru Yoshida, Kaiso Junen 2 [A 10 Years Memoir vol.2] (Chuokoron, 1998) pp.182-183.
9For Japan's and US stances on the Security Treaty and negotiations between the two countries, see Takeshi Igarashi,Sengo Nichibei Kankei no Keisei (Kodansha, 1995); Kazuya Sakamoto, Nichibei Domei no Kizuna, Ayako Kusunoki,
Yoshida Shigeru to Anzenhosho Seisaku no Keisei (Minerva Shobo, 2009).
10
Memorandum by Mr. Robert A. Fearey of the Office of Northeast Asian Affairs, Tokyo, 1951, Foreign Relations of theUnited States: 1951, Asia and the Pacific, Volume VI, Part 1, p.858.
11
Some studies of the Security Treaty criticize the treaty as unequal because of Japan‘s poor negotiation. See Narahiko
Toyoshita, Nichibei Anpo Joyaku no Seiritsu (Iwanami Shoten,1996).
12
Kumao Nishimura, San Franshisuko Heiwa Joyaku, pp.140-141.
13
In the mid-1950s, the US government, valuing Japan's political and economic stability, decided to treat Japan as anequal alliance partner and to revise the Security Treaty without Japan amending its Constitution and building sufficientdefense power. See Osamu Ishii, Reisen to Nichibei Kankei: Partnership no Keisei, (Japan Times 1989); Kazuya Sakamoto,
Nichibei Domei no Kizuna.
14
For the revision of the Security Treaty, see Yoshihisa Hara, Sengo Nihon to Kokusai Seiji, (Chuokoron, 1988); Yoshihisa
Hara, Nichibei Kankei no Kozu, (NHK Books, 1991); Kazuya Sakamoto, Nichibei Domei no Kizuna; Shingo Yoshida,
Nichibei Domei no Seidoka, (The University of Nagoya Press, 2012), Ichiro Kaji, “Anpo Joyaku no Joyaku Kigen ni
Kansuru Kosatstu [A Study on the Duration Provision of the US-Japan Security Treaty] ” Handai Hogaku, vol.69, no.52

980

(2020).
15
Hitoshi Ashida was a leading member of the National Democratic Party at that time. He became Prime Minister in 1947
but resigned the following year because of the Showa Denko Scandal. He remained, however, an opinion leader in Japanese
Politics on Constitutional and Rearmament issues. His Diary, Ashida Hitoshi Nikki vol.1-7 (Iwanami Shoten, 1986), is an
essential source for studying postwar Japanese politics. See the following study: Akira Yajima, Ashida Hitoshi to Nihon
Gaiko: Renmei Gaiko kara Nichibei Domei he (Yoshikawa-kobunkan, 2019).
16
Nakasone Yasuhiro was a member of the National Democratic Party at that time. He was a factional leader of the Liberal
Democratic Party for a long time. He was a Prime Minister from 1982 to 1987. He left numerous memoirs, for example,
Nakasone Yasuhiro ga Kataru Sengo Nihon Gaiko [Japanese Foreign Policy since 1945: Yasuhiro Nakasone Oral History],(Shinchosha, 2012).
17
Eiichi Nishimura was a member of the Right Socialist at that time. In 1967, he became Chairperson of the Democratic
Socialist Party, established in 1960.
18
Takeo Miki was Secretary General of the National Democratic Party in 1951. He became a factional leader of the Liberal
Democratic Party. In 1974, he became a Prime Minister. Materials related to him were collected and organized by his almamater, Meiji University, and made available online for a fee by Japan Digital Archives Center, J-DAC: “Miki Takeo Kankei
Bunsho [Takeo Miki Papers],” Japan Digital Archives Center, accessed on July 20, 2022, https://j-dac.jp/MIKI/index.html
19
Eki Sone was a member of the Right Socialist at that time. He became a Deputy Chief Cabinet Secretary in the Katayama
Cabinet in 1947. Later, Sone became the first Secretary General of the Democratic Socialist Party. Kensei Shiryo Shitsu[Modern Japanese Political History Materials Room] of the National Diet Library has “Eki Sone Papers,” a collection ofmaterials related to him, and makes us available to the public.
20
Other leading members: Masanosuke Ikeda, the Liberal Party; Naoyoshi Kitazawa, the Liberal Party, who served as asecretary to Prime Minister Yoshida in 1945; Shiro Kiuchi, a member of the National Democratic Party; Hisao Kuroda,
Chairperson of the Laborers and Farmers Party; Goro Morishima, a member of the Liberal Party, who was a diplomat until
1946; Hanji Ogawa, a member of the National Democratic Party; Soji Okada, a member of the Left Socialist; Itaru
Yonehara, a member of Japanese Communist Party.
21
Minutes of the 3rd The Peace Treaty of San Francisco and Japan-US Security Treaty Special Committee of the Houseof Representatives, October 18, 1951, accessed on July 20, 2022, https://kokkai.ndl.go.jp/txt/101205185X00319511018
22
Minutes of the 5th The Peace Treaty of San Francisco and Japan-US Security Treaty Special Committee of the Houseof Councilors, October 25, 1951, accessed on July 20, 2022, https://kokkai.ndl.go.jp/txt/101215185X00519511029
23
Minutes of the 9th The Peace Treaty of San Francisco and Japan-US Security Treaty Special Committee of the Houseof Representatives, October 25, 1951, accessed on July 20, 2022, https://kokkai.ndl.go.jp/txt/101205185X00919511025
24
Minutes of the 3rd The Peace Treaty of San Francisco and Japan-US Security Treaty Special Committee of the Houseof Representatives.
25
Shigeru Yoshida, Kaiso Junen 3, p.145.
26
Ayako Kusunoki, Yoshida Shigeru to Anzenhosho Seisaku no Keisei, pp.228-232.
27
Shigeru Yoshida, Kaiso Junen 3, p.145.
28
Kumao Nishimura, San Franshisuko Heiwa Joyaku, p.49.
29
Minutes of the 3rd The Peace Treaty of San Francisco and Japan-US Security Treaty Special Committee of the Houseof Representatives.
30
Shigeru Yoshida, Sekai to Nihon, (Chuokoron, 1992) p.163.
31
Goro Fujita, “Ashida Shokan no Saikento [Reconsidering the Ashida Memorandum: The Relationship Between thePlan of Emergency Stationing of US Forces and the Police Reform of 1947],” Kokusai Seiji [International Relations],
vol.207 (2022), pp.138-140.
32
Ministry of Foreign Affairs of Japan, Heiwa Joyaku no Teiketsu ni Kansuru Chosho Dainisatsu [vol.2], p.213.
33
Minutes of the 3rd The Peace Treaty of San Francisco and Japan-US Security Treaty Special Committee of the Houseof Representatives. This Ashida's question at the committee is known as the Yoshida-Ashida debate. See Akihiko Tanaka,
Anzenhosho, (Yomiuri Shimbun, 1997), pp.93-97.
34
Minutes of the 9th The Peace Treaty of San Francisco and Japan-US Security Treaty Special Committee of the Houseof Representatives.
35
Minutes of the 7th The Peace Treaty of San Francisco and Japan-US Security Treaty Special Committee of the Houseof Councilors, October 31, 1951, accessed on July 20, 2022, https://kokkai.ndl.go.jp/txt/101215185X00719511031

10
81

36

“Acheson’s Replies at Press Conference on Atlantic Pact,” The New York Times, (March 19, 1949), accessed on July20, 2022, https://timesmachine.nytimes.com/timesmachine/1949/03/19/issue.html
37
Minutes of the 7th The Peace Treaty of San Francisco and Japan-US Security Treaty Special Committee of the Houseof Councilors.
38
Minutes of the 4th The Peace Treaty of San Francisco and Japan-US Security Treaty Special Committee of the Houseof Representatives, October 19, 1951, accessed on July 20, 2022, https://kokkai.ndl.go.jp/txt/101205185X00419511019
39
Minutes of the 3rd The Peace Treaty of San Francisco and Japan-US Security Treaty Special Committee of the Houseof Representatives.
40
Shigeru Yoshida, Kaiso Junen 4, pp.41-44.
41
Minutes of the 5th The Peace Treaty of San Francisco and Japan-US Security Treaty Special Committee of the Houseof Councilors.
42
See the following for studies of the issues of prior consultation and its negotiations between Japan and the US: Kazuya
Sakamoto, Nichinei Domei no Kizuna; “Iwayuru Mitsuyaku Mondai ni Kansuru Yushikisha Iinkai Hokokusho,” Ministryof
Foreign
AffairsofJapan(2010),
accessed
on
July
20,
https://www.mofa.go.jp/mofaj/gaiko/mitsuyaku/pdfs/hokoku_yushiki.pdf; Takashi Shinobu,Nichibei Anpo to Jizen
Kyogiseido [The US-Japan Security Treaty and Prior Consultation], (Kobundo.2014).
43
Minutes of the 19th The Peace Treaty of San Francisco and Japan-US Security Treaty Special Committee of the Houseof Councilors, accessed on July 20, https://kokkai.ndl.go.jp/txt/101215185X01919511115
44
Kumao Nishimura, San Franshisuko Heiwa Joyaku, p.56.
45
Minutes of the 3rd The Peace Treaty of San Francisco and Japan-US Security Treaty Special Committee of the Houseof Representatives; Minutes of the 5th The Peace Treaty of San Francisco and Japan-US Security Treaty Special Committeeof the House of Councilors.
46
Minutes of the 8th The Peace Treaty of San Francisco and Japan-US Security Treaty Special Committee of the Houseof Representatives, October 24, 1951, accessed on July 20, 2022, https://kokkai.ndl.go.jp/txt/101205185X00819511024
47
Shigeru Yoshida, Sekai to Nihon, p.163.
48
Shigeru Yoshida, Kaiso Junen 3, p.65.
49
Masataka Kosaka, Saisho Yoshida Shigeru, (Chuokoron 1968), pp.74-89.
50
Ministry of Foreign Affairs of Japan, Heiwa Joyaku no Teiketsu ni Kansuru Chosho Daiyonsatsu [vol.4], Diplomatic
Archives of the Ministry of Foreign Affairs of Japan (2001): pp.368-369, accessed on July 20, 2022,
https://www.mofa.go.jp/mofaj/annai/honsho/shiryo/archives/pdfs/heiwajouyaku4_08.pdf

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