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USINDOPACOM J06/SJA TACAID SERIES

TOPIC: THE PRC’S MODIFICATION OF CIVILIAN

FLIGHT ROUTES IN THE TAIWAN STRAIT 

 BOTTOM LINE

 On 30 January 2024, the People’s Republic of China (PRC) announced unilateral changes to civilian flight routes in 

the Taiwan Strait in breach of prior commitments to Taiwan authorities and absent coordination with concerned 

parties as required by International Civil Aviation Organization (ICAO) guidance. 

 These changes provide the PRC with an asymmetric advantage by creating new dilemmas for Taiwan authorities 

responsible for managing complex civil air traffic corridors and air defenses, respectively. 

 Issues related to civil aviation and safety in the Taiwan Strait should be addressed in dialogue between both sides. 

 Despite administering critical airspace, Taiwan authorities are excluded from ICAO and lack the ability to 

coordinate safety measures and mediate disagreements through ICAO’s procedures. 

 All of international civil aviation’s most important stakeholders, including Taiwan, should have the opportunity to 

participate meaningfully in ICAO’s work. 

WHY THIS MATTERS

 Taiwan’s exclusion from ICAO may lead to unforeseen safety risks for aircraft operating in the Taiwan Strait. 

 The international nature of civil aviation in the Taiwan Strait means that the international community has an 

interest in ensuring Taiwan authorities can deliver air navigation services and aviation safety.

 The PRC’s breach of prior commitments to Taiwan authorities and failure to coordinate changes as required by 

ICAO guidance undermines the rules-based international order. If left unchecked, the PRC could be emboldened 

to take further coercive action against Taiwan and others in violation of international law, rules, and norms. 

 Taiwan’s Civil Aviation Administration (CAA) operates largely on its own without the benefit of ICAO’s expertise 

and institutional mechanisms for resolving disputes and coordinating safety and technical interoperability. 

 Taiwan authorities face an increasingly difficult challenge in distinguishing military and civilian flights in the 

Taiwan Strait. This potential for ambiguity increases risk of miscalculation and unintended consequences. 

 Expanded civilian flight routes afford the People’s Liberation Army (PLA) increased opportunity to disguise 

military flights behind a civil façade in a manner that could threaten peace and stability and reduce Taiwan’s 

ability to identify, warn, and defend against attack. Concern that the PLA will mask military flights in civilian fight 

routes is grounded in the PRC’s propensity to blur civil-military distinctions in other domains.

 If the Taiwan air force is compelled to respond to an increasing number of potential threats, the readiness of 

Taiwan’s air defenses could degrade to the detriment of Taiwan’s self-defense capability. 

DETAILED DISCUSSION

 In 2015, the PRC unilaterally established civilian flight routes M503, W121, W122, and W123.iSoon after, 

following objections from Taiwan due to aviation safety concerns,

ii the PRC agreed to move M503 six nautical 

miles (NM) west; limit traffic to only southbound non-military flights; direct aircraft to veer west in emergencies;

and not make changes to routes or implement W121, W122, and W123 without consulting Taiwan’s CAA.

iii

1. Background 
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 The PRC breached the 2015 agreement in January 2018 by launching northbound flights in M503 and westbound 

flights in W121, W122 and W123 without consulting Taiwan authorities.

iv

 ICAO failed to acknowledge a subsequent request by Taiwan authorities 

for mediation over M503.v

 Again, without consulting Taiwan authorities, the PRC broke the 2015 

agreement on 30 January 2024 by moving M503 six NM east and 

launching eastbound flights on W121, W122, and W123.vi

 M503 now hugs the eastern edge of the Shanghai Flight Information 

Region (FIR) and is only 4.2 NM from the Taipei FIR and the Taiwan 

Strait centerline (also known as the median line).

vii

 A FIR is an area in which ICAO designates a country or region as responsible for coordinating civil air traffic, 

information, and alert services for aircraft in flight. Taiwan’s CAA administers the Taipei FIR.viii

 The introduction of bidirectional air traffic and higher volumes of aircraft on the Taipei FIR’s immediate periphery 

could test the Taiwan CAA’s capability and capacity to ensure safety of flight in the Taiwan Strait. 

 The Taipei FIR overlaps substantially with Taiwan’s Air Defense Identification Zone (ADIZ) – an area used by 

Taiwan’s defense forces to assist in aircraft identification 

and threat warning.ix

 The western boundary of the Taipei FIR traverses the 

Taiwan Strait centerline.

x

 

 The centerline does not have a legal status, but for 

decades following its establishment in 1955, both the PRC

and Taiwan managed risk of escalation by respecting the 

centerline and generally avoiding centerline crossings.

 The PRC’s military aircraft now regularly cross the centerline to wear down Taiwan’s air defenses, demonstrate 

superior air power, and advance political objectives.xi

 To the east of the centerline in the Taipei FIR, as depicted in the inset graphics, the Taiwan air force maintains

patrol areas to meet its responsibilities in the ADIZ related to threat identification and warning.

 Aircraft entering these areas are intercepted for 

identification by fighters scrambled from Taiwan. 

 M503’s eastward shift significantly reduces Taiwan’s air 

defense buffer.

xii

 M503’s extension routes also raise concerns. W122 is only 

2.8 NM from Matsu, and W123 is only 1.1 NM from 

Kinmen.

xiii Matsu and Kinmen are outer islands controlled 

by Taiwan, but claimed by the PRC. 

 In addition to a greater volume of air traffic in proximity to 

Matsu and Kinmen, the activation of eastbound flights in 

W121, W122, and W123 means these routes are now open 

to Taiwan-facing aircraft – i.e., a potential threat profile. 

 Moreover, Taiwan authorities operate commercial flight 

routes (W2, W6, W8) to Matsu and Kinmen that intersect 

with M503 and must now be de-conflicted with 

bidirectional traffic in M503.

 A spokesperson for the PRC said that modifications to flight 

routes in the Taiwan Strait were necessary to alleviate 

congestion and dismissed concerns as “completely unwarranted.”

xiv He also claimed that Taiwan is an integral 

part of the PRC and therefore consultation is not required for such “internal matters.”

xv

Source: CSIS AMTI

Source: CSIS AMTI
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 Taiwan’s Mainland Affairs Council said that the PRC was ignoring safety, “disrespecting” Taiwan’s responsibility to 

manage safety of flight in international airspace, and trying to

“package civil aviation” to “change the status quo in the strait.”

xvi

 Taiwan authorities have demanded that the PRC reverse its 

actions and engage in dialogue regarding any changes to flight 

routes in the Taiwan Strait.xvii

 Many international observers contend that the PRC’s actions 

deliberately coincided with Taiwan’s elections and were driven

by geostrategic ambitions rather than aviation safety.xviii

 A spokesperson for the U.S. State Department said that,

“[i]ssues related to civil aviation and safety in the Taiwan Strait 

should be decided through dialogue between both sides.”

xix

 Also of note, members of Canada’s parliament urged ICAO in an 

open letter to pay close attention to the PRC’s unilateral move to modify its M503 flight path, calling it a 

“significant safety issue” in the Taiwan Strait.xx

 ICAO is a technical agency of the United Nations (UN) created in 1944 by the Convention on International Civil 

Aviation (“Chicago Convention”). ICAO’s broad mission includes ensuring peaceful and safe global aviation.

xxi

 ICAO established the Taipei FIR at its 18th council session in 1971.xxii

 Later in 1971, the PRC became the sole representative of China to the UN, but Taiwan’s responsibility to 

administer the Taipei FIR in accordance with ICAO guidelines endured. That responsibility continues to this day. 

 The Taipei FIR is part of ICAO’s network of regions and Taiwan’s CAA is the “sole entity overseeing, and is 

responsible for safe air traffic management throughout” the Taipei FIR.

xxiii

 Although planning flight routes that exist entirely within one FIR generally falls to the government administering 

that FIR, Section 4.2.6 of ICAO’s Air Traffic Services Planning Manual stipulates that establishing and changing 

flight routes should be done “only after they have been coordinated with all parties concerned.”xxiv

 The manual does not limit “all parties concerned” to only ICAO 

contracting states. As such, “all parties concerned” may 

reasonably include Taiwan authorities as well as contracting 

states concerned by aviation safety in the Taiwan Strait.

 For the reasons described in this TACAID (proximity of M503 to 

the Taipei FIR, intersection with Taiwan-controlled flight 

routes, proximity to Taiwan-controlled islands, the CAA’s 

responsibilities under ICAO, prior commitment by the PRC to 

coordinate, etc.), Taiwan authorities should have been 

consulted in accordance with ICAO guidelines to ensure 

continued safety of civil aviation in the Taiwan Strait.

 However, the PRC has refused to coordinate with Taiwan 

authorities and instead uses its influence to exclude Taiwan 

from ICAO, even in an observer status capacity.xxv

 From 2015-2021, Fang Liu (a PRC national) served as Secretary 

General of ICAO.xxvi During this period, a Taiwan delegation to 

ICAO was forced out; Taiwan authorities were excluded from 

meetings and denied safety-related information; and ICAO blocked Twitter accounts that criticized Fang Liu’s 

actions in relation to Taiwan.

xxvii

 Taiwan remains excluded from ICAO and relies on partners for information on changes to ICAO’s policies.xxviii

2. The Role of ICAO 

Source: CSIS AMTI
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 Nevertheless, Taiwan’s CAA continues to meet ICAO’s Standards and Recommended Practicesxxix and is 

developing a next-generation air traffic control automation system to enable the Taipei FIR to remain 

interoperable through 2032 under ICAO’s Global Air Navigation Planxxx and Aviation System Block Upgrades.

xxxi

 The PRC’s efforts to exclude Taiwan authorities from ICAO are not purely a matter of cross-strait relations. 

 Rather, the international nature of civil aviation in the Taiwan Strait means that the international community has 

an interest in ensuring Taiwan authorities can deliver air navigation services and aviation safety. Of note: 

o Taiwan’s CAA manages air traffic and services for an international airport that ranked the world’s ninth

largest by cargo volumexxxii and tenth largest by international passengers in 2019.

xxxiii

o The CAA administers 18 international routesxxxiv in a FIR that includes over 176,000 square NM (much of 

which is international airspace) and provides air traffic control to well over 1.3 million flights annually.

xxxv

 Despite international interest in safety of flight and Taiwan’s responsibilities to the international community 

under ICAO, Taiwan authorities have no formal avenue for lodging concerns through ICAO. 

 Likewise, as Taiwan is not an ICAO member, it likely cannot leverage dispute resolution procedures codified in 

Articles 84-88 of the Chicago Convention, which grant ICAO authority to resolve “disagreement between two or 

more contracting States relating to the interpretation or application of this Convention and its Annexes.”xxxvi

 However, ICAO member states (including the United States) are not prohibited from using ICAO’s dispute 

resolution procedures to register disagreement and challenge the PRC’s failure to coordinate changes that bear 

on the international community’s interest in civil aviation safety in the Taiwan Strait. 

 ICAO member states can also continue to advocate for Taiwan’s participation in ICAO, consistent with the 

position taken by the U.S. Department of Transportation. 

 At ICAO’s 2022 Assembly, U.S. Secretary of Transportation Pete Buttigieg said, “We believe that all of 

international civil aviation’s important stakeholders – particularly those who administer critical airspace, like 

Taiwan – should have the opportunity to participate meaningfully in ICAO’s work.”xxxvii

 In recent years, Taiwan’s diplomatic partners including Saint Lucia, Guatemala and Tuvalu, as well as other ICAO 

members such as France, Japan and New Zealand have publicly endorsed Taiwan’s participation in ICAO.

xxxviii

 The changes made by the PRC give rise to new dilemmas for Taiwan authorities charged with managing complex

civil air traffic corridors and air defenses, respectively. 

 The PLA now has new pathways to disguise military activities behind a civil facade, which provides a potential 

asymmetric advantage in its all-domain 

pressure campaign against Taiwan.

 The possibility of the PLA masking 

military flights in civil fight routes could 

threaten peace and stability in the 

Taiwan Strait and reduce Taiwan’s 

ability to identify, warn, and defend

against attacks. 

 Such action would be consistent with the 

PRC’s propensity to blur civil-military 

distinctions in other domains – e.g., the 

integration of commercial ferries into 

amphibious invasion training and the 

ubiquitous use of fishing vessels in 

support of military objectives. 

 The challenge to Taiwan’s air defenses is 

compounded by the likelihood of 

3. Implications of the PRC’s Actions
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increased air traffic in the Taiwan Strait (including routes adjacent to Taiwan-controlled islands), bidirectional 

flights near Taiwan’s air defense buffers, and Taiwan-facing flights emanating from the PRC mainland. 

 With M503 flights regularly operating just a few miles west of the centerline, Taiwan air force alert teams could 

be hard-pressed to distinguish an intentional centerline crossing by the PLA from a civilian passenger plane 

veering slightly off-course.

 This ambiguity not only erodes the centerline’s value as a normative constraint on escalation, but also increases 

risk of miscalculation and unintended consequences. 

 If the Taiwan air force is compelled to respond to an increasing number of potential threats, the readiness of 

Taiwan’s air defenses could degrade to the to the detriment of Taiwan’s self-defense capability. 

 Taiwan’s CAA must now hastily adjust plans to ensure aircraft in the Taipei FIR are cognizant of the PRC’s changes 

to flight routes in the Taiwan Strait and sufficiently equipped to avert danger and mitigate safety concerns.xxxix 

 Absent representation at ICAO, Taiwan’s CAA operates largely on its own without the benefit of ICAO’s expertise 

and institutional mechanisms for coordinating safety measures and technical interoperability. 

 As a result, there may be unforeseen safety risks for civil aircraft operating in the Taiwan Strait. 

 The PRC’s breach of its 2015 commitments regarding flight routes in the Taiwan Strait and its failure to coordinate 

with concerned parties in accordance with ICAO guidance epitomize broader efforts to undermine the rulesbased international order – i.e., the system of laws, agreements, principles, and institutions that the world came 

together to build after two world wars to manage relations between states, to prevent conflict, and to uphold the 

rights of all people.xl

PROPOSED COUNTER-LAWFARE APPROACH

**This section offers suggested language for incorporation into communication strategies**

 The PRC’s unilateral changes to civilian flight routes in the Taiwan Strait breached prior commitments to Taiwan 

authorities and did not comply with ICAO guidance. 

 Despite administering critical airspace, Taiwan authorities are excluded from ICAO and lack the ability to 

coordinate safety measures and mediate disagreements through ICAO’s procedures. 

 Taiwan’s exclusion from ICAO may lead to unforeseen safety risks for aircraft operating in the Taiwan Strait. 

 All of international civil aviation’s most important stakeholders, including Taiwan, should have the opportunity 

to participate meaningfully in ICAO’s work. 

 Issues related to civil aviation and safety in the Taiwan Strait should be addressed in dialogue between both sides.

 The PRC’s breach of prior commitments to Taiwan authorities and failure to coordinate as required by ICAO 

guidance undermines the rules-based international order. If left unchecked, the PRC could be emboldened to 

take further coercive action against Taiwan and others in violation of international law, rules, and norms.

 The PRC’s expansion of civilian flight routes in the Taiwan Strait provide increased opportunity for the PLA to 

disguise military flights behind a civil aviation façade in a manner that could threaten cross-strait peace and 

stability and reduce Taiwan’s ability to identify, warn, and defend against attack. 

 With more PRC-controlled aircraft operating near the Taiwan Strait centerline, Taiwan authorities will face an 

increasingly difficult challenge in distinguishing intentional centerline crossings from passenger planes that veer 

slightly off-course – this ambiguity not only erodes the centerline’s value as a normative constraint on 

escalation, but also increases risk of miscalculation and unintended consequences

 Consistent with the United States’ longstanding one China policy, which is guided by the Taiwan Relations Act, the 

three U.S.-China Joint Communiques, and the Six Assurances, USINDOPACOM opposes unilateral changes to the status 

quo from either side, including forms of coercion that jeopardize Taiwan’ssecurity. 

 USINDOPACOM supports and defends a free and open Indo-Pacific and opposes any attempt to use coercion or 

force to settle disputes. USINDOPACOM shares these deep and abiding interests with allied and partnered forces 

who champion a free and open Indo-Pacific supported by the rules-based international order.
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i

J. Chung, CAA Says Consensus on PRC’s New Flight Routes, Taipei Times, Mar. 3, 2015, 

https://www.taipeitimes.com/News/front/archives/2015/03/03/2003612638. 

ii See S. Shan, CAA, Military Reject China Flight Routes, Taipei Times, Jan. 14, 2015, 

https://www.taipeitimes.com/News/front/archives/2015/01/14/2003609190 (“M503 falls within the Shanghai FIR, which is very 

close to the Taipei FIR and has to accommodate many international flights.”).

iii S. Shan, Officials Protest Risky Flight Path Change, Taipei Times, Feb. 1, 2024, https://www.pressreader.com/taiwan/taipeitimes/20240201/page/1. Taiwan’s summary of the agreement (大陸委員會): 

mac.gov.tw/en/News_Content.aspx?n=14271038DDC4104F&sms=E828F60C4AFBAF90&s=A0E0B1BF38389FD0. The PRC’s 

perspective (中华人民共和国驻美利坚合众国大使馆): http://us.china-embassy.gov.cn › t20150306_4914947. See also

International Civil Aviation Organization, the First Meeting of South China Sea Major Traffic Flow Review Group (SCS-MTFRG/1), 

Kuala Lumpur, Malaysia, 19-20 January 2015, Agenda Item 5: Discuss strategy for development/realignment of routes and 

optimization of FLAS/FLOS and set implementation targets and timelines. IMPLEMENTATION OF ROUTE M503 ALONG THE 

SOUTHEAST COAST OF CHINA).

iv S. Shan, PRC Aviation Routes Protested, Taipei Times, Jan. 5, 2018,

https://www.taipeitimes.com/News/front/archives/2018/01/05/2003685206. 

v D. DeAeth, UN Aviation Org. Stays Silent on Taiwan’s M503 Dispute with China, Taiwan News, Jan. 9, 2018, 

https://www.taiwannews.com.tw/en/news/3337250.

vi See Taiwan Today, MOFA Condemns China’s Unilateral Adjustment of Flight Routes, Demands Prompt Negotiations, Feb. 1, 2024, 

https://taiwantoday.tw/news.php?unit=2,6,10,15,18&post=248110. 

vii A. Brar, China's Sudden Flight Route Change Puts Taiwan Under Pressure, Newsweek, Feb. 2, 2024, 

https://www.newsweek.com/china-taiwan-flight-pressure-m503-new-shanghai-xiamen-1866311.

viii See Civil Aviation Administration, Air Traffic Services, https://www.caa.gov.tw/article.aspx?a=228&lang=2 (last accessed Mar. 4, 

2024).

ix See Asia Maritime Transparency Initiative, A Primer on M503 and Civil Aviation in Asia, Mar. 14, 2018, https://amti.csis.org/primerm503-civil-aviation-asia/.

x

Id.

xi See, e.g., Center for Preventive Action, Confrontation Over Taiwan, Feb. 9, 2024, https://www.cfr.org/global-conflicttracker/conflict/confrontation-over-taiwan (“Chinese military aircraft crossed the median line over three hundred times during [a 

four-day military] demonstration and continue to cross it on a near-daily basis, effectively erasing the status quo.”).

xii See B. Blanchard, Taiwan Angered at 'Unilateral' China Change to Taiwan Strait Flight Path, Reuters, Jan. 31, 2024, 

https://www.reuters.com/world/asia-pacific/taiwan-angered-unilateral-china-change-taiwan-strait-flight-path-2024-01-31/ 

(emphasizing that “the new route would be about 7 km (4.3 miles) from the median line, which would squeeze the pre-warning and 

reaction time for Taiwan's air defenses”).

xiii S. Shan, supra note iii.

xiv A. Brar, supra note vii. 

xv Id. 

xvi B. Blanchard, Taiwan Angered at ‘Unilateral’ China Change to Taiwan Strait Flight Path, Reuters, Jan. 31, 2024, 

https://www.reuters.com/world/asia-pacific/taiwan-angered-unilateral-china-change-taiwan-strait-flight-path-2024-01-31/. 

xvii See Indo-Pacific Forum, Taiwan Blasts PRC’s ‘Irresponsible’ Civilian Aircraft Routes Over Strait, Feb. 18, 2024, 

https://ipdefenseforum.com/2024/02/taiwan-blasts-prcs-irresponsible-civilian-aircraft-routes-over-strait/. 

xviii See, e.g., A. Laliberte, Time to End the Exclusion of Taiwan from the International Civil Aviation Organization, Centre of 

International Policy Studies, Mar. 3, 2020, https://www.cips-cepi.ca/2020/03/03/time-to-end-the-exclusion-of-taiwan-from-theinternational-civil-aviation-organization/ (raising questions about the reliability of the ICAO for information on air travel and its 

restriction to Taiwan citizens during COVID-19); C. Tiunn, The Dangers of Excluding Taiwan from International Organizations, Council 

on Foreign Relations, Sept. 22, 2023, https://www.cfr.org/blog/dangers-excluding-taiwan-international-organizations (“Because 

Taiwan does not have communications with ICAO, the Taiwanese Civil Aeronautics Administration had to quickly reach out to the

Japanese and Philippine Flight Information Regions (FIRs) and ask them to direct flights to safety when the [PRC’s] military exercises 

[in the waters and airspace around Taiwan in 2022] began.”). 

xix C. Chin-yeh & E. Yang, U.S. State Department Critical of China's Modified M503 Flight Path, Focus Taiwan, Feb. 2, 2024, 

https://focustaiwan.tw/politics/202402020005.

 
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xx See H. Li-yu & F. Huang, Canada Lawmakers Urge ICAO to Look at China's Revised M503 Flight Path, Focus Taiwan, Feb. 10, 2024, 

https://focustaiwan.tw/politics/202402100008. 

xxi See International Civil Aviation Organization, Who We Are, 

https://www.icao.int/secretariat/CapacityDevelopmentImplementation/Pages/Whoweare.aspx (last accessed Mar. 4, 2024). 

xxii See Civil Aviation Administration, supra note viii. 

xxiii A. Lampert & D. Shepardson, Buttigieg Backs Taiwan Participation in UN Civil Aviation Body, Reuters, Sept. 27, 2022, 

https://www.reuters.com/world/buttigieg-backs-taiwan-participation-un-civil-aviation-body-2022-09-27/. 

xxiv International Civil Aviation Organization, Air Traffic Services Planning Manual, First Edition, Section 4.2.6 (1984).

xxvSee American Legislative Exchange Council, Resolution Supporting Taiwan’s Meaningful Participation in International 

Organizations Including the International Civil Aviation Organization (ICAO) and Interpol, Dec. 23, 2022, https://alec.org/modelpolicy/resolution-supporting-taiwans-meaningful-participation-in-international-organizations-including-the-international-civilaviation-organization-icao-and-interpol/ (“Taiwan’s efforts for full membership and even participation [in ICAO is] routinely blocked 

by the People’s Republic of China.”).

xxvi International Civil Aviation Organization, Former Secretaries General, 

https://www.icao.int/secretariat/SecretaryGeneral/Pages/former-secretaries-general-all.aspx (last accessed Mar. 1, 2024).

xxvii International Civil Aviation Organization, Strategic Planning Coordination and Partnerships’ Office – SPCP, 

https://www.icao.int/secretariat/SecretaryGeneral/SPCP/Pages/default.aspx (last accessed Mar. 1, 2024). See also, B. AllenEbrahimian, UN Aviation Agency Blocks Critics of Taiwan Policy on Twitter, Axios, Jan. 27, 2020, 

https://www.axios.com/2020/01/27/as-virus-spreads-un-agency-blocks-critics-taiwan-policy-on-twitter; M. Ortagus, ICAO’s 

Outrageous Practice of Blocking Twitter Users Who Reference Taiwan, Feb. 1, 2020, https://2017-2021.state.gov/icaos-outrageouspractice-of-blocking-twitter-users-who-reference-taiwan/.

xxviii C. Tiunn, supra note xviii. 

xxix International Civil Aviation Organization, SARPs - Standards and Recommended Practices, 2016, 

icao.int/safety/safetymanagement/pages/sarps.aspx.

xxx International Civil Aviation Organization, Global Air Navigation Plan (GANP), icao.int/airnavigation/pages/ganp-resources.aspx

(last accessed Mar. 1, 2024).

xxxi International Civil Aviation Organization, Aviation System Block Upgrade (ASBU) Implementation Monitoring Report, 2022, 

https://www.icao.int/EURNAT/Pages/Aviation-System-Block-Upgrade-(ASBU)-Implementation-Monitoring-Report-.aspx. 

xxxii Airports Council International, The Top 10 Busiest Airports in the World Revealed, Airports Council International, Apr. 11, 2022,

https://aci.aero/2022/04/11/the-top-10-busiest-airports-in-the-world-revealed/.

xxxiii W. Shu-fen, L. Hsin-Yin, Taiwan's Taoyuan Airport Reports Record-High Transit Volume Last Year: Operator, Focus Taiwan, Feb. 9, 

2024, https://focustaiwan.tw/society/202402090003.

xxxiv J. Lin, et.al, Review of Taiwan’s Aviation Safety Management, Flight Safety Foundation, Oct. 17, 2019, 

https://flightsafety.org/asw-article/review-of-taiwans-aviation-safety-management/. 

xxxv See W. Shu-fen, supra note xxxiii. 

xxxvi Chicago Convention on International Civil Aviation (1944), Ch. XVIII, Article 84.

xxxvii A. Lampert & D. Shepardson, Buttigieg Backs Taiwan Participation in UN Civil Aviation, Reuters, Sept. 27, 2022, 

https://www.reuters.com/world/buttigieg-backs-taiwan-participation-un-civil-aviation-body-2022-09-27/. 

xxxviii See Y. Cheng-yu & J. Chin, Taiwan Calls for ICAO Inclusion as Congress Ends, Taipei Times, Oct. 9, 2022, 

https://www.taipeitimes.com/News/taiwan/archives/2022/10/09/2003786716. 

xxxix See L. Y-wen, et.al., Flight Path Adjustments Shows China Rejects Strait Median Line: Experts, Focus Taiwan, Jan. 31, 2024,

https://focustaiwan.tw/cross-strait/202401310009. 

xl See generally J. deLisle, U.S.-Japan-Dialogue: Deterrence, Defense, and Trilateral Cooperation, Foreign Policy Research Institute, 

Dec. 12, 2022, https://www.fpri.org/article/2022/12/u-s-japan-taiwan-dialogue-deterrence-defense-and-trilateral-cooperation/

(“Beijing has increased pressure on Taiwan, expressed growing impatience with the status quo, and has been developing the means 

for invading or blockading Taiwan. . . China’s control of Taiwan or other nearby areas would accelerate its ability to undermine and 

rewrite international norms and rules.”).