The Black Sea's Receding Safe Waters

Welcome back, and thanks for being here.

Another week, another newsletter, and another slight shift in what we look at.

The goal is to take some time for a little inspection not only of hardware and companies defining defense and dual-use, but also the wider strategic picture in all its forms.

In this case, I wanted to try focusing on a region made critical by ongoing conflict.

The Black Sea.

This is a potentially massive topic if we wanted to cover it in full (if that’s even possible). So we’ll start by focusing on recent events, and the particular challenges and questions it raises.

Onward.

Around 3 a.m. on Oct. 6, the Alfa Watan was about 70 nautical miles off the Bulgarian town of Byala, heading for the Romanian port of Sulina.

Air and sea drones hit her and a second ship, the Able, which was carrying wheat. The Able's 18 crew were rescued. The Alfa Watan sank. Rescuers found overturned life rafts, but no sailors.

It was the first recorded strike on shipping inside Bulgaria's exclusive economic zone (EEZ). It didn't stay unique for long.

On Oct. 13, drones hit two more ships off Bulgaria. The HS Dignity, bound for the Romanian river port of Braila, sank 17 nautical miles off Krapets, with 11 crew reported missing. The Ukrainian-owned Chelsea 3 was hit by three drones 18 miles off Byala. All 15 of its crew survived.

In a week, the strikes moved from 70 miles offshore to 17.

The western Black Sea is Ukraine's main route for seaborne exports.

After Russia quit the U.N.- and Turkish-brokered grain deal in July 2023, Ukraine opened its own shipping corridor. By the end of July 2026 it had carried about 209 million metric tons of cargo, including 124 million tons of grain.

Those ships hug the coast, sailing through Romanian, Bulgarian and Turkish territorial waters. The Carnegie Endowment estimates about 90% of Ukrainian farm exports depend on those routes.

It isn't only Ukraine's trade. Two of the four ships hit off Bulgaria were heading for Romanian ports on the Danube.

Under the law of the sea, a coastal state's sovereignty runs 12 nautical miles out.

Beyond that, out to 200 miles, is the EEZ. The coastal state controls resources there, like fish and gas, but otherwise it’s open sea. Legally, a ship there is the responsibility of the country whose flag it flies.

That often has little to do with who owns or runs it. Many cargo ships register in small countries with low fees and light regulation, a practice known as flying a flag of convenience. The HS Dignity, sunk 17 miles off Bulgaria, flew the flag of Guinea-Bissau.

So in law, the strike 17 miles out was an attack on a ship from West Africa. A few miles closer, it would have been an attack inside a NATO member’s sovereign waters.

Zoom out, and the strikes off Bulgaria are part of a bigger shift.

Ukrainian missiles and sea drones have pushed Russia's Black Sea Fleet back from Crimea to Novorossiysk, now its only fully functional naval base.

Novorossiysk is also Russia's main Black Sea oil port. Its Sheskharis terminal ships nearly a fifth of the country's seaborne crude, and drone attacks have halted loadings there more than once this summer. Shadow-fleet tankers have been hit as far away as Turkey's coast.

There's more at stake on NATO's side, too. Romania expects first gas in 2027 from Neptun Deep, one of the EU's biggest gas projects, in its own EEZ.

The fight at sea is now over trade and energy, and both sides' economies are within range.

Both sides are now hitting merchant shipping.

Russia has struck Ukrainian ports and Ukraine-bound ships throughout the war. Ukraine has been going after Russia-linked tankers.

In the 12 months to Sept. 21, Ambrey counted 45 merchant ships struck outside the Black Sea's previously listed war zone, against none the year before. Thirty-three came in the last three months.

The weapon has changed, too. In the war's first year, drifting sea mines made up 15 of the 17 pieces of unexploded ordnance found. So far in its fifth, it's two of 53. Ambrey now calls drones "the dominant floating hazard in the Black Sea."

Who launched the drones off Bulgaria isn't settled. Ukrainian President Volodymyr Zelenskyy blamed Russia for the Oct. 5 sinking of the Royad Mammadov off Romania, which killed two people.

Bulgarian Prime Minister Rumen Radev has been more careful. He says Bulgaria lacks "solid, clear evidence to level accusations against any specific party," though "logic suggests the outcome works to the advantage of the Russian Federation."

He summoned the Russian ambassador. According to the Bulgarian government, she didn't rule out a third party.

On Sept. 16, three weeks before the first sinking off Bulgaria, London's Joint War Committee extended its Black Sea "listed area" to the whole sea. The committee speaks for the underwriters who decide where war-risk cover applies.

Only one area is left out: the territorial waters of Turkey, Bulgaria, Romania and Georgia, out to 12 miles.

Being listed doesn't ban a voyage, but owners pay an extra war-risk premium, priced ship by ship.

In January, brokers put Black Sea premiums at about 1% of a ship's insured value. One shipping firm puts the added cost at around $25,000 a day for a large vessel.

Hugging the coast inside 12 miles avoids the listing, but adds about 100 nautical miles, plus permits and paperwork in three countries. For most ships, that's uneconomic.

The market drew the same line the law does, and priced the risk before any government named who was causing it.

Under the 1936 Montreux Convention, Turkey controls warship access through the Bosporus and the Dardanelles. It enforces the rules strictly, and since 2022 allied navies no longer rotate ships into the Black Sea.

NATO's presence there is on land and in the air. At sea, the alliance relies on its three coastal members. Turkey, Romania and Bulgaria began a joint mine-clearing operation in July 2024, and Bulgaria has taken seven mine-countermeasure ships from Belgium and the Netherlands.

That's the right kit for the last threat. It isn't built for drones.

So far, the response has been words. Radev asked Mark Rutte and Ursula von der Leyen for help with maritime and air surveillance. Rutte said NATO would adjust its posture "as needed."

Three things stand out.

First, the frontier is now a line on a chart. A strike inside 12 miles would land on a NATO member’s sovereign territory. The alliance would then have to decide whether that counts as an attack on the member, or as another violation to absorb. 

Second, the gray zone is doing its job. An attack in an EEZ, on a ship flagged in Togo or Guinea-Bissau, with no confirmed attacker, gives no government a clear reason to act. That ambiguity is useful to whoever's behind it.

Third, the cost lands on trade, not states. Premiums, detours and lost ships squeeze a trade route without anyone formally closing it.

There's a lot we don't know yet. Attribution is open, and one week of strikes closer to shore is a data point, not yet a trend.

The ships going down off Bulgaria fly the flags of Togo and Guinea-Bissau, which makes them easy to ignore.

It's also why the line they're being sunk next to matters.

That’s it for this week.

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