From the certificate holder’s application to the proposal to remove LUBL from the AIP Republic of Moldova.
Alexei Rogov, Administrator of S.E. “Moldaeroservice”, signs Letter No. 421 of 8 September 2015, addressed to the Civil Aviation Authority, requesting the suspension of Bălți Aerodrome Certificate No. 02 for the period from 10 September 2015 to 1 May 2016.
Legal basis cited in the request: RAC-CAO 0125(1)(d).
Subsequent AIS documentation identifies CAA Letter No. 1853 of 11 September 2015 among the documents related to the change in LUBL’s status. The full content of this letter should be presented only after the original document has been retrieved and verified.
Document referenced in: RAW DATA PRESENTATION FORM RD 1703-005.
CAA Director Mircea Maleca reviews Request No. 421 and decides to approve the request to suspend the certificate. The CAA sets 18 September 2015 as the effective date, instead of 10 September 2015 as initially requested by the operator.
Legal basis cited by the CAA: RAC-CAO 0125(1)(d).
Effective date specified by the CAA: 18 September 2015.
Through the same Letter/Decision No. 1910, the CAA sets out the obligations arising from the withdrawal/suspension of the certificate, including the return of the original certificate, notification of the aeronautical information service, and the measures applicable where the aerodrome is closed to all flights.
References cited by the CAA: RAC-CAO 0125(3); RAC-CAO 0135(1)(a), (c) and (d).
S.E. “Moldaeroservice” submits the original of Bălți Aerodrome Certificate No. 02 to the CAA by Letter No. 444 of 21 September 2015, in implementation of CAA Decision No. 1910 of 18 September 2015.
Legal basis: CAA Decision No. 1910 of 18 September 2015.
In the aeronautical information publications, NOTAM A0065/16 — “LUBL… AD CLOSED” — was published, recording for users of the aeronautical information system that the aerodrome was closed.
NOTAM A0065/16 · LUBL · AD CLOSED
AIS Form RD 1703-005, initiated by the CAA Airports Directorate (originator: Vladimir Buinitki), proposes that LUBL be listed in AIP AD 1.5 as “Noncertified”. The document is dated 1 March 2017 and bears an authorization for publication dated 2 March 2020.
Documentary chain indicated: No. 421/08.09.2015 → CAA No. 1853/11.09.2015 → No. 444/21.09.2015 → NOTAM A0065/16.
By Letter No. 30 of 8 February 2021, S.E. “Moldaeroservice” informs the CAA that the resumption of LUBL operations is not planned in the near future and proposes that the Air Navigation Commission remove the LUBL section from the AIP of the Republic of Moldova.
The proposal to remove LUBL from the AIP was made in 2021 and should not be confused with the suspension of the certificate in September 2015.
Administrative and aeronautical information documents concerning the suspension of the certificate, the operational closure, and the subsequent change in LUBL’s status.
The request signed by Administrator Alexei Rogov concerning the suspension of Bălți Aerodrome Certificate No. 02 for the period from 10 September 2015 to 1 May 2016.
Răspunsul Autorității Aeronautice Civile prin care este admisă cererea operatorului și sunt stabilite data efectivă și obligațiile aferente suspendării certificatului.
Submission to the CAA of the original Bălți Aerodrome Certificate No. 02 in implementation of CAA Decision No. 1910 of 18 September 2015.
Publication in the aeronautical information system of the “AD CLOSED” status for LUBL aerodrome.
AIS form concerning amendments to the information published for LUBL and the designation of its status as “Noncertified” in AIP AD 1.5; document dated 1 March 2017, with publication authorization dated 2 March 2020.
Notification to the CAA that the resumption of LUBL operations is not planned in the near future, together with the proposal to remove the LUBL section from the AIP of the Republic of Moldova.
The original documents make it possible to reconstruct the sequence of administrative actions, but they leave two essential questions unanswered: what was the specific factual reason that led S.E. “Moldaeroservice” to request the suspension, for almost eight months, of Bălți Aerodrome Certificate No. 02, and why did the Civil Aviation Authority approve that request within such a short period, without reservations, conditions, or additional requests for clarification, given that it concerned the country’s second most important international civil airport?
S.E. “Moldaeroservice” requests the suspension of the certificate for the period from 10 September 2015 to 1 May 2016. The available documents reviewed do not indicate any specific factual reason for this measure.
Only ten days after the request submitted by the operator of the country’s second most important international civil airport, the Civil Aviation Authority approves the request and orders the suspension of the airport certificate, without reservations, conditions, or any additional requests for clarification.
On 22 December 2015, the Militzer & Münch project for the 49-year concession and modernization of Bălți-Leadoveni International Airport was publicly presented, with announced investments of approximately EUR 30 million in a first phase and a further EUR 10–15 million in a subsequent phase, bringing the estimated total investment to up to approximately EUR 45 million. The project envisaged, among other things, the construction of a new passenger terminal and cargo facilities, as well as the modernization and extension of the runway.
The public sources identified to date do not make it possible to establish when discussions between Militzer & Münch and the public authorities or state-owned entities involved actually began and, therefore, do not support a finding of a causal link between those discussions and the suspension of the certificate in September 2015.
The temporal proximity of the events nevertheless justifies further documentary clarification of this issue, including the identification of any correspondence, meetings, or investment proposals predating 22 December 2015. As a general matter, the public presentation of an airport project involving investments of tens of millions of euros would ordinarily be preceded by a period of concept development, investment assessment, technical preparation, and contacts between the interested parties. This observation constitutes a reasonable inference as to the preparation required for a project of this scale, but at present it is not evidence that negotiations with Militzer & Münch had begun before the certificate was suspended.
The sequence of events raises the question of whether the suspension was an exclusively operational, technical, or financial measure, or whether it formed part of a broader institutional context concerning the future of the airport. The documents currently available do not yet allow this question to be conclusively resolved.
