ANEN is as always at your disposal and once you consult the document of allegations, we hope that you will transfer to us all those issues that you consider relevant in order to achieve the best legal environment that will promote the development and potentiality of our sector (Photo Pedro Seoane)

Following the opening to public consultation by the Ministry of Transport, Mobility and Urban Agenda of the draft law amending the consolidated text of the State Ports Act, the Merchant Navy and the Maritime Navigation Act, ANEN has already submitted, on behalf of the nautical sector, the allegations to the said draft.

The document, which is attached in PDF, details the above-mentioned allegations submitted by the Secretary General of ANEN, Carlos Sanlorenzo, to the State Secretariat for Transport, Mobility and Urban Agenda, whose main points concern:

• The need to establish a specific regulation for State seaports that is clear and responsive to the peculiarities of the sector.
• The necessary establishment of a specialized body within State Ports.
• the need to eliminate distortions resulting from the competitive distribution, the regulatory diversity of the State-CCAA and the disparity of interpretative and applicable criteria of the port authorities themselves. The necessary improvement in competition and market unity.
• the need for adequate regulation to ensure the economic and financial balance of concessions: duration of concessions, fees, land valuation, appropriate rebalancing techniques.
• The need to clarify the legal regime of old concessions.
• The relevance and opportunity to anticipate tax benefits for the sector and to deepen measures to mitigate the economic effects caused by the health crisis situation caused by the Covit-19 pandemic.
• The problem of the abandonment of ships and the proposal to regulate a notarial file for the disposal of abandoned recreational vessels.

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ANEN ALEGATIONS