In the end, an RD was published and used to make changes in the regulations governing nautical degrees and water bikes, thus robbing the debate of issues of essential interest to the navigators.

Anavre has submitted the application for the procedure for challenging RD 339 / 2021 which is followed before the Supreme Court at the request of our Association.

The letter is essentially divided into two parts, the first being a request that the Royal Decree itself be declared null and void in full, or that it be annulled because it has not followed the procedures legally provided for its promulgation.

This was because, in changing the hierarchical range of the rule, a new file was not initiated and the draft Royal Decree was not submitted to the processing of public information, which would have made it possible to include in the scope of the rule aspects that were excluded because what was submitted to consultations and the stage of allegations was a draft Ministerial Order, so that no issues proposed by Anavre such as modification of the navigation areas, endowment and approval of radio equipment, etc... could not be dealt with in the discussion of the same Decrees.

The second part of the report is to challenge in a subsidiary manner a wide range of precepts contained in Royal Decree 339 / 2021 on the grounds that they are contrary to national rules, some as important as the constitutionally established principles of equality of persons and legal certainty; yes as international rules and agreements to which Spain is a party; by applying to craft for specific regulatory recreational for merchant and passenger ships, to the single European market and to the free movement of goods within the EU, among other reasons.

ANAVRE IMPORT TEXT