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And this is the response of the central executive body of Ukraine!!!

As previously reported (see the information in the News section dated January 10, 2025), the Association appealed to the Ministry of Communities and Territories Development of Ukraine with a request to provide information on the re-tracking of the effectiveness of the Order of the Ministry of Infrastructure of Ukraine No. 441 dated June 22, 2022, according to which, starting from June 29, 2022, tariffs for the transportation of all types of cargo by rail were increased by 1.7 times at once.

In response to this appeal, the Association received a response that did not even mention whether or not the Ministry of Communities and Territories Development of Ukraine re-tracked the effectiveness of the Order of the Ministry of Infrastructure of Ukraine No. 441 of June 22, 2022.

Instead, it is reported that the order of June 22, 2022, No. 441 was submitted for state registration in accordance with paragraph nineteen of clause 13 of the Regulation on State Registration of Regulatory Legal Acts of Ministries and Other Executive Bodies, approved by the Cabinet of Ministers of Ukraine of December 28, 1992, No. 731.

It is unclear why the EBA should refer to this provision of the law in its response, since the Association did not even address the issue of state registration of the Order of the Ministry of Infrastructure of Ukraine No. 441 dated June 22, 2022.

From the Association:

  1. The letter from the Ministry of Communities and Territories Development of Ukraine is an elementary response, since the issues raised by the Association were not answered at all.
  2. Given the text of the response, the effectiveness of the Order of the Ministry of Infrastructure of Ukraine No. 441 of June 22, 2022 was not re-tracked, which is a gross violation of Article 10 of the Law of Ukraine “On the Principles of State Regulatory Policy in the Field of Economic Activity”.
  3. The EBA once again emphasizes that the introduction of a new increase in tariffs for freight rail transportation without considering the assessment of the results of the previous regulatory act on the increase of such tariffs, as well as the degree of achievement of the goals set by it, is a significant violation of the requirements of the current legislation on regulatory policy.

Annex: Letter of the Ministry of Communities and Territories Development of Ukraine dated January 23, 2025 No. 1723/47/10-25.

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