1003 -COMMENT OF UKRAPCHORMET 1

The Honorable Donald Evans Secretary of Commerce Attn: Import Administration Central Records Unit, Room 1870 U.S. Department of Commerce 14th Street and Constitution Avenue, NW Washington, DC 20230 Department of Commerce PUBLIC DOCUMENT A-823-812 Inquiry on Ukraine NME Status Total number of pages: 25 June 13, 2002 SUBJECT: The Ukrainian Association of the Enterprises of Ferrous Metallurgy comments on the Market Economy Status of Ukraine in the Antidumping Investigation of Carbon and Certain Alloy Steel Wire Rod from Ukraine The Ukrainian Association of the Enterprises of Ferrous Metallurgy pursuant to the Department’s notice of April 19, 2002 (67 FR 19394), is pleased to submit comments regarding revocation of the non-market economy country status for Ukraine and has to advise the following. 1. The Extent to Which the Currency of the Foreign Country is Convertible Into the Currency of Other Countries Ukrainian currency unit – hryvnia has been convertible for the current accounts since its introduction in 1996. The exchange rate of hryvnia has always been set based on the actual 1003 -COMMENT OF UKRAPCHORMET_1.doc 14.06.02 interbank transactions rate. At times of economic stability for the world economy, no surrender of the foreign currency was required (e.g., 1997-98). Full convertibility of hryvnia can be illustrated by the statistics of the official exchange rate in comparison with real GDP or foreign trade balance ...