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Fy staten – de tapte igjen. Det skulle bare mangle!

15 Jun 2012

Staten forsøkte å rane fiskerinæringen for allerede tildelte strukturkvoter. Staten tapte i tingretten. Nå har de tapt igjen! Lagmannsretten var like klar og tydelig som tingretten – staten har forsøkt […]

Av advokat Henrik Grung og advokatfullmektig Christina Riisnes

Staten forsøkte å rane fiskerinæringen for allerede tildelte strukturkvoter. Staten tapte i tingretten. Nå har de tapt igjen! Lagmannsretten var like klar og tydelig som tingretten – staten har forsøkt å gå for langt, men blir stanset av grunnloven.

Da er det klart – Staten v/Fiskeri og Kystdepartementet gikk på et nytt tap i Borgarting lagmannsrett mot rederiet Volstad AS. Dommen er ikke p.t. rettskraftig, men er likevel et flott signal til fiskerinæringen og da særlig rederier som er påført skade av endring i strukturkvoteordningen ved forskriftsendring 8. juni 2007.

Dommen viser at Volstad AS –  som en modig næringsaktører,  sammen med våkne domstoler, gir staten berettiget motbør. States ly får altså ikke gjennomslag for tidvis lite gjennomarbeidede, uhensiktsmessige og hardt rammende regelendringer som ville gitt uforutsigbarhet og urolige rammevilkår for næringen. Det fører ikke frem – HELDIGVIS! Dommen gir staten klar beskjed om at  næringen og arbeidsplassene skal gis trygghet for langsiktighet og utvikling i bransjen.

Sakens gjelder gyldigheten av § 7 i strukturkvoteforskriften. 

Da forskriften trådte i kraft i 2005 og helt frem til bestemmelsen i § 7 ble endret ved forskrift 8.juni 2007, var det ingen begrensninger i hvor mange år strukturkvoter kunne tildeles. Ved endring i 2007 ble det – helt overraskende – innført en begrensning på 20 år for nye strukturkvoter og 25 år for de fartøyer som allerede har blitt tildelt strukturkvoter. Forskriften hadde altså tilbakevirkende kraft. Gyldigheten av dette var gjenstand for lagmannsrettens behandling.. 

Sakens bakgrunn

Rederiet Volstad AS hadde – i likhet med en rekke øvrige i bransjen,  innrettet seg etter forskriften fra 2005 og strukturerte maksimalt under 2005- ordningen ved å kondemnere to av sine fartøyer. Det gjenværende fartøyet ble tildelt strukturkvote tilsvarende begge de to kondemnerte fartøyenes kvoter. Ved tidsbegrensningen på 25 år, som ble innført ved forskriftsendring i 2007, ble rederiet fratatt deler av motytelsen de hadde innrettet seg på og få, og følgelig var grunnlaget for at de valgte å gjennomføre kondemneringen underminert ved statens forsøk på endring ved et pennestrøk.

Sakens sentrale spørsmål

Problemstillingen i saken var om forsøket på tidsbegrensningen (25 år)  for de fartøyer som allerede var tildelt tidsubestemte strukturkvoter, var i strid med tilbakevirkningsforbudet  i Grunnloven § 97.

Vurderingen av om forskriftsendringen er grunnlovsstridig skjedde konkret for Volstad AS, og ikke for næringen i sin helhet. Lagmannsretten la likevel til grunn at det skal tas hensyn til helheten ved en lovregulering, og ikke om ethvert urimelig utslag for den enkelte kan føre til grunnlovsstrid. På dette grunnlaget oppfattet lagmannsretten, som tingretten, rederiet Volstad AS som representativ i hvert fall for de rederiene som har strukturert maksimalt under 2005-ordningen. Dommen kan derfor få betydning for flere enn bare Volstad AS – denne delen av næringen kan og bør juble for en viktig prinsippseier!

Kort om lagmannsrettens vurdering – Grunnloven § 97

Grunnloven § 97 slår fast at ”Ingen Lov maa gives tilbagevirkende Kraft.”

En grunnbetingelse for beskyttelse i  Grunnloven § 97  er at den tilbakevirkende lovgivningen må være til skade for den som påberoper seg bestemmelsen.

I følge Lagmannsretten er det ikke tvilsomt at tilbakevirkningen medfører skade for Volstad AS, herunder blant annet at:

  • Volstad AS ville miste alle sine strukturkvoter innen 2033.
  • På kort sikt utgjør skaden at omstetningsverdien av rederiets fartøy mest sannsynlig er redusert
  • Bortfall av strukturkvoter ved utløpet av perioden på 25 år vil mest sannsynlig føre til inntektstap for selskapet sammenlignet med om strukturkvotene ble opprettholdt.

Et ytterligere sentralt spørsmål for lagmannsretten var i hvilken grad Volstad AS spesielt (torsketrålgruppen generelt) kunne ha en berettiget forventing om at det enkelte fartøys strukturkvotefaktor ville blitt tatt hensyn til ved den årlige kvotetildelingen i overskuelig framtid Også her var lagmannsretten  klinkende klar!

”rederne hadde – og – har en sterk og beskyttelsesverdig forventing om tildeling av kvote i henhold til den etablerte kvotefaktoren på det enkelte fartøy”.

Lagmannsretten mente at bransjepraksis klart viste at kvotefaktorene fartøyene i mellom har ligget fast. Forskriften fra 2005 ble videre etablert i nær kontakt med fiskerinæringen selv, og var i samsvar med et kompromiss i næringen. På bakgrunn av ovennevnte konkluderte lagmannsretten:

”I et regime der kvotefaktorene fartøyene i mellom innenfor samme gruppe tradisjonelt har ligget fast, vil en forskrift vedtatt på bakgrunn av et tett kontakt med næringen og i tråd med næringens omforente forslag ha et klart avtalepreg. Omfanget av oppofrelser den enkelte reder måtte gjøre i forbindelse med struktureringen som ledd i en frivillig, men av staten ønsket handling, underbygger ytterligere at innføringen av strukturkvoter uten forhåndsfastsatt tidsbegrensning hadde et avtalepreg”

Rettslig sett er det ikke tilstrekkelig at tilbakevirkningen medførte skade for Volsatd AS, ei heller at det i tillegg var konkludert tydelig med at Volstad AS hadde en berettiget forventning om at tidsubegrenset kvote bestod.

Staten  forsøkte tappert å argumentere for at  ran fra næringen kunne forankres i viktige samfunnsmessige hensyn. Dette er – som et utgangspunkt rettslig sett et sentralt moment i vurderingen av grunnlovsvernet, men også her ble staten fullstendig avkledd. Ingen av de påberopte samfunnmessige hensyn som staten påberopte ble hørt.

Lagmannsretten konkluderte enstemmig med at det heller ikke forelå tilstrekkelige sterke samfunnsmessige hensyn for å gi forskriftsendringen tilbakevirkende kraft.

Så da er det altså klart – lagmannsretten konkluderte med at statens simple forsøk på ran – ved å (forsøke) å innføre tidsbegrensning for allerede tildelte tidsubegrensede kvoter,  strider mot tilbakevirkningsforbudet og de grunnleggende vernereglene som skal beskytte mot mot maktmisbruk fra staten – det strider mot Grunnloven § 97.

Dommen er ikke rettskraftig

Vi får vente i spenning å se om staten v/ Fiskeri og Kystdepartementet velger å akseptere tingrettens- og nå også lagmannsrettens velstrukturerte og velbegrunnede enstemmige dommer. Vi var ikke i tvil etter tingrettens dom – denne kunne ikke staten vinne. Nå spørs det om de satser ”kvitt eller dobbelt” ved å anke til Høyesterett. Dersom dommen ankes venter vi at resultatet blir stående, hvis Høyesterett i det hele tatt vil behandle den. 

Dersom dommen blir rettskraftig vil også andre aktører i fiskerinæringen, som foretok omstrukturering etter 2005- ordningen, med stor sannsynlighet få beholde strukturkvotene som tidsubegrensede og følgelig også få igjen verdifallet ved omstruktureringen – så gjenstår det å se nettoeffekten – hensyn tatt tapt avskrivning……..

Kvoter som ble tildelt for første gang etter 8. juni 2007 forblir tidsbegrenset i henhold til forskriftsendringen.

Denne saken er et godt eksempel på den virkning stadig endrede rammevilkår har for næringsaktører som har tilpasset seg og har berettigede forventninger til et regelverk. Saken viser også at det er mulig å vinne frem mot slike inngrep overfor aktører som forsøker å drive frem et levedyktig næringsliv her langt nord på europatorget. Saken bør bidra til å sette søkelyset også mot andre sektorer som –  i tillit til skapertrang og rettferdighet,  innretter seg, men stadig oftere rammes at statens håpløse iver etter  å endre rammebetingelsene.

 FY STATEN!

Om forfatteren

Henrik Grung
Henrik Grung Henrik Grung er partner ved vårt kontor i Ålesund. Han arbeider hovedsakelig med strategisk juridisk rådgivning og tvisteløsning for en rekke av virksomhetene i Møre og Romsdal innen bransjene fiskeri, eiendomsutvikling, myndighetsforvaltning, handel og industri.

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