Fristen for å komme med uttalelser til høringsnotat om endringer i akvakulturloven gikk ut 3. desember. Advokat Halfdan Mellbye har utarbeidet en høringsuttalelse på vegne av advokatfirmaet Steenstrup Stordrange. Dere finner uttalelsen nedenfor. Et hovedpoeng er at departementet etter vår oppfatning er alt for ukritisk i sin argumentasjon for høye overtredelsesgebyrer og at forslaget legger opp til alt for høye maksimale gebyrsatser.
Vår høringsuttalelse om akvakulturloven
04 Dec 2012
Fristen for å komme med uttalelser til høringsnotat om endringer i akvakulturloven gikk ut 3. desember. Advokat Halfdan Mellbye har utarbeidet en høringsuttalelse på vegne av advokatfirmaet Steenstrup Stordrange. Dere […]
Om forfatteren
Halfdan Mellbye
Halfdan Mellbye har i 25 år arbeidet med ulike juridiske problemstillinger innenfor fiskeri- og havbruksnæringen. Han har blant annet arbeidet svært mye med næringsreguleringsspørmål og han har i tillegg særlig gode kunnskaper om de biologiske og miljømessige utfordringene for næringsutøverne. Han har i en årrekke vært faglig ansvarlig for faget Havbruksjus ved Universitetet i Bergen. Han har nylig utgitt boken "Rettslig regulering av norsk akvakultur" som er utgitt på Universitetsforlaget 2018. Halfdan har møterett for Høyesterett.
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- Halfdan Mellbye
Email: hme@sands.no
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