Havbruk i norsk fjord

Forstår oppdrettsforvaltningen næringen godt nok?

10 Feb 2013

Forvaltningen av fiskeoppdrettsnæringen er fordelt på en rekke fagorganer med stor myndighet på hvert sitt ansvarsområde. Dette skaper klare utfordringer som ikke tas tilstrekkelig alvorlig i dag. Generelt bør forvaltningen […]

Havbruk i norsk fjordForvaltningen av fiskeoppdrettsnæringen er fordelt på en rekke fagorganer med stor myndighet på hvert sitt ansvarsområde. Dette skaper klare utfordringer som ikke tas tilstrekkelig alvorlig i dag. Generelt bør forvaltningen samordnes bedre praktisk for å få til en effektiv og optimalt fungerende næringsforvaltning. Samtidig viser enkeltsaker at noen fagorganer dessverre mangler den grunnleggende praktiske næringsforståelse som er forutsetningen for å treffe gode vedtak.

Da jeg begynte å arbeide med fiskeoppdrettsnæringen på midten av 1980-tallet var en av de første personene jeg snakket med fiskeriretteleieren på Austevoll. Han satt på kommunehuset og var samtidig knyttet til Fiskerisjefen i Hordaland. Han snakket med næringens aktører hele tiden og hadde store praktiske kunnskaper om både fiskeri- og oppdrettsnæringen samtidig som han var en nøkkelperson i forvaltningens saksbehandling i enkeltsaker. På denne måten fikk man en forvaltning som forstod næringen svært godt og derfor kunne treffe enkeltvedtak med stor treffsikkerhet.

Utviklingen har senere gått i retning av faglig spesialisert forvaltning der enkeltvedtak treffes av saksbehandlere som har store kunnskaper på sine fagfelt. Det er selvsagt ikke i seg selv noe negativt, men det er viktig å erkjenne at dette gir en utfordring når målet er å få til en best mulig næringsforvaltning. Risikoen er at disse spesialiserte saksbehandlerne ikke kjenner næringen godt nok.

Dette er selvsagt et sammensatt bilde. Vi har mange organer og saksbehandlere innenfor oppdrettsforvaltningen som kombinerer god næringsforståelse og evne til å gjennomføre sine forvaltningsoppgaver. Samtidig ser vi dessverre også stadig eksempler på forvaltning som mangler den nødvendige forståelse for næringen og derfor treffer vedtak som har helt unødvendige negative konsekvenser.

For oss som arbeider som advokater i næringen er disse uheldige vedtakene særlig tydelige i og med at vi vet nøyaktig hvilke rettslige rammer forvaltningen har og derved også hvilket spillerom de har for å utøve skjønn. God forvaltning skal selvsagt benytte dette skjønnet til å forfølge de faglige hensyn de er satt til å vokte over og de skal samtidig benytte skjønnet slik at næringen får gjennomføre hensiktsmessige tiltak som de selv ønsker dersom dette ikke strider mot sterke faglige hensyn. Vi ser dessverre alt for ofte eksempler på at forvaltningen ikke forstår hvor viktig det er å benytte skjønnet på begge måter.

Etter min oppfatning bør de sentrale fiskerimyndighetene, som har det overordnede ansvar for reguleringen av fiskeoppdrettsnæringen, ta disse problemstillingene på alvor. Det trenges praktiske tiltak for å sikre at alle deler av oppdrettsforvaltningen kjenner både næringen og de ulike sidene ved sine forvaltningsoppgaver godt nok. For meg som jurist er det naturlig å peke på at deler av forvaltningen trenger bedre kunnskaper både om alminnelig forvaltningsrett og de rettslige rammene for sin egen forvaltningsutøvelse. Kurset Havbruksjus, som jeg og ansatte ved Fiskeridirektoratet laget for Universitetet i Bergen for 10 år siden, kan anbefales til dette formålet.

Om forfatteren

Halfdan Mellbye
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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