Havbruk

Oppdrettsanlegg og arealforvaltning

05 Jul 2013

  Forvaltning av sjøarealene er et tema som alltid er aktuelt for oppdrettsnæringen. I denne artikkelen vil jeg presentere hovedtankene i regleverket om arealbruk og peke på noen rettslige forhold […]

 

Havbruk i fjord

Forvaltning av sjøarealene er et tema som alltid er aktuelt for oppdrettsnæringen. I denne artikkelen vil jeg presentere hovedtankene i regleverket om arealbruk og peke på noen rettslige forhold knyttet til kommunale arealplaner som det er viktig at oppdrettere er klar over i arbeidet med å få klarert nye lokaliteter.

 

 

Hovedregel – adgang til etablering dersom det ikke er grunn til å nekte

Det rettslige utgangspunktet for oppdrettsnæringens bruk av sjøarealet er Høyesteretts dom i Rugsund-saken (Rt. 1985 s. 1128). Høyesterett slo her fast at grunneieren på land ikke har enerett til å drive fiskeoppdrett i sjøområdet utenfor sin eiendom. Konsekvensen av dommen er at en oppdretter har adgang til å etablere anlegget sitt i sjøen dersom han ikke er i veien for – eller til urimelig sjenanse for – annen virksomhet.

I tillegg må oppdretteren ha de nødvendige tillatelser etter plan- og bygningsloven, akvakulturloven, matloven, havneloven og forurensningsloven. Lovgivningen setter den samme typen krave for å innvilge søknaden som Høyesterett la opp til i Rugsund-saken. Hovedprinsippet er at lokaliteten godkjennes dersom det ikke er gode grunner til å avslå søknaden om etablering. Samtidig må det legges til at myndighetene etter de fem lovene står relativt fritt til å bestemme hva som er en ”god grunn” for å nekte etablering. Den viktigste rettslige begrensning er at praktiseringen av avslagsgrunnen skal være konsekvent fra sak til sak. Forvaltningen kan ikke praktisere usaklig forskjellsbehandling.

Kommunenes arealplaner

En av de viktigste grunnene til å nekte etablering fremgår av akvakulturlovens § 15 første ledd a som fastslår at lokalitetstillatelse ikke kan gis når dette er i strid med ”vedtatte arealplaner etter plan- og bygningsloven”. Dette innebærer altså at en søknad om lokalitetstillatelse skal avslås dersom kommunens kystsoneplan regulerer det aktuelle arealet til et formål som er uforenelig med akvakultur.

Det er viktig å merke seg at det er to metoder kommunene kan bruke dersom man ønsker at et område skal være åpent for akvakultur. Det ene muligheten er at man i kommuneplanen reserverer området for akvakultur. Det kan man typisk gjøre i mindre områder der det er etablert anlegg eller der kommunen vet at den vil ønske at fremtidige anlegg plasseres. Den andre muligheten er at man lar akvakultur være et av flere mulige alternativer til bruk av større områder. Dette kan kommunen typisk gjøre for større sjøarealer der man ikke er sikker på den fremtidige bruken. Plan- og bygningsloven slår i § 11-7 nr.6 fast at kommunene kan regulere til flere ulike bruksalternativer ”i kombinasjon”.

I slike flerbruksområder skal det i utgangspunktet presiseres hvilke bruksalternativer som er tillatt. For adgangen til å etablere akvakulturanlegg er det avgjørende om dette er ett av bruksalternativene. Dette skal normalt markeres ved forkortelser i kommuneplanens arealdel. Er et område markert som FFF-område betyr det at området er reservert for friluft, farleder og fiske. Da trenger man i utgangspunktet dispensasjon fra kommunen for å etablere et oppdrettsanlegg. Er området derimot markert som FFFA-område åpner det i tillegg for akvakultur, og tillatelse kan ikke nektes etter akvakulturloves § 15 første ledd a.

I praksis har vi også sett at kommuner regulerer kystområder som flerbruksområde uten at det er presisert i planen hvilken bruk som er tillatt. Da må man undersøke nærmere hva kommunen har ment. Den viktigste kilden vil da være kommunestyrets vedtak om kommuneplanen og saksdokumentene til dette. Det er særlig viktig å være oppmerksom på at det at planen har reservert spesielle områder til akvakultur ikke er til hinder for at de også tillater akvakultur i flerbruksområdet. Det er i slike tilfeller lett å misforstå planene og oppfatte det slik at akvakultur er forbudt i det generelle flerbruksområdet.

Vi har også i praksis sett andre tolkningsspørsmål knyttet til disse arealplanene. I et tilfelle var selve oppdrettsanlegget plassert i et område reservert for akvakultur, mens fortøyningene måtte plasseres slik at de gikk inn i et FFF-område, men da relativt dypt nede i sjøen. Kommunen så praktisk på det og mente at noen slike fortøyninger nede i sjøen ikke innebar motstrid med flerbruksområdet. Fylkeskommunen var imidlertid i utgangspunktet uenig, og det ble en konfliktsak av det. Vi oppfatter det som uheldig når regionale myndigheter opptrer formalistisk i slike saker og ikke aksepterer lokalt praktisk skjønn fra den kommunen som tross alt har laget kommuneplanen. Det kan likevel være klokt at kommunen avsetter tilstrekkelig store arealer når det disponeres sjøområder til akvakultur.

 

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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