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14 Aug 2013

1. oktober 2013 kl. 15.00 er leveringsfristen for den som vil søke om å få tildelt en eller flere av de grønne konsesjonene som ble utlyst 1. juli. I denne […]

1. oktober 2013 kl. 15.00 er leveringsfristen for den som vil søke om å få tildelt en eller flere av de grønne konsesjonene som ble utlyst 1. juli.

I denne artikkelen skal jeg ikke gå gjennom regelverket i detalj, men heller peke på noen hovedutfordringer som denne konsesjonsrunden reiser både for søkere og forvaltning. Prosessen for tildeling av de grønne konsesjonene fremstår som en stor utfordring både for søkerne og for fiskeriforvaltningen som skal behandle søknadene.

Det som forbauser meg aller mest med det regelverket som nå er presentert er at fiskerimyndighetene har ønsket å gjøre sin egen jobb så vanskelig – og jeg tenker da særlig på den jobben som skal gjøres av det fagorganet som skal vurdere søknadenes kvalitet. Deres oppgave vil for det første være å vurdere om den enkelte søknaden oppfyller de skjønnsmessige minstekravene som er oppgitt i regelverket.  For det andre skal de sette opp en faglig begrunnet rekkefølge mellom søkerne i de gruppene der dette er avgjørende for tildelingen, det vil si i alle gruppene bortsett fra gruppe B der rekkefølgen settes opp på basis av budnivå.

De faglige vurderingene er uansett vanskelige, og de er ekstra vanskelige når saksbehandlingen forbyr all kommunikasjon mellom søkerne og fagorganet. Det fremgår klart av søknadsskjemaet som fastslår at søkerne ikke kan komme med endringer eller gi tilleggsopplysninger etter at søknadsfristen har gått ut. Det må selvsagt også bety at fagorganet heller ikke kan innhente tilleggsopplysninger fra søkerne.

Når dette sannsynligvis blir et problem for fagorganet skyldes det at søkerne inviteres til å være oppfinnsomme og presentere gode løsninger. Det er en svært åpen søknadsprosess departementet legger opp til. Det innebærer selvsagt at søknadene vil inneholde elementer som man ikke har ventet på forhånd, og like sikkert er det at fagorganet vil ha spørsmål knyttet til søknadene. De vil ganske enkelt ofte lure på hva søkeren har ment med sine forslag. Det virker derfor korttenkt når fiskerimyndighetene ikke åpner for at fagorganet kan ha en form for dialog med søkerne, for eksempel gjennom en to trinns søknadsbehandling slik jeg tidligere har foreslått. Man kan selvsagt si at det er søkerne som må formulere seg klart, men det er i praksis umulig for en søker å forutse hvilke spørsmål som måtte dukke opp hos fagorganet og presentere svarene på alle spørsmål i søknadene. Konsekvensen er dessverre at regelverket eter all sannsynlighet vil gi en kvalitativt dårligere prosess en det som ville vært tilfellet om fagorganet fikk anledning til å innhente ytterligere opplysninger hos søkerne.

Når det er sagt er det samtidig slik at søkerne må ta den utfordringen som ligger i at søknaden må være så klar og entydig at den svarer på de spørsmålene som fagorganet kan tenke seg å stille. En av de store utfordringene for søkerne i denne søknadsrunden er å kvalitetssikre søknadenes innhold slik at de ikke er til å misforstå.  Etter min oppfatning bør søkerne ta dette så alvorlig at de for eksempel bør la andre fagfolk enn de som har skrevet søknaden gjennomgå et ferdig utkast for å stille spørsmål. I den endelige søknaden besvarer man så spørsmålene slik at muligheten for uklarheter og misforståelser hos fagorganet reduseres så mye som mulig.

For søkerne synes det videre som en farlig strategi å forplikte seg til å oppnå løsninger de ikke er sikre på å få til og så håpe på det beste. Ved slike søknader kan man risikere to ting. Det ene er at fagorganet avslår søknaden fordi de ikke tror søkeren kommer til å få til det han har lovet. Det andre er at det settes vilkår som innebærer at det kan få store negative konsekvenser for oppdretteren om de usikre målsetningene ikke nås. Det å sende inn en søknad som lover for mye er altså et risikoprosjekt for søkeren.

Det er også viktig å merke seg at de nye konsesjonene ikke skal brukes til utprøving av nye løsninger. I merknadene til forskriften er det pekt på at den som vil prøve ut nye løsninger kan søke om en FOU – konsesjon (Forskning og utvikling). Slike konsesjoner deles ut fortløpende uten konkurranse og uten at det må betales vederlag.

Søknadene om grønne konsesjoner skal altså basere seg på velprøvde løsninger, og det må utarbeides grundige og vel bearbeidete søknader som tar de saklige forbehold som er nødvendige.  

Det kan også være fornuftig å prøve å forutse det konkrete innholdet i konsesjonen og kommentere den i søknaden. Forskriftens § 9 fastslår at det skal settes vilkår for tillatelsene ”som medverkar til at dei kriteria som er avgjerande for tildelinga blir etterlevde”. Her vil det i praksis være adgang for søkeren som selv ønsker å formulere forslag til vilkår. Fagorganet vil selv avgjøre hvilke vilkår som settes, men de må vurdere forslag som kommer fra søkerne.  Og dersom fagorganet setter vilkår søkerne er misfornøyde med vil det være lettere å få gjennomslag for en klage når søkeren selv har foreslått alternativer.

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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