Fiskesalgslagene og forvaltningsloven

02 Sep 2013

Når Stortinget rett før sommeren vedtok en ny Fiskesalslagslov, som viderefører hovedprinsippene i Råfiskloven, vedtok de samtidig en videreføring av en helt spesiell ordning med overføring  av offentlig myndighet til […]

fiskebåt_shutterstock_3350947Når Stortinget rett før sommeren vedtok en ny Fiskesalslagslov, som viderefører hovedprinsippene i Råfiskloven, vedtok de samtidig en videreføring av en helt spesiell ordning med overføring  av offentlig myndighet til fiskesalgslagene.

Fiskesalslagsloven inneholder en rekke bestemmelser der salgslagene får myndighet til å treffe forvaltningsvedtak.  Juridisk sett er det utfordrende at salgslagene, som er private organisasjoner eid av fiskerne, gis adgang til å utøve myndighet på det offentliges vegne. Det er på den bakgrunn positivt at Fiskeridepartementet i et eget kapittel i lovproposisjonen (Prop 93 L 2012-2013 kap. 8) tar opp forholdet til forvaltningsloven.  Problemstillingen blir der hvilke rettigheter partene har i saker der salgslagene treffer forvaltningsvedtak.

I proposisjonen oppsummerer departementet på en god måte hvilke avgjørelser som vil være typiske forvaltningsvedtak som følger forvaltningslovens regler. Det heter det på s. 33 – 34:

”Dette vil vere avgjerder der fiskesalslaget utøver myndigheit med direkte heimel i lova, og som gjeld for alle partar i førstehandsomsetninga uavhengig av medlemskap i fiskesalslaget. Blant desse er fastsetjing av avgift, fastsetjing av alminnelege salsvilkår og omsetningsformer, fastsetjing av minstepris, vedtak om regulering eller dirigering og vedtak om fangst som er hausta i strid med føresegner fastsette i eller med heimel i lova eller havressurslova.”

Forvaltningsvedtakene vil enten være forskrifter eller enkeltvedtak. Forskriftene er de generelle reglene som gjelder for alle aktører i det aktuelle fisket. Enkeltvedtakene er vedtak rettet mot den enkelte aktør.

For forskriftene er saksbehandlingsreglene beskrevet i loven selv, i og med at loven i stor grad gjør unntak fra forvaltningslovens regler om saksbehandling. Reglene er ikke omfattende, men de sikrer i hvert fall at slike generelle bestemmelser i noen tilfeller skal tas opp med de sentrale aktørene i næringen før de iverksettes. 

For enkeltvedtak vil hovedregelen være at forvaltningslovens omfattende saksbehandlingsregler vil gjelde, selv om det er unntak fra en del bestemmelser når det gjelder enkeltvedtak om dirigering av fangster etter lovens § 14 annet ledd.

For alle enkeltvedtak vil det være klagerett til Fiskeridepartementet.  I proposisjonen påpeker departementet at de vil ha full adgang til å prøve slike saker, men departementet presiserer samtidig at de vil være ”særs atterhaldne” med å overprøve salgslagenes skjønnsmyndighet i saker der loven har gitt myndigheten til salgslagene.

Samlet sett er bildet at salgslagene er gitt en usedvanlig uavhengig posisjon som i liten grad er underlagt de kontrollmekanismer som ellers gjelder i vår forvaltning.  Ut fra en generell betraktning er det vanskelig å se den saklige grunnen til at partene i saker som håndteres av fiskessalslagene ikke skal ha de samme rettigheter som man har på andre områder der det treffes enkeltvedtak.  Det at loven gir offentlig myndighet til private organisasjoner skulle egentlig tilsi at kontrollmekanismene gjøres ekstra gode i og med at salgslagene ikke er underlagt den samme demokratiske kontroll som alle andre organer som utøver offentlig myndighet.

Den løsning som er valgt har sammenheng med tradisjonen fra Råfiskloven og salgslagenes sterke politiske stilling. Det gir imidlertid salgslagene et særlig stort ansvar for på egen hånd å sikre en saklig og rettferdig behandling av de involverte aktørene i sakene de behandler.

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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