Lovendring i akvakulturregelverket: Inndragning av utbytte ved biomasseoverskridelser

30 Jan 2014

Ny bestemmelse inntatt i akvakulturloven § 29a

I akvakulturloven § 29a er det nå kommet en ny bestemmelse om administrativ inndragning av utbytte som er oppnådd gjennom overtredelse av bestemmelser i eller i medhold av akvakulturloven.

Administrativ inndragning er aktuelt ved flere typer overtredelser av akvakulturregelverket, men særlig ved overtredelser av maksimalt tillatt biomasse (MTB) og antallsbegrensninger på produksjonsenhetsnivå, jf. akvakulturdriftsforskriften §§ 48, 47a, 48 og 48a.

Bestemmelsen ble inntatt ved lovendring som trådte i kraft fra 1. januar 2014, jf. lov 21. juni 2013 nr. 74 om endringer i akvakulturloven og kongelig resolusjon 21. juni 2013 nr. 745.

Tidligere var det ingen slik uttrykkelig bestemmelse om administrativ inndragning. I tråd med hva som var forutsatt i de tidligere forarbeidene, fungerte likevel akvakulturloven § 30 om overtredelsesgebyr i mange tilfeller i realiteten som en inndragningsbestemmelse. I fiskerimyndighetspraksis ble overtredelsesgebyr utmålt med utgangspunkt i fortjenesten som følge av overtredelsen, med fradrag for variable kostnader. I tillegg kom et ”pønalt” (strafferettslig) tillegg. I den senere tid har regelen vært gjenstand for kritikk og rettslig prøving hos Sivilombudsmannen og domstolene, med hensyn til grunnlovens § 96 som slår fast at straff bare kan ilegges ved dom (ikke gjennom forvaltningsvedtak). Den nye regelen om inndragning i § 29a er uten det tidligere ”pønale” tillegg.

Ikke lenger et skyldkrav – Inndragning også ved hendelige uhell og force majeure

I bestemmelsen som tidligere reelt sett lå til grunn for inndragning, i akvakulturloven § 30 om overtredelsesgebyr, måtte det foreligge forsett eller uaktsomhet hos overtrederen. Etter den nye bestemmelsen i § 29a, kan utbyttet inndras på objektivt grunnlag, det vil si uten hensyn til skyld (både forsett og uaktsomhet). Bestemmelsen er dermed på dette punkt tilsvarende som ved inndragning av utbytte fra fangst, jf. havressurslova § 54 med tilhørende forskrift.

Det er ikke gjort unntak for force majeure eller lignende. Inndragning kan dermed også skje ved hendelige uhell og ved helt uforutsette hendelser. Lovgivers tanke er at årsaken til lovbruddet ikke er relevant, idet formålet med inndragning er nullstilling – overtrederen skal verken tjene på overtredelsen eller tape på at utbyttet inndras. Samtidig som kravet om skyld ble erstattet med en objektiv regel, ble også det ”pønale” tillegg fjernet som nevnt ovenfor.

Selv om det ikke er gjort unntak for force majeure eller lignende, kan inndragning bare skje så langt det ”ikke vil være klart urimelig”, jf. akvakulturloven § 29a første ledd tredje punktum. Dersom forvaltningen vurderer at det vil være klart urimelig å foreta inndragning i et enkelt tilfelle, skal inndragning ikke skje. Forarbeidene nevner som eksempel at nettopp i tilfeller hvor det foreligger force majeure kan det være aktuelt å benytte unntaksbestemmelsen. Andre tilfeller kan være der overtredelsens art eller omfang er svært beskjeden, eller hvor det er umulig å ta rede på hvor stor overtredelsen har vært eller inndragningsbeløpets størrelse. Unntaksbestemmelsen må ses i sammenheng med at oppdretter plikter å planlegge driften på en slik måte at kravene til MTB overholdes. Det er en rekke forhold som kan gå galt, og dermed føre til at MTB-en overskrides, eksempelvis uvær, sykdomsbrudd, havari på brønnbåt, utsatt slaktedato på grunn av forhold hos slakteri mv. Oppdretter må legge inn tilstrekkelig marginer – også for uforutsette hendelser. Dersom oppdretter tar en bevisst risiko, vil inndragning neppe være ”klart urimelig”. På den annen side kan biomasseoverskridelse være foranlediget av forhold oppdretter ikke kunne unngå. Dette vil i så fall tale for at det vil være klart urimelig med inndragning av utbytte.

Skjerpet beviskrav

For spørsmålet om inndragning kan vedtas, legges det til grunn et krav om klar sannsynlighetsovervekt. Dette er tilsvarende som ved inndragning etter havressurslova § 54, som har klare likhetstrekk med akvakulturloven § 29a. Det skjerpede beviskrav må ses i sammenheng med at inndragning normalt er en alvorlig sanksjon. Kravet er lavere enn beviskravet i straffesaker (utover rimelig tvil), men høyere en det vanlige sannsynlighetskravet i sivile saker (mest sannsynlig). Høyesterett har i Rt. 2011 s. 910, som gjaldt konkurranserettslig overtredelsesgebyr, uttalt at kravet til klar sannsynlighetsovervekt innebærer at det må fremskaffes en samling ”tungtveiende, nøyaktige og samstemmende bevis”. Viktige bevis vil blant annet være dokumentasjon fra tellinger/veiinger og kontrolltellinger/veiinger, innrapporteringer til myndighetene, slakterapporter mv. For oppdretter er det derfor viktig å ha gode rutiner og sørge for tilstrekkelig dokumentasjon av driften hvis det senere skulle bli et spørsmål om inndragning på grunn av mulige biomasseoverskridelser.

Hvis det først konstateres inndragning, gjelder et krav om vanlig sannsynlighetsovervekt ved fastsettelsen/utmålingen av utbyttets størrelse.

Utmåling av inndragningsbeløpet (utbyttet)

Med hjemmel i akvakulturloven § 29a femte ledd har departementet i forskrift gitt nærmere bestemmelser om inndragning, herunder om standardisert eller skjønnsmessig utmåling av utbytte og fradrag for utgifter, se forskrift 20. desember 2013 nr. 1675 om reaksjoner, sanksjoner med mer ved overtredelse av akvakulturloven. Forskriften erstattet – med virkning fra 1. januar 2014 – forskrift 29. mars 2007 nr. 361 om reaksjoner ved overtredelse av akvakulturloven (”Reaksjonsforskriften”).

For biomasseovertredelser, er de beregningsregler som fulgte av den tidligere reaksjonsforskriften § 10 tredje ledd, i stor grad videreført i den nye forskriften § 6.

Utgangspunktet er at det er overtrederens netto utbytte som skal inndras. Dette utmåles med utgangspunkt i ”salgspris per kilogram multiplisert med antall kilogram ulovlig stående biomasse, fratrukket fôrkostnader og andre variabler”. Av effektivitetshensyn er beregningen gjort standardisert, slik at man benytter gjennomsnittlige priser, fôrfaktorer og variable kostnader (forsikringskostnader og slaktekostnader inkl. fraktkostnader) basert på blant annet offisiell statistikk fra Sjømatrådet og Fiskeridirektoratets lønnsomhetsundersøkelse.

Overtrederen har likevel anledning til å dokumentere ”reelle variable kostnader, herunder fôrkostnader og oppnådd salgspris”. Hvis tilstrekkelig dokumentasjon på slike kostnader foreligger, skal disse legges til grunn fremfor de standardiserte satser. Dette bør gjøres dersom det foreligger et ikke ubetydelig avvik mellom reell netto utbytte og netto utbytte beregnet etter standardisert fremgangsmåte. Igjen er det derfor viktig at oppdretter sørger for god dokumentasjon for slike kostnader.

Det gis i følge lovens forarbeider ikke fradrag for andre variable kostnader enn forsikringskostnader og slaktekostnader inkl. fraktkostnader. Eksempler på hva som ikke dekkes er innkjøp av smolt, lønns- og driftskostnader mv.

Forvaltningsrettslig klage og domstolprøving

Fiskeridirektoratets beslutning om administrativ inndragning av utbytte treffes gjennom vedtak, som kan påklages til klageorgan på vanlig måte. Det kan videre reises søksmål om gyldigheten av forvaltningsvedtaket. I saker om gyldigheten om vedtak om inndragning av utbytte, kan retten prøve alle sider av saken, og kan avsi dom for realitet i saken, jf. akvakulturloven § 29a fjerde ledd. I dette ligger at retten kan prøve blant annet forvaltningens skjønn i forbindelse med om det skal fattes vedtak om administrativ inndragning (eller ikke), og fastsettelsen/utmålingen av inndragningsbeløpets størrelse.

I akvakulturloven § 33a er departementet gitt hjemmel til gjennom forskrifter å fastsette at en part må reise søksmål innen seks måneder fra han fikk kunnskap om endelig vedtak. Bestemmelsen ble tatt inn i loven ved lov 21. juni 2013 nr. 74 om endringer i akvakulturloven, og departementet har foreløpig ikke fastsatt slike søksmålsfrister.

Om forfatteren

Bjørn Ivar Bendiksen
Bjørn Ivar Bendiksen Bjørn-Ivar Bendiksen er senioradvokat ved SANDS i Tromsø og nestleder for firmaets faggruppe for fiskeri/havbruk. Han bistår sjømatnæringen og øvrige maritime næringer bl.a. med kontakt opp mot fiskeri/havbruksmyndighetene, lokalitetsklarering, spørsmål knyttet til tillatelser/drift/sanksjoner, bransjespesifikke kontrakter, nybygg og overdragelse av virksomhet/rettigheter/fartøy og andre problemstillinger innenfor næringen.

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