These mass appeals have had the effect of freezing SEPA’s new licence conditions, meaning strengthened environmental safeguards for wild salmon and sea trout will not come into force until the legal process concludes.

Each appeal has generated substantial documentation. Initial analysis suggests thousands of documents have now been submitted across the cases to the Scottish government’s Directorate for Environmental Appeals and Reviews (DPEA), creating considerable pressure on an already resource-intensive process.

A preliminary was held last week, where the Scottish government reporter identified and clarified the legal issues to be examined. WildFish did not submit material to this procedural stage but is closely monitoring the appeals given the implications for wild salmon conservation.

Before the hearing, the salmon-farming sector stated that it is “disappointing that the latest of many SEPA consultations includes a focus on sea lice” and has claimed that “sea lice levels [are] now among the lowest on record”, asserting that a SEPA official denied a link between wild salmon declines and sea-lice emissions in 2020.

WildFish believes this presents a misleading picture. The Scottish government’s own 2021 scientific review concluded that “the body of scientific information indicates that there is a risk that sea lice from aquaculture facilities negatively affect populations of salmon and sea trout on the west coast of Scotland”.

Sea lice attach to passing fish, eating and eroding their skin and fins, increasing susceptibility to disease and predation, and significantly reducing their chances of survival. Recent analysis of official data shows persistent breaches of lice levels set by the salmon-farming industry’s own Code of Good Practice during 2025. According to official data, more than 20 farms are currently exceeding their stated lice thresholds. While this is outside the spring smolt migration, elevated lice levels pose a threat to resident sea-trout populations, which remain in severe decline.

Nick Underdown, Scotland director at WildFish, said: “Sea-lice from open-net salmon farms are a recognised threat to Scotland’s wild salmon and sea trout. SEPA’s new licence conditions were a long-overdue – albeit still inadequate – step towards better environmental protection. Yet their implementation has been frozen by over 200 industry appeals.

“Every fish counts. Wild salmon and sea trout need the best possible chance of survival if their populations are to recover from their tragically depleted levels. The industry’s resistance to tighter sea-lice regulation raises serious concerns about whether environmental safeguards can be stalled through procedural overload. This process must be transparent, accountable, and focused on delivering urgent protection for wild fish.”