The Welsh Government's consultation on the future of farm payments closes in just six days. The consultation paper can be viewed by clicking here.
You can respond to the consultation by emailing your comments to FfermioCynaliadwy.
The FUW has consulted with its County Branches and Standing Committees, and will be submitting a detailed response, but key concerns and comments highlighted by Committee Members include the following, which you may wish to consider:
1. The consultative nature of the Welsh Government's consultation is welcome
2. The Welsh Government is right to acknowledge that rushing forward with designing a new scheme would be foolish at a time when we do not know what the trading and economic landscape will look like after Brexit - so is right not to propose not committing to a timetable
3. Modelling should be very thorough before any decisions are made and must place far more focus on rural jobs and businesses than has happened to date - the Welsh Government and Assembly must be aware of all the possible implications of any decisions to avoid the risk of severe adverse impacts which would contravene Wales' Wellbeing Goals
4. The current RPW Online and SAF system is state of the art. We need to develop this into something better and more targeted, not phase it out and replace it with Public Goods contracts which would be many times more complex to administer
5. Public Goods deliver against only some of the seven Future Wellbeing of Generations goals, so they should form part of a scheme or schemes - focussing only on Public Goods means many Wellbeing Goals will be ignored - prosperity, jobs, culture and equality for example
6. In this context, Labour Shadow Farming Minister David Drew was right to have highlighted at the recent Labour Party Conference that Public Goods should only be one element of a future policy, and that "...from a social justice point of view [farmers] would need to be supported with more than just environmental payments after Brexit."
7. The Welsh Government's figures show 43% of people employed in agriculture speak Welsh - well above the percentage of any other type of employment. A scheme focussing on Public Goods would threaten the farming industry, and by definition threaten the industry in which Welsh is most preserved
8. Competitors in other countries and regions will continue to receive direct support, whereas the current proposals imply that Welsh farmers will have to comply with many times more rules and restrictions, and work harder and lose more agricultural land, to get payments. This would cleary place Welsh farmers at a competitive disadvantage
9. A scheme focussed only on Public Goods would breach the Wellbeing goal of equality because it would disadvantage tenant farmers who are our most efficient but also our most vulnerable farmers. This is because delivering Public Goods often or invariably goes against the interests of a landlord or the terms of a tenancy agreement.
10. A large proportion of Welsh farms rely on common grazing. Public Goods payments would reduce the access to payments currently inherent to the Basic Payment Scheme, as many public goods are unrelated to the legal rights of graziers. This would transfer power and the right to claim payments away from active farmers to the owners of common land, which would be unacceptable
11. Commons Councils represent an extremely costly, bureaucratic and burdensome means by which to manage most Welsh commons, and any requirement to form such Councils to access payments would disenfranchise and discriminate against graziers compared with their non-commoner counterparts - again leading to discrimination
12. Wales should follow the EU by seeking to strengthen the Active Farmer criteria, as active farmers deliver most in terms of supporting the rural economy, creating employment, spending money on other Welsh businesses, protecting Welsh society and enhancing the environment. Less activity means less of these benefits.
13. Protecting family farms and food production must be placed at the heart of any future policy: Wales should do all it can to avoid the declines in family farming and family farms seen especially in parts of England, where large companies have effectively taken over vast areas to the detriment of rural communities and society in general
14. Payments must be capped in order to help protect the reputation of any scheme and to ensure money is directed at family farms rather than allowing the sort of unlimited payments which investors and companies have taken advantage of in England, to the detriment of family farms, communities and the reputation of the CAP in general.