National Farmers' Union (NFU) Cymru has warned that the Welsh Government's greenhouse gas emissions consultation is likely to have been overshadowed by the ongoing 'Brexit and Our Land consultation'.
The union accused the Government of bad timing as well as unfairly putting much of the burden of environmental issues on to farmers and said that there was a lack of detail over the impacts of the level of afforestation planned.
The ‘Achieving our low-carbon pathway to 2030’ consultation, which closed on October 4, set out the actions that need to be developed and implemented at a sectoral level to reach the overall 2030 target of a 45% emissions reduction.
The consultation contains proposals for power, transport, buildings, agriculture, land use and forestry, as well as the public sector and waste.
The proposals include 66,000ha of additional tree planting to be implemented at a rate of 2,000-4,000ha a year on Welsh land.
Around 90% of this has been suggested to come from afforestation with 10% taking the form of agro-forestry.
Commenting on proposals, NFU Cymru Rural Affairs Board chairman Hedd Pugh said: “To put Welsh Government proposals into context, the Welsh Government Woodland Estate extends to 126,000ha currently.
"The average farm size in Wales is 48ha. To achieve afforestation on the scale proposed will require the complete afforestation of some 1,400 farms in Wales.”
He added: “It is highly concerning that Welsh Government appears to have made no assessment of the impact on the farming families affected, our rural communities and the economy or indeed the environment by opting not to publish a regulatory impact assessment alongside the consultation.
"In the absence of this assessment, we remain wholly unconvinced that the Welsh Government is seeking to strike an appropriate balance between decarbonisation and meeting wider economic, environmental, social and cultural objectives.
“There can be no doubt that Welsh Government plans to use the future land management programme as proposed in their ‘Brexit and Our Land’ consultation as the mechanism to drive this land use change.
The timing of proposals is very disappointing given that we are currently mid-way through consulting our members on the ‘Brexit and Our Land’ consultation.
"This is undoubtedly the most significant consultation for Welsh farming in a generation and farmers will rightly have all their attention focussed on that consultation.
"There can be no doubt that this has over-shadowed the proposals for decarbonisation. There is also a distinct lack of detail on the scale of land use changes required to meet the Welsh Government low-carbon agenda in ‘Brexit and Our Land’.
Overall, as farmers, we recognise the very important role that we have to play in contributing to the decarbonisation agenda in Wales. However, this burden must not fall unequally on the farming sector or on our rural communities.
"Nor must targets in Wales be achieved by ‘off-shoring’ food production to other parts of the world. This would be a wholly unsustainable position for Welsh Government to adopt and not align with the Paris Climate Agreement in 2015 which recognises the fundamental priority of safeguarding food security.
“There can be no doubt that Brexit and Our Land’ is the most significant consultation for Welsh farming in a generation. We urge all farmers to consider the proposals and get involved in the consultation process ahead of the consultation closing date on October 30.”