Our response to Welsh Government’s Sustainable Farming Scheme consultation

We are supportive of some of the proposals and actions of the Sustainable Farming Scheme in Wales. This is a specialist consultation and we have focussed where we can add a water customer-focussed perspective to the development of a government scheme that could help:

1. Finance and implement well supported, nature based solutions that contribute to water quality improvement at a catchment level, and as part of collaborative action by the water industry, communities and other sectors.
2. Farmers, as business customers who we represent, to:
   • Deliver actions that help them reduce water pollution, and
   • Increase their available water supply and business resilience to climate change challenges.

Summary of our key points

• The implementation of the Scheme would be strengthened through a collaborative, catchment management approach from the beginning of its operation to include farmers supported and not supported by the scheme.
• Collaborative implementation should start immediately (as early as 2024) rather than wait for the second tranche of the Scheme’s implementation particularly in locations or catchments where it would contribute to effective, long-term pollution reduction and farming business resilience. This should seek to involve communities, the water industry and other sectors in the delivery of actions.
• Some of the optional actions outlined in the consultation could help slow rainwater flow to reduce flooding and run off pollution risk. These would complement some nature-based water management solutions that the Scheme’s universal actions would help implement, e.g. such as soil health planning, multispecies cover crop, peatland and hedgerow management and quite importantly woodland management (Q12). With this in mind, we consider that the following optional actions should be prioritised:
  • Capital support to manage and harvest water supplies
  • Additional ponds and scrapes
  • Leaky/dam and wet sites infrastructure actions.
• Additional subsidies for optional and collaborative actions should:
  • Enable collaboration between participating and non-participating farmers to the scheme (as the consultation suggests).
  • Go further to support and incentivise collaboration with other land users and sectors, e.g. the water industry, local communities.
  • Incentivise their combined implementation with universal actions that might help accelerate the improvement of water quality and resilience to drought and climate change challenges).
• The economic analysis and modelling of the scheme should consider evidence from pilots and demonstrator projects. For example, there may be opportunities to cost and test the effectiveness of some of the consultation’s proposed actions through the Teifi Demonstrator catchment project.