Concerns have been raised that the Welsh government's proposed Sustainable Farming Scheme (SFS) continues to ignore domestic food production at a time of global crisis.
NFU Cymru has reaffirmed its position that the Welsh government must recognise that tree planting and habitat creation "often represent a permanent change in land use".
The union submitted its response to the devolved government’s consultation for the post-Brexit support scheme, announced in 2019 and set to replace the BPS and Glastir from 2025.
NFU Cymru broadly welcomed the proposals for a universal set of actions that all farmers undertake in return for an annual universal baseline payment, but questioned whether these actions are realistic and deliverable for every farmer.
The union has been clear in its response to the proposals that the Welsh government must revise some of the universal actions it is proposing.
For example, proposals for all farmers to achieve 10% tree cover and 10% habitat, have been widely rejected by the union’s membership.
NFU Cymru maintains that there are 'many practical reasons' why such targets will "prove impossible to achieve on the ground, disadvantaging farmers".
NFU Cymru President Aled Jones said: “As a globally responsible nation we must ensure that proposals for increased tree cover and habitat are not achieved at the expense of food production.
"I remain concerned that the SFS continues to lack outcomes to ensure levels of domestic food production are maintained and enhanced to ensure the stable supply of safe, high quality, affordable food in Wales."
The union also remains particularly concerned that many tenant farmers and those with common land rights will find it difficult to meet the scheme’s requirements.
Mr Jones said: “Our support is very much dependent upon Welsh government developing a set of universal actions that are practical and achievable for all farmers in Wales, irrespective of sector, land type and location.
"NFU Cymru is clear that the universal actions as currently proposed do not meet this objective," he said.
The government’s proposals for the universal actions to be delivered via multi-annual contracts, for example, represent a significant change from the Basic Payment Scheme.
There are industry concerns that the new scheme is likely to represent a barrier to entry for farmers who do not own the land that they farm.
How equal access to the scheme is to be secured for tenant farmers and farmers with common land rights remains a key issue to be addressed by the government.
NFU Cymru says that support must be targeted at active farmers - the people and businesses taking the risks associated with food production.
Mr Jones added: “Whilst progress has been made there is clearly significantly more work to do to translate proposals into an operational and attractive scheme that farmers across Wales and in all sectors will be able to participate in.”