Members of the Farmers' Union of Wales's common land committee have expressed extreme concern about the implications of the Welsh Assembly Government's (WAG) new Glastir scheme for upland communities.
Committee chairman, Rhymney farmer Lorraine Howells, has now written to Assembly opposition environment and agriculture party spokesmen stressing the disruption that the introduction of Glastir after 2011 could cause for upland communities which rely on common land.
"While we would encourage every commoner and graziers' association to look into the possibility of getting their common into the Glastir scheme, we have major concerns about the practicality of doing this for many commons," she said.
"The introduction of the Glastir scheme represents one of the most significant changes for upland communities seen for more than half a century, and failure to enter the scheme will represent the loss of vast sums of money for some local economies."
Miss Howells explained that the vast majority of common land - about eight per cent of Wales's total land area - is categorised as Less Favoured, and 18 per cent of Welsh farmers declare common land on their Single Application Forms. "In some areas, communities are almost entirely reliant on their common grazing rights.
"Recognition of the specific handicaps faced on such land, and the risk of land abandonment and rural depopulation, led to the Hill Farming Act being passed in the immediate post-war period, and has effectively meant support for these areas since the introduction of the 1947 Agricultural Act. However, the introduction of the Glastir scheme represents the abandonment of such payments.
"The EU rules associated with agri-environmental schemes, which are far more restrictive than those which apply to Less Favoured Area payments, bring with them inherent difficulties for common land as they do not properly take into account the unique nature of common land management in the UK."
During the committee meeting members expressed concern that, while there may well be commons where the majority agree that they want, or have little financial alternatives but to sign up to Glastir, the chances of this majority being large enough to meet the 80% criteria set by WAG and the EC may be slim.
"Even if more than 80% do agree to participate, many feel that they will still not take the risk of entering the scheme and incurring penalties as a result of the actions of the minority who decide they wish to continue exercising their full legal rights to graze an individual common."
There is also the concern that those who rely upon common land for 365 days a year, because they have relatively little normal farmland, will be unable to enter the Glastir scheme without reducing their stocking numbers to the extent that their businesses become unviable, and that this will preclude participation.
Members were also concerned that the WAG's decision will mean competitors in other regions of Europe will continue to receive LFA payments which aid production, while Welsh farmers who face similar handicaps will have to make their farms less productive to access equivalent funds, thus undermining the very principles of the European Common Market.
"The FUW has long argued that the Tir Mynydd scheme should be continued, and that any necessary changes should be made over a prolonged period, by adapting the current LFA scheme, as was proposed in the relevant WAG consultation and supported by the Rural Development Sub Committee," said Miss Howells.
"We have also called for delaying the implementation of the Glastir scheme by 12 months in order to seek ways to address the numerous concerns we have; a move which would also ease the significant pressures that implementing Glastir over such a short timescale represents for WAG staff at a time of significant budgetary pressures.
"The union's reasoning for adopting these positions remains completely valid and, as various deadlines approach and changes continue to be made to the scheme, our concern that the implementation timetable is inappropriate grows.
"These concerns have already been made clear to Rural Affairs Minister Elin Jones and her officials. However, the committee felt it was important to reiterate these to opposition spokesmen."