The Farmers' Union of Wales has written to deputy minister for agriculture Alun Davies highlighting key areas of concern in draft CAP proposals leaked from the European Commission.

The document, when finalised, will lay down the rules for future direct payments to farmers throughout Europe, and could have far-reaching consequences for Welsh farmers if left unaltered, the union claimed.

Speaking at the Pembrokeshire County show (today, August 16), FUW president Emyr Jones said: "This is a very early and incomplete draft Regulation, and our priority at this stage is to take the opportunity to lobby for changes, and highlight to government and Brussels the impact that the Regulations would have on Welsh farmers if left unchanged."

"The Regulation implies that there is limited scope in terms of varying flat rate payments between areas, depending upon local needs. Yet we know from the modelling carried out by the Union over the past two years that having one payment rate per hectare for the whole of Wales would be disastrous, especially in areas such as Pembrokeshire where farms are, on average, smaller, yet can be just as productive as a large upland farm."

The main focus of the document relates to the abolition of the current single payment entitlement system, where farmers' payments per hectare vary depending upon their historical payments, and its replacement during a 5 year transition period with payments per hectare which are identical throughout a region (such as Wales). The union claims that 5 years is nowhere near long enough to minimise disruption, and that much more flexibility is required in terms of varying payments between geographic regions.

Mr Jones also expressed concern regarding the particular implications for dairy farmers, and the dairy industry as a whole, in the absence of a Regulation which takes account of local needs.

"In areas such as Pembrokeshire, where the dairy industry is so important in terms of rural communities and local employment, any move to an overly simplistic flat rate payment based upon the Welsh average could be devastating.

"The dairy industry is already reeling from the impact of high input costs and low milk prices, and a move to a flat rate payment would make many businesses simply unsustainable", added Mr Jones.

Mr Jones was also severely critical of the suggestion that half of all individual payments made in the first year (2014) be based upon the Welsh average payment per hectare.

"We find it incomprehensible that such a figure is being stipulated, and cannot understand why the flexibility which was afforded to areas such as England under the original Regulations is not being suggested in regions such as Wales which opted to keep the historical payment system."

In its response to the minister, the union suggested that proposals to scrap and replace current single payment entitlements 'overnight' constituted anything but a gradual transition towards flat rate payments.

"The approach would presumably mean a business losing all its historical entitlements overnight, and being awarded a new number of entitlements based upon the land claimed in the first year of the scheme.

"This seems like a very awkward way of administering the transition, and it takes little account of the flexibility businesses need in terms of taking on extra land or letting it go from year to year," said Mr Jones.

The Union has therefore suggested a genuine 'soft-landing' approach over a period far longer than five years, during which farmers should be allowed to continue to use the entitlements they currently hold, while those entitlements would gradually fall in value as the element of direct payments based upon a flat rate increases.

"It is important to highlight concerns such as these at the earliest opportunity, and we have also sent a copy of our initial analysis Welsh MEPs and the English minister for their consideration" added Mr Jones.

The Farmers’ Union of Wales will stage a "Farming and Rural Forum" at 11am on Thursday (August 18) on their stand at the Denbigh and Flint County Show.

The panel will comprise Llyr Huws Gruffydd, Plaid Cymru AM for North Wales; Mark Isherwood, Conservative AM for North Wales; and David Hanson, Labour MP for Delyn, along with David Jones, Principle of the Llysfasi Agriculture College.

FUW’s Denbighshire county chairman Clwyd Spencer, who will chair the forum, said: "When more and more pressure is put upon rural services, and with agriculture being the main industry and employer in these areas, the union strongly believes it is important for members, and residents in rural areas, to be given the opportunity to question and raise issues of concern with local, elected representatives from Cardiff Bay and Westminster.

"With no set agenda, we urge those attending the County Show to visit our stand at 11am to take part in this important forum. The issues raised, and discussed, will be dictated by those in attendance.

"This is an excellent opportunity to discuss local concerns with local politicians, and we hope for a good open debate on issues such as TB, Single Farm Payments and Rural Development, and much more”.

BCMS staff will also be present on the stand to assist and advise farmers on the new cattle passports which came into circulation on 1st August 2011.

Visitors are invited to come to the union stand in the afternoon for free strawberries and wine.

The Farmers' Union of Wales has demanded an explanation from Defra minister Jim Paice after the European Commission implied farmers' problems with sheep electronic identification (EID) are caused by the UK allowing sub-standard ear tags.

Responding to letters from the union to the EC's directorate general for health and consumers and the directorate general for agriculture and rural development, the Commission suggested that "a significant part of the problem encountered (with EID) may result from the use of bad quality ear-tags......"

It also stated that "the Commission services have repeatedly encouraged the UK competent authorities to ensure that only high quality electronic ear-tags are approved for the tagging of sheep".

Speaking at Anglesey County Show today, FUW president Emyr Jones, a Bala beef and sheep farmer, said: "Given that the EC is responsible for laying down the rules with regard to EID, they seem to be implying that tags in the UK fall below the standards set by themselves.

"We have, therefore, asked the UK Minister for assurances that this is not the case. If this is not what the Commission is implying, then it is an effective admission that the standards set by Europe are not capable of being delivered in terms of the Regulation.

"Either way, we are being forced to use a costly technology which is not fit for purpose."

Mr Jones added that any enhancement of the minimum EU tag standards by the UK authorities might be open to legal challenges, given that Europe has set a pan-European standard which should have minimised any problems with the technology.

"There may also be a problem in terms of any enhanced standard leading to the compulsory tagging of animals with small ears with larger tags than is practical or humane, leading to a massive welfare issue," he added.

Mr Jones's letter to Mr Paice states: "The FUW has long objected to the compulsory electronic identification and recording of sheep and this position was based upon evidence gathered during numerous trials which identified major shortcomings with EID technology.

"The experience of our members since EID was made compulsory has confirmed that these concerns were well founded.

"Nevertheless, the Union recognises that those Member States, such as the UK, which now object to EID represent a minority within the EU, and that efforts must therefore be made to ensure that the impact of the current Regulations are minimised, particularly in terms of penalties which may be incurred as a result of circumstances which are beyond the reasonable control of farmers.

"Given the above concerns, I would be grateful for your assurances that any allegations by the European Commission that UK sheep tags do not meet the standards set by themselves are incorrect, and that systems are in place in order to deal appropriately with any cases where tags are believed to be sub-standard."

The Farmers' Union of Wales today accused the Badger Trust of "failing to tell black from white" when dealing with basic facts about badgers after it slammed the BBC for using the trust's own badger population figures.

In a letter sent today to BBC director general Mark Thompson, the trust's chairman David Williams demands to know where the makers of a Radio 4 programme obtained an estimate of UK badger population numbers.

Mr Williams wrote: "The Trust also notes with regret that the BBC gave an unattributed assertion in the programme that the badger population has surged to an estimated 300,000.

"Please give the reference(s) for this figure and any scientific basis for the clear implication in the programme that legal protection had caused a 'surge'," the letter added.

But the figure is stated clearly in the Badger Trust's own "Eurasian Badger Factsheet" which reveals that badger numbers have increased to "a total estimated population of around 300,000".

FUW vice president Brian Walters said: "The Badger Trust has a track record of misinterpreting the science relating to badgers and bovine TB and this letter suggests they can't grasp basic facts and figures even when published by themselves.

"It confirms our suspicion that they are failing to tell black from white when it comes to all issues relating to badgers and bovine TB."