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A response to the Sustainable Farming Scheme (SFS) Consultation

A summary of the Stump Up For Trees response to the SFS Consultation.

The Welsh government's Sustainable Farming Scheme (SFS) will be one of the biggest changes to land management policy in decades. SUFT submitted a response to the consultation on the key questions that directly relate to our primary activities – as a charity led by the farming community, directly involved in ecological restoration and sustainable land management for nature. We have given our consent for the full response to be made public as part of the consultation. For accessibility, however, we have written (below) a summary of the key points raised. We are supportive of a participatory approach to policy design, and the emphasis of our response is to highlight key concerns and provide constructive criticism.


It is important that any decisions are driven and determined by the farming community to ensure the benefits of the SFS extend to future generations. This should also include a more open acknowledgement of the potential change, adaptation and resilience that may be required across farming with the impact of climate changes in Wales. 

Many of the proposed ‘Universal Actions’ are structured around restrictions, rather than supportive adaptation and the monitoring of change. Applying a mentoring approach, not a mandatory approach, and allowing choice would strengthen support for the SFS. It would also ensure that actions to improve the economic resilience of farms, including woodland and habitat, are taken.

10% tree cover

Policies make long-term, landscape-scale change, including woodland in policy change ensures the effects are multi-generational. As a woodland creation charity, we would encourage increasing tree cover across Wales. However, importantly and significantly, we do not believe that a 10% rule can or should be applied to every farm in Wales. This rule does not consider farm viability, the place-based impacts and characteristics of landscape or landscape change.

We would not advise a specific % target be applied to each individual farm: this level of generalisation risks setting an average target that applies anywhere, yet is ultimately unsuitable everywhere. A large number of farms could and should have significantly greater than 10% tree cover. A large number of farms should have less. We would suggest reviewing country-wide tree cover to water catchments. This has significant benefits for a better understanding of water quality and flood mitigation. In addition, administrative bodies already exist to manage these catchments. This could then be included as part of the collaborative, rather than individual actions. The potential for increased tree cover could be included as an individual action, but all farms be given firstly, access to advice and support to identify how this can improve the farmed landscape; and secondly, be given the option for demonstrating alternative management plans to improve environmental outputs and meet targets in alternative ways, if suitable (i.e. carbon sequestration through soil management, environmental improvements through increased hedgerow/shelterbelt or other habitat improvements such as improved peatland).


There is no good reason to exclude hedgerows from tree cover. If the core purpose is to meet carbon sequestration targets, the recent and increasing evidence of the carbon capture of hedgerows, the different impacts of the wide range of hedgerow management styles, and the impacts on soil carbon need to be considered. 

Hedgerow management (UA11)

Further review of this Universal Action is needed. It does not appear to reflect either the structural or environmental importance of hedgerows within the Welsh rural landscape. The variation in hedgerow types makes hedgerows one of the most significant environmental habitats in this country. For example, an ancient hedgerow with significant gaps may hold some of the oldest tree species in any given area. This Universal Action would require them to be felled and replanted, damaging a significant habitat. In addition, farmers should lead design choices supported by a review of the local landscape. Centralised specification should be avoided (some of the best quality hedgerows in the South East are, for example, Beech). Hedgerow design is a place-based, cultural and environmental decision that should not be prescribed. Some of the requirements of this action are also contradictory or unachievable. A 5yr-old hedgerow will not be stockproof; ongoing maintenance and management is needed to ensure this.

Woodland maintenance (UA12)

This action has the potential to bring back into management small farm woodlands – an aim and a potential benefit across the countryside, which has the potential of bringing new energy to landscapes and communities. The only key amendment would be that new tracks may be necessary within woodlands if any ability to manage them is going to be developed.

Welsh language

There is no inclusion of key Welsh habitats of Coed-Cae and Fridd (see Oliver Rackhams ‘Ancient Woodlands of South-East Wales’ for a good explanation of Coed Cae). This is disappointing given the apparent desire to support Welsh language and culture. These two habitats are a good example of the unsuitability of the Phase 1 habitat classifications in implementing the SFS (as the only extensively available mapping for a habitat review). There are no direct translations in English of these habitats (‘scrub’ is not a fully suitable replacement for Fridd). They have, therefore, not been included in the habitat classifications and have never been properly included in mapping. The current mapping of habitat and priority habitat has poor coverage across Wales, and the exclusion of these habitats, which are important both culturally and environmentally, is a further issue. Their exclusion from mapping has resulted in their significant loss and removal due to the preceding subsidies of CAP and BPS. Furthering this in the SFS would be a tragedy.

Landscape naming is a key aspect of Welsh cultural heritage (see the importance of re-naming Eyri and the Bannau Brycheiniog). Landscape features in Welsh, farming practices, may have a huge potential to inform the SFS and make it more appropriate for Wales. The inclusion of these habitats may, in turn, help support and strengthen Welsh language knowledge and communities.

Common Land

Managing Common Land is hard work. It takes a lot of time and is difficult. That means that more resources should be allocated to it rather than less. A collaborative approach that rewards management rather than ownership could benefit the rural community significantly.  This could encourage management uptake by tenants and communities alongside, rather than prioritising, the often highly wealthy major landowners. Landowners who, on the Welsh commons, are largely uninterested in the actual management of the land which is undertaken by the active graziers (it would be great to extend this definition from grazier to common land manager, and to therefore include a wider range of habitat management).

Habitat baseline review being undertaken during 2024

Serious reflection is needed on whether there is the ability to conduct a Habitat Baseline Review, bearing in mind that the maps currently in use are significantly out of date (the dates of surveys can be reviewed via Datamap Wales - many are over 30 years old and no longer relevant). The accuracy and efficacy of a final product would be questionable. There is limited expertise and resources for completing new surveys, and many of the approaches used are problematic for an agricultural review, where practice may be more important than classification.

For more information about the consultation itself see the Welsh Goverments pages here:

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