The Agriculture (Wales) Bill – greater clarity and ambition needed (part 1)
The Agriculture (Wales) Bill was introduced in September 2022. Despite various rounds of consultations and iterations of what the future of agriculture, agricultural policy and support could look like in Wales, 8 key concerns (some of them major) remain in the current proposal. This first blog post introduces our first three concerns (some of them echoed in the ETRA Committee report on Agriculture (Wales) Bill), which all have to do with the concept at the centre of the Bill, ‘Sustainable land management’ (SLM). We argue that SLM is ill-defined, without a clear sense of purpose or a justification of its role. Further, as it stands, SLM is lacking regarding public health, food consumption and rural development. While the Bill’s provisions on SLM could be somewhat improved, it would be preferable to replace SLM outright with the broader and more inclusive objective of social-ecological resilience.
1. We need a clearer structure and definition of core principle
There is no context or explanation in the Bill first as to why SLM was chosen to be at its centre; there is indeed not even an explanation that SLM is actually the framework/approach for agriculture and farm support. It is only when reading the Explanatory Memorandum that this is clarified.
A clear definition of SLM – or any alternative concept – should either be included in the Bill or the Bill should place a duty on the Minister to write a statement that includes a chosen definition. The latter option would enable the definition to evolve over time rather than being stuck in hard law, but would enable future Ministers to modify such definition without full Parliamentary scrutiny, thereby potentially creating instability and uncertainty.
It should also be clarified within the Bill that the concept is the underpinning objective, if this is to be the case.
2. The proposed Sustainable Land Management objectives have major gaps
SLM is structured around four objectives, with major gaps. The first objective – production of food and other goods in a sustainable manner – only addresses partially the problem facing the agri-food supply chain, as it does not tackle food consumption or nutrient recovery/waste. Sustainable food production and consumption are two sides of the same coin and emphasising the importance of producing healthy, nutritious, high-quality food would address public health issues, especially around obesity and alcohol consumption. It is questionable (on moral and public health grounds) whether farmers should be supported to produce commodities such as apple, hop or barley that result in alcohol production – bearing in mind the cost to the taxpayer who effectively supports farmers financially for their production but also afterwards when financing the NHS.
Despite the fourth objective on the conservation, promotion and enhancement of the countryside and cultural resources, public access, and the Welsh language, there is nothing directly addressing rural development and rural communities.
3. It’s time for social-ecological resilience
Consequently, ‘Sustainable land management’ is not ambitious or holistic enough as an underpinning concept – the Bill should espouse social-ecological resilience instead. Sustainable land management (SLM) is not a ‘bad’ concept, but more is needed. Agriculture, the community, the environment and the land are all stretched and under considerable pressures.
Any adopted concept should be (i) tailored to the capacities and needs of Welsh agriculture, (ii) forward-looking, able to address changes as they arise (future-proofed) and (iii) be coherent with the aims and spirit of the Well-Being of Future Generations Act 2015 and the Environment (Wales) Act 2016. Now is the time to be ambitious and create a Welsh agricultural policy and resulting payments that are fit for the 21st century. Sticking to what we know simply won’t do anymore.
Choosing an alternative such as social-ecological resilience allows for tailored, forward-looking approaches that also reflect the links with the Well-Being of Future Generations Act, and the Environment (Wales) Act. It is not just either economic resilience or ecological resilience, but resilience across the board including the ecosystem (soil, water, air, plants, microbes etc), farms, farmers, communities, supply chains and fundamentally also resilience of policies and legal and political systems. If any component breaks/cannot absorb shocks, then this endangers the entire system – highlighting the approach’s holistic nature. It also leads to greater emphasis on practices such as regenerative agriculture (more in point 5 in forthcoming second post). Further, it calls for meaningful engagement of stakeholders, with processes, goals and criteria co-designed and co-delivered in a way that ensures policy is tailored in light of the context – yet without simply off-loading responsibility or accountability by politicians/the state or leading to regulatory capture.
Clearly, if such a concept is adopted, then the Bill should address the concerns regarding definition, purpose, role etc in integrating the concept and using it to underpin agricultural policy – without such clarity, the full potential of the concept would risk being limited and undermined.
Centring the Bill on a concept such as social-ecological resilience would have positive knock-on effects, especially in developing the objectives and purposes for financial support and would more directly enable the financing of rural development. This is developed further in our second blog post which looks at how support and advice needs to be recalibrated.