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					                                                                                       Our Ref:     JCC/PS/JW
                                                                                       Your Ref:    -

Dr Andrew Kruszewski
OST Science Review Team
Office of Science and Technology
Bay 307, 1 Victoria Street
London SW1H 0ET

by email:                                             13 April 2005

Dear Dr Kruszewski


I refer to your letter of 19 January 2005 to our Chief Executive, Dr Campbell Gemmell.

The Scottish Environment Protection Agency (SEPA) is grateful for the opportunity to respond to the
Office of Science and Technology‟s review of science in DEFRA.

SEPA interacts with DEFRA on many levels and in many guises. In particular we liaise with the global
atmosphere division, the Chief Scientific Officer Advisor, the representatives involved with the UK
Environment Research Funders‟ Forum (ERFF) and we interact in other ways through appropriate staff
within the Scottish Executive.

SEPA was involved in consultation during the development process and was broadly very supportive of
the DEFRA science strategy. We perceive that the strategy has continued to improve the
understanding and input of science in DEFRA‟s policy making.

Our detailed comments are attached in Appendix 1.

SEPA will be pleased to provide any further information, if requested, and we would wish to engage in
consultation on future strategy drafts.

As a public body committed to openness and transparency, SEPA feels it is appropriate that this
response be placed on the public record.   If you require further clarification on any aspect of this
correspondence, please contact Peter Singleton, Emerging Issues Unit Manager, SEPA Corporate
Office, at the address shown below.

Yours sincerely

Professor James C Curran
Head of Environmental Strategy


                                                             Corporate Office
                                                             Erskine Court, Castle Business Park, Stirling FK9 4TR
                     Chairman          Chief Executive       tel 01786 457700 fax 01786 446885
                     Sir Ken Collins   Dr Campbell Gemmell

                                             Appendix 1

                Office of Science and Technology Review of Science
                                     in DEFRA

Questions: How effectively the Department:

1.     has developed a clear, overall science strategy

We are generally very supportive of DEFRA‟s science strategy. We think there was a good consultative
process during its formulation, and it was apparent to us how the various priorities were arrived at and
resolved. The strategy seems clear and straightforward. Admittedly we have little information as to
subsequent detailed delivery.

2.     ‘horizon scans’ to identify future science-related issues

DEFRA has one of the leading “horizon scanning” groups within environmental science in the UK.
SEPA has found both the DEFRA horizon scanning team and the DEFRA horizon scanning research
programme useful and thought provoking and the output has been used constructively in helping us to
develop our own environmental vision, and subsequent corporate vision, as part of our long-term
business planning. It has been recognised by ERFF that horizon scanning is an activity of strategic
importance. SEPA is keen to maintain and improve links with this and other such groups in the UK.
The issue of how to manage this effectively and to network appropriately, at a distance, has yet to be
fully resolved.

3.    reviews and harnesses existing research and identifies gaps and opportunities for future

SEPA is aware that this is a significant issue for all procurers of research; how does an organisation
ensure the work it requires has not already been carried out elsewhere, and how does it ensure that
new work builds sufficiently on previous work?          Both SEPA and DEFRA are members of the
Environment Research Funders‟ Forum (ERFF) which, at a strategic level, exists to ensure that funders
are aware of each others‟ programmes and research needs and that added value and synergy is
captured. However, at a project level in the UK, this is generally carried out by having peer review of
proposed research projects. Whilst SEPA has not been asked to perform this for DEFRA led research
(although we perform a similar role for the Scottish Executive‟s equivalent department), we are very
interested in how successful DEFRA is judged to be at this task, and if there are any general lessons
that can be learned as part of this review.

4.      commissions and manages new research

SEPA has limited involvement with DEFRA commissioned research. Our main issue in this area is
establishing and maintaining relevant and effective lines of communication between DEFRA and
agencies of devolved administrations within the UK. On occasion there have been projects, about
which SEPA has not been informed, failing to address specific issues which we could have suggested –
thereby potentially resulting in more holistic, cost-effective and robust outputs.1

5.      ensures quality and relevance of the work it carries out and sponsors

No specific comment, but SEPA is very interested in best practice in this area, particularly in relation to
research and development projects.

6.      uses research and scientific advice, for example in formulating policy

SEPA is interested in the current debates about the development of evidence-based policy or the
facilitating of science into policy. It is our perception that science does not always drive policy
considerations. Science is introduced further along the pathway, either to substantiate or discredit
policy initiatives. We feel there should be a more strategic role for science to identify the critical issues
which require policy development. In addition, we perceive that a robust scientific analysis is not used
to determine more precisely the nature of a policy development. For example, we are concerned that
different environmental problems, or indeed environmental directives from Europe requiring
transposition, often stimulate rather similar, well-rehearsed policy or regulatory responses – rather than
taking a fresh, innovative look at the best and most appropriate policy/regulatory tools to adopt. We are
thinking particularly of the need to introduce smart regulation which delivers contemporaneous
environmental, social and economic benefits, in order to promote sustainable development.

7.      publishes results and debates their implications openly

It appears that enormous advances have been made in the openness, transparency and public debate
of environmental research findings. It is pleasing to note the first signs of a return of public confidence
in government-led environmental science.

  Follow-up comments from SEPA:
“SEPA is a „little brother‟ to Defra and sometimes feels left out of the loop. For example, Defra will commission a
piece of research that – with a small change in scope – could also be very helpful to SEPA. But because Defra did
not consult SEPA about the research scope, that extra useful piece was not added and an opportunity for cost
effective joint sponsoring was lost.
This is mostly an issue of communications between DEFRA and SEPA and both sides have room to improve – it‟s
not solely a Defra problem. The creation of bodies such as ERFF has helped a lot at the very top level and this
opens the way for more intensive contact at lower levels. But so far, at the lower (project officer) levels, there is still
a problem.
Defra does sometimes ask but less often appears to listen and act. If it followed up more by saying “we heard you
and we have taken the following action” then more people would be encouraged to make the effort to
communicate with Defra.
The situation varies greatly across Defra. In soils research there is a very good relationship – perhaps because
this is a rather new policy area and everyone has had to work together to get started. It is in the more established
areas that the lack of communication is most apparent.
Distance (Scotland-London) is a contributory factor. Videoconferencing should help but often it seems Defra is
unable to make its facilities work.
Overall, the situation has improved over the past 5 – 10 years though it‟s hard to say why. Possibly it‟s just that the
growing maturity of SEPA makes it easier.”

8.     shares, transfers and manages knowledge

There is a marked difference between sharing information, making results available, holding
consultation, and having an informed and open debate. This is an area where many departments and
agencies struggle; DEFRA possibly manages better than most. However, this is an area where all
departments can improve and SEPA would be interested in the review team‟s view of “best practice”.
SEPA has been instrumental in suggesting electronic, targeted-audience, drill-down, dissemination of
outputs by the Scotland & Northern Ireland Forum for Environmental Research (SNIFFER) and also the
Foundation for Water Research (FWR). These electronic services seem popular with users.

9.     has implemented the guidance contained in Guidelines 2000 and the Code of Practice for
Scientific Advisory Committees

No comment.

10.    uses, maintains and develops scientific expertise (including both capacity and capacity

No comment.

13 April 2005

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