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					Dr Andrew Kruszewski
OST Science Review Team
Bay 307
1, Victoria Street

8th April 2005

                           OST Review of Science In Defra

Thank you for the opportunity to respond to the above consultation.

FARM, the independent voice of farmers, was set up in November 2002 by a group of
working farmers and professional campaigners with the stated aim of bringing farmers,
consumers and environmentalists together to develop common objectives upon which
to base a viable and sustainable future for UK farming.

FARM brings unique attributes to issues affecting agriculture by combining the practical
knowledge and input of working farmers with the specialist expertise of environmental

This submission has been researched and produced within FARM by a working
committee called the Science Review Group. Over the past 12 months our work has
involved information gathering through a number of meetings, including DEFRA’s
Sustainable Farming, Food and Fisheries Science Division and the John Innes Centre
as well as contributing to a number of related publications, including the “Just
Knowledge?” report produced by the Food Ethics Council.

Some of the points raised in this submission go beyond the specific criteria suggested in
the consultation document, but we feel that it would be a missed opportunity if these
were not addressed within the scope of the review.

Yours Sincerely,

John Turner
Chair, Science Review Group,

OST Review of Science In Defra

[1]    FARM sees scientific research and development as an investment in the future of
our sector. The “trajectory” of science defines the way farming will be encouraged to
develop, and therefore it is a crucial part of our work to help ensure that the longer-term
objectives of research and development are consistent with the practical requirements
needed to deliver models of sustainable agriculture.

[2]     In September 2003, FARM wrote to the Secretary of State, setting out a proposal
for the establishment of a Sustainable Food and Farming Research Council. The key
objectives for this proposal were a response to areas that we felt were either weak of
lacking in DEFRA’s research agenda:

      To retain a practical focus to the work that it commissions

      To ensure that those responsible for the allocation of funding represent the
       diverse range of social, economic, medical and environmental issues

      To ensure an efficient integration with other governmental departments

      To support a diverse range of scientific research establishments which includes
       those dealing with relatively “low-tech” solutions

      To promote transparent working practices to ensure that public money is used to
       promote systems of agriculture that are consistent with public aspirations.

      To provide a forum for those scientists who hold divergent views to be able to
       express them freely without fear of retribution.

[3]     The review conducted by the Public Accounts Committee, “Reaping the Rewards
of Agriculture” suggests that at government level, there is a relatively narrow set of
criteria used for measuring the returns on investment in agricultural research and
development. The emphasis placed upon intellectual property rights and spin-off
companies suggests a focus towards emergent technology and a solutions-based
approach to problem solving.

[4]   The requirements of agriculture are often more basic and key areas such as soil
science, disease vectors and basic crop husbandry often appear to play a “Cinderella”
role in comparison to emergent technologies like Genetic Modification and

[5]    In its introduction to this consultation “Why do we need this review?” the OST
cites BSE and Foot and Mouth disease as episodes that have attracted heightened
public concern about the quality of science. In both of these instances, a relatively rapid
response was needed in a situation where there was incomplete scientific
understanding. Furthermore, the erosion of farmers’ ability to exercise underlying
principles of good animal husbandry and added the pressures on biosecurity caused by
a centralised food distribution systems and a cheap food policy served to amplifying the
effects of such diseases. Nevertheless, following the experience of such crises, it is by

                   FARM     28 Penton Street, London N1 9PS          UK

no means clear whether the farming industry is currently any better equipped to avoid
such emergencies.

These general points help place the practical context within which Defra’s science work
is placed.


[6]    Although this review addresses the effectiveness of Defra’s science, there is a
lack of clarity concerning the boundaries of Defra’s remit. That is to say, it is clear that
there are overall objectives determined by government policy and other government
departments, including the OST, which frame Defra’s science agenda. Therefore where
there appear to areas for improvement, it is unclear whether this is due to a failing within
Defra, or due to wider issues of government and the interaction of government

[7]    The overall objective facing farming is to maintain its role as a source of food
production and a diverse range of other primary inputs, including those for energy, fibre
and pharmaceutical markets. This activity has to be set within a second objective of
“sustainable production” – a term open to a diverse set of interpretations, each
suggesting a very different approach towards production.

[8]     There is currently a considerable gulf between the aspirations of policy
statements regarding sustainability and their translation into practical working models.
There appears to be a similar gap between science and research and its application in
everyday farming life. What works well in a computer model or in a laboratory often fails
in the field due to the complex interaction of soils, climate, pests, disease, markets,
economics and a myriad of other variables.

[9]     Many aspects of policy concerning farming fail to recognise the central role of
farmers as those who translate policy into practice. This is in stark contrast to the
recognition afforded them in cases where blame is attributable such as diffuse water
pollution or the decline of wildlife species. Therefore, farmers often find themselves
accountable for the methods and impacts related to production, but policy, resources
and information are focussed on service industries such as water authorities,
veterinarians and the pharmaceutical and agro-chemical industry – a solutions-based
approach rather than one of prevention.

[10] The consultation highlights a number of key areas of Defra’s science policy,
including strategy, horizon scanning, commissioning research and its management. The
criteria for the terms of reference suggests a more deeply embedded culture of “science
for the sake of science” and a “top down” approach to implementation. Within this list
there appears to be a lack of priority given to understanding how knowledge is applied
in practical everyday situations and identification of the principal beneficiaries.

[11] Similarly, whilst there does appear to be effective dialogue with the food
processing industry, plant breeding and the agrochemical / biotechnology industry, there
is far less effective information gathering from those working at the applied level of
farming. Science should be informed by observation, and there is a wealth of knowledge
lying beyond the microscope and lab coats, which rarely seems to be acknowledged, let
alone harnessed.
                     FARM 28 Penton Street, London N1 9PS UK

Defra Science Policy:

[12] The change in government science policy to one of greater market focus and the
privatisation of plant-breeding and other research facilities has led to greater emphasis
being placed on solutions-based research programs. Within plant breeding, this has
resulted in a focus on the major commodity crops, in particular Wheat, Oilseed Rape
and Maize. This focus on existing market demands and upon crops where there is
relatively large-scale production leaves significant gaps in development of those crops
that fail to meet these criteria.

[13] One of the most significant aspects of the mid term review of the CAP is that
farmers will be able to exploit new markets rather than making decisions that are greatly
influenced by the subsidies for which each crop qualifies. Unfortunately, many of the
opportunities presented by the market involve crops for which relatively little (if any)
work is being done to develop varieties, agronomy and processing. There is, therefore a
concern that the significant challenges facing farming and that the objectives of diverse
markets and sustainable systems are inadequately supported by research agendas.

 [14] The diversity and relevance of research is constrained by a sectoral approach to
farming by both government and the industry itself. The recent DEFRA initiative of
introducing a Scientific Advisory Group to coordinate these different interests and
lobbies within farming appears to have made only a marginal difference and there is a
strong case for a more radical and fundamental review. For instance, the classification
criterion used by Defra of “organic farming” contains many projects that have a
relevance to all aspects of sustainable agriculture. It is easy to envisage that greater
spending on such projects could attract criticism that organic farming was being given
disproportionate funding and therefore unnecessary constraints are being imposed
upon research agendas. Equally, the implied relevance and dissemination of these
research findings may also lead to a failure to reflect its full potential by being targeted
at a very narrow section of farming.

Research Priorities Group

[15] The First Report published by the Research Priorities Group identifies many of
the aspects and drivers discussed in this submission and as such, must be welcomed
as a useful first step towards a realignment of the food and farming agenda. One
criticism that we have with the report is that in common with the overall policy culture
discussed previously, it fails to reflect the importance of the working farm at the centre
of its focus.

[16] Farming needs role models that demonstrate good practice and that clearly show
how objectives can be realised. With the privatisation of ADAS and other research
facilities, examples of working “test beds” for research are regrettably few and far
between. We feel that there is a case for reviewing best practice in other European
countries such as Holland, Italy and Ireland, where science and research appears far
more closely integrated with its application. Therefore within the criteria of how Defra
ensures the quality and relevance of the work it carries out, there is also a case for
reviewing how it determines and measures “success”

                   FARM      28 Penton Street, London N1 9PS          UK

[17] Despite the establishment of the RPG, the process of commissioning research
and setting research priorities continues to be a rather opaque process and we feel
there is some room for improvement. It is unclear how potential funding projects are
identified and how these are prioritised in terms of funding streams. It is also unclear
who is involved in this decision-making process and the interests that they represent.

Ethical and Social issues

[18] FARM has fully endorsed the recent report prepared by the Food Ethics Council
“Just Knowledge”, which deals with the issue of engaging ethical, cultural and
environmental issues as an integral part of the process of determining research
agendas. We believe this report serves as a useful discussion document that will help
ensure ethical and social issues are imbedded in the process of determining research
agendas. Recent examples of Defra’s science work such as the GM farm Scale
Evaluations would suggest there is still some capacity for engaging with Social and
Ethical aspects of food and farming policy.

[19] In areas where public money alone is used as a source of funding, the research
should be independent and protected from commercial interests. Serious concerns were
raised during the Field Scale Evaluation (FSE) Trials of GM crops, that the scope of the
trials (including the different management strategies) were unduly influenced by
commercial interests, undermining both public and farming confidence in the findings as
a result.

Horizon scanning

[20] Whilst welcome as a tool to help inform future shocks and opportunities, there is
a danger that too much reliance on horizon scanning to inform research agendas will
lead to a form of “peripheral vision”, where today’s problems are overlooked. There are
many instances where the same gaps in knowledge – for instance in areas of soil
science – that were evident 20 years ago and are still evident today. Therefore there is
therefore a need to match foresight with improvements in the process of reviewing
existing research and identifying gaps in knowledge, especially in areas that are used to
support and inform wider policy decisions.

We look forward to the findings of the review.

John Turner
Chair, Science Review Group, FARM
April 2005

                   FARM     28 Penton Street, London N1 9PS         UK

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