Irish Innovation Policy: An agenda for discussion (December 2019)

1.      Introduction

This paper provides a brief overview of the history and current position of innovation policy in Ireland.  A strong and relevant innovation policy framework has always been seen as fundamental to the creation and maintenance of a successful and sustainable social and economic system for the country.
As we move towards the year 2020 and beyond such a framework has acquired even more importance.  It is beginning to be noticed that there is an intellectual and comprehension gap between reality and aspiration in the planning of our future.  On the one hand, ritual acknowledgement is made to the scientific consensus that rising levels of greenhouse gases combined with massive degradation of the environment (particularly soil and wildlife habitats) is threatening another major extinction event at worst or radical life-style changes at best.  On the other hand, planning for the future of agriculture, food, transport, health and many other areas is proceeding on the basis of business as usual.
In this context it is imperative and urgent to examine our innovation policy framework and to assess its fitness for purpose for the future.

2.      Innovation and the Innovation System

‘Innovation’ is the introduction and diffusion of new solutions in response to problems, challenges or opportunities that arise in the social and/or economic environment. Resulting from ‘new combinations’ (Schumpeter 1934) of knowledge, capabilities and resources, innovation is regarded as a major source of change in all social and economic activities, in poor as well as rich countries.
‘Innovations’ are novel creations in the form of new or improved products or processes of economic or societal importance, usually developed by firms. New products (product innovations) may be material goods or intangible services; it is a question of what is produced. New processes (process innovations), on the other hand, may be technological or organizational; here, it is a question of how the products are produced.
Innovation primarily takes place in firms (usually in the private sector) but is also significant in the public sector (Mazzucato 2011). An innovation system is one that includes not just the innovations/innovators themselves but also “all important economic, social, political, organisational, institutional and other factors (activities) that influence the development, diffusion and use of innovations” (Edquist 2018).  As Fernando Flores (2013) puts it, Innovation ≠ Science + Technology + Creativity, but must always be contextualised in situated practices and in particular times and places, where culture and social mood play important roles.
In formulating this document, we have had discussions with Ken Guy, former Head of the Science and Technology Policy Division at OECD.  Ken was a member of the panel that reviewed the Research Prioritisation exercise in 2015. He has also provided a useful frame for thinking about innovation system.

3.      Innovation Policy for the 21st Century

The different perspectives on innovation are also reflected in policy. A narrow policy perspective considers invention only, while a broader, more holistic perspective, emphasises the entire innovation cycle from creating novel ideas to their implementation and diffusion. Many of those who have looked at innovation and its role in the regional, national and global economies believe that innovation policy practice is seriously lagging behind innovation research when it comes to being systemic, broad-based, demand-oriented or holistic (Breznitz et al, 2018). This means that, in many cases, innovation policies tend to be partial rather than holistic, and that most of these partial policies were of a linear kind.
Innovation policy can be seen as involving a division of labour between private and public organisations. Within such an approach, two conditions must be fulfilled for there to be reasons for public innovation policy intervention in a market economy:
  1. Private organisations must prove to be unwilling or unsuccessful in achieving the objectives formulated; i.e. a policy problem must exist.
  2. The state (national, regional, local) and its public organisations must also have the ability to solve or mitigate the policy problem.
These two conditions show the central importance of the issue of additionality in solving policy problems. Innovation policy pursued by public organisations is sometimes needed. However, policy actors must try to ensure that they do not replace, duplicate or crowd out what private actors (can) accomplish.

4.      Irish Innovation Policy Heretofore

Over the past decade there have been a number of papers and articles discussing both the history of innovation policy in Ireland and its recent development (Fitzgibbon 2011; O’Doherty and Fitzgibbon 2014; O’Doherty 2017; Noonan, Kelly & Vidolov 2015; Bradley & Kennelly 2008; Dept of Jobs, Enterprise and Innovation 2015; Cogan et al. 2015; Kavanagh 2018; Kitchin 2018). The following points summarise the contents of these papers:
●       Since the 1970s, while the focus of industrial policy has been to promote both indigenous industry and foreign direct investment (FDI), in practice the main focus of industrial policy has been on the attraction of foreign direct investment (FDI).  The agency responsible for the development and implementation of this policy – the IDA – was extremely successful and attracted almost unanimous support for its policy and strategy.  The impact on industrial development and employment in Ireland since that time has been enormous and well recognised.
●       Up until the late 1990s, public support for research was at a very low level, as the main drivers of economic growth were the foreign-owned manufacturing plants which utilised the benefits of research performed in their home countries and had little need of research in Ireland.  Increasing globalisation in the 1990s saw the foreign firms in Ireland move up-market and away from basic manufacturing towards higher-skilled activities.  This necessitated the introduction of a very significant increase in research funding and infrastructure, around the year 2000, through the mechanism of Science Foundation Ireland and other programmes.
●       At the same time, new policy structures were in place.  Forfás incorporated some of the innovation activities of the National Board for Science and Technology (est. 1978).  Within the public administration system there was a new Cabinet Committee and Interdepartmental Committee for Science, Technology and Innovation.  The Irish Council for Science, Technology and Innovation was established to provide independent external advice to these committees and to Forfás.  The office of Chief Science Advisor to the Government was established in 2004.
●       The approach to public research and technology organisations (RTOs) is one place where Ireland differed significantly from other European countries, large and small.  The Agricultural Institute was established in the 1950s with help from Marshall Aid and has existed continuously since then (today as Teagasc).  For industry, Sean Lemass established the IIRS in 1946 and it continued in existence until 1993.  It was, however, seen as of minor importance to the inward investment policy and never adequately funded.  Its industry support functions, including applied research, were transferred to the newly-established Enterprise Ireland in 1994 but were discontinued shortly thereafter by the new organisation.
●       In recent years the various research and innovation functions have gradually been transferred to the Department of Business, Enterprise and Innovation.  Forfás and the Advisory Council were abolished in 2015.  SFI continues, but with a revised remit to support more applied research.  The function of Chief Science Advisor to the Government was transferred to the Head of SFI.
●       In the past, national policy for research and innovation benefited substantially from external advice and input.  The review of Irish science policy undertaken by OECD in the 1960s provided a foundation and stimulus for the developments over the following decades.  The report of the Science, Technology and Innovation Advisory Council in 1995 led to Technology Foresight, the establishment of the Irish Council for Science, Technology and Innovation, of Science Foundation Ireland and of Research Councils for Science and Engineering and for the Social Sciences, the setting up of the Interdepartmental Committee on Science, Technology and Innovation, and other structural changes.
One issue is that innovation agencies can approach innovation in very different ways, and this diversity can be lost in any broad-brush approach to innovation policy.  Here, Breznitz et al (2018) provide a useful typology for classifying innovation agencies based on, on one dimension, whether the focus is on radical or incremental innovation, and on a second dimension, whether innovation agency is concerned with a narrow set of ambitious objectives or whether it is more decentralised in character, delegating R&D and objective setting to private sector actors.  These two dimensions generate four different types of innovation agency

Breznitz et al (2018) locate various agencies in different countries in their taxonomy and, in Figure 3, we have done the same with a selection of existing and defunct Irish innovation agencies. A significant conclusion arising from the wide-ranging work of Breznitz and his colleagues over a number of recent years (2015-2018) is that it is generally, but not exclusively, new and relatively smaller ‘peripheral’ agencies (in terms of budget, personnel and even remit) that have the greatest impact on innovation ‘practice’..[1]
Some agencies, such as Science Foundation Ireland and the ESRI, do not fit into the classification scheme, while previous organisations, such as the National Board for Science and Technology (NBST), Eolas and Forfás existed at a ‘meta’ level, above the ‘Breznitz’ classification scheme.  Significantly, such a ‘meta-agency’ is also missing from the current Irish innovation system.

5.      Innovation Policy Gaps

Centring innovation policy around attracting foreign direct investment has been a success, but it has also led to a number of gaps and deficiencies. 
First, the strategy has meant that innovation policy has largely overlooked the needs of many indigenous businesses, in particular in terms of the role of innovation policy in raising their overall level of productivity. The importance of the indigenous sector is recognised in the Government’s Future Jobs Strategy which has “improving SME productivity” as one of its five pillars.  However, there’s a lack of knowledge about the broad area.  So, for instance, there’s not much research on how indigenous businesses scale up, nor on the nature of innovation in indigenous firms, nor on the differences between sectors. There is a general consensus, but relatively little concrete thinking, on how to promote and enhance technological and supply chain relationships between Irish SMEs and multinational companies - even those in the same sector. 
Second, Ireland’s ranking on international innovation indices – where it is typically mid-table – is skewed by the peculiarities of the Irish economy, with its high levels of services exports, intellectual property payments and outward investment, all of which are related to tax avoidance.  While patent data has to be treated with caution, Ireland’s, per capita applications to the EU patent office in 2018 was less than half the number applied for by Switzerland, Luxembourg, the Netherlands, Sweden, Denmark and Germany. Moreover, two companies – Aptiv Technologies and Accenture – accounted for 38% of the Irish applications and almost certainly these applications are based on research done outside Ireland. A critical discussion of the state of patent applications and entrepreneurship in Ireland can be found in Finfacts (June 2019)   https://www.finfacts-blog.com/2019/06/the-poor-state-of-entrepreneurship-in ireland.html
Third, innovation requires individual commitment, high levels of trust, rootedness and a sense of belonging to a distinct community (Bradley & Kennelly 2008). By way of illustration, Ireland was perhaps at its most innovative (across many domains) between 1880 and 1920, and this innovation was founded on a deep sense of place and a strong cultural identification. More recently, Ireland has punched well above its weight in cultural innovation (whether in film, theatre, music, etc.).  The lesson is that to stimulate local innovation, people must know and appreciate who they are, where they are from, and where they are trying to go. Indigenous innovative capabilities therefore depend on a strong cultural and social base, capitalising upon tacit resources embodied in self-knowledge and tradition. In the emerging sustainable age, this deep sense of place, fostered by a forward-looking public policy, should be an important driver of innovation in Ireland’s indigenous enterprises. This approach to innovation is very different to the FDI/SFI understanding, which is essentially aspatial, acontextual, ahistorical, and acultural.
Fourth, the strategy has emphasised funding basic scientific research, even though it has long been recognised that basic research doesn’t necessarily lead to commercial innovation.  In the Irish context, this is being partly addressed by trying to deepen industry involvement in the sixteen SFI-funded Research Centres as well as developing fourteen new Technology Centres.  However, this shift – from science to engineering – has typically underappreciated the fundamentally social nature of technology-in-use.
Fifth, the emphasis on STEM research has resulted in very little investment in research in Arts, Humanities and Social Sciences.  Most recently, all of the Research Priority Areas announced in early 2018 are in STEM. As Prof Robert Kitchin has said, “the prioritisation areas ignore issues such as housing, education, economics, public administration and the wider public good.  Government seems to believe that creating jobs will fix everything, yet having full employment did not prevent the last crash and Ireland continues to be riddled with a diverse set of crisis issues”.  That crash cost the Irish state €60bn, but the cause of the crash was more to do with topics routinely covered in social science – e.g. corporate governance, banking regulation, property bubbles, neo-liberalism, etc. – rather than STEM research.  The issue was also recognised by the International Panel which reviewed the implementation of the Research Prioritisation Exercise in 2015. In their report, they stated that “research prioritisation should be positioned in a broader, strategic research framework which recognises the need to fund excellent research in other areas, in order to underpin the wider skills agenda, to meet broader societal goals and to enhance further Ireland’s reputation for outstanding science”.  The logic here is not to reduce spending on STEM research, but to invest more heavily in developing our collective knowledge and understanding of other important domains.
Beyond this, there’s little discussion around the different ways of thinking about innovation and innovation policy, and the consequential different models and nature of the actors that might, or might not, have a role in innovation policy development and/or implementation. For instance, innovation policy is currently premised on the notion that the state should buy rather than make knowledge (Teagasc is an exception) and that the state’s role should be to create and manage markets for knowledge production and consumption. There is little if any debate about the merit of this approach or investigation of its downsides (the policy arguably fosters short-term thinking, opportunistic tendering, and militates against institution-building for the longer term).  Likewise, there’s little discussion on what ‘centralisation’ might mean in the context of innovation, or on the role of local actors – e.g. county councils – in innovation policy. This lack of debate can be partly attributed to the disappearance of the innovation policy structures that were in place 10-15 years ago.
The economist Colm McCarthy (2019) has identified another example of the lack of coordination in inward investment policy.  A big effort has been made to attract data centres to Ireland and this has been very successful.  Data centres, however, are enormous users of electricity with consequent implications for energy supply and security, climate change policy and other areas.  Little attention has been paid to this conflict of objectives.

6.      Identifying the Problem

While a lot has been written in the last decade or so about research, innovation and economic development – with a tendency to paint a positive picture of progress – it is difficult to substantiate these arguments with hard evidence.  This reflects a reduction in innovation performance information, particularly in relation to business performance, over the past ten or twelve years.
Prior to that period, Forfás undertook two types of activities which helped to provide the basis for innovation targets in the various innovation policy plans since 2000 and for fine-tuning policy instruments in the light of actual performance.  The first activity was the undertaking every two years of a survey of R&D in the business sector, with a very detailed published report identifying, among other things, the difference in performance between foreign-owned and indigenous enterprises, as well as a number of more specific innovation indicators.  The second activity was the undertaking of independent, external evaluations of the various innovation programmes operated by the agencies.  The evaluations were conducted in line with best international practice in the field.  It is usually the case that those evaluated in this way do not particularly appreciate such scrutiny but there is little doubt that it can help identify problems and opportunities and improve performance overall.
The CSO continues to prepare what used to be known as the Community Innovation Survey for Ireland under the heading of Innovation in Irish Enterprises, the latest issue of which relates to the period 2014-2016.  The CIS is an EU-wide initiative and was originally carried out jointly in Ireland by the CSO and Forfás.  The current version (April 2018) is a 12 page PDF on the CSO’s website while the CIS 2008-2010 (April 2012) was an 80+ page publication.  This went into much greater detail on the differences in firm performance of R&D but in particular into the non-research and non-technological aspects of innovation such as the diffusion of knowledge and technology into firms, organisation and marketing activities and the barriers being faced by SMEs.
The absence of these data and analysis makes it very difficult to identify precisely what is happening and to get a handle on what needs to change.  This is a major criticism of current practice.

7.      Innovation Policy Overseas

Virtually all developed countries, including OECD members (and most developing ones), have some kind of national representative body/council that deals with policy advice and formulation on some (and increasingly wider) aspects of their ‘national innovation systems’, including funding and governance issues.
The OECD has produced a series of Reviews of Innovation Policy which provide a   a comprehensive assessment of the innovation system of individual OECD member, focusing on the role of government. Thus far, the OECD has reviewed 22 countries: Portugal (in 2019), Austria (in 2018), Kazakhstan, Norway, Finland, Costa Rica (in 2017), Malaysia, Lithuania, Luxembourg, Sweden (in 2016), Croatia, France, Korea, Viet Nam (in 2014), Mexico (in 2013), Slovenia (in 2012), Russia (2011), China, Hungary, Norway (in 2008), Chile (in 2007), Switzerland (in 2006). The OECD  provide concrete recommendations on how to improve policies which impact on innovation performance, including R&D policies. Each review also identifies good practices from which other countries can learn.  It would be timely for Ireland to consider commissioning the OECD to carry out such a review.
Beyond the OECD studies, the Swedish Agency for Innovation Systems, VINNOVA, carried out a survey/analysis in 2015 of the characteristics and the challenges facing ‘National Research and Innovation Councils as an Instrument of Innovation Governance’ (Serger et al. 2015).  The authors of this study note that ‘the interest in innovation councils responds to a growing need for strengthening the coordination, inclusiveness and, ultimately, the effectiveness of innovation policy governance’. The questions asked were ‘What is the function, composition and role of councils in different national innovation systems – and how do they reflect the evolving demands on innovation governance? What are some of the challenges that may be experienced, and what are alternative approaches to addressing these challenges?’
This study, which built on previous international comparisons of national innovation councils conducted by the OECD, provides a comparative analysis of national Innovation Councils in Austria, Denmark, Finland, Germany, Netherlands, Switzerland, UK, Canada, US, China, Japan and Korea. The report found that while numerous countries have established innovation councils, their structural characteristics differ significantly between countries. The most notable differences were around mandate (strong or weak), focus (narrow or broad), anchoring (primary reporting relationships), resources (large or small), outputs (analyses or decisions).
The study also highlighted some new trends that demonstrate innovation councils’ reaction to the evolving demands of innovation governance. These include a strengthened focus on forward-looking activities (e.g. foresight processes in Germany and multi-annual plans for research and innovation in Japan and South Korea), a greater tendency to involve foreign expertise (in the case of Austria, Germany, the UK, the Netherlands, Switzerland and Singapore), and more attention to stakeholder inclusion and communication (in the case of Denmark, Canada, and USA).

8.      Case Studies

Case: Swedish National Innovation Council

Arising from the results of the VINNOVA report and other analytical and political developments, the Swedish Government decided in February 2015 to establish the National Innovation Council (NIC).
The NIC consists of ten external advisers from industry, unions and academia, including three university professors (from environmental studies and innovation studies, and one university vice-chancellor), one union representative, as well as CEOs of large firms (Volvo Group, Stora-Enso) and small firms (including innovative entrepreneurs and one business angel). The NIC members are appointed in their personal capacity and do not represent the organisations from which they come, or any political party.
Five representatives from the government participate in the NIC meetings. In addition to the Prime Minister, the Minister of Finance, the Minister of Enterprise/Innovation, the Minister of Research and the Minister of International Development Cooperation and Climate (also Deputy Prime Minister) participate in the meetings. The small secretariat of the NIC is placed under the auspices of the Office of the Prime Minister, i.e. superior to all ministries, which is important.
The existence and operation of the NIC is based on the premise that research is not the same as innovation nor always a basis for innovations, and that much research funding is intended for basic research and research in areas with little relation to innovation.
Since research and innovation are different actions, there is a need to distinguish between innovation systems and research systems. Research policy and innovation policy are also seen to be different phenomena, with different objectives and using different policy instruments, in a transformation of innovation policy from linear to holistic – with the aim of leading to a better research policy and a better innovation policy.
The NIC is thus not a science/research and technology/innovation policy council. Instead, it is dedicated to dealing with innovation policy in a much broader sense than most of the science, technology and innovation policy councils in other countries. The Swedish NIC also partly deals with research policy issues, but in the broader context of innovation. This approach is similar to how the Swedish Research Policy Council (which continues to exist) is dealing with innovation policy. This means that the areas of responsibility of these two councils overlap and must be coordinated.
They also intrude into the territories of many additional policy areas, such as labour market, public procurement, energy, transport, health care, environmental and regional policies. This makes it clear to everyone that policy areas do overlap to various degrees. In the Swedish approach, innovation policy and research policy should be separate from each other in the design phase – but it must be ensured that they support each other when implemented.

Case: Finland’s Research and Innovation Council

Nieminen et al (2016) identify these key milestones of the Finnish science, technology and innovation system since 1990.
1990 – National innovation system is introduced as a central policy concept.
1995 – Finland joins the EU.
1996 – Government’s decision of additional research funding programme for 1997-1999.
1999 – R&D funding exceeds 3 per cent of GDP.
2004 – Structural evaluation of the research system.
2005 – Council of the state decision in principle on the structural development of the STI system.
2006 – Structural renewal of universities and research institutes begins.
2007-2009 – Establishment of six strategic centres of STI, SHOKs.
2008 – National innovation strategy by the Government.
2010 – R&D funding 3.9 per cent of GDP.
2013 – Decision of the government to reorganize public sector research organizations.
2012-2015 – Decisions to cut public R&D and education expenditures.
Finland’s Research and Innovation Council is an advisory body chaired by the Prime Minister. The Council discusses key issues relating to the development of research and innovation policy that supports wellbeing, growth and competitiveness.  It was set up in 2008 to, among other things: (a) follow national and international developments in research, technology and innovation; (b) evaluate developments within the sphere of its authority; (c) address major matters relating to the development of science, technology and innovation policy and prepare proposals and plans.
In September 2013, the Finnish government adopted a Resolution on Comprehensive Reform of State Research Institutes and Research Funding aimed at building up multidisciplinary, high-level research of significant societal relevance and research in support of government decision making. The resolution covers the reorganisation of public research institutes, reallocation of some public research funding to competitive research funding, and the creation of a new, strategic research funding instrument (the Strategic Research Council) within the Academy of Finland to support long-term research on challenges facing Finnish society (see chapter 6 of the OECD Review of Innovation Policy: Finland, 2017).  The members of the Strategic Research Council currently comprise two persons working in the senior management of government research institutes, four university professors, two senior executives of a private company and one retired senior civil servant.

9.      Potential Recommendations

Recommendation 1: Review existing supports for ‘domestic’ innovation

The objective here is to get a clearer sense of the various incentives and  support mechanisms available to businesses engaged in innovation. This review should identify, analyse and critique the agencies providing the support, the conditions surrounding the support, levels and types of support given, overall and specific budgets, domestic/FDI focus, etc.  The aim of the review would be to identify strengths and weaknesses in Ireland’s approach to industrial innovation, which should help shape future approaches.  Such a review should also help ensure that the Irish innovation support system relates to actual practice and would be most appropriately led by DEBI.

Recommendation 2: Utilise the expertise & experience of the OECD in reviewing overall Irish productivity & innovation policy

In the area of innovation policy in particular, the Irish Government, along with the wider civil and public service, has built up a long-term relationship with the OECD and its Secretariat in Paris. This goes back to 1966, with the publication of ‘Science & Irish Economic Development’, which was a sister report to the highly influential ‘Investment in Education’ and led to the establishment of the first National Science Council in Ireland. The Centre for Entrepreneurship, SMES, Regions & Cities (CFE) at the OECD is currently finalising a ‘Review of SME and Entrepreneurship policies and programmes in Ireland’ on behalf of the Minister and Department of Business, Enterprise & Innovation (DBEI). This has identified an overall productivity problem among established SMEs (in particular in the medium-sized category where both manufacturing and services sectors have experienced a recent decline in productivity) and highlighted the role of innovation in increasing and maintaining productivity.
In the context of the upcoming review of ‘Innovation 2020’ of It would seem to make much sense for the Irish government to use our relationship with the OECD to conduct a wider review of Irish productivity and innovation policy, along the lines of previous studies, both in Ireland and other member states. The review of specific supports for innovation envisaged in Recommendation 1 would be an important input to this wider OECD-related exercise.

Recommendation 3: Establish an Irish Innovation Council

Any OECD-related review of Irish innovation policy will take some time.  In the context of such factors as:
  1. the upcoming restatement of overall innovation policy (revision of Innovation 2020)
  2. the 20-year anniversary of the major Technology Foresight exercise published at the turn of the millennium and
  3. the ongoing Science Foundation Ireland strategy review
  4. the ongoing but increasingly urgent issue of how Irish indigenous industry can become competitive in a rapidly evolving global environment and the significant role of innovation in that transformation
all taking place within wider national and international economic and social developments, such as Brexit and climate change, it is now timely to consider establishing an Irish Innovation Council. Given how the role of innovation and innovation policy is currently being rethought, as outlined above, such a Council could learn from the Swedish NIC, with its focus on the total innovation process.
A Council drawn from a range of interests similar to those represented in the Swedish case – i.e. industry, academia and government/public service – would also be in keeping with the approach adopted in the almost 50-year history of Irish policy advisory and implementation bodies. As is the case in Sweden, an issue that might arise is whether a separate ‘research’ council/forum dealing with basic research and other non or part-innovation issues might or might not be required or how existing structures might be adapted for that role.
The setting-up of an Innovation Council does not necessarily imply establishing a new statutory organisation/agency. In a similar way to the Climate Change Advisory Council or the Irish Fiscal Advisory Council,  it could operate out of an existing government department. The Council might be most appropriately located within the Department of Business, Enterprise and Innovation (though Sweden’s NIC is under the auspices of the Office of the Prime Minister).  Regardless of its location, an Innovation Council would need a level of autonomy and independence as well as adequate financial and professional resources (e.g. ‘dedicated’ policy analysts). There is much experience in establishing such structures within the Irish civil/public service. 

Recommendation 4: Initiate a new Foresight Exercise

In the context of climate change and the ecological crisis, it is important that we have formal ways of planning for the longer-term.  Traditionally, Ireland has benefited from Technology Foresight and economic planning exercises – the Technology Foresight exercise carried out in the late 1990s and published almost 20 years ago was pivotal in creating Science Foundation Ireland – and it is now appropriate to conduct a similar forward-looking exercise, but with a broader remit.  As well as addressing climate change and the ecological crisis, creating an equitable and sustainable digital society should also be part of the remit.
Such an exercise might be conducted under the auspices of the proposed Irish Innovation Council, but it would probably be more appropriate, given time constraints and the need for a broader remit, to initiate the exercise promptly in partnership with the Department of An Taoiseach. The exercise should be part of an ongoing, continuous process of policy formulation.

References

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