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- Herausgeber: John Wiley & Sons
- Kategorie: Geisteswissenschaft
- Sprache: Englisch
Provides practical, globally informed solutions for a stronger U.S. homeland security framework
Comparative Homeland Security: Global Lessons, Third Edition, offers critical insights into how democratic nations around the world approach homeland security (HS) threats. As the scope and complexity of HS challenges continue to expand—ranging from terrorism and public health crises to nation-state cyber operations and disinformation campaigns—this much-need book fills a crucial gap by systematically comparing international responses and offering lessons that can be adapted for the American context. Author Nadav Morag, an acknowledged expert with extensive experience both in the U.S. and internationally, structures the text around key functional areas within homeland security, such as counterterrorism, critical infrastructure protection, emergency management, and civil-military coordination.
The third edition significantly updates previous material, integrating fresh analyses on grey zone threats and post-pandemic public health security strategies. New discussions on emerging threats, including cyber-enabled subversion of democratic institutions and infrastructure, provide timely frameworks for understanding modern hybrid warfare. Each chapter presents case studies from multiple democracies, including the UK, Israel, Canada, Australia, France, Germany, and Japan, emphasizing actionable strategies and institutional frameworks. This global perspective enables readers to critically assess the transferability of foreign approaches to enhance U.S. homeland security through informed, cross-national learning.
Exploring how nations around the world address security challenges and what the U.S. can learn from their experiences, this book:
- Expands understanding of homeland security through comparative analysis of democratic nations’ policies and strategies
- Incorporates up-to-date discussions of urgent threats including cyberattacks and disinformation operations
- Explores international public health preparedness and lessons learned from global responses to COVID-19
- Highlights critical infrastructure protection strategies from nations with diverse threat landscapes
- Includes analysis of interagency coordination and civil-military relations in a global context
Organized by thematic policy areas to enable quick reference to relevant case studies and strategic insights, this is essential reading for graduate-level students in homeland security, emergency management, criminal justice, and public policy programs, particularly in courses such as Comparative Homeland Security, International Security Policy, and Emergency Preparedness. Practitioners in government, defense, and civil security roles will find the book’s global perspective and practical applications a valuable resource in real-world practice.
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Table of Contents
Cover
Table of Contents
Title Page
Copyright
Preface to the Third Edition
Preface to the Second Edition
Preface to the First Edition
Introduction: Studying Homeland Security Policies Followed by Other Countries
Chapter 1: Country Overview
State of Israel (
Medinat Yisrael
)
United Kingdom of Great Britain and Northern Ireland
Canada
The Commonwealth of Australia
The Federal Republic of Germany (
Bundesrepublik Deutschland
)
The French Republic (
République Française
)
Kingdom of the Netherlands (
Koninkrijk Der Nederlanden
)
Republic of Italy (
Repubblica Italiana
)
Japan (Nippon-Koku)
Conclusion
Issues to Consider
Chapter 2: Counterterrorism Strategies, Laws, and Institutions
Defining and Categorizing Terrorism and the Evolution of Counterterrorism Legislation
Counterterrorism Laws
Precharge Detention and Other Restrictions of Freedom of Movement of Terrorism Suspects
Denial of Access, Removal of Citizenship, and Deportation of Citizens as Counterterrorism Tools
Conduct of Investigations and Judicial Proceedings
Interrogation of Terrorism Suspects
Counterterrorism Warfighting
Institutional, Organizational, and Strategic Aspects of Counterterrorism Efforts
Conclusion
Issues to Consider
Chapter 3: Law Enforcement Institutions and Strategies
Israel
United Kingdom
Canada
Germany
France
Japan
Conclusion
Issues to Consider
Chapter 4: Emergency Preparedness, Response, and Management
Emergency Medical Services and Incident Response
Hospital Preparedness and Response
Scene Response, Command, and Management
Emergency Management Strategies and Institutions
Post-Event Social Services
Crisis Communication and Resiliency Promotion
Media Relations
Conclusion
Issues to Consider
Chapter 5: The Role of the Military in Security and Support for Civil Authorities
Legal Frameworks for the Domestic Use of the Military
Overview of the Military Role in Homeland Security
Types of Military Forces and Missions
Disaster Response and Infrastructure Protection
Conclusion
Issues to Consider
Chapter 6: Immigration, Naturalization, Asylum, and Border Security
Background
Models of National Identity and Immigration Policy
The EU: An Overview
The EU: Borders and Immigration
The Schengen System
EU Border Security
EU Asylum and Naturalization Policies
Immigration Policies in EU Member States: The Cases of Germany, France, and the Netherlands
Immigration, Asylum, and Border Security Outside the EU
Conclusion
Issues to Consider
Chapter 7: Critical Infrastructure Protection and Transportation Security
Critical Infrastructure Protection: Introduction
Overall Approaches to CIP and the Private Sector
Public–Private Security Partnerships
Private Sector Critical Infrastructure Responsibilities
Cybersecurity
Aviation and Maritime Security
Conclusion
Issues to Consider
Chapter 8: Public Health Strategies and Institutions
Health Systems and Institutions Overview
Epidemiological Systems and Contingency Planning in Epidemics and Pandemics
Quarantine and Isolation Powers
Coping with COVID-19
Conclusion
Issues to Consider
Chapter 9: Foreign Actor Gray Zone Threats and International Comparative Responses
Threats to Critical Infrastructure – Cyber Attacks
Threats to Critical Infrastructure – Kinetic Attacks (Physical Sabotage)
Threats to Critical Infrastructure – Espionage
Threats to Political and Societal Stability – Disinformation
Legal and Regulatory Frameworks to Combat Disinformation
Conclusion
Issues to Consider
Conclusion
Bibliography
Index
End User License Agreement
List of Illustrations
Introduction
Figure I.1 Soviet ICBM.
Figure I.2 New Orleans after Katrina.
Chapter 1
Map 1.1 Map of Israel.
Figure 1.1 Israeli parliament building.
Figure 1.2 Inner courtyard of the Israeli Supreme Court building.
Map 1.2 Map of the United Kingdom.
Figure 1.3 British Houses of Parliament.
Figure 1.4 No. 10 Downing Street, residence of the prime minister and location of cabinet me...
Figure 1.5 Old Bailey London, the Central Criminal Court of England and Wales.
Figure 1.6 Scottish Parliament building.
Map 1.3 Map of Canada.
Figure 1.7 Flags of Quebec and Canada.
Figure 1.8 Canadian parliament building.
Figure 1.9 Supreme Court of Canada.
Map 1.4 Map of Australia.
Figure 1.10 Australian parliament building.
Figure 1.11 Flags of Australian states and territories.
Figure 1.12 High Court of Australia.
Map 1.5 Map of Germany.
Figure 1.13 Bundestag.
Figure 1.14 Bundesrat.
Map 1.6 Map of France and its regions.
Figure 1.15 French National Assembly.
Map 1.7 Map of the Netherlands and its regions.
Figure 1.16 States General.
Figure 1.17 Netherlands Supreme Court.
Map 1.8 Map of Italy and its regions.
Figure 1.18 Italian Chamber of Deputies building.
Figure 1.19 Italian Senate building.
Figure 1.20 Italian Court of Cassation.
Map 1.9 Map of Japan and its regions.
Figure 1.21 Japanese Diet.
Figure 1.22 Japanese Supreme Court.
Chapter 2
Figure 2.1 Grand hotel in Brighton, England, following the IRA bombing of 12 October 1984.
Figure 2.2 British police officers.
Figure 2.3 British army sniper pair.
Figure 2.4 John Locke, 1632–1704.
Figure 2.5 Plenary hall of the Israeli parliament (Knesset).
Figure 2.6 Israeli Ministry of Defense and IDF Headquarters Complex, Tel Aviv.
Figure 2.7 House of Commons, Canadian parliament.
Figure 2.8 Memorial to the victims of the 2002 Bali bombings, Bali, Indonesia.
Figure 2.9 Bundestag Assembly Hall.
Figure 2.10 Israeli Independence Hall, Tel Aviv.
Figure 2.11 Northern Ireland mural.
Figure 2.12 UK passport control.
Figure 2.13 Red Army Faction logo.
Figure 2.14 French riot police.
Figure 2.15 Clairvaux Prison, France.
Figure 2.16 UK police cordon sign.
Figure 2.17 European Court of Human Rights.
Figure 2.18 French Gendarme demonstrating the use of a search dog.
Figure 2.19 Israel Air Force Apache helicopter.
Figure 2.20 Hamas terrorist attacks Kibbutz Alumim, October 7, 2023.
Figure 2.21 Israel police logo.
Figure 2.22 Separation barrier between Jerusalem and the West Bank.
Figure 2.23 Thames House, London, Headquarters of the Security Service.
Figure 2.24 Headquarters of the London Metropolitan Police.
Figure 2.25 AFP vehicle.
Chapter 3
Figure 3.1 Nineteenth-century British police constables.
Figure 3.2 London Metropolitan Police officers.
Figure 3.3 Ottawa police officers.
Figure 3.4 Logo of the German federal police.
Figure 3.5 French National Police vehicle.
Figure 3.6 Japanese police Koban.
Chapter 4
Figure 4.1 MDA mobile intensive care unit.
Figure 4.2 London ambulance service bicycle.
Figure 4.3 Hadassah Medical Center, Jerusalem, Israel.
Figure 4.4 Glasgow Royal Infirmary, Scotland.
Figure 4.5 LAS cordons and access control.
Figure 4.6 London Fire Brigade vehicle.
Figure 4.7 Gold, Silver, and Bronze.
Figure 4.8 BBC Headquarters, Broadcasting House, London.
Chapter 5
Figure 5.1 German soldiers on parade.
Figure 5.2 Flag of the Israel border police.
Figure 5.3 The isolated community of Baker Lake in the Canadian Arctic territory of Nunavut.
Figure 5.4 French gendarmes on parade.
Chapter 6
Figure 6.1 Mosque in Amsterdam.
Figure 6.2 EU map.
Figure 6.3 European Parliament Plenary Hall, Strasbourg, France.
Figure 6.4 European Commission Headquarters, Brussels, Belgium.
Figure 6.5 European Court of Justice, Luxembourg.
Figure 6.6 Border sign on the Austrian border.
Figure 6.7 Schengen area map.
Figure 6.8 French Schengen visa.
Chapter 7
Figure 7.1 Orot Rabin power station, Hadera, Israel.
Figure 7.2 Oil refinery, Haifa, Israel.
Figure 7.3 Claerwen Dam, Wales.
Figure 7.4 Black Mountain Communications Tower, Canberra, Australia.
Figure 7.5 Olympic Stadium, London.
Figure 7.6 Landing strip at Shark Bay, Western Australia.
Figure 7.7 Frankfurt Airport, Germany.
Figure 7.8 Israeli Navy patrol boat.
Figure 7.9 UK Coastguard helicopter.
Figure 7.10 Australia’s maritime jurisdiction.
Chapter 8
Figure 8.1 Soroka Medical Center, Beersheba, Israel.
Figure 8.2 Toronto General Hospital.
Figure 8.3 ECDC headquarters, Stockholm, Sweden.
Figure 8.4 Quarantine has long been an established practice in Australia. Sydney Quarantine...
List of Tables
Chapter 9
Table 9.1 Selected Cyberattack Campaigns Attributed to Nation States (2014–2023)
Table 9.2 Selected Russian Sabotage Activities in Europe (2023–2024)
Table 9.3 Russian Disinformation Cases and Impacts in France and Germany
Guide
Cover
Table of Contents
Title Page
Copyright
Preface to the Third Edition
Preface to the Second Edition
Preface to the First Edition
Introduction: Studying Homeland Security Policies Followed by Other Countries
Begin Reading
Conclusion
Bibliography
Index
End User License Agreement
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Comparative Homeland Security
Global Lessons
Nadav Morag
Sam Houston State University
Huntsville, TX, USA
Third Edition
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Preface to the Third Edition
The first edition of this book was published in late 2011 and the second edition in 2018. Over the last 7 years, some homeland security threats and the responses of governments have evolved. Furthermore, certain dramatic events that occurred since 2018 have significantly impacted homeland security across a range of countries surveyed here. This includes the response to the COVID-19 virus that emerged in early 2020 and eventually claimed at least 7 million lives worldwide (though the real number is likely far higher), as well as the October 7, 2023 terrorist attack and massacre by Hamas (and allied groups) against Israelis near the Gaza Strip. Additionally, in the time period since 2018, increased Western tensions with Russia over the Ukraine War and with China over Taiwan and the South China Sea, as well as with Iran and North Korea, have resulted in increased threats to critical infrastructure (both cyber threats and, to a lesser extent, kinetic threats). This rising nation-state threat is also visible in the growing use of disinformation via the Internet and social media aimed at causing disruption in Western countries. In short, there are many changes in policy and, in some cases, institutions, which are worth considering for students and practitioners of homeland security studies. As will be noted in the introduction, there is significant utility in learning from the experiences and ways of doing business with other countries as part of the process of improving homeland security-related policies, whether in the realm of counterterrorism, policing, emergency management, military support for civil authorities, immigration, border security, critical infrastructure protection, or transportation security.
Preface to the Second Edition
The first edition of this book was published in late 2011. As the reader can imagine, much has changed since then in the homeland security enterprise. Over the last 6 years or so, the world has seen the rise and fall of the so‐called Islamic State; a massive influx of migrants to Europe causing crises in the Schengen Area and European Union (EU) (and playing a role in precipitating the British decision to leave the EU); an epic natural disaster in Japan; an Ebola outbreak that spread significantly beyond the confines of previous outbreaks; group and individual terrorist attacks using bombs, firearms, knives, and motor vehicles; Russian and Chinese hacking and cyberespionage; major natural disasters in the United States; and a range of other homeland security challenges. These challenges and the natural evolution of laws and policies have necessitated the writing of a second edition to reflect many of these changes. This edition also delves into cybersecurity policy issues – an area that has been growing exponentially but was not touched on in the first edition.
I have also endeavored to make this book more useful as a guide, not only to students but also to those involved in the policymaking process, by including more sidebars in the chapters with cases, policy language, and other vignettes of information that may help generate policy ideas. Overall, while the book has been updated and I have brought in new content to make the book slightly more comprehensive, the previous chapter structure and format have been maintained.
Preface to the First Edition
This book is primarily designed as a textbook for students of the emerging academic and practitioner discipline of homeland security. While no universally accepted definition of homeland security exists at present (or is likely to ever exist), the introductory chapter of this book will posit a working definition around which the book’s chapters are organized. This book is not designed to be an introductory text for students of homeland security, as there are a number of books available. Instead, this book is designed to serve as a text and resource for a subfield within the discipline of homeland security, that of “Comparative Homeland Security.” This subfield is chiefly concerned with analyzing and understanding the homeland security policies followed outside the United States (homeland security is a quintessentially American concept, as will be explained in the Introduction to this book). Comparative Homeland Security accordingly mirrors the various subject areas within the broader field of homeland security, and hence this book will touch upon most (or all, depending on one’s definition of homeland security) of these issue areas.
This book has several flaws, and there is little point in trying to conceal them now as the reader will discover them soon enough. The first, and chief, flaw is a lack of comprehensiveness. This book does not even begin to scratch the surface of the subfield of Comparative Homeland Security. As will be noted in the Introduction to this book, the field of homeland security is extremely broad and covers issues as diverse as counterterrorism, law enforcement, emergency management and response, public health, strategic communications, and a host of other public policy issues. Adequate treatment of this topic solely within the American context would require, at a minimum, a shelf‐load of books, and doing so in the context of the handful of foreign countries addressed in this book would require several shelf‐loads of books. Accordingly, it is not the author’s intent to be comprehensive because comprehensiveness requires far more space than is available here. Moreover, aside from space issues, comprehensiveness is not really possible at this stage in the development of this subfield because only a small percentage of the information needed to address this issue in a truly thorough manner is publicly accessible.
Researchers who focus on homeland security strategies and policies in the domestic American context often do not have access to the materials that they need because these are either classified or otherwise held close and not made publicly available or, in some cases, are unwritten and can only be accessed through identifying the appropriate persons and obtaining their acquiescence to be interviewed. Nevertheless, a surprising amount of material is available in the public sphere, as many organizations and agencies produce reports, analyses, strategy papers, and other types of documentation, and there is also a growing body of academic studies in the field. Consequently, while researchers of domestic homeland security policy will often come up empty when looking for documentation on which to base their research, they also enjoy an extensive and expanding pool of materials with which to work.
The researcher interested in exploring the homeland security policies of other nations, however, is in a position of comparative disadvantage. This is because not all countries of interest tend to follow the American approach of, by and large, making strategy and policy publicly available as a way of ensuring governmental accountability to the public. Granted, materials produced by governmental agencies for public consumption are sanitized and always designed to portray the agency in question in as favorable a light as possible (many have photos of smiling agency personnel and members of the public embellishing the document). Nevertheless, much can still be learned from them if one “reads between the lines” and triangulates this information with data from other sources. In addition, academic studies and documents produced by various assessment entities (public and private) often provide a more critical take on policies. The culture of public accountability is quite strong in the United States and is shared by some countries of interest in this text, including the United Kingdom, Canada, Australia, and, in some cases, Germany, and consequently these countries offer greater access to information about policy. In other cases, such as Israel, France, and Italy, there is little of the culture of public accountability, and consequently, far fewer materials are available to the public because there is less of a sense that the public has the “need to know.”
In addition to the absence of materials with respect to many countries, there is also a linguistic barrier to the comprehensive study of homeland security policies overseas. An all‐inclusive study of the publicly available materials in the handful of countries dealt with in this book would require the researcher to be fluent not only in English but also in Hebrew, French, German, Italian, Dutch, and Japanese. Perhaps a few lucky (and brilliant!) individuals with this linguistic repertoire can be found somewhere, but the author is definitely not among them (having true command of only a paltry two of these), and thus some documentation could not be analyzed. Consequently, this is somewhat similar to the story of the man who is found attentively searching for his car keys underneath a streetlight in the middle of the night. When asked where he dropped the keys, he points to his car, shrouded in the darkness, down the street. When subsequently asked why he is searching for his car keys near the streetlight when he dropped them near his car, he replies: “because this is where the light is.”
A second flaw in this book has to do with the absence of a strong methodology for comparing policies and strategies across countries. Most works that deal with comparative analysis in fields and subfields such as comparative politics, comparative public health, comparative policing, etc., do not integrate the data and analyze it but rather lay out different policies (followed by different nations or jurisdictions within a nation) side by side – though this methodology does help increase understanding of how and why things are done in different contexts (such as countries) through comparing and contrasting. As this is an introductory text designed to introduce the reader to the subfield of Comparative Homeland Security, the goal here is not to produce a theoretical tome that will solve the problem of the absence of a good comparativist methodology that truly integrates data and analysis. Nevertheless, by breaking the book down by issue areas within homeland security and then looking at the approaches of different countries in those contexts, the author has attempted to at least take one step in the direction of some sort of integrative approach to comparing across countries. A true comparative study will have to await the development of a strong methodological tool.
A final flaw (and one would hope that this is, indeed, the final flaw) in this book is that some of the data provided to the reader may be inaccurate. This is chiefly for two reasons: firstly, Comparative Homeland Security is a highly dynamic field, with homeland security laws, policies, and strategies overseas constantly evolving, and while the author has attempted to provide as much up‐to‐date information as possible, changes are constantly occurring and no book in this area can be 100% current. Secondly, policy and strategy, as expressed in documents and briefings, is not necessarily what really happens. In order to understand what really happens, a researcher has to have worked in the various areas within homeland security in a senior capacity (in order to have a good overall view of policy and strategy) in all of the countries touched upon in this book, and he/she needs to simultaneously continue working for all of these agencies in all of these countries to make sure that the knowledge that they have is indeed still relevant. Perhaps this is possible if, as some quantum mechanics physicists suggest, there are infinite parallel universes, but that is of no help.
There you have it, dear reader: A book with partial and, in some cases, dated information and the absence of a powerful methodological tool. Nevertheless, this book will provide you with a strong grounding and basic understanding of the emerging subdiscipline of Comparative Homeland Security. Since comprehensiveness is not an option, the focus here is on providing vignettes of information that are interesting and useful, and consequently, each chapter touches on a different mix of countries and different sets of issues. Hopefully, this book will stimulate your interest in this field and encourage you to look outside your national borders (this book is written primarily for an American audience but will hopefully be of use to others as well) for answers to homeland security problems. The more policymakers and practitioners in different countries can learn from each other’s strategies and approaches, the greater will be the shared pool of knowledge. This knowledge will ultimately make people safer, which is reason enough to study Comparative Homeland Security.
IntroductionStudying Homeland Security Policies Followed by Other Countries
What Is Homeland Security?
Homeland security is a uniquely American concept. While a number of other countries around the world have employed the term since its entrance into common usage in the wake of the monstrous terrorist attacks against the World Trade Center and Pentagon on 11 September 2001, they have done so essentially because they were following America’s lead. Despite the fact that many such countries have partially adopted the term, they have yet to really internalize the discipline of homeland security in the way that it is being understood and applied in the United States. Of course, disciplines, both in terms of their practitioner and academic components, take several decades at a minimum in order to become fully developed and accepted, and consequently, it is no surprise that homeland security as an enterprise is still evolving and that there are a wide range of definitions for this discipline. It is not the purpose of this volume to provide a definitive definition of homeland security but rather to focus on the approaches and policies followed by a select group of countries within the realm of what is generally considered to be homeland security. However, in order to do this, we must begin with some sort of baseline working definition in order to determine which types of overseas policies should be surveyed and which should not.
As homeland security is an American concept, there is some logic in turning to the National Strategy for Homeland Security, originally issued in July 2022 and revised in October 2007, in order to shed some light on the concept. According to the National Strategy, homeland security is defined as “…a concerted national effort to prevent terrorist attacks within the United States, reduce America’s vulnerability to terrorism, and minimize the damage and recover from the attacks that do occur” (Bush, 2007, p. 3).
Based on this definition, homeland security would appear to essentially be focused on counterterrorism and thus recognizable overseas as essentially a national strategy for counterterrorism. Indeed, the British government issued such a strategy in 2006 (with the latest revision in 2023), known as Countering International Terrorism: The United Kingdom’s Strategy, which will be discussed in Chapter 1.
All the countries surveyed in this work have either written strategies or unwritten approaches to dealing with terrorism, and hence, in this context, the United States would appear to be just another country with just another counterterrorism strategy. Of course, in the wake of 9/11, homeland security may have indeed been viewed by many as an alternative term for counterterrorism. Nevertheless, on page 6 of the National Strategy, it is noted that preparedness in a homeland security context also requires coping with “…future catastrophes – natural and man‐made…” (Bush, 2007, p. 6), and page 10 of the document notes that catastrophic natural disasters and public health emergencies are part of the homeland security threat menu (Bush, 2007, p. 10). The National Strategy goes on to refer to a broad range of other policy issues, including transportation security, policing, border security, critical infrastructure protection, countering radicalization, and cybersecurity, to mention a few. Looking at this document as a central reference point and viewing it holistically thus suggests that homeland security, as interpreted by the leadership of the executive branch of government in the United States, Includes many diverse issues.
In terms of actual policies and institutions, one of the most important outcomes of the National Strategy and a slew of other federal strategy documents that have been produced and updated over the years since 2001 is the creation of homeland security agencies (or homeland security functions within existing agencies) at all levels of American government. The most significant of these institutional changes was, naturally, the creation of the Department of Homeland Security (DHS) in November of 2002. Thus, in order to help define homeland security, and in addition to looking at the National Strategy, one can also look at the policy areas for which DHS is responsible, as DHS is the principle federal agency with homeland security duties, though by no means the exclusive one. On 6 June 2002, then President George W. Bush, in an address to the nation, outlined the four essential missions of the newly proposed DHS: (i) border and transportation security, (ii) emergency preparedness and response, (iii) coping with the threat of weapons of mass destruction, and (iv) intelligence gathering and analysis designed to create an integrated intelligence picture (DHS, 2008, p. 5). These missions have evolved to some degree since then. In 2016, DHS also expanded its list of missions to include (i) preventing terrorism and enhancing security, (ii) securing and managing US borders, (iii) immigration, (iv) cybersecurity, and (v) disaster preparedness (DHS, 2016). In the Department’s strategic plan for fiscal years 2014–2018, and falling within the five missions noted above, areas of focus included (i) preventing terrorist travel, strengthening aviation security, preventing the smuggling and use of nuclear weapons and materials, and protecting key leaders, facilities, and events; (ii) securing the US southern border and combatting international organized crime; (iii) strengthening the immigration system (to include combatting immigration fraud and enhancing detention and removal efforts); (iv) reducing cyber risk and enhancing critical infrastructure resilience, both physical and cyber-related; and (v) enhancing preparedness and response to threats and hazards (DHS, 2014a, pp. 6–20).
In view of the above, and without attempting to produce a perfect and definitive definition of homeland security, a functional categorization of the policy areas that fall within the sphere of homeland security, based on DHS’s 2014 Quadrennial Homeland Security Review, may appear as follows:
Policies directed at mitigating the threat of terrorism and large‐scale criminality (of the type that threatens social and economic stability) to include:
Counterterrorism strategy.
Intelligence sharing and coordination.
Policing strategies.
Countering homegrown radicalization.
Policies directed at enhancing security measures, to include:
Border security and immigration enforcement.
Transportation security (air, maritime, and surface).
Critical infrastructure protection (including cooperation between the private and public sectors).
Cybersecurity.
Policies directed at the management of the immediate and long‐term effects of acts of terrorism, natural disasters, and/or public health emergencies to include:
Emergency and disaster preparedness and response.
Mitigating, responding, and recovering from biological threats.
Development of political, social, and economic resiliency (DHS, 2014b, pp. 76–80).
The Third Quadrennial Homeland Security Review of April 2023 included an additional focus on combatting crimes of exploitation as a sixth mission area (DHS, 2023, p. 6). Thus, at least from the perspective of the DHS, homeland security is now just as much about fighting human trafficking, ensuring access to immigration benefits, preventing foreign espionage, building resilience in the face of climate change, and coping with infectious diseases (to name just a few sub-missions), as it is about fighting terrorism. This hodgepodge of missions, only some of which are seemingly related, may lead one to question whether there is any glue that holds the entire enterprise together. To be fair, there are many departments and agencies in the federal government that engage in a wide range of disparate missions. The US Department of the Interior, for example, has a wide range of disparate missions, including land management, stewardship of national parks, provision of services to Native American tribes, conservation, and environmental protection.
If there is a common denominator to the homeland security enterprise, it can be argued that this involves addressing most threats to the country’s sovereignty, stability, and the normal operation of government and society at local, state, and/or federal levels of government – perhaps barring strictly economic threats such as the collapse of the stock market or consumer spending, the breakdown of credit markets, and other such issues that are not necessarily directly brought about by disasters, health emergencies, cyber-attacks by hostile foreign actors, criminal actors, or terrorism. Thus, various DHS mission areas can be interpreted as preparing for, mitigating, responding to, and/or recovering from threats to sovereignty, stability, and the normal operation of government and society. In this way, human trafficking, for example, can be viewed as a threat to sovereignty (including border security), and large-scale criminal enterprises, in general, can threaten stability and the normal operation of government and society – at least in a local area. Similarly, a pandemic threatens social stability and impacts the operation of government and the economy. Immigration too, while arguably not a homeland security issue when the system operates correctly, can become one in cases of immigration fraud, particularly those related to individuals suspected of being a threat in terms of membership in organized criminal networks, terrorist organizations, or engagement in espionage and/or sabotage at the behest of a foreign government.
All of these missions require the sharing of information, interagency and intra‐agency cooperation, and interface with critical stakeholders such as Congress, state and local government, and the public. While the aforementioned listing of the various policy areas is undoubtedly imperfect, it does have the advantage of, more or less, covering those areas identified in various governmental strategy papers and academic studies as part of homeland security. Accordingly, these areas will be addressed in this book in differing degrees of detail, with respect to the approaches taken to them outside the United States (based on the availability of information and space for analysis).
The aforementioned discussion does not, of course, imply that the federal government has a monopoly on knowledge and understanding and is thus able to define homeland security in an unambiguous and correct manner. However, given the absence of a universally agreed‐upon definition, using the broad scope of missions outlined by the federal government represents a reasonable typological compromise in view of the central role played by the federal government in defining homeland security policy, executing it at the federal level, and funding a wide variety of homeland security‐related activities at the state and local levels.
While we may view the aforementioned policy areas as constituting the field of homeland security in the United States, one would be hard-pressed to find any similar amalgamation of what would appear to be very disparate policy domains in the rest of the world. Counterterrorism, emergency management, combatting human trafficking, coping with communicable diseases, immigration policy, etc., broadly speaking, are not seen as part of the same discipline overseas, and there certainly is nothing equivalent to DHS in trying to bring together these policy areas under one institutional framework (the Australians briefly toyed with the idea of creating their own version of DHS and then decided against it). Of course, there are long‐standing cooperative relationships between intelligence agencies and police or between police, fire, and emergency medical services, as many challenges require a multidisciplinary response. However, no one overseas has attempted to put so many different functions and activities within the same rubric and argue that they are all part of the same type of public policy domain.
Homeland Security Versus National Security
The concept of homeland security is uniquely American, largely because most other democratic countries do not distinguish as clearly between what in the United States might be colloquially referred to as the “home game” versus the “away game.” Historically, the United States benefitted from its geographic isolation far from the wars and political machinations of the leading powers on the European and Asian continents. Consequently, there gradually developed a view that there was a distinct separation between domestic and international challenges, and policies (and their attendant institutions) employed overseas were largely irrelevant domestically and vice versa. As the United States came to play a very large role on the world stage during and after the Second World War, the concept of national security, and its attendant institutions, including the Department of Defense, the Central Intelligence Agency, the National Security Council, and the National Security Agency, developed apace. The goal of national security policy was to protect and enhance the various elements of national power (military, diplomatic, informational, economic, etc.) and to safeguard national interests overseas.
Since much of the development of the concept of national security occurred in the context of the Cold War, it is not surprising that the discipline of national security was focused on the Soviet threat and ensuring that the United States was able to contain and deter Soviet ambitions and actions worldwide. Many of the tools employed in safeguarding national security – warfighting, espionage, paying off allies and potential allies, disinformation campaigns, occasional assassination, and other measures – were seen as necessary and legitimate policies for use overseas but certainly fundamentally contrary to American laws and values in a domestic context. Consequently, apart from counterespionage operations and other limited spillovers into the domestic arena, national security was essentially an overseas endeavor.
Figure I.1 Soviet ICBM.
Credit: US Department of Defense/Wikimedia Commons/Public Domain.
With the effective ending of the Cold War in 1989 and the collapse of the Soviet Union in December 1991, threats to national security were transformed and diminished. Of course, countries such as North Korea, Iraq under Saddam Hussein, and Iran (the states constituting George Bush’s “axis of evil”) were still problems (and the United States would go to war against Iraq in 2003). More recently, the rise of China and the resurgence of Russia (and its invasion of Ukraine) pose ongoing challenges, Nevertheless, the pervasive sense of fear of Soviet encroachment (and Soviet nuclear missiles) that propelled national security to the top of the governmental agenda diminished considerably with the faltering and then collapse of the Soviet empire. At the same time, new threats were developing, the primary one, at least for a time, being international terrorism.
Terrorism, however, is a very different kind of threat, both in terms of scope and modus operandi. Terrorists, even those supported by nation-states, cannot command the elements of national power in the way that a state can and thus do not constitute anything remotely similar to an advanced, capable, and belligerent nation‐state. Nevertheless, with the advancement of military technology and the increasing ubiquity of traditional and social media, terrorist groups are increasingly in a position to effectively attack vulnerable targets and populations and to create the impression that they are almost as dangerous and threatening as the Soviet Union once was. Since, in public affairs, impressions are more important than reality, as people act based on their impressions, terrorists are well placed to transform themselves into being perceived as major threats to the security of the United States, even though, in terms of the power that they are able to wield, they really do not deserve to be viewed in such a way. Impressions may motivate people’s actions, but they cannot magically transform terrorists from relatively weak actors into global superpowers. Consequently, terrorists must generally infiltrate their target societies in one manner or another and then strike at relatively undefended and vulnerable targets (usually those that involve public access of some sort) in order to create the impression of power. This means that, at least in democratic countries, the terrorist threat cannot be addressed using exactly the same policies and institutions that are employed against national security threats outside the country’s borders. Arguably, nowhere is this distinction starker than in the United States, with its long traditions of keeping the military and intelligence agencies largely out of domestic affairs. Consequently, in dealing with terrorist threats within American territory, a new concept and approach seemed to be needed, one that was more or less encapsulated by the concept of homeland security. This, I would argue, was the genesis of the concept of homeland security, and it was a very terrorism-centric way of viewing the enterprise.
After the shock of 9/11 began to gradually abate, the United States was hit in 2005 by a massive natural disaster in the form of Hurricane Katrina. In the wake of what was perceived as the impotence of governmental entities at the local, state, and federal levels in preparing for the hurricane and dealing with its aftermath, the concept of homeland security evolved and began to focus on natural disasters in addition to terrorism. There is, of course, some logic in viewing the threat of terrorism and that of natural disasters or pandemics as part of the same discipline. After all, many of the measures instituted to prepare for and recover from the aftermath of emergencies can be applied to terrorist threats, natural disasters, and public health threats, as well as other types of threats (e.g., attacks on critical infrastructure). Also, many of the preventive techniques are also common to coping with all three categories of threats (for example, intelligence gathering, analysis, and dissemination are critical elements of prevention regardless of whether the information pertains to the activities of a terrorist cell, a hurricane moving toward shore, a cyber-attack, or the spread of a pandemic). Moreover, if one is to consider terrorism a major threat to the lives and livelihoods of Americans, natural disasters and pandemics certainly qualify as threats that are equally serious, if not more so. Since 2001, the United States has not been subjected to a terrorist attack that even remotely resembles 9/11, whereas it has had to cope with multiple significant natural disasters over the more than two decades since 9/11. This, of course, was seen with the outbreak of the COVID-19 pandemic in early 2020, which killed one million Americans between 2020 and 2023 (Johns Hopkins University Coronavirus Resources Center, 2023) and generated an economic cost that has been estimated as 20 times greater than that of 9/11 (Hlavka and Rose, 2023). Perhaps other countries did not evolve toward developing a concept of homeland security because they did not view national security as almost exclusively focused overseas and ending at the national borders, and because, for many other democracies (Canada perhaps being a partial exception), large‐scale natural disasters are simply not as common or as threatening as in the case of the United States.
The aforementioned reflections are, at least to some degree, philosophical musings regarding the concepts of national security and homeland security (though the reader should bear in mind that philosophical musings are sometimes the first step and basis for strategic policymaking). The upshot is that homeland security is a concept and discipline that is of American origin and still largely alien to the rest of the world. The reader may thus inquire as to the utility of a book that focuses on international homeland security policies if homeland security does not technically exist internationally, at least not as a unified discipline. The answer to this is that while homeland security as a discipline is alien to other countries, there is a wealth of experience and tested policies and approaches employed overseas in the various areas that constitute homeland security, and it would not make sense for Americans to remain blissfully unaware of them. Reinventing the wheel and repeating the mistakes of others are activities that are both wasteful and counterproductive.
Figure I.2 New Orleans after Katrina.
Credit: US Navy/Wikimedia Commons/Public Domain.
International Comparative Homeland Security
Learning from other countries’ experiences and approaches is important not only because it makes sense for American decision-makers to learn from the experiences of foreign governments but also because in many cases, the threats are transnational, and consequently, while homeland security is a fundamentally domestic concept, safeguarding it requires cooperation with other countries. Whether the threat emanates from radicalized Europeans accessing the United States under the Visa Waiver Program in order to execute terrorist attacks or aircraft passengers flying into the United States from an Asian city carrying the latest viral or bacterial pandemic with them, many homeland security threats emanate from abroad. Examples of such threats abound. In the terrorism sphere, in addition to the 9/11 attackers, Ahmed Resam (the “millennium bomber”), arrested in 1999, used Canada as a staging area for his plot to bomb the Los Angeles International Airport, and Richard Reid (the “shoe bomber”) boarded a Miami‐bound flight in Paris in December 2001. In addition, the 2006 transatlantic liquid explosives plot (the “Overt Plot”) was hatched and prepared in the United Kingdom, and Umar Farouk Abdulmutallab (the “underwear bomber” or “Christmas bomber”) boarded his Detroit‐bound flight in Amsterdam in December 2009. The spillover of Mexican criminal violence into the United States has also been an issue of concern for some time. In the public health sphere, the SARS outbreak in China led to some outbreaks in the United States, with the public health system being put on alert in December 2003, and the outbreaks of avian influenza and swine flu in Southeast Asia and Mexico, respectively, led to pandemic concerns in the United States, as did the Ebola crisis of 2014–2015. Of course, COVID-19, with its profound impact on the United States, is thought to have emerged in Wuhan, China, before crossing the Pacific. In short, there are no lack of examples of homeland security threats emanating from overseas.
It therefore follows that addressing these threats will require not only international cooperation but also an understanding of how other countries, particularly allied democratic nations, address these issues within their own borders. To be able to do this, one must have some baseline knowledge of the governmental and institutional framework and legal basis under which these countries operate. An additional advantage in conducting comparisons is that they help identify options that may otherwise be overlooked, as well as the manner in which various policies that have not, thus far, been adopted in the United States might play out in the United States (Watts, 1999, p. 2).
The focus of this book will be on a handful of democratic countries for three primary reasons: (i) As noted in the Preface to the first edition, time and data limitations do not allow for an across‐the‐board survey of policies followed by countries worldwide. (ii) There is little point in looking at nondemocratic countries since part of the goal of this analysis is to provide information and ideas that might be used by policymakers at various levels of government (and not only in the United States), as well as students of homeland security, in order to improve policies in the United States or in other democracies. Nondemocratic countries are simply less relevant because their policies and practices are usually considerably less applicable to democratic states. Finally, (iii) there is little point in looking at significantly dysfunctional countries, those without significant homeland security‐related policies in place or those with such policies that clearly do not work. In view of the above, this book will focus primarily on Israel, the United Kingdom, France, Germany, Canada, and Australia with a more cursory discussion of additional countries, when their policies are of particular interest, including Japan, the Netherlands, and Italy. Also, as noted in the Preface to the first edition of this book, it was not possible to obtain sufficient data on the policies of each of these countries with respect to each policy area of homeland security surveyed. Time constraints and, in many cases, the sensitivity of the data mean that creating a neat matrix in which each area of homeland security can be laid out and complete data on each country can be filled in is simply not feasible. Accordingly, the focus will be on the most significant strategic policies (with some detailed examples) of these various countries where information was available. This means that not every country will be covered in every chapter, and thus each chapter will involve a different mix of countries with differing levels of emphasis on each. The choice of country to be addressed per homeland security issue area will depend not only on the availability of information but also on the degree to which a particular country has a particularly interesting or useful set of policies in a given issue area. It will be left to future researchers in this field to write definitive accounts of the policies of each country touched upon here within each homeland security issue area.
This volume fits into the general literature dealing with comparative government (though, of course, the focus is on homeland security‐related issues). Consequently, a few words with respect to the comparative method are in order.
The Comparative Method and Comparative Homeland Security
As with any other social science research methodology, the comparative method has its advantages and its disadvantages. If we confine ourselves to focusing on policy‐oriented research and analysis, we find that the comparative method does not provide us with a means of measuring the degree of efficacy of policies followed by different entities in different contexts (in our case, countries) and designed to achieve goals that may be slightly different from one another. This is because the comparative method is not designed to be able to provide meaningful measurements of differing policies operating in differing contexts. To use a fairly simplistic example, the “adversarial legal system,” generally in place in common law countries such as the United States, the United Kingdom, Canada, and Australia, puts the court (a judge and often a jury) in the role of “impartial arbiter,” with the court’s primary role being to ensure that the proceedings adhere to the law and provide due process. On the other hand, an “inquisitorial legal system,” the system in place in many civil law countries, such as France, Italy, and Spain, gives the court the role of determining the facts of the case and assigning guilt or liability. Common law systems are focused on judges (and juries) and allow considerable scope for ad hoc decisions by courts with respect to specific legal cases, whereas civil law systems tend to leave little room for judicial discretion and focus more on a codified body of generalized principles (Slapper and Kelly, 2009, pp. 1869–1876). In reality, there is a considerable degree of crossover between these approaches, and adversarial systems can act inquisitorially in some ways and vice versa. Nevertheless, these two systems are different in their fundamental principles as well as in the way they operate.
While it may be possible to measure the overall efficacy of the judicial system in France and then compare that to the efficacy of the system in the United States (by looking in both cases at variables such as conviction rates, the number of unresolved cases in the system in a given year, the length of legal proceedings, the cost of legal proceedings, etc.), it is not possible to measure the effectiveness of the judicial system in the United States by looking at how things are done in France and then use French measures of success, based as they are on the French system, to determine US success. This is equivalent to the proverbial comparison of apples to oranges. Rather than measuring things, the comparative method is designed to discover “empirical relationships among variables” (Lijphart, 1971, p. 683), and this means that the comparative method allows us to understand how processes work and thus increases our understanding of policy issues and our range of conceivable policy options. Looking at the approaches, policies, and experiences of other countries with respect to homeland security policy areas makes it possible to gain a greater understanding of the options available to policymakers, a sense of how policies should be selected and evaluated, and an understanding of the options available to overseas partners as well as how they operate and cope with their own threats – many of which are, as noted earlier, “transferrable” to the United States. In other words, the comparative methodology gives us the framework in which to study different policies and policy contexts but not really the ability to translate and apply one country’s policies in another. In order to translate one country’s policies into the context of another country, one needs to, as it were, push the policies of the country with the potential solutions through a filter, with the filter representing the system in place in the country we are trying to influence. Whatever comes out of that filter is what is deemed implementable in the country in question. To put this more clearly, if we want to apply a French policy in the United States, we need to first take that policy and see how much of it can be applied in the United States given American laws, the federal system (which does not exist in France), the US Constitution, America’s institutional structure, American culture, and other variables that collectively make up the American way of doing business. These variables make up the filter, and whichever French policies can make it through the filter, as is or in a modified version, are policies that could potentially be adopted in the United States to improve American homeland security policy. Yet another way of putting this is that there are a variety of barriers to the implementation of foreign approaches in the United States. These barriers can be legal, institutional, organizational, social, cultural, or otherwise. Most strategic‐level foreign homeland security‐related policies will not be able to be applied in toto to the United States given these barriers, but some percentage of those policies, or adaptations of these policies, may be able to get through the barriers (or filter) and, if applied, have the potential to positively influence homeland security policy.
As a quick example, the British policing and intelligence model (to be discussed in more detail in Chapters 2 and 3) involves the operation of special units, generally referred to as Special Branches (SBs) (or, in some jurisdictions, as Counterterrorism Branches) in the United Kingdom’s 45 regional police forces and 2 of its 3 national police forces. SB units act as the intelligence arm of their respective police forces of which they are a part as well as a liaison between the domestic intelligence service, MI5 (officially known as the British Security Service), and their respective police forces. These SB units consist of officers with security clearance who are trained by MI5 and support intelligence‐gathering missions conducted by MI5, as well as generating their own intelligence leads. SB units provide MI5 operations with local expertise and networks, and their relationship with MI5 allows the local SBs to be part of national‐level investigations run by MI5.
To apply the SB model to the United States, one would first have to consider that the United Kingdom does not have a federal system of government. Rather than being entirely independent of the national government, the 45 regional police forces are all governed by a combination of their respective chief constables, elected local police commissioners and councils, and the Home Office. The Home Secretary has significant control over policy in the various police forces, as well as MI5 (which reports to the Home Secretary) (Lewis, 2006). Consequently, the United Kingdom can implement national‐level protocols and doctrines at the local level, something that cannot be mandated in the
