Wiley Series in Homeland and Defense Security

Title Page




Introduction: Studying International Homeland Security Policies

What is Homeland Security?

Homeland Security versus National Security

International Comparative Homeland Security

The Comparative Method and Comparative Homeland Security

Structure of the Book

Issues to Consider

Chapter 1: Country Overview

The State of Israel (Medinat Yisrael)

The United Kingdom of Great Britain and Northern Ireland

The Dominion of Canada

The Commonwealth of Australia

The Federal Republic of Germany (Bundesrepublik Deutschland)

The French Republic (République Française)

The Netherlands (Koninkrijk der Nederlanden)

The Republic of Italy (Repubblica Italiana)

Japan (Nippon-koku)


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

Conduct of Investigations and Judicial Proceedings

Interrogation of Terrorism Suspects

Counterterrorism War-Fighting

Institutional, Organizational, and Strategic Aspects of Counterterrorism Efforts


Issues to Consider

Chapter 3: Law Enforcement Institutions and Strategies

Policing Agencies

Harnessing the Community as a Source of Information for Law Enforcement and Public Safety


Issues to Consider

Chapter 4: Integration and Counter-Radicalization


Models of National Identity as the Source of Immigration Policy

The Degree of Integration of Muslim Populations in Europe

The Radicalization Process

European Governmental Responses to Radicalization


Issues to Consider

Chapter 5: The Role of the Military in Security and Support for Civil Authorities

Legal Frameworks

Overview of the Military Role in Homeland Security

Type of Forces and Missions

Disaster Response and Infrastructure Protection


Issues to Consider

Chapter 6: Border Security and Immigration Policies

The EU: Overview

The EU: Borders and Immigration

National Immigration and Asylum Policies in Europe


Issues to Consider

Chapter 7: Security Policies: Critical Infrastructure Protection, Public–private Partnerships, and Aviation, Maritime, and Surface-Transport Security

Critical Infrastructure Protection (CIP): Introduction

Overall Approach to CIP and the Private Sector

Government Agency Security Interface with the Private Sector

Critical Infrastructure Protection Institutions and Governmental Entities

Private-Sector Critical Infrastructures Responsibilities/Licensing

Aviation, Maritime, and Surface Transportation Security

Aviation Security

Maritime and Port Security

Surface Transportation Security


Issues to Consider

Chapter 8: Emergency Preparedness, Response, and Management

Emergency Medical Services and Their Role

Hospital Preparedness and Response

Incident Response, Command, and Management

National, Regional, and Local Response Strategies and Planning

Post-Event Social Services

Public Communication

Crisis Communication and Resiliency Promotion

Media Relations Policies


Issues To Consider

Chapter 9: Public Health Strategies and Institutions

Health Systems and Institutions Overview

Epidemiological Systems and Contingency Planning in Epidemics and Pandemics

Quarantine Powers


Issues to Consider

Conclusion: International Homeland Security



Wiley Series in Homeland and Defense Security

Series Editor

TED LEWIS         Professor, Naval Postgraduate School

Foundations of Homeland Security: Law and Policy / Marin J. Alperen, Esq. Comparative Homeland Security: Global Lessons / Nadav Morag

Title Page

For Galia, Adi, and Edan


This volume is designed primarily as a textbook for students of the emerging academic and practitioner discipline of homeland security. Although no universally accepted definition of homeland security exists at present (or is ever likely to exist), in the introductory chapter I posit a working definition around which the other chapters are organized. The book is not designed to be an introductory text for students of homeland security, as there are a number of these. Instead, it 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 concerned primarily with analyzing and understanding the homeland security policies followed outside the United States (homeland security is a quintessentially American concept, as explained in the Introduction). Comparative homeland security accordingly mirrors the various subject areas within the broader field of homeland security, and hence I touch on most (or all, depending on one's definition of homeland security) of these issue areas.

Regrettably, a field as sweeping in scope as comparative homeland security cannot be comprehensively addressed in a single volume. As noted in the Introduction, 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. 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, although researchers of domestic homeland security policy will sometimes still 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 is, however, 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 that 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 embellish their documents with photos of smiling agency personnel and members of the public). 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 view of policies. The culture of public accountability is quite strong in the United States and is shared by some of the countries of interest in this book, including the United Kingdom, Canada, Australia, and, in some cases, Germany, and 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, so 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!) people with this linguistic repertoire can be found somewhere, but I am definitely not among them (having true command of only 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 searching attentively 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 darkness, down the street. When 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.”

As the subfield of comparative homeland security is quite new, it also, at present, lacks the kind of comprehensive methodological base that other, more mature, areas of inquiry enjoy. Most works that deal with comparative analysis in fields and subfields such as comparative politics, comparative public health, and comparative policing do not integrate the data and analyze them but, rather, lay out different policies (followed by different nations or jurisdictions within a nation) side by side, although 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, I have attempted to at least take one step in the direction of some sort of integrative approach to comparing across countries.

Finally, comparative homeland security is a very dynamic field, with homeland security laws, policies, and strategies overseas constantly evolving, and while I have attempted to provide as much up-to-date information as possible, changes are occurring constantly and no book in this area can be 100 percent current. In addition, the reader should also bear in mind that policy and strategy as expressed in documents and briefings is not necessarily what really happens. To understand what does really happen, researchers have 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 on in this book, and they need simultaneously to continue working for all of these agencies in all of these countries to make sure that the knowledge they have is indeed still relevant but clearly no such person exists.

Despite the above challenges—most of which, in one form or another, are common to all works in homeland security or other areas of public policy—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, so each chapter touches on a different mix of countries and different sets of issues. Hopefully, the book will stimulate your interest in this field and encourage you to look outside your national borders (although written primarily for an American audience, the book will be of use to others as well) for answers to homeland security problems. The more that policymakers and practitioners in different countries can learn from each others' strategies and approaches, the greater will be the shared pool of knowledge, and this knowledge will ultimately make people safer. That is reason enough to study comparative homeland security.


I would like to thank Kristin Darken and Melissa Lieurance for their invaluable assistance in creating the maps and graphics for this book.

Nadav Morag


Studying International Homeland Security Policies

What is Homeland Security?

Homeland security is a uniquely American concept. Although 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 September 11, 2001, (9/11), they have done so essentially because they were following America's lead. Despite the fact that many countries have partially adopted the term, they have yet to really internalize the emerging discipline of homeland security in the way that it is being developed in the United States. Of course, disciplines, both in terms of their practitioner and academic components, take at least several decades to become fully developed and accepted, so it is no surprise that homeland security is still evolving and that there is a wide range of definitions for this discipline. It is not our purpose in 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 homeland security. However, 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 premier homeland security strategy document, the National Strategy for Homeland Security, a revised version of which was issued by then president George W. Bush and his Homeland Security Council in October 2007, 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 essentially to be focused on counterterrorism and thus recognizable overseas as a “national strategy for counterterrorism.” Indeed, the British government issued just such a strategy in 2006, known as Countering International Terrorism: The United Kingdom's Strategy, which is discussed in Chapter 2.

Figure I.1 Old Glory at Ground Zero. U.S. Navy photo by Journalist 1st Class Preston Keres. September 15, 2001. Image released by the U.S. Navy with the ID 010915-N-3995K-024 @ Wikimedia Commons.


All the countries surveyed in this book 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. Indeed, in the wake of 9/11, homeland security may have 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. 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 cyber security, 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, is an extremely broad field. It seems to involve most threats to the stability and normal operation of government and society at the 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 brought about directly by disasters, health emergencies, or terrorism. This 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 definition developed by the federal government represents a reasonable topological compromise in view of the central role played by the federal government in defining homeland security policy.

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 governance. The most significant of these institutional changes was, naturally, the creation of the Department of Homeland Security (DHS) in November 2002—although a much smaller Office of Homeland Security and a Homeland Security Council (modeled on the National Security Council) had been in existence previously and were established by presidential executive order in October 2001. Thus, 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 principal federal agency with homeland security duties. On June 6, 2002, then president George W. Bush, in an address to the nation, outlined the four essential missions of the newly proposed DHS: (1) border and transportation security, (2) emergency preparedness and response, (3) coping with the threat of weapons of mass destruction, and (4) intelligence gathering and analysis designed to create an integrated intelligence picture (DHS, 2008a, p. 5). Without getting into a survey of the convoluted process of organization and reorganization in DHS and the evolution of DHS missions and areas of responsibility since the creation of this mammoth department (except for the Department of Defense and the Department of Veterans Affairs, the largest, by employee numbers, in the federal government) suffice it to say that the current strategic goals of DHS, based on the department's strategic plan published in 2008, include (1) counterterrorism (including border security, enforcement of immigration laws, and procedures); (2) protection from weapons of mass destruction; (3) protection of critical infrastructures and key resources (including partnerships with private-sector providers, ensuring government continuity of operations during emergencies, cyber security, and protection of air, maritime, and surface transportation sectors); and (4) ensuring emergency preparedness through strengthening response and recovery (DHS, 2008b, 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 may be summarized as follows:

Needless to say, these areas include a great deal of overlap, and all of them require the sharing of information, inter- and intraagency cooperation, and interfacing with the public. Although the list of policy areas above is no doubt imperfect, it does have the advantage of, more or less, covering those areas viewed in various governmental strategy papers and academic studies as part of homeland security, and these areas are, accordingly, addressed in this book in differing degrees of detail (based on the availability of information and space for analysis) with respect to approaches taken to them outside the United States.

Although we may view the policy areas above as constituting the field of homeland security in the United States, one would be hard-pressed to find a similar amalgamation of what would appear to be disparate policy domains in the rest of the world. Counterterrorism, security, and crisis management, broadly speaking, are not seen as part of the same discipline overseas, and there certainly is nothing equivalent to DHS in trying to bring these policy areas together under a single institutional framework (the Australians toyed briefly 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 and fire and emergency medical services since many challenges require a multidisciplinary response, but 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 issue.

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 was referred to by some as the “home game” versus the “away game.” Historically, the United States benefited 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 that 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 in the wake of World War II, 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, 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; such as fighting wars, espionage, paying off allies and potential allies, disinformation campaigns, the 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.

With the effective end of the Cold War in 1989 and the collapse of the Soviet Union in December 1991, threats to national security were transformed and diminished. Although countries such as North Korea, Iraq under Saddam Hussein, and Iran (the states constituting George W. Bush's “Axis of Evil”) were still problems (and, of course, the United States would go to war against Iraq in 2003) and the rise of China was certainly to pose challenges, the pervasive sense of fear of Soviet encroachment (and Soviet nuclear missiles) that propelled national security to the top of the governmental agenda came to an end with the faltering and then collapse of the Soviet empire. At the same time, new threats were developing, of which the primary one was to become that of international terrorism.

Figure I.2 Soviet SS-X-15 mobile intercontinental ballistic missile. May 23, 1984, U.S. Department of Defense @ Wikimedia Commons.


Terrorism, however, is a very different type of threat, in terms of both scope and modus operandi. Terrorists cannot, of course, command the elements of national power 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 global media, terrorist groups were increasingly in a position to effectively attack vulnerable targets and populations and to create the impression that they were 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 (whether or not those impressions conform strictly to reality), terrorists were surprisingly well-placed to transform themselves into major threats to national security even though, in terms of the power that they were able to wield, they really did 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 democratic countries at least, this means that the terrorist threat cannot be addressed using exactly the same policies and institutions that were employed against national security threats outside the borders. Arguably, nowhere was 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.

Figure I.3 Poster of Osama Bin Laden. Al Qaeda propaganda poster found by U.S. Special Operations Forces in Afghanistan, n.d., public domain under terms of Title 17, Section 104 of the U.S. Code @ Wikimedia Commons.


Figure I.4 Aerial view of floodwaters in downtown New Orleans after Hurricane Katrina. September 1, 2005, U.S. Navy photo @ Wikimedia Commons.


After the shock of 9/11 gradually began to abate and in the absence of any additional successful terrorist attacks on U.S. soil coupled with a new kind of shock, the massive natural disaster of Hurricane Katrina and what was perceived as the impotence of governmental entities at the local, state and federal levels in dealing with its aftermath, the concept of homeland security evolved and began focusing on natural disasters as well as those of the human-made variety. There is, of course, some logic to viewing the threat from 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. Also, many of the preventive techniques are also common to coping with all three categories of threats (e.g., intelligence gathering, analysis, and dissemination are critical elements of prevention regardless of whether the information pertains to the activities of a terrorist cell or the spread of a pandemic). Moreover, if one is to consider terrorism to be 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 (particularly in the case of a pandemic outbreak that may kill millions and bring about the collapse of the health system). Perhaps other countries did not evolve toward developing a concept of homeland security because they did not see national security as focused almost exclusively overseas and ending at the national borders and because, for many other democracies (with the exception of Japan), large-scale natural disasters are simply not as common or as threatening as they are for the United States.

The comments above, at least to some degree, are philosophical musings regarding the concepts of national security and homeland security (although the reader should bear in mind that philosophical musings are usually 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 (even if they may use the term to describe counterterrorism policy). 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 discipline. The answer to this is that although 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.

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, although homeland security may appear to be 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 mutation 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 (UK), 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 pandemic 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. In short, there is no lack of examples of homeland security threats emanating from overseas.

It therefore follows that addressing them will not only require 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 to 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 here (Watts, R. L., 1999, p. 2).

The focus of this book is on a handful of democratic countries, for three primary reasons: (1) as noted in the Preface, time and data limitations do not allow for an across-the-board survey of policies followed by countries worldwide; (2) 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 students of homeland security to improve policies in the United States, and nondemocratic countries are simply less relevant because their policies and practices are usually considerably less applicable to democratic states; and (3) there is little point in looking at significantly dysfunctional countries, countries without significant homeland security–related policies in place or those with such policies that clearly do not work. In view of the above, in this book we focus primarily on Israel, the UK, 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, 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. Because of the time constraints and, in many cases, the sensitivity of the data, it is simply not feasible to create a neat matrix in which each area of homeland security can be laid out and complete data on each country can be filled in. Accordingly, the focus will be on the more significant strategic policies (with some detailed examples) of the various countries where information is available. This means that not every country is covered in every chapter, and thus each chapter involves 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 of the countries touched upon here in each issue area of homeland security.

This volume fits into the general literature dealing with comparative government (although, 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, the system generally in place in common law countries such as the United States, UK, Canada, and Australia puts a judge 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. Common law systems are focused on judges (and juries) and allow considerable scope to ad hoc decisions by courts with respect to specific legal cases, whereas civil law systems tend to leave little room for judicial discretion and to 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 in which they operate.

Although 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, and the cost of legal proceedings), 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 U.S. 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 (whether or not they view it as that) makes it possible to gain a greater understanding of the options available to U.S. 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.

To understand homeland security–related approaches, strategies and policies followed in the primary countries surveyed in this book: Israel, the UK, France, Germany, Canada, and Australia (and to a lesser degree, Japan, the Netherlands, and Italy), it will first be important to understand the historical, political, and institutional contexts in which these countries operate (more on this later).

Structure of the Book

In this book we address each area of homeland security based on the categories comprising the field of homeland security but with a focus on the overarching approaches, legal bases, institutions, and some of the specific policies followed by the countries noted above as well as, in certain contexts, the supranational European Union. Each chapter, however, focuses on a different mix of countries and issues within the general topic of each chapter because the goal of the book is to provide some interesting perspectives of policies and approaches followed overseas rather than an exhaustive catalog of countries and their respective laws, institutions, and policies. In addition, sidebars that provide snapshots of particular practices or issues pertaining to topics being addressed within each chapter are interspersed within the text to provide the reader with some examples and a more concrete sense of how the issues being discussed are addressed by one or another of the countries in this survey.

Chapter 1 consists of a brief overview of the political institutions and judicial systems of Israel, the UK, Canada, Australia, France, Germany, Italy, the Netherlands, and Japan. The objective of this chapter is to provide the reader with the general political and institutional context in which these countries operate. Chapter 2 is a survey of counterterrorism laws, strategies, institutions, and examples of specific policies followed by a number of countries. Chapter 3 focuses on policing and law enforcement institutions and strategies, which are an important facet of homeland security given that traditional policing plays an integral part in counterterrorism efforts. This is the case both because in all the countries surveyed as well as in the United States, the first line of defense and most ubiquitous counterterrorism actor is the local law enforcement official and because a significant component of terrorist activity involves a criminal nexus of one sort or another. Chapter 4 focuses on the status of Muslims in Europe and the counter-radicalization strategies followed by some European countries given that homegrown radicalization is considered a growing problem not only in the United States, but especially in Europe. Particularly as international travel (especially to areas of known Jihadi activity such as Pakistan, Yemen, or Somalia) has come under greater scrutiny by the authorities, domestic radicalization has increasingly afforded global Jihadi groups an alternative to traveling to their target countries. Moreover, radicalized individuals from Europe and other areas that enjoy visa-free travel to the United States can pose a significant threat to homeland security.

Chapter 5 focuses on the role played by military forces in a number of countries in the provision of domestic security and support for civilian authorities. The issue of the military's role in domestic security is often quite controversial in the United States, but as shown in this chapter, many countries have few qualms about employing their respective military establishments for domestic security missions, particularly when conditions are not normal. Chapter 6 focuses on border security, immigration policy, and survey border management approaches followed with respect to the supranational European Union (a model that could conceivably be applicable at some future date to the North American Free Trade Area or any other North American combined border security regime). Chapter 7 focuses on security strategies with respect to protecting potential terrorist targets. The chapter begins with a brief discussion of critical infrastructure protection and governmental partnerships with the private sector—which in all the countries surveyed currently make up the bulk of critical infrastructure operators. Chapter 9 then moves on to focus on transportation security and look at the air, maritime, and surface transportation sectors. The ready access and mass use of transportation networks (and their criticality for economic and social interaction and activity) have made them prime targets the world over for terrorist attacks, as attested to by the large number of attacks against buses in Jerusalem, Tel Aviv, and other Israeli cities between 2000 and 2004; the Madrid rail network in 2004; the 7/7 and 20/7 attacks against public transportation in London in 2005; and of course, the Al Qaeda attack against four U.S. airliners on 9/11.

In Chapter 8 we look at strategies, institutions, and policies followed by the countries surveyed that are designed to respond to emergencies (whether terrorism-, natural disaster-, or public health–related) and to manage the intermediate- and long-term impact of such emergencies, including emergency preparedness and emergency response and management. The focus is also on the approaches taken by several countries toward crisis communications, with an eye to fostering public resiliency. Finally, in Chapter 9 we look at a number of public health strategies, institutions, laws, and policies followed by a variety of countries surveyed.

Although none of the countries and policies to be surveyed represent perfect policy approaches and solutions to all homeland security problems, many of them have proven useful and comparatively successful in achieving specific policy objectives and thus should be of interest to others in analyzing and improving upon homeland security laws, strategies, and policies in the United States and other countries as well as building a foundational knowledge base for students of homeland security.

Issues to Consider