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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:
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.
Nadav Morag is Professor and Chair of the Department of Security Studies at Sam Houston State University. He also serves on the faculty of the Center for Homeland Defense and Security (CHDS) at the Naval Postgraduate School. Previously, he was a Senior Director at Israel's National Security Council. He has written extensively on terrorism, homeland security, and Middle East policy, including previous editions of Comparative Homeland Security: Global Lessons.
CONTENTS
Preface to the Third Edition
Preface to the Second Edition
Preface to the First Edition
INTRODUCTION: STUDYING HOMELAND SECURITY POLICIES FOLLOWED BY OTHER COUNTRIES
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
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
2 COUNTERTERRORISM STRATEGIES, LAWS, AND INSTITUTIONS 77
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
3 LAW ENFORCEMENT INSTITUTIONS AND STRATEGIES
Israel
United Kingdom
Germany
France
Japan
4 EMERGENCY PREPAREDNESS AND EMERGENCY 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
5 THE ROLE OF THE MILITARY IN SECURITY AND SUPPORT
OF 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
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
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
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
Issues to Consider 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
Bibliography
Index
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:
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...
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