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Articles

Practising homeland security across the Atlantic: practical learning and policy convergence in Europe and North America

Pages 328-346 | Received 03 Nov 2011, Accepted 19 Dec 2011, Published online: 01 Mar 2012
 

Abstract

Despite different traditions, interests and perceptions characterizing North American and European approaches to homeland security, since 9/11 policy-makers across the Atlantic have formulated increasingly similar policies to deal with terrorism and other international security threats. Challenging mainstream accounts elaborated in the policy convergence literature, and drawing from sociological works in performance studies, this essay argues that the recent evolution of homeland security policies in Europe and North America can be understood as an instance of ‘practical learning’. From this perspective, this outcome is the result of the acquisition on the part of European and North American policy-makers of the practical knowledge necessary to carry out the new policies, policies learned by mimicking the practices of their counterparts across the Atlantic. This argument is then applied to examine two cases of policy convergence in Europe and North America – the proposal for a ‘European Passenger Name Record’ system and the project of a regional ‘Security Perimeter’.

Notes

1. European Commission, Proposal for a Council Framework Decision on the use of Passenger Name Record (PNR) for law enforcement purposes, COM (2007) 654, Brussels, 6 November 2007. For an overview, see Hailbronner et al. (Citation2008).

2. These proposals are part of the European Commission's recently launched European border management strategy (‘Preparing the next steps in border management in the European Union’ (SEC 2008) 153. Brussels, 13 February 2008).

3. This theme has been mentioned on various occasions during bilateral meetings between US and European homeland security officials. See, for example, ‘U.S. Meets With Europe To Unite Against Terrorism’, US Department of Homeland Security; 6th January 2011; available at http://www.thegovmonitor.com/world_news/united_states/u-s-meets-with-europe-to-unite-against-terrorism-44438.html

4. Homeland Security, for instance, is not mentioned in Heichel et al.'s (2005) overview of empirical works on cross-national policy convergence in Comparative Politics and International Relations. More recently, the influence of US policies on European approaches to homeland security has been addressed in Pawlak (Citation2007).

5. Practice theory is well established in the social sciences, especially Sociology and Anthropology (Ortner Citation1984, Schatzki et al. Citation2001, Reckwitz Citation2002). Recently, this body of work has spilled over to the field of International Relations (Williams Citation2007, Pouliot Citation2010, Adler and Pouliot Citation2011). Works on expertise and expert performance, instead, have not yet been the object of systematic attention in IR scholarship.

6. For the purpose of this paper, policy convergence is defined as ‘any increase in the similarity between one or more characteristics of a certain policy (e.g., policy objectives, policy instruments, policy settings) across a given set of political jurisdictions (supranational institutions, states, regions, local authorities) over a given period of time’. (Knill Citation2005, p. 768; for a critical take on the concept of ‘convergence’, see Pollit Citation2001). In the present case, the focus is on the convergence of policy content within two regions (Europe and North America) and the type of process analyzed is what in the policy convergence literature is known as ‘Beta convergence’ – laggard policy actors catching up with leaders with regard to a particular policy (Heichel et al. Citation2005, pp. 831–834; see also Knill Citation2005, p. 769).

7. See, for instance, the content of the 2002 US National Strategy for Homeland Security and the EU's 2001 Action Plan on the Fight Against Terrorism.

8. The full text of the letter is available at: http://www.statewatch.org/analyses/no-2-useu.pdf

9. This stance has been reiterated in personal interviews with officials from the EU Commission and the US and Canadian governments. This point is further elaborated in the second part of the paper, where I present two exemplary cases of transatlantic policy convergence.

10. On lesson drawing as premised for policy transfer and convergence, see Rose (Citation1991).

11. On ‘skill acquisition’ in expert performance studies, see Proctor and Kim-Phuong (Citation2006).

12. On the role of ‘observational learning’ as part of practical learning, see Janelle and Hillman (Citation2003, p. 42), Starkes et al. (Citation1996).

13. The conditions outlined above are necessary, but not sufficient for successful convergence. Demand for a policy (i.e. the proposed initiative should address a pressing policy issue) and adequate political will to carry out the new policy are additional conditions for this outcome to occur. In turn, if the necessary conditions for practical learning are present in a given situation, yet policy convergence does not occur, the argument would be falsified.

14. Outcome of Proceedings, EU–US informal JHA senior level meeting (22–23 January 2007, Berlin), 5655/07, Brussels, 26 January 2007, p. 63.

15. European Commission, Accompanying document to the Proposal for a Council Framework Decision on the use of Passenger Name Record (PNR) for law enforcement purposesimpact assessment, SEC (2007) 1453, 6 November 2007.

16. Council Directive 2004/82/EC of 29 April 2004 on the obligation of carriers to communicate passenger data. Official journal of the European Union, L 261, 06/08/2004, p. 24.

17. Agence Europe, ‘EU/JHA: French Presidency repeats benefits of “European PNR”’, 3 December 2008.

18. European Commission, ‘Preparing the next steps in Border Management in the European Union – Impact Assessment’, Commission Staff Working Document, COM (2008) 69 final; SEC (2008) 154, p. 62.

19. European Commission, ‘Preparing the next steps in Border Management in the European Union – Impact Assessment’, op cit., p. 63.

20. European Commission, Communication the possibility of introducing an EU ESTA – Roadmap (2011). This document refers to the ESTA's US version as term of reference to determine the system's applicability to Europe (p. 3).

21. US State Department official, Interview with author, Washington, January 2009.

22. US Department of Homeland Security Official, Interview with Author, Washington, January 2009.

23. US State Department official, Interview with Author, January 2009.

24. European Commission Official, Interview with author, Brussels, December 2008.

25. While DHS officials only go as far as to say that ‘what happened with the EU might have been in the background’ (DHS official, Interview with author, January 2009), representatives from other US departments are more candid about this influence.

26. It should be noted that even in Europe harmonization of border control policy is still a work in progress, and the European model is still mostly intergovernmental.

27. The ‘P4P’ was launched in September 2001 by the US administration as an attempt to spur further regional economic integration.

28. See for example, the comments by Kelly Ryan, deputy assistant secretary for the Bureau of Population, Refugees, and Migration at the US Department of State, at a hearing on the Safe Third Country Pact at the House Committee on The Judiciary, Subcommittee on Immigration, Borders and Claims, held on 16 October 2002.

29. In his testimony to the US House of Representative on the Canada-US Safe Third Country agreement (see footnote 32), US deputy assistant secretary Kelly Ryan, for instance, mentions how the two governments ‘have sought to learn the lessons of others who have developed similar arrangements (and) watched our friends in the European Union implement a safe country agreement’.

30. Telling is the response by the then Immigration Minister Elinor Caplan to a question about the project: ‘When you say “perimeter”, people think the European model where you erase the internal borders. That is not what we are talking about’ ‘Border Deal Would Screen Travelers Before they Arrive’, National Post, November 9, 2001.

31. For example, Canadian officials were talking about co-operating with US authorities on a system for dealing with the entry of third-country nationals, in effect, a common visa policy.

32. ‘Trilateral dialogue is worth the effort; Partnership tackles continent's economic, security needs’, Christopher Sands and Greg Anderson, The Edmonton Journal, 19 April 2008.

33. Indeed, in December 2010 the Canadian press reported that negotiations on a revamped security perimeter agreement between the US and Canadian governments had been under way for some time. (‘Canada negotiating perimeter security deal with U.S.’, The Globe and Mail, December 8 2010). In February 2011, the US President and the Canadian prime Minister officially announced the launch of a new perimeter initiative. ‘Harper and Obama eye sweeping change in border security’, The Globe and Mail, February 2, 2011.

34. ‘Freedom, security, privacy – European home affairs in an open world’, Report of the Informal High-Level Advisory Group on the Future of European Home Affairs Policy (‘The Future Group’), June 2008, pp. 10.

35. For a critical view on the politics of homeland security, see Bigo and Tsopukala (Citation2008).

36. ‘International Travel Security High on G8 Agenda – leaders’ action plan to focus particularly on air travel’, 8 June 2004, State Department Press Releases and Documents.

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