Skip to main content
SpringerLink
Log in

Practical continentalism: North America, territorial security and the European model

  • Article
  • Published:
Journal of Transatlantic Studies Aims and scope

Abstract

The lack of formal regional security institutions and the persistence of national border controls seems to indicate that in North America, unlike Europe, a truly post-national approach to territorial security has failed to materialise. Recent policy experiments with territorial security in the USA, Canada and Mexico, however, are not as removed from their transatlantic counterparts as is often claimed. This paper contends that a kind of practical continentalism underlies the governance of territorial security on both sides of the Atlantic. This system of governance has not completely displaced the state-centric model upon which the modern approach to territorial security is based. It has, however, reformulated some of its core principles, resulting in a more complex and regionalised model of territorial security. To illustrate this argument, this paper first presents the key principles underlying the approach to territorial security that has emerged in North America after 9/11, highlighting the parallels with the European experience. It then considers some of this approach’s most relevant policy applications and compares them to initiatives proposed on the other side of the Atlantic. This paper concludes by exploring possible future scenarios characterising relations between North America and Europe over territorial security, and, in particular, the prospect for further transatlantic convergence in this policy field.

This is a preview of subscription content, log in via an institution to check access.

Access this article

Log in via an institution

Price excludes VAT (USA)
Tax calculation will be finalised during checkout.

Instant access to the full article PDF.

Institutional subscriptions

Similar content being viewed by others

Notes

  1. United States’ National Strategy for Homeland Security (Washington, DC: Homeland Security Council, 2002), 22.

  2. A. Capling and K. R. Nossal, ‘The contradictions of regionalism in North America’, Review of International Studies 35, no. 1 (2009): 147–167

    Article  Google Scholar 

  3. S. Clarkson, Does North America Exist? (Toronto: University of Toronto Press, 2008); Pattnayak Hussain and Hira, North American Homeland Security: Back to Bilateralism? Back to Bilateralism? (Westport: Praeger, 2008).

    Book  Google Scholar 

  4. See, for example, C. Rudolph, ‘International migration and homeland security’: Cooperation and collaboration in North America’, Law and Business Journal of the Americas 11, no. 3–4 (2005)

    Google Scholar 

  5. J. Stevenson ‘How Europe and America defend themselves’, Foreign Affairs 82, no. 2 (2003)

    Google Scholar 

  6. Anja Dalgaard-Nielsen, ‘Homeland Security. American and European Responses to September 11th’, in The Politics of European Security, ed. Jess Pilegaard (Copenhagen: Danish Institute for International Studies, 2004)

    Google Scholar 

  7. Esther Brimmer, Transforming Homeland Security: U.S. and European Approaches (Washington, D.C.: Center for Transatlantic Relations, 2006).One exception is Robert Pastor. His view of the ‘lessons’ that the Old Continent can teach the New, however, pre-dates 9/11 and it is centred on economic rather than security issues. See

    Google Scholar 

  8. R. Pastor, Toward a North American Community: Lessons from the Old World for the New (Washington, DC: Peterson Institute, 2001).

    Google Scholar 

  9. Wallace has defined the approach to the governance of European security as ‘intensive transgovernmentalism’. (H. Wallace, ‘The Institutional Setting: Five Variations on a Theme’, in Policy-Making in the European Union, ed. H. Wallace and W. Wallace (Oxford: Oxford University Press, 4th ed., 2000).Arguably, arguments contrasting North America with Europe in territorial security matters tend to conflate the latter with the European Union and its economic realm. As we will see shortly, this characterisation does not reflect this policy field’s actual features and dynamics. That being said, when comparing the two regions we should keep in mind that current policy developments in Europe’s territorial security are occurring in the context of an ambitious regional political and economic integration project. The pressure for deeper cooperation is thus higher in Europe than across the Atlantic. The presence of this distinctive contextual factor, however, renders the argument defended in this paper even more illuminating. Because of the different integrative forces at play, we should in fact expect a marked (and growing) transatlantic divide in the territorial security realm. On the contrary, I point to the existence of significant similarities in this policy area, despite the different institutional contexts in which they are taking place. What should be surprising then is not North America’s admittedly still limited yet improving regional cooperation in territorial security matters (which is occurring in the absence of a formal regional institutional framework), but the relatively shallow level of integration that an ‘united’ Europe has so far achieved in this policy field.

    Google Scholar 

  10. On the concept of ‘practice’ and its application to the study of international relations, see E. Adler and V. Pouliot, International Practices (Cambridge: Cambridge University Press, 2011).

    Book  Google Scholar 

  11. ‘Final Report of the National Commission on Terrorist Attacks upon the United States’, Official Government Edition, July 2004, p. 339 et ss.

  12. Since 2001, ‘Homeland’ and ‘Homeland security’ have become common terms in the United States official and public discourse to define the new policy field. Canada and Mexico have shied away from using this terminology. Canadian officials prefer talking about ‘Public Safety’, while Mexico has stuck with the more traditional ‘internal security’. Despite their reservations about some of the implications of the new approach to territorial security that the new term homeland implied, the two governments have in practice accepted its key premises, especially that a more aggressive stance regarding border security is necessary in the post 9/11 world.

  13. United States’ National Strategy for Homeland Security, 2; emphasis added.

  14. S. E. Flynn, ‘Beyond Border Control’, Foreign Affairs, 79, no. 6 (2000): 57–68.

    Article  Google Scholar 

  15. US Customs and Border Protection, ‘CSI in Brief, available at https://doi.org/www.cbp.gov/xp/cgov/border_security/international_activities/csi/csi_in_brief.xml. Zolberg has defined this type of policy as ‘remote control’ (A. Zolberg, ‘Matters of State: Theorizing Immigration Policy’, in The Handbook of International Migration: The American Experience, ed. C. Hirschman, P. Kasinitz, and J. DeWind (New York: Russell Sage, 1999)).

  16. US National Strategy for Homeland Security, 22.

  17. Privy Council Office. Securing an Open Society: Canada’s National Security Policy (Ottawa: National Library of Canada, 2004), 46.

    Google Scholar 

  18. As the 9/11 Commission put it, ‘The US government cannot meet its own obligations to the American people to prevent the entry of terrorists without a major effort to collaborate with other governments’ (National Commission on Terrorist Attacks upon the United States, The 9/11 Commission Report. (New York: W.W. Norton & Company, 2004), 390.

  19. United States’ National Strategy for Homeland Security, 59; Canada’s National Security Strategy, 37–40.

  20. The 9/11 Commission Report, 428. Mexico, unlike its northern neighbours, has historically relied on a European-style ministry of interior (‘Secretaría de Gobernación’) as the lead agency responsible for the management of territorial security.

  21. The nexus between foreign policy and the protection of the EU external frontiers was first explicitly made in the action plan on illegal migration that the European Council adopted in February 2002. See ‘Proposal for a comprehensive plan to combat illegal immigration and trafficking of human beings in the European Union’ (Official Journal C 142 of 14.06.2002).

  22. Since the 1990s one of the options put on the table in some scholarly and policy circles has been that of a ‘North American Community’, which would involve a deeper degree of integration of various sectoral fields, including homeland security, and an advanced regional institutional framework (Pastor, Toward a North American Community). This vision, however, was put on the backburner in the aftermath of 9/11, in favour of more securitarian measures to protect the North American Homeland. Although there has been renewed interest in recent times (see, for example, ‘Building a North American Community, the 2005 Report of the US Council of Foreign Relations-sponsored Task Force chaired by Manley, Aspe and Weld), North American governments have not officially endorsed the initiative.

  23. The recent spat between Italy and France (two of the most influential EU members) over the handling of migrants who crossed the Mediterranean as a result of the turbulences that followed the so-called ‘Jasmine revolutions’ in North Africa is a good example of the continuing centrality of national governments in the European Union (S. Carrera, E. Guild, M. Merlino, and J. Parkin, ‘A Race against Solidarity: The Schengen Regime and the Franco-Italian Affair’, CEPS Working Paper (2011). In April 2011, the French government in fact unilaterally re-instated border controls with its southern neighbour without consulting with EU institutions, thus violating the spirit of the Schengen agreement.

    Google Scholar 

  24. A. Stubb, Negotiating Flexibility in the European Union (Houndsmill: Palgrave, 2002).

    Book  Google Scholar 

  25. Another notorious example of variable geometry in Europe has to do with the economic realm. The Euro, the common currency introduced in 1999 (and in circulation since 2002) currently covers only 17 and the 27 members of the EU. Membership depends on the willingness or ability of member states to be part of the Euro-zone. As for the Schengen regime, EU member states can therefore opt out, or, if they meet certain economic criteria, join in the club at a later stage. For an overview of the Euro’s history and key features, see D. Marsh, The Euro: The Politics of the New Global Currency (New Haven, CT: Yale University Press, 2009).

    Google Scholar 

  26. On Schengen and its evolution, see R. Zaiotti, Cultures of Border Control (Chicago: University of Chicago Press, 2011). On the challenges stemming from the regime’s expansion, see

    Book  Google Scholar 

  27. Heather Grabbe, ‘The Sharp Edges of Europe: Extending Schengen Eastwards’, International Affairs 76, no. 3 (2000): 519–536.

    Article  Google Scholar 

  28. Thierry Balzacq, Didier Bigo, Sergio Carrera, and Elspeth Guild, Security and the Two-Level Game: The Treaty of Prüm, the EU and the Management of Threats (CEPS Working Document no. 234, Brussels: Centre for European Policy Studies, 2006).

    Google Scholar 

  29. J. Noble, ‘Fortress America or Fortress North America?’, Law and Business Review of the Americas 11, no. 3/4 (2005): 462–477.

    Google Scholar 

  30. See Smart Border Declaration and Action Plan; available at https://doi.org/www.international.gc.ca/anti-terrorism/declaration-en.asp; and https://doi.org/www.dfait-maeci.gc.ca/anti-terrorism/actionplanen.asp.

  31. ‘It’s time for homeland hardball’, op. cit.

  32. The concept of ‘safe country of asylum’ is the key component of the Dublin Convention, which European countries signed in 1990 and became effective in 1997. According to this agreement, if an alien applies for asylum after travelling through a country that is party to the protocol relating to the status of refugees and thus considered to be ‘safe’, he or she will be sent back to that country to file his/her application. On the Dublin Convention and its provisions, see A. Hurwitz, ‘The 1990 Dublin Convention: A Comprehensive Assessment’, International Journal of Refugee Law, 11, no. 4 (1999): 646–677.

    Article  Google Scholar 

  33. The Integrated Border Enforcement Teams (IBET) were originally established in 1996 along the border in the western region of Washington state to combat drug smuggling and illegal immigration. The Smart Border Plan expanded this project to the entire US-Canada border. Since the 1990s EU member states have organised several joint operations to manage Europe’s external borders, such as Operations Triton and Orca (sea borders), Operation Visa (air border) and Operation Eastern External Borders (land borders). On the management of Europe’s external frontiers, see J. Monar, ‘The European Union’s “Integrated Management” of External Borders’, in Soft or Hard Borders? Managing the Divide in an Enlarged Europe, ed. Joan DeBardeleben (Aldershot: Ashgate, 2005).

    Google Scholar 

  34. These officers are government-appointed civil servants posted in selected third countries whose job is to obtain and exchange information on illegal immigration and related issues, to assist, advise and train consular and diplomatic staff as well as airline companies, and to co-operate with the authorities of the host country. European countries had deployed Immigration Liaison Officers (ILOs) since the 1990s as part of their ‘remote control’ policy (S. Lavenex, ‘Shifting Up and Out: The Foreign Policy of European Immigration Control’, West European Politics, 29, no. 2 (2006): 329–350).

    Article  Google Scholar 

  35. The idea of a common database system for the purpose of maintaining and distributing information related to border security and law enforcement is behind the Schengen regime’s Schengen Information System (‘SIS’). On SIS and Europe’s new ‘digital borders’, see Dennis Broeders, ‘The New Digital Borders of Europe: EU Databases and the Surveillance of Irregular Migrants’, International Sociology, 22, no. 1 (2007): 71–92.

    Article  Google Scholar 

  36. In the joint statement that officially presented the Beyond the Border initiative, US president Obama and his Canadian counterpart Harper referred to their common objective to be that of ‘pursuing) a perimeter approach to security, working together within, at, and away from the borders of our two countries to enhance our security and accelerate the legitimate flow of people, goods and services between our two countries’. ‘Declaration by President Obama and Prime Minister Harper of Canada: Beyond the Border: A Shared Vision for Perimeter Security and Economic Competiveness’, February 4, 2011; available at https://doi.org/www.dhs.gov/xlibrary/assets/wh/us-canada-btb-action-plan.pdf, i-v.

  37. ‘Beyond the Border’, 1–27.

  38. A major concern is that Mexico has not taken part in regional security arrangements in the past, and thus its integration with the other two partners might be difficult. Another issue raised by Canadian officials is the difference between the problems at the US-Canadian border and those at the US-Mexican border (illegal immigration, drug and arms trafficking). From a practical perspective, the addition of a new partner could have therefore rendered existing informal co-operation more cumbersome.

  39. In the security realm, the main trilateral forum was the Working Group on Security, whose mandate was to coordinate the activities of various specialised working groups (Traveller Security, Cargo Security, Border Facilitation, Aviation Security, Maritime Security, Law Enforcement, Intelligence Cooperation).

  40. A. Acharya, ‘Regional Institutions and Security Order in Asia’ (paper prepared for the second workshop ‘Security Order in the Asia-Pacific’, Bali, Indonesia, May 29 to June 2, 2000), 18.

  41. Rudolph, ‘International Migration and Homeland Security’.

  42. On postnationalism as a term to portray recent social, political and spatial developments affecting Europe and the rest of the world in areas such as citizenship, law and governance democracy and territory see Y. N. Soysal, Limits of Citizenship: Migrants and Postnational Membership in Europe (London and Chicago: University of Chicago Press, 1994)

    Google Scholar 

  43. M. Zürn, and C. Joerges, Law and Governance in Postnational Europe: Compliance Beyond The Nation-State (Cambridge: Cambridge University Press, 2005)

    Book  Google Scholar 

  44. D. M. Curtin, Postnational Democracy: The European Union in Search of a Political Philosophy (The Hague; London: Kluwer Law International, 1997)

    Google Scholar 

  45. A. Appadurai, ‘Sovereignty without Territoriality: Notes for a Postnational Geography’, in The Geography of Identity, ed. P. Yaeger (Ann Arbor: The University of Michigan Press, 1996).

    Google Scholar 

  46. For a critical view on the politics of homeland security, see D. Bigo, and T. Tsoukala, eds., Terror, Insecurity and Liberty. Illiberal Practices of Liberal Regimes after 9/11 (New York: Routledge, 2008).

    Google Scholar 

  47. ‘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.

Download references

Author information

Authors and Affiliations

  1. Department of Political Science, Dalhousie University, Halifax, NS, Canada

    Ruben Zaiotti

Authors
  1. Ruben Zaiotti
    View author publications

    You can also search for this author in PubMed Google Scholar

Corresponding author

Correspondence to Ruben Zaiotti.

Additional information

Notes on contributor

Ruben Zaiotti is Director of the European Union Centre of Excellence and Assistant Professor in the department of Political Science at Dalhousie University (Canada). His main areas of interest are transatlantic relations, European Union politics, security, border control and migration.

Rights and permissions

Reprints and permissions

About this article

Cite this article

Zaiotti, R. Practical continentalism: North America, territorial security and the European model. J Transatl Stud 12, 90–103 (2014). https://doi.org/10.1080/14794012.2014.877269

Download citation

  • Published:

  • Issue Date:

  • DOI: https://doi.org/10.1080/14794012.2014.877269

Keywords

Search

Navigation