Memorandum submitted by Society of British
Aerospace Companies (SBAC)
1. INTRODUCTION
1.1 SBAC is the UK's national trade association
representing companies supplying civil air transport, defence,
security and space markets. SBAC encompasses the British Aviation
Group (BAG) and UKspace. Together with its regional partners,
SBAC represents over 2,600 companies across the UK supply chain.
1.2 SBAC members provide support to the
Home Office's Office for Security and Counter Terrorism (OSCT)
through participation in the UK Security and Resilience Industry
Suppliers Community (RISC). RISC is an alliance of companies,
trade associations and think tanks with links to academia that
brings together the UK industrial community to support the Government
in creating a more secure and safe environment for UK citizens.
1.3 SBAC members are engaged in the fast
developing domestic and international security markets for which
there are many interfaces with government departments, emergency
services and other agencies. There are opportunities for the Home
Office and other appropriate agencies to continue to work closely
with industry to meet the UK's national counter-terrorism needs
and SBAC therefore welcomes the opportunity to contribute to this
inquiry.
2. SUMMARY
2.1 The UK's national policy agenda is affected
by well-documented security challenges, especially the threat
posed by terrorism. Industry has a critical role to play in supporting
OSCT and other government agencies in delivering CONTEST and must
do so in the context of rapid change. Industry should be looked
upon as a key component of the UK's ability to meet the major
threats identified in the Government's National Security Strategy
(NSS), especially the severe threat posed by terrorism;
2.2 UK industry possesses a broad range
of capabilities that can support the Home Office and other appropriate
agencies in delivering UK national security; industry should be
considered as a willing strategic partner to agencies responsible
for delivering counter-terrorism;
2.3 Industry welcomes the Government's decision
to update the UK's Counter Terrorism Strategy (CONTEST II) and
looks forward to continued cross-government engagement through
existing mechanisms such as RISC to deliver it. RISC provides
government and industry with the opportunity to review security
matters collaboratively and, where appropriate, to work together
to improve the UK's ability to meet operational requirements that
are needed to counter terrorism.
2.4 Specific recommendations relating to
this inquiry's scrutiny of the Prepare and Protect strands of
CONTEST are listed in section five.
3. DELIVERING
THE UK'S
COUNTER-TERRORISM
STRATEGY—SBAC VIEW
ON THE
UK CONTEXT
3.1 The UK faces a serious, sustained and
well-documented terrorism threat. As recognised in CONTEST and
the NSS, multi-agency cooperation and public/private sector partnership
working are necessary to meet this challenge.
3.2 It is encouraging that CONTEST identifies
that "Successful delivery of this counter-terrorism strategy
depends upon partnerships between all parts of Government; the
public, private and voluntary sectors; and all of us as individuals
and as members of communities." It is hoped and anticipated
that industry's role in counter-terrorism will continue to be
looked upon positively in future revisions of CONTEST.
3.3 CONTEST makes clear that the current
threat from terrorism is genuinely international in scope. As
such, traditional boundaries between "defence" and "security"
policy are increasingly blurred. For example, overseas stabilisation
and peace-keeping operations can help to tackle the conditions
which might promote terrorism and lead to terrible consequences
for domestic security. Similarly, in industrial terms, "defence"
equipment, systems and technologies can be adapted and deployed
in a domestic, civil context to help counter the threat posed
by terrorism. Government structures and industry's outlook are
adapting to reflect this increasing trend. It is encouraging that
OSCT has been established to coordinate the UK's domestic counter-terrorism
effort across all the departments that are responsible for security
policy both at "home" and overseas. SBAC members can
continue to assist the OSCT with its responsibilities, including
with respect to how UK Ministry of Defence (MoD) industrial capability
can be merged into domestic security at both technical and other
levels.
3.4 No single Government department is responsible
for the provision of all aspects of UK security. UK National Security
governance must continue to address the new and complex interconnected
challenges by integrating the outlook and activities of all the
relevant agencies. The NSS explains that "the major security
challenges require an integrated response that cuts across departmental
lines and traditional policy boundaries." Similarly the processes
for developing and supplying the equipment, systems and technologies
that may be required to mitigate (and respond to) emerging terrorist
threats will continue to benefit from integrated engagement across
Whitehall and with private operators of the Critical National
Infrastructure (CNI). Industry is fully supportive of an integrated
government approach to meet national security challenges such
as the terrorism threat.
4. INQUIRY COMMENTS
4.1 Against this background SBAC would offer
the following comments.
4.1.1 OSCT has engaged industry in a productive
manner during its first two years of operation. The co-ordinated
articulation of OSCT and other departments' priority operational
requirements that draw on industrial capability is the next natural
step for the security agenda.
4.1.1.1 With regards to developing UK-based
security operational requirements, the Home Office has a leading
role to play in setting counter-terrorism priorities and working
with other agencies and industry to deliver them. Since 2007 OSCT
has engaged the security industry positively through RISC; considerable
progress has been made through this channel and it is hoped that
strong dialogue will continue. RISC has emerged as the principal
strategic point of contact between Government (OSCT) and Industry
to address counter-terrorism issues.
4.1.1.2 Industry in the UK welcomed the Government's
establishment of four pilot RISC "Industry Advisory Groups"
(IAGs) in April 2008 on themes pertinent to the current threat
posed. Industry is encouraged that the Ministry of Defence (MoD),
the Centre for the Protection of National Infrastructure (CPNI),
The Transport Security and Contingencies Directorate (TRANSEC)
in the Department for Transport (DfT), the Home Office Science
and Development Branch (HOSDB) and other Government Departments
and operational agencies are represented within these IAGs' deliberations;
in this way OSCT and the full range of appropriate domestic security
agencies are able to draw upon the relevant capabilities and experience
whilst engaging industry in a coordinated manner. With a drive
to develop the groups' objectives and outcomes well underway,
the IAGs are seen by SBAC as useful mechanisms for pulling HMG
and industry closer together. Industry can best bring its technology
and investment to bear in helping to solve security problems when
it is taken into the confidence of the Government agencies. The
IAGs should therefore be given time to develop and work in a proactive
manner with all relevant agencies across Government who are tasked
with addressing future threats and challenges.
4.1.1.3 The publication of CONTEST II could
place necessary additional requirements on these groups' activities
and Industry will aim to be responsive to HMG's needs. Government
should therefore consider carefully whether wholesale reform of
these groups will be necessary in the wake of CONTEST II. In so
far as industry is involved in delivering CONTEST the collaborative
formation of the Government's necessary requirements that can
be met by private sector suppliers is the next natural step for
the counter-terrorism agenda. Greater clarity over future capability
requirements will help to encourage industry to invest shareholders'
money in developing new approaches.
4.1.2 It is not easy to judge how well the
UK's critical infrastructure is prepared for, and protected against,
terrorist attacks. Despite the work being done by the CPNI which
has gone out of its way to contact the supply side of industry
this is because CNI ownership is overwhelmingly in private sector
hands, subject to different regulatory regimes and the demands
of shareholders. Improvements could be made and stronger relations
with industry (both installations' private operators and industry
suppliers) could be developed. As CONTEST makes clear, "the
private sector is crucial in protecting the UK and UK interests."
This is because it is often private companies who are responsible
for the financing and operational delivery of protective security
measures around critical assets (including energy installations,
transport systems and crowded places) across the country. Similarly,
the effectiveness of UK critical infrastructure's protective security
measures is to a certain extent reliant upon industrial suppliers'
ability to develop new and innovative solutions to mitigate against
specific threats. Against this backdrop, a continued debate is
needed about the role that regulators of the CNI might play on
security issues in the future. In that respect the Government's
efforts to protect the CNI against terrorist attacks could benefit
from stronger interaction with the private sector at the strategic
level:
4.1.2.1 With respect to oversight of private
operators' operational security responsibilities, the Government
might feel it should have powers to impose security/resilience
standards on CNI designated operators/organisations. It might
choose to do this by ensuring that sectoral Utility Regulators
take into account security and resilience capabilities when making
judgements about investment and competition issues. This may require
legislation. The introduction of security and resilience measures
can be seen as non added value costs hitting the bottom line.
Unless there is some financial incentive to invest within a level
playing field there could be large variances in the approaches
taken by the Boards of CNI operators. The supply industry believes
that this is an important area for the Government to tackle.
4.1.2.2 In the area of encouraging counter-terrorism
innovation from the UK security industrial base, Government should
work closely with RISC to address industry's concern around the
existing potential for disproportionate third party liability
exposure following acts of terrorism in the UK or across the European
Union (EU). In industry's view legislation introduced after the
events of September 11 2001 in the United States has helped to
create an environment whereby closer public and private collaboration
has encouraged stronger security technology innovation. The US
"Safety Act" removed barriers to innovation because
the Government was tasked with approving new technologies that
are appropriate for deployment. Upon each technology's approval
by the Department of Homeland Security (DHS), suppliers are protected
against unmanageable liability claims that might follow new attacks.
This both encourages companies to invest in security technology
innovation and ensures stronger product quality control. In addressing
the existing potential for unmanageable liability claims following
new attacks in the UK, potentially in a similar manner to the
US's experience, the OSCT would help foster an environment whereby
the delivery of technological innovation and harmonisation necessary
for the counter-terrorism agenda would be more easily achieved.
4.1.2.3 With respect to the International
security policy agenda the UK should also encourage counter-terrorism
innovation by looking to take full advantage of the EU's €1.4
billion budget from 2007-13 that offers Government agencies, academia
and industry up to 75% of the cost of undertaking research and
development in the security field.
4.1.3 In meeting the counter-terrorism challenges
that the UK faces, the provision of state-of-the-art systems,
technologies, services and equipment will continue to be critical.
SBAC members are widely acknowledged as world leaders in the provision
of defence and security systems, equipment and technologies. For
example, they provide cutting edge system integration capabilities
that support the emergency services and protect the UK's borders.
Industry was encouraged by the Home Secretary's October 2008 IPPR
Security Lecture which recognised that Government departments
"need to be working with industry." She also highlighted
that "We are world leaders in security and defence technologies
and we have on our doorstep great expertise and creativity, prepared
to help us solve some of the problems we face. We do not want
to forgo that opportunity. We have worked hard to develop new
forms of engagement and new mechanisms for sharing problems, ideas
and solutions."
5. PROPOSED RECOMMENDATIONS
TO BE
INCLUDED IN
THE INQUIRY
REPORT
5.1 Industry should continue to be recognised
in CONTEST as a key strategic partner to the Home Office and other
appropriate agencies in delivering the UK's counter-terrorism
strategy through the RISC Framework;
5.2 The Government should consider whether
the private sector's role in supporting CONTEST, as both a supplier
and an operator of the nation's Critical National Infrastructure
(CNI), should be treated more thoroughly in future revisions of
the National Security Strategy;
5.3 A continued debate is needed about the
role that regulators of the CNI might play on security issues
in the future. The Government might feel that it should have powers
to impose security/resilience standards on CNI designated operators/organisations;
5.4 Government should work closely with
Industry to address its concern around the existing potential
for disproportionate third party liability exposure following
acts of terrorism in the UK or across the EU to bring the market
into line with US practice;
5.5 The four pilot RISC IAGS setup at the
request of Government in April 2008 should be updated to meet
specific needs arising from CONTEST II if appropriate, but also
be given time to deliver the outcomes and deliverables that have
already been agreed to date;
5.6 The Home Office and other appropriate
agencies should continue to engage industry at senior and operational
levels through RISC to formulate and develop future security technology/equipment
operational requirements and responses;
5.7 RISC and the associated IAGs should
evolve over time to cover all security and resilience issues,
not just the threat from terrorism.
6. CONCLUDING
REMARKS
6.1 SBAC and other RISC members already
support OSCT and other agencies responsible for counter-terrorism
with a broad range of equipment, technologies and systems. Industry
in the UK should continue to be identified as a willing strategic
partner to the Home Office in meeting complex counter-terrorism
challenges.
6.2 SBAC would welcome the Committee's recognition
of industry's crucial role in the UK's counter-terrorism effort.
Through its support of OSCT through RISC, industry will continue
to contribute to the UK's counter-terrorism effort.
January 2009
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