Written Evidence Submitted by Edward Sudall (CLL0109)

Executive Summary ● The evidence base of lessons learnt to avert poor COVID-19 response existed before the onset of COVID-19. The political under-prioritisation of preparedness in response to prior policy documents is partially to blame for Britain's under performance. ● The dictum to ‘Follow The Science’ is problematic and counter-intuitively indicative of poor use of the necessarily broad scientific evidence base and uncertain information required to face the complexity of a pandemic ● Demarcating science from non-science in lending epistemic authority to British made epidemiological models rather than precautionary emergency management illustrates systematic errors. ● Socially constructed assumptions about risks and anxieties shaped how British decision-makers responded, and did not respond, to the threat of COVID-19. ● Whitehall communications in COBR-SAGE foster miscommunication by design in having too many voices, an overabundance of expertise, and diffuse responsibility. ● British policies such as The Civil Contingencies Act and UK Concept of Operations are agents in the process of decision-making and are too generally designed around frequent risk ‘emergencies’, such as terrorist and national security issues, than national scale rare yet high magnitude hazards such as pathogen outbreaks.

Introduction

1. My name is Edward Sudall and I am submitting evidence. I am an MSc student at the department of Science and Technology Studies (STS) at University College London (UCL). I worked as an uploader who edited articles from The Washington Post, The New York Times, and our own reporters at The Independent newspaper from January 2020. I am therefore familiar with the real-time commentary and media response to COVID-19. I became invested in the government response partly out of the disparate reports and fact-claims from across the world, but most of all in my Science Policy study within STS. Science Policy in An Era of Risk and Uncertainty, taught by Dr Carina Fearnley of The UCL Early Warning Research Centre, in particular, illuminated the differing mechanisms and competencies of national responses.

2. I am submitting evidence on the efficacy of UK intra-government communications in its response to COVID-19. I however emphasise that policies, albeit grouped in different themes, are interrelated and bear family resemblances even when categorically distinct. International government communications, for instance, affects prior preparedness, non-pharmaceutical interventions, and determines what data makes it into epidemiological models. Nevertheless, for the sake of brevity, I keep my submission terse given the scale of challenges; my citations, nonetheless, are open to further investigation and I am open to providing clarifications to the Science and Technology and Health and Social Care Committees as they may see fit.

Lessons Learnt To Lessons Enacted

3. The inquiry requests that ‘lessons learnt’ from the pandemic be evidenced. Scientific evidence alone is however insufficient for preventing and addressing disasters of intercontinental complexity in an era of uncertainty unless they are acted upon. Consider pertinent prior inquiries such as Scientific Advice and Evidence in Emergencies (2010-11), Science in Emergencies: UK Lessons from Ebola (2014-15), and Operation Cygnus (2016) which all provided evidence-based lessons learnt. Those lessons however were under prioritised and under-funded, leaving the UK vulnerable to the COVID-19 pandemic (Department of the Official Report (Hansard) et al., 2010; House of Commons Select Committee, n.d.; Mellish et al., 2020; Public Health England, 2020). I therefore distinguish between lessons learnt and lessons enacted; the existence of sound evidence alone is seldom enough to alter policy. We also distinguish between good evidence and chosen evidence; relevant expertise and evidence is out there but unevenly distributed and selected. For example, a 2007 systematic review of physical distancing measures and lockdowns from the 1918 influenza pandemic, concluded early lockdown and physical distancing reduced peak death rates by 50% compared to cities without lockdowns (Hatchett et al., 2007). Such dormant evidence became a priority, however, in reaction to the COVID-19 emergency rather than in pre-emption for a COVID-19 scale emergency. The admittance of lessons to be learnt, then, is of little use if the policy apparatus fails to enact those lessons.

4. While the prior distinctions may appear pedantic, the process of learning from COVID-19 supports them. Since the existence of correct information and lessons learnt on-paper from the past seemingly had little bearing on adequately preparing the UK for COVID-19. Johns Hopkins’ vetted Global Health Security Index (GHSI), for instance, ranked the UK second “most prepared'' nation in the world for a pandemic, as illustrated below: 5. 6. (The Global Health Security Index, 2019)

7. This second place ranking is partially formed from an absence of evidence, such as in the unpublished Exercise Cygnus. Jeremy Hunt, health secretary in 2016, defended UK preparations after Cygnus exposed failings by citing that “a US think tank ranked us second most prepared” (Sherling, 2020). Assumedly he refers to the GHSI which is, however, only as good as the data provided and data enacted. The GSHI assessment would bear a different result with Cygnus data communicated and thereby factored-in. The GSHI rank is actually an example of scientific evidence misleading because of ignorance of pertinent data and its confident ranking inviting, perhaps even enacting, complacency compared to mid-ranked nations like New Zealand (Boyd et al., 2020). In reality, the inverse of GHSI has come about. The UK has underperformed with a cumulative confirmed death count of 127,156 on 14 April 2021 (Official UK Coronavirus Dashboard, 2021). And, population factored in, one of the worst death counts in the world: 8.

9. (Coronavirus (COVID-19) Deaths, 2021.)

10. The Lowy Institute ranks the UK sixty-sixth for its COVID-19 performance. Nations with harsher prior experience of epidemics and natural hazards meanwhile performed far better; the Westminster-modelled New Zealand government ranks first in the world (Lowy Institute, 2021.). New Zealand has 26 deaths (COVID-19: Current Cases, 2021.). Sheila Jassanoff et al categorise the UK as a “chaos country” whereas New Zealand is best defined as a control country (Jasanoff et al., 2021). Jack Stilgoe and co-authors blame UK under-performance on “A climate of complacency, weak leadership, policy hesitancy, vacillation and presumptions of national exceptionalism” (Jasanoff et al., 2021, p. 102). These are indeed proximate causes of mismanagement. But the ultimate causes behind them are difficult to discern. Assumptions of British exceptionalism and improvised response nonetheless can contribute. The assumptions are key because tacit background culture informs policy through demarcating what risks and messages are communicable and what risks and messages are acceptable within a socio-historically contingent frame (Arnoldi, 2009, pp. 105–120; Douglas & Wildavsky, 1983)

Following The Science to Post-Normal Science 11. Mary Douglas asserts that risks are conceptualised through cultural anxieties rather than objective, pure, evidence. (Douglas & Wildavsky, 1983). British politicians prioritise individual liberty, trade, and travel. Prime Minister Boris Johnson, for instance, gave a speech in February 2020 praising how the UK would remain resilient, free, and trading whilst much of the world hastily interfered with individuals’ rights by implementing restrictions (Whittell, 2020). British politicians weighed the risks of psychologically salient messages about subjected people, stifled trade, and blocked travel and gave these more receptive dread than the faraway and nebulous risks of COVID-19 (Paul Slovic, 2006; Slovic et al., 1982). SAGE, for instance, initially deemed lockdowns unacceptable to Britain, because they were authoritarian and thereby antithetical to British values and customs (Hunt, 2021). Lockdowns and restrictions are conspicuously unreferenced in the January 2020 SAGE minutes (Scientific Advisory Group for Emergencies, 2020). Instead of a scientific method to contain the virus, then—restrictions having been used in liberal democracies long- before Wuhan—COBR and SAGE framed lockdowns as, in Jeremy Hunt’s words, “China-style” (Hatchett et al., 2007; Hunt, 2021; Taiwan in Time: Remembering the SARS Lockdown - Taipei Times, 2020)

12. Contrary to following the science, then, the UK government chose and selected the science best suited to its preferences, biases, and values. As Sheila Jassanoff explains, “we gain explanatory power by thinking of natural and social orders as being produced together. The texture of any historical period, cultural and political formations, can be properly appreciated only if we take this co-production into account” (Jasanoff, 2011). The cultural preoccupation of British experts co-produced the evidence and what counted as ‘the science’ to follow. Yet in government communications following 'The Science' became emblematic, without regard to uncertainty, complexity, and sometimes misleading science.

13. Indeed, the frame of following the science with the definite noun—the—suggests a problematic interpretation of homogenous science offering facts determining optimal outcomes in comprehensive cost-benefit analysis, a ‘normal science’ approach. Joseph Ravetz, on the contrary, identifies our era of uncertainty as post-normal, because “Facts are uncertain, values in dispute, stakes high and decisions urgent” (Ravetz, 1999). Considering the uncertain science from the WHO and CDC, the UK advised against masks, and in doing so left the empirical science from East Asia off the table. Britain delayed responses, to create British-made epidemiological models; SAGE valued such models above the Chinese equivalents by ignoring them and then dismissing models presented at SAGE in March 2020 (“Special Report: Johnson Listened to His Scientists about Coronavirus - but They Were Slow to Sound the Alarm,” 2020; Whittell, 2020). SAGE and COBR deemed the stakes so high that quantified local evidence had to be accrued for sufficient cost-benefit analysis to indicate an unambiguous response. Response demanded urgent decisions yet the emergency apparatus delayed. These examples demonstrate how following the normal science of ‘certain evidence’ and quantitative cost-benefit analysis leads astray in a post-normal uncertain challenge like COVID-19.

14. We recommend instead instigating an “extended peer community” for evidence and action (Ravetz, 1999). We do not mean more people at the SAGE table (although more test-trace experts from Taiwan, for example, may help) but that international expertise and models be given peer-level authority. (Smith et al., 2020; Summers et al., 2020). The delay for Imperial College to model the outbreak locally needlessly delayed and diminished the efficacy of response, revealing a reliance on modelling on accrued data instead of modelling on nations’ experience. For example, in Hong Kong, masks were viewed as “common sense” with supportive local evidence after SARS (Leung, 2020; Seto et al., 2003). Although evidence was flexibly uncertain in the case of masks, the burden of action and proof should have been that Chinese models were accurate and been subject to assiduous falsification tests whilst East Asian learnt precautions were enacted. Instead, British model seeking checked, only to ultimately vindicate, whether the virus models from China applied to British populations.

15. A rebuttal that British models could offer more accuracy flounders because British models themselves were uncertain choices—with severe-projection models from Imperial chosen over milder-projection models from Oxford (Pearce et al., 2020). An objection that this claim is built on hindsight also does not hold because approaches elsewhere offered a better response at the time; and learning from the past, by definition, entails hindsight. Therefore, an extended peer-led community where wearing masks was imitated despite ambiguity (since WHO confidently decreed no harm but insufficient evidence for efficacy), and where foreign peers’ models are assumed to be accurate is a better approach. Such a policy would have given adequate justification for earlier lockdown measures. Measures which the Imperial College modelers advocate would have averted transmission and excess deaths in the first wave (Hughes, 2020; Ward, 2020).

16. Indeed, the concession of authority to science implicit in government messaging is dubious, for if science is followed then non-science logically goes unfollowed. This demarcation “is no mere academic matter” for “to decide who is doing science and who is not” entails what advice is broached and received (Gieryn, 1983). We note SAGE has “no emergency managers” among its 86 members nor even among its additional 275 working group members; “This is an emergency that is effectively being managed by epidemiologists, virologists, and politicians” (List of Participants of SAGE and Related Sub-Groups, 2021.; Whittell, 2020) So, conventional natural scientists and politicians comprise management despite lacking the expertise to manage in an emergency. “Emergency planners need to be involved in response and disaster risk management of pandemics, to contribute to the science” concludes Professor Alexander, who demarcates emergency management (EM) as contributory science (Alexander, 2020).

17. Whereas the policy apparatus deemed EM impertinent, perhaps non-science, enough to preclude membership. Given the utility of interdisciplinary science, we recommend that SAGE welcome emergency managers, replacing members from over-represented demographics. We recognise that EM professionals have their own biases and interests but given the over-representation of physicians, epidemiologists, and psychologists, such a policy to include un-represented emergency managers is reasonably uncontroversial—and a key lesson learnt. A more integrated co-produced and post-normal COBR-SAGE complex would feasibly work better.

18. Former Cabinet Secretary Gus O’Donnell claims that the Prime Minister chose the “wrong forums” for challenging assumptions about how to properly respond to the pandemic (Did It Have to Be This Bad? - Tortoise,2021; O’Donnell,2021). Relying on SAGE and COBR entails a division between expert advisers and ministerial decision- makers, with management structurally distributed to localities in silver and bronze teams. This design fosters miscommunication because SAGE, subgroups, COBR, and working support groups all congregate in different, and often virtual, spaces. 361 voices currently comprise the scientific expertise (List of Participants of SAGE and Related Sub-Groups, 2021). Expertise fed into COBR which is further demarcated into a strategy team, chaired by Boris Johnson, and implementation team, chaired by Michael Gove (O’Donnell, 2020).

19. Given the sheer number of voices and given the iterations of different meetings, and changing attendees, miscommunication is inevitable. Anthropology evidence suggests conversations become confused and multiple beyond four-to-twelve participants, and thereby more garbled voices the harder to glean essential information to reach consensus decisions (Dezecache & Dunbar, 2012; Dunbar & Dunbar, 1998; Krems & Wilkes, 2019). British common law also converges on that fact: juries are capped at twelve. For examples of miscommunication, politicians and advisers have indulged in mutual blame for giving false advice and ignoring advice; behaviour fatigue made it into national broadcast justifying delayed response despite not existing in the psychology literature; SAGE followed procedures for an influenza pandemic despite scientists’ public communications that COVID-19 is far different (Hunt, 2021; Mahase, 2020; Ward, 2020; Whittell, 2020). Inner circle SAGE meetings traditionally also converge around twelve in number. Yet SAGE has doubled-down on its maladaptive strategy, expanded numbers, and brokered hundreds of advisers in subgroups, yet communicating timings for subsequent lockdowns has again gone awry twice, despite voluminous deliberation. In present COBR-SAGE, just as with multiple juries being assigned to a confusing case, garbled messages, misunderstandings, and conflicts across meetings and summaries are inevitable. I consider the number of advisers far too numerous and, their expertise too general, to be suitable for swift pandemic emergency response. I therefore go as far as to contend that COBR-SAGE is a poor forum for handling COVID-19. Noteworthy is the sheer abundance of expertise and the under-focus presently on management at 70 Whitehall. I believe that communication issues emerge by its very design.

20. What alternative forums could Johnson have chosen, to move beyond an integrated co-produced and post-normal COBR-SAGE, as previously suggested? Former head of the civil service, Gus O’Donnell suggests “an executive committee structure that can critically assess the enormous amount of data and opinion being directed at it”, a structure already designed for the National Security Council (O’Donnell, 2021). I similarly advise that an executive committee—a Pandemic Response Council—with emergency managers, epidemiologists, and public health experts liaising with ministers in one co-located space. Such a structure has debate in-built to “challenge, their [adviser] reasoning as to what decisions are required, and their evidence base. Politicians then cross-examine the other members to test the evidence and recommendations. Then politicians debate the issues” (O’Donnell, 2021.). Thus, allowing elected and non-elected members to understand perspectives’ and maintain a coherent operating picture.

21. For such a Pandemic Response Council, the profession of members is demonstrably less key than its methods, ethos, and culture. A culture of emergency management and egalitarian debate is more important than affiliated professions, because even nations with epidemiology-heavy advisers fare well if the cabinet is receptive to national emergency management and proposal debate. Consider New Zealand for instance. The cabinet is used to navigating national-scale hazards such as volcanoes and earthquakes, so has ministers for emergency management and biosecurity, and even a new minister for COVID-19 response (Ministerial List, 2021). Whereas Britain requires more concerted involvement from emergency managers in building procedures and “live documents” and alert systems (Did It Have to Be This Bad? - Tortoise, 2021). To become as tacitly knowledgeable, competent, and adaptive as New Zealand.

22. A precautionary principled emergency response in the style of New Zealand is actually “more rigorous and rational—and potentially more robust—than the indiscriminate use of often-inappropriate methods” (Stirling, 2007). As demonstrated in the UK reliance on cost-benefit analysis and Imperial College models. By embracing a pre-emptive precautionary approach rather than “spurious promises to determine ‘science-based’ policy” (Stirling, 2007), New Zealand achieved more rational and ‘scientific’ methods of containment and mitigation. 23. The UK Concept of Operations (COO) asserts disruption and emergencies of all kinds to be amenable to distributed management with COBR intervening only to manage national catastrophes (Cabinet Office, 2010). “Far from a permanent state or norm of exception, then, emergency powers are the “last resort'”(Adey & Anderson, 2011). The Cabinet Office attests that “There must be no expectation that the Government will agree to use emergency powers'' and planning and response arrangements must assume that they will not be used'', quoted in (Adey & Anderson, 2011). The COO itself asserts that “The use of emergency powers is a last resort option” (Cabinet Office, 2010, p. 64). Aforementioned preparedness simulations for pandemic flu, like Exercise Cygnus, notably never included COBR or SAGE advice committees within their architecture. Because the assumption written into the Concept of Operations is that lower-level authorities best address issues independent of higher government, with escalating government intervention after catastrophe onset justifies national interference (Adey & Anderson, 2011, p. 2886).

24. 25. (Cabinet Office, 2010, p. 68)

26. The ultimate causes behind proximate failures in the UK COVID-19 response structure rests therefore with the aforementioned ‘architecture’—with policy precedents suited to what the UK has most experience of and success with—national security. The onus on security is obvious in the COO featuring “terrorist” and “terror” sixty-four times, compared to “pandemic” (5 times) and “disease” (eight times) 13 times. Qualitatively, as well, the mechanisms for addressing terror are laid-out where pandemic scenarios remain vague. For example, it states that Defra will be the lead for animal disease outbreak, and only in passing refers to pandemic response without mentioning what would trigger such a response. A paragraph beginning about assistance abroad includes, in passing, a reference to what department is to handle a pandemic: “(eg DECC will lead in the response to an accident at an overseas nuclear facility; DH [Department of Health] will lead in the response to a pandemic” without a mechanism to monitor alert levels and initiate such a response (Cabinet Office, 2010, p. 42). Despite the UK risk register, registering a pandemic as the biggest hazard year-on-year (Cabinet Office, 2017). 27. Moreover, the COO ultimately ensured that response be unpublished and secretive (despite open science allowing for swifter feedback), a response to foreign emergency be precluded from the picture (restrictions became merited after first UK cases), the response be triaged from local-to-national (seeking emergency powers and enactment delayed action), and it be the tacit prerogative of the prime minister whether to attend COBR meetings (customarily PMs do but there is nothing written to ensure regular attendance) (Cabinet Office, 2010; Whittell, 2020). In short, a delayed reactive national structure is in-built because policy documents are biased against national coordination with emergency powers - and thereby national emergency response - being deemed a last resort. Rather than a first-response as ‘national emergency’ implies. Such a lesson for emergency powers was already learnt with Exercise Cygnus, but enactment came reactively instead of pre-emptively, “the most important thing we discovered from that [Cygnus] exercise is that we needed emergency powers to allow the government to act quickly and those have now sadly become law because of what we face'' with COVID-19 (Sherling, 2020).

28. Countries with ‘level 3’ action plans and emergency powers from the start, remember, fared far better not because they had more expertise - in fact they have fewer experts - but because operation documents, legislation, and political actors both adopted a national coordinated response from the start, when an epidemic became widely reported.

29. Intelligence and security agencies notably play a managing role in response to national security hazards (Adey & Anderson, 2011) with greater success. The structure of COBR is even designed with a situation cell and intelligence unit grouped together (Cabinet Office, 2010). Whereas SAGE is separate from COBR, as illustrated below, for pathogen hazards. Despite no such division and secrecy being conducive to emergency communication and co-ordinated pandemic response.

30. 31. (Adey & Anderson, 2011, p. 2888) 32. On the contrary to a fealty to tradition embodied in the COBR-SAGE mechanism, the mechanism tacitly is untraditional in overlooking how intelligence and security agencies have traditionally enabled crisis management and co-located communication to highly successful outcomes. That co-located streamlined and highly organised space allows for effective crisis management. At least where national security, intelligence, and terror are concerned. As permanent Secretary Richard Mottram explains “COBR came out of a defence and nuclear release set of arrangements … had an interesting impact... It drove the way communications were thought of ... [and it] gave it a defence flavour, which may not have been that helpful’ (Haddon, 2010).

33. Indeed, COVID-19 has exposed gaps in COO and COBR assumptions about handling emergencies in general without focus on the genre of emergency in particular. For example, the “incredibly hierarchical” structure of COBR works well for security- trained specialists and government biosecurity scientists from the Porton Down Biosecurity Centre (MacAllister, 2021). But not for higher education scientists and Socratic debate given that “one of the big problems identified in crisis” for COBR “was ‘groupthink’, where consensus pushes out critical analysis or alternative views that might prove crucial” even as early as 2010 (Haddon, 2010), Robert MacAllister notably concurred in 2021, that “groupthink” is a problem (MacAllister, 2021). Note that Exercise Cygnus recommended a more specific Pandemic Concept of Operations (Public Health England, 2020, p. 8). I recommend the same; the current COO is too general that its apparatus has the flaws of relying on national security design without the benefits of such design in integrating intelligence and security experts - in the case of COVID-19 pandemic experts - into a one-room management response. Conclusion

34. COVID-19 has been a real-world experiment. An experiment that has put systems of governance, emergency management, and cultural assumptions thoroughly to the test. Although by many standards, the UK appeared well situated to deal excellently with a pandemic, the UK under and mis performed. The evidence I have given has focused on what I hold to be the most impactive changes for mitigating future waves and mitigating future pandemics. Since earlier concerted action and disaster management communications, as illustrated by culturally Anglophone Australia and New Zealand, averts the need for more stringent measures later on. In summary I suggest:  Creation of an executive committee, The Pandemic Response Council (TPRC)  A Pandemic specific Concept of Operations with a clause for ease of emergency powers enactment and precautionary pre-emptive response  The TPRC be capped to twelve comprised of medical officers, emergency managers, public health experts, co-located with relevant minister group  Mandated egalitarian and Socratic debate to ensure clarity and optimal decision pathways 35. The evidence I present also suggests that cultural assumptions need to be considered more forthrightly and reflexively. Post-normal science offers opportunities to extend peer community for epistemic evidence from abroad and from emergency management procedures; the imitation of competent governance and in-sourcing of expertise may be a worthy venture for the commons committee. Given that COVID- 19 is “no black swan event” there is opportunity in tragedy (UCL IRDR 10th Annual Conference: Keynote Speech by Marc Gordon, 2020). The opportunity to enact lessons and avert repeated mistakes for the future.

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