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Criminal Justice Act 1988, s.30 Magistrates Courts Act 1980, s.5e Criminal Procedure Rules (2014), r.33.3(3) & 33.4 EXPERT EVIDENCE REPORT NOTE: only this side of the paper to be used and a continuation sheet to be used if necessary. All sheets and paragraphs to be consecutively numbered. If Reports are to be typed please use double spacing. Report of : (name of expert) Dr. Nick Ritchie Contact Address : Department of Politics University of York Heslington York YO10 5DD Phone: (01904) 324104 nick.ritchie@york.ac.uk Qualifications : Obtained his PhD at the University of Bradford thesis examined the evolution of US nuclear weapons policy from 1990-2004. Was a Post-Doctoral Research Fellow at the Department of Peace Studies, University of Bradford. Relevant experience and accreditation : Worked for six years as a researcher at the Oxford Research Group on global security issues, in particular nuclear proliferation, arms control and disarmament. Was a lead researcher on the Nuclear-armed Britain programme. Executive Committee member, British Pugwash Group Board of Advisors, UK Project on Nuclear Issues (RUSI) Regularly gives talks and papers at NGO and think-tank events on nuclear disarmament, proliferation and arms control.

Report 1. I have been provided with the materials forwarded to me by the prospective Prosecutor in this instance. Insofar as I have read and digested those materials, I am given to understand that, the prosecution posture and theory of case is, at least in large part, dependent upon the following political and strategic propositions with respect to the current Conservative administration s policies concerning the continuity of the Trident ballistic missile nuclear weapon system and especially indeed regarding its intentions for a so-called like-for-like replacement of this system. Namely, that : a) A principal component of the government s rationale for replacing the current Trident system beginning with the procurement of a new fleet of Successor ballistic missile submarines is to maintain the current continuous at sea deterrent system (CASD) operational posture. This enables the UK to deliver a major nuclear strike at relatively short-notice against the command and control structure & systems of any would-be nuclear capable aggressor ; b) most especially since the political hardening of UK-Russian diplomatic and international relations following Russia s annexation of the Crimea in 2014 and the subsequent active involvement of Russian military forces in the disputed civil war in Eastern Ukraine ( Donbass region), in reality, the primary, if not only, potential nuclear capable aggressor for the UK and NATO remains Russia ; c) the ability to strike at both the political and military command and control capacity of the Russian state, that which was formerly diplomatically termed by a senior Government official in the Cold War era as the ability to hold at risk key centres of Soviet state power, in practice, translates to a nuclear strike on certain strategic targets in and around the capital city of Moscow. 2

d) Such an attack or strike is consistent with the scenario as set out in the prosecution theory of case I have been shown. This reflects statements from the Liberal Democrats as part of the previous coalition government that targeting Moscow remains a core rationale for replacing the Trident SLBM nuclear weapons delivery system evidenced in, for example, former Lib-Dem MP Sir Menzies Campbell MP in his Financial Times article Time to abandon the'moscow Criterion (17th May 2012), and more especially the then Deputy Prime Minister Nick Clegg s MP speech to Lib-Dem Party Conference (29 October 2012), regarding the continuation of the ability to flatten Moscow. e) Finally, I have been shown the materials upon which this prospective Prosecutor proposes to rely and drawn from the formal review of alternatives to the like-for-like Trident replacement by the UK Cabinet Office (titled HMG:Trident Alternatives Review :16 July 2013 ), and further as drawn from the written evidence subsequently submitted in 2013 by the Ministry of Defence to the House of Commons Defence Select Committee enquiry titled Deterrence in the twenty-first Century 1 and from which this prospective Prosecutor proposes to establish that :the UK does not possess nuclear weapons as part of the military inventory, that they have no function as war-fighting weapons, or to achieve military objectives; but rather the UK views its nuclear weapons as political not military or war fighting weapons. 2. I am now very happy to state that, having seen the evidence upon which this Prosecutor proposes to base these essentially political contentions and strategic propositions, and having accordingly analyzed this rationale, I find them and it to be entirely credible and consistent, and indeed in general keeping with my own assessment of the UK Government s political and strategic stance in these matters. 1 House of Commons Defence Committee - Deterrence in the twenty-first century - Eleventh Report of Session 2013 14 (Published on 27 March 2014) 3

3. To be very clear I do not myself find this rationale to be persuasive. Such a rationale for nuclearised UK security grossly overestimates the apparent certainties of nuclear deterrent threats, the asserted necessity of the capacity to articulate such threats in an era of complex globalisation, and the dangers of perpetuating a dangerous, risk-prone global security system based on the threat of massive nuclear violence. It reflects a UK nuclear culture or system of thought that eulogises about nuclear weapons as a guarantee of security to the extent that it has descended into political dogma. I have argued for serious consideration of alternative force postures to the so-called like-forlike replacement as an interim step down the nuclear ladder that reduce the salience of UK nuclear weapons and nuclear risk (see for instance my 2013 paper titled Trident Tribulations: Understanding the UK s Trident Alternatives Review available to download at : http://www.armscontrol.org/act/2013_10/trident-tribulations-understandingthe-uks-trident-alternatives-review) List of any Materials referred to and exhibited hereto. Details of any other Literature, Publications and other Material relied upon. (1) Trident Tribulations: Understanding the UK s Trident Alternatives Review Statement of facts supplied. Statement as to facts within knowledge All other facts Statement regarding any examination, measurement, test or experiment done and relied upon. 4