Different countries use different means to ensure everybody and their dog don't just turn up and use their services (such as hospitals, schools or pensions).
Some countries – such as the UK – prefer to control the border but then have very few checks on the inside.
Other countries – such as many other EU countries – prefer to have an ID card of some sort that documents that the holder is entitled to access services.
And finally some countries – mainly Scandinavian ones, I believe – have a central database that keeps track of who can do what.
Of course most countries use a combination of these factors – for instance, when you use the Scottish NHS, they ask you for some personal details so that they can find your CHI number, which is the Scandinavian approach.
The UK approach is really nice once you're on the inside, because you don't need to carry any ID and in general don't need to prove who you are all the time. The problem with it is that it depends on controlling the border, which just isn't very easy these days. After all, any person who arrives legally – as a tourist, student or business person – can become an illegal immigrant simply by overstaying their visa. It also makes it almost impossible to have different immigration policies in different parts of the country (such as making it easier to move to Scotland than to England).
The other two approaches work much better in the modern world because being in the country doesn't entitle you to anything per se. If you don't have an ID card or a database identification number, you won't be able to access non-emergency health care, sign your kids up for school, or do any of the many other tasks you do as a resident.
Schengen, the EU's passport-free zone, to some extent depends on members using ID cards or databases so that gaining access to a country doesn't entitle people to anything. And one might argue that this is also the basis for the EU's free movement of people. For instance, Denmark knows exactly how many EU citizens have moved there and when, because they have to register for a database identification number as soon as they move there, so there isn't the same feeling that the government isn't in control of immigration.
It was thus quite interesting how the Leave campaign was so obsessed with controlling the borders. Unless they want to make it illegal to be a tourist, people will arrive, and some won't leave again, even though they were supposed to. And of course maintaining the open border with EU member Ireland will make it impossible to keep out EU citizens (because they can at all times travel legally to Ireland).
The lack of ID cards or a database is also what is making life so difficult for EU citizens in the UK post-Brexit. It's difficult to prove how long we've been here, and whether we actually ever ticked the boxes for being a legal resident. In many other countries, it would be an administrative piece of cake to find everybody who had been here legally for more than five years and send them a permanent residence permit, without any need for 80-page forms.
Much as I love the lack of ID cards and database identification numbers in Scotland and the rUK, I'm starting to think that what the Leave voters really wanted was a national ID card and/or a universal database, because that's the only thing that would make it harder to be an illegal immigrant here.
Of course Theresa May's solution works, too – namely to make the UK so unattractive and despised abroad, with a basket-case economy, that nobody in their right mind wants to move here. If she succeeds, immigrations numbers will fall below zero without any need for border controls, ID cards or databases. What a victory!
The Tories' Brexit dreams are getting wilder and weirder by the day, as shown by yesterday's dramatic story in The Telegraph: "British jam, tea and biscuits will be at the heart of Britain's Brexit trade negotiations, the Government has said, as it unveiled plans to sell food to other countries to boost the economy."
I loved @garydunion'sresponse on Twitter: "Is it just me or is it becoming really obvious that the Tories don't know the difference between an economic strategy and a period drama?" Much as this is an intriguing explanation for their madness, I think the real answer lies in their provincialism, though. It's clear they don't understand the world we're living in.
The thing is that we can all pine for specific products from home when we're abroad, so when visiting family and friends in other countries it can often be a welcome gift to bring these items.
Tea, jam and biscuits is probably what the Brexiteers bring when they visit migrant expat friends abroad, so they assume these are universally sought-after delicacies.
However, having spent the first 30 years of my life outwith the UK, I can reveal that British tea, jam and biscuits aren't that popular abroad – in fact, I think most markets have already reached saturation point.
Perhaps it's easier to explain by imagining what would happen in Denmark adapted the Brexiteers' economic strategy. The Danish culinary equivalent would be rye bread and salt liquorice. This is what a Dane would take to friends abroad, not butter and bacon.
So if Danish food companies tried to export mainly what they wanted to eat themselves, the Danish embassies would be busy trying to flog rye bread and salt liquorice to unsuspecting foreigners. "Don't buy Danish bacon, buy our superior salt liquorice instad!" No, I can't see it happening, either.
Why don't the Brexiteers understand that the way to be a successful exporter is by selling what the customers want to buy, not to sell what you want for yourself?
Lots of people are currently talking about Scotland (and perhaps Gibraltar) doing a Reverse Greenland, which means that the UK would leave but Scotland (et al.) would remain within the EU.
I don't think that's particularly likely for the following two reasons:
A Greenlandic solution doesn't mean that Greenland is independent in all areas where the EU is representing Denmark. Instead, Copenhagen is ultimately in charge of these areas (unless they're devolved, of course). In other words, if Scotland achieved a Reverse Greenland solution, Westminster would for instance have to conduct their own trade policy for England while representing Scotland in Brussels at trade summits. It would lead to a lot of conflicts of interest at Westminster, and I don't think Brussels would like this at all.
As Craig Murray has pointed out, there's no legal basis in the EU treaties for having a territory of a non-member state as a member: "The European Union is an institution which is based on treaties which have legal force. There is nothing whatsoever in any of those treaties, and nothing in any existing arrangement with any state, that makes it possible for part of a state, even a federal state, to be inside the EU, when the state itself is outside. [...] The Greenland case is not in the least comparable because its relationship with the EU is based on the fact that it is an autonomous territory of an EU member state, Denmark. That is completely different from the situation of an autonomous territory of an EU non-member, which the UK will be." I presume this means that the only way it would work would be if the UK remained a member, and England and Wales then left the EU (like Greenland). Given the size of England, I really can't see this happening.
However, I think it's absolutely correct and proper that Nicola Sturgeon explores all options before calling a second independence referendum.
When people in Scotland discuss an alternative to the Additional Member System currently used for Holyrood elections, they often assume the only real alternatives are FPTP (the system used for Westminster elections), STV (used for Scottish council elections) or d’Hondt with party lists (known from elections to the European Parliament.
However, a different system is used in Denmark (and similar ones are used in Norway and Sweden), and it is taken for granted there -- and nobody ever suggests changing the system, so it's definitely not a bad way to conduct elections.
It is basically Sainte-Laguë with top-up seats and personal votes instead of party lists (Sainte-Laguë is a variant of d’Hondt).
It has several attractive properties:
All politicians need personal votes to get elected. There isn't a party list where the person at the top of it can lean back in the knowledge that they'll get elected no matter what.
There is even competition amongst candidates from the same party, so that voters can elect the ones they like the best.
It is reasonably fast to count (different from STV, which in practice has to be done computationally). In Denmark, they normally count the party votes on the night so that you know exactly how many seats each party has won, and then they count the personal votes the next day.
Practically every vote counts: Because of the national top-up seats almost every vote counts -- the only truly wasted votes are the ones cast for tiny parties that didn't gain any representation (like UKIP or RISE).
To make the system more tangible, I have here tried to show what the 2016 Holyrood election would have looked like if this system had been used instead of AMS.
NB: I have simplified the system slightly in various ways. For instance, Denmark operates with a fourth layer between the regions and the national results, and the parties have several options to choose from with regard to how party votes should be distributed to the candidates. I don't believe these differences are critical for the present purpose, but of course civil servants should look into the details if Holyrood ever decides to switch to this system.
The current constituencies would be kept, but they would change status to being nomination constituencies (“opstillingskredse” in Danish), which means that the local parties would be able to put up candidates for election, just like they do now. (Actually, Denmark has more nomination constituencies, so if Scotland adopts this system it might make sense to increase the number from 73. This would have the advantage of making politics more local.)
However, electing members of parliament would happen in larger units, electoral regions (“valgkredse” in Danish) -- I’ve used the current Holyrood regions for this purpose, except that I've put Orkney & Shetland and Na h-Eileanan an Iar into separate regions. In Denmark, each electoral regional will elect as many members of parliament as the number of nomination constituencies within it, but I’ve kept the number of seats within each region unchanged.
Each electoral region consists of regional seats (Danish “kredsmandater”) and a few national top-up seats (Danish “tillægsmandater”). The regional seats are allocated locally, without any reference to events outside the electoral region, whereas the top-up ones are allocated nationally based on votes cast across the country. For instance, in this simulation the West of Scotland region containts 17 seats: 14 regional ones and 3 top-op ones.
Step 1: The election
Each voter will be given a ballot paper listing all candidates in the entire election region, but with the ones from their own nomination constituency listed before the other candidates.
As an example, here is the ballot paper for Eastwood in the West Scotland region. The local candidates here are Jackson Carlaw, John Duncan, Ken MacIntosh, Stewart Maxwell, [GRN candidate, Eastwood] and [UKIP candidate, Eastwood] (because the Greens and UKIP didn't put up any candidates in most constituencies in the real election I've used this notation where necessary):
Each voter has to tick exactly one box. If they vote for a candidate, it is a vote both for the party that this candidate represents and for the actual candidate. If they vote for a party, it is a vote for the party only.
And yes, ballot papers can be really long in Denmark. I think I've once seen one that was more than a metre long. In Sweden, where they have a similar system, they have separate ballot papers for each party, and the voter picks one and puts it inside an envelope. I'm not sure that’s a better solution, though.
(For the purpose of this simulation, I have used the constituency votes for the large parties and the list votes for the small parties. For simplicity I've also ignored all parties smaller than UKIP. Furthermore I've assumed that everybody will vote for their local candidate. In reality, given the greater choice of candidates, and given the option of voting for just the party, of course the results from an actual election under this system would have been very different.)
538203 voters: 17 seats, of which 14 regional seats. Turnout was 63%.
What this shows is first of all that there are 14 regional seats and three top-up seats.
The table lists all parties that put up candidates in this electoral region. The first line (marked with 1) shows the actual number of votes received for each party, i.e., the SNP got 148,659 votes, Labour 90,468, etc.
The next line shows the number of votes divided by 3, and the last one the number of votes divided by 13. For larger regions, one would produce more rows, dividing the number of votes by 15, 17, 19 and so forth.
Once the table has been produced, one looks for the largest number in it. In this case, it’s the 148,659 votes cast for the SNP. This means that the first regional seats goes to this party, and this is marked in the table by highlighting the number in blue and putting “(1)” after the number.
Now one has to find the second-largest figure, which is 90,468, and the second seat therefore goes to Labour. Similarly, the third seat is allocated to the Conservatives.
When we get to allocating the fourth seat, the SNP’s number of votes divided by 3 (49,553) is larger than any other remaining figure, and the fourth seat thus goes to the SNP.
We proceed in this way until all the 14 regional seats have been allocated.
Step 3: Allocation of the top-up seats to the parties
After allocating regional seats in all electoral constituencies in the country, the next step is to allocate the top-up seats.
To do this, all the votes cast for all parties in the entire country are added up.
Then one excludes small parties. These are the ones that didn’t either win at least one regional seat or get at least 2% of the votes. For this reason, UKIP gets excluded (getting 1.9% is not enough).
To allocate the top-up seats, one calculates the share of the vote and then tops up with top-up seats to make the share of seats the same.
That is, if a party got 10% of the votes, it should get 10% of the seats in parliament, i.e., 65 seats, so if it only got 50 regional seats, it will get a top-up of 15 seats.
(The actual calculations are slightly more complex than this, but this is the principle. The figures below have been done according to the actual rules.)
Here are the country-wide results:
Step 4: Allocating top-up seats to specific regions
Now that the top-up seats have been allocated to the parties, they need to be placed in specific electoral regions.
The calculations are similar to the ones for allocating seats in the electoral constituencies, except that the whole country is being looked at, and we use the divisors 1, 4, 7, etc., instead of 1, 3, 5, etc.
In the following table, the regional seats already allocated above are marked with an X.
To allocate the first top-up seat, the largest number in the entire table is found (computers are much better at this than humans), in this case it’s the 12,106 votes the Lib Dems got in West Scotland; because the Lib Dems are indeed due a top-up seat, the first top-up seat gets allocated to them there.
The second-largest number is the 11,784 votes the Lib Dems got in South Scotland, so the next top-up seat is allocated here.
The procedure is repeated many times. Once a party has got all the top-up seats it is entitled to, it can get no more, even if the largest number left in the table belongs to this party. For instance, the third-largest number in the table is the 8,637 belonging to the Greens in the Lothians, but the Greens aren't due any top-up seats, so instead the third seats goes to the SNP in the Lothians.
The same applies to regions. For instance, let's look at the 16th top-up seat. It can't go to the SNP in South Scotland (6792) because this region isn't due any more seats; it can't go to the Tories in Lothian (6783) for the same reason; and neither can the SNP in West Scotland get it (6757). It therefore goes to the SNP in North East Scotland (6746).
The last seat goes to Labour in the Highlands and Islands (4978). All the seats have now been allocated.
Now that we have established exactly how many seats each party gets in each electoral regional, we need to determine which of the candidates standing that have been elected.
To do this, we simply count the number of votes cast for each candidate, and the candidate with the most votes gets the first seat, the one with thesecond-most votes gets the next seat, and so on. (Political parties in Denmark can choose between different systems, but this needn't concern us here.)
This party got seven seats here (six regional seats and one national top-up seat). The first one goes to Rona MacKay with 17,060 votes, the second one to Stuart McMillan with 17,032 votes, the third one to Kenneth Gibson with 16,587 votes, and so on.
The last three candidates on the list are not elected. However, Ruth Maguire becomes the first reserve in case any of the seven elected members has to step down, with Gail Robertson being the second reserve. In this way, by-elections are not needed.
(Please note that the results are quite misleading because I've taken the figures from an AMS election. At the moment only people in Eastwood were able to vote for Stewart Maxwell, and his personal vote got squeezed last week because it was a three-way race, but if people all over the West Scotland region had been able to vote for him, I'm certain he would have been much higher up the list, given his high media profile.)
This completes the election.
Scottish National Party (58 MPs)
George Adam, Clare Adamson, Alasdair Allan, Tom Arthur, Colin Beattie, Keith Brown, Aileen Campbell, Willie Coffey, Angela Constance, Bruce Crawford, Roseanna Cunningham, Ash Denham, Graeme Dey, Bob Doris, James Dornan, Jennifer Dunn, Mairi Evans, Fergus Ewing, Linda Fabiani, Joe Fitzpatrick, Kate Forbes, Jeane Freeman, Kenneth Gibson, Jenny Gilruth, Toni Giugliano, Christine Grahame, Clare Haughey, Donna Heddle, Jamie Hepburn, Fiona Hyslop, DJ Johnston-Smith, Bill Kidd, Richard Lochhead, Richard Lyle, Gordon MacDonald, Angus MacDonald, Derek MacKay, Rona MacKay, Ben Macpherson, Gillian Martin, John Mason, Michael Matheson, Mark McDonald, Ivan McKee, Christina McKelvie, Stuart McMillan, Alex Neil, Gil Paterson, Shona Robison, Gail Ross, Michael Russell, Shirley-Anne Somerville, Stewart Stevenson, Nicola Sturgeon, John Swinney, David Torrance, Maureen Watt, Humza Yousaf.
Conservative Party (28 MPs)
Michelle Ballantyne, Miles Briggs, Alexander Burnett, Jackson Carlaw, Finlay Carson, Colin Clark, Ruth Davidson, Murdo Fraser, Jamie Greene, Kirstene Hair, Alison Harris, Alex Johnstone, Callum Laidlaw, John Lamont, Gordon Lindhurst, Dean Lockhart, Edward Mountain, Oliver Mundell, Robbie Munro, Andrew Polson, Douglas Ross, John Scott, Graham Simpson, Liz Smith, Alexander Stewart, Ross Thomson, Kyle Thornton, Adam Tomkins.
Labour (28 MPs)
Jackie Baillie, Claire Baker, Neil Bibby, Bill Butler, Kezia Dugdale, Patricia Ferguson, Neil Findlay, Iain Gray, Cara Hilton, Lesley Hinds, Daniel Johnson, James Kelly, Johann Lamont, Lewis MacDonald, Ken MacIntosh, Jenny Marra, Paul Martin, Siobhan McCready, Margaret McCulloch, Michael McMahon, Carol Mochan, Elaine Murray, Paul O’Kane, John Pentland, Alex Rowley, Elaine Smith, Linda Stewart, David Stewart.
Green Party (8 MPs)
Maggie Chapman, John Finnie, Ross Greer, Patrick Harvie, Alison Johnstone, Kirsten Robb, Mark Ruskell, John Wilson.
Liberal Democrats (7 MPs)
Kris Chapman, Alex Cole-Hamilton, Katy Gordon, Willie Rennie, Mike Rumbles, Tavish Scott, Jamie Stone.
A term that is often used to describe Nordic culture is the so-called Law of Jante:
Generally used colloquially in Denmark and the rest of the Nordic countries as a sociological term to negatively describe a condescending attitude towards individuality and success, the term refers to a mentality that de-emphasises individual effort and places all emphasis on the collective, while discouraging those who stand out as achievers.
There are ten rules in the law as defined by Sandemose, all expressive of variations on a single theme and usually referred to as a homogeneous unit: You are not to think you're anyone special or that you're better than us.
The ten rules state:
You're not to think you are anything special.
You're not to think you are as good as we are.
You're not to think you are smarter than we are.
You're not to convince yourself that you are better than we are.
You're not to think you know more than we do.
You're not to think you are more important than we are.
You're not to think you are good at anything.
You're not to laugh at us.
You're not to think anyone cares about you.
You're not to think you can teach us anything.
Although there are differences, I tend to think Scottish culture can be similar to this -- people tend not to brag about their own achievements (perhaps even to the point of self-deprecation), and they tend to strive to fit in. The Scottish cringe is at least partly a consequence of this, because it is often the result of people standing out by being too Scottish compared to the consensus level. Perhaps the hatred many people feel towards Alex Salmond can also best be explained as a consequence of the Scottish Law of Jante.
However, in the Scottish version there has historically been an outlet for people who wanted to pursue their dreams, namely becoming a lad o pairts (I've seen it defined as "the young boy from humble origins who demonstrates academic talent and is able to achieve success, often in London or in the colonies, owing to the historically superior Scottish educational system").
Of course some Scandinavians have also "escaped" to other countries -- for instance, the Norwegian playwright Ibsen was absent from Norway for 27 years, and the Danish poet Henrik Nordbrandt has spent most of his adult life in Greece and Turkey.
However, one of the consequences of the British Union is that it has always been extremely easy for anybody talented to have a career to London -- in many cases probably easier that achieving the same in Scotland.
Of course, in today's globalised world talented people from everywhere flock to London, New York and other global hotspots, and indeed talented Scandinavians seem to emigrate much more than they used to.
The Scottish lads o pairts therefore don't depend on the UK any more, and it would probably be much better for the Scottish economy if it was easier to have a successful career without having to leave Scotland.
Update (15/01): See also Gerry Hassan's article about the Scottish Tut.
Although the SNP benefitted hugely from First Past The Post (FPTP) in May (gaining almost all the Scottish seats on 50% of the votes), I remain committed to proportional representation -- I believe FPTP is poison for popular engagement, at least in a multi-party system, because so many people feel their vote doesn't count.
Proportional representation comes in many varieties, however (and some are more proportional than others). We're already using three different systems in Scotland: (1) The Additional Member System (AMS), which we use for electing the Scottish Parliament; (2) the Single Transferrable Vote (STV), which we use for electing the councils; and (3) d'Hondt, which we use in elections for the European Parliament.
The SNP opted for STV in their recent Westminster manifesto. I can understand why -- STV is a decent system in many contexts, especially when the candidates aren't organised into parties (for instance, it's a great system for electing members for a committee in an political party). However, it has some shortcomings which makes it less than ideal for Westminster elections.
Firstly, STV benefits those parties who are good at predicting their support. For instance, if May's election had been held using this system, Labour and the Liberal Democrats would probably not have predicted the scale of their losses, so they would have put forward too many candidates, which could have exaggerated their losses; in the same way, the SNP might not have been bold enough, which again would have harmed them. (This problem can be alleviated by forcing the voters to prioritise all the candidates and not just one or two, but we don't tend to do that in Scotland.)
Secondly, STV doesn't help parties with varying levels of support in different areas. In particular, whereas the SNP's 50% support resulted in nearly 56 out of 59 seats under FPTP, it would probably only have resulted in around 30 seats in Scotland under STV; the fact that the SNP also had supporters in England wouldn't have led to any additional seats.
The Danish electoral system would be much better for the SNP. Denmark uses a variant of d'Hondt (Sainte-Laguë to be precise) in multi-member constituencies, but crucially all the votes get added up nationally afterwards, and additional seats are allocated in order to ensure that every vote counts. In other words, if the SNP got 50% of the votes in Scotland and about 5% in the rest of the UK so that the UK-wide support was exactly 10%, the SNP would have received 10% of the seats, which would actually be even better than the current 56 seats.
Some years ago I made a simulation of the 2005 Westminster election using the Danish electoral system. I didn't at that time assume the SNP would have received any votes outwith Scotland, but Nicola Sturgeon would definitely have appealed to many voters down south after her phenomenal performance in the TV debates.
My guess is the SNP chose STV for their manifesto in order to tempt the Lib Dems, and that's of course a completely valid reason to opt for this, but the Danish system would be much better for the SNP.
During the second half of my studies in linguistics and computer science at Aarhus University I stayed at the on-campus student halls called Parkkollegierne. I had a small room (about 12 sq m) and shared the kitchen and bathroom with 14 other students. The monthly rent was approximately £150 at the time, including heating and electricity. (Towards the end of my stay there we got broadband and a phone line in each room, but the price was added to the rent.)
Given that Denmark is generally quite a bit dearer than Scotland, and given that Danish students get generous grants from the state for studying (about £400 per month), I had expected student housing would be cheaper in Scotland than in Denmark, so I was quite surprised when I realised that students often pay a small fortune here, whether they live in a student hall or in private accommodation. My stepson is going to Edinburgh to study law in September, and he's been given a room in a student hall costing more than £500 per month (and that seems to be the average price, for a room that's not on campus and smaller than the one I had in Århus)!
I simply don't understand why it's so dear. There must be legal reasons for it, or some clever property developers would have made some private student halls at half the price and made a fortune. I know there were many problems with overcrowded and unhygienic student accommodation in the 1980s, but if the legislation is now preventing people from offering reasonable accommodation at a fair price, then that's a huge problem and must be resolved.
Not every student has the option to study while staying with their parents, and we want students to be able to study what they're good at and interested in, even if it's far from home, but student halls are simply prohibitively expensive -- it will either cost the parents a fortune or increase student debt dramatically.
The Scottish Government should as a matter of priority go on a fact-finding mission to similar countries to find out how they manage to provide affordable student accommodation.