There was an interesting article in The Irish Times today about the consequences for Ireland when the (r-)UK leaves the EU’s customs union:
Even if there were a free-trade agreement, allowing free movement of goods between the UK and the EU, this will not apply to imports from countries outside the EU. Thus border controls will be essential to ensure that imports from third countries, such as China or India, comply with EU regulations.
This will have huge implications for the retail sector, much of which currently operates on a British Isles basis. Goods travel from warehouses in the UK to the Republic without problem. After Brexit, this will require new bureaucracy and customs duties, entailing a major increase in cost.
That could raise prices significantly for Irish consumers, posing serious competitiveness problems for the wider economy. Because of the small size of the Irish retail market, going it alone is a high-cost option.
Although they don't mention it, this is likely to be a much bigger problem than most people realise because of the way modern businesses depend on just-in-time manufacturing and low stock levels. What this means is that shops tend to get new deliveries all the time instead of having a lot of stock, and this will lead to huge problems if the over-night deliveries sometimes get disrupted by customs checks.
It's possible some companies will start treating Ireland as part of their French operation rather their British one (for instance, Kellogg's might prefer to sell the products made for the French market in Ireland instead of the British ones to avoid the customs checks). That would definitely make Ireland feel less British over time.
From a Scottish perspective, it means that if we leave the UK at the same time as Brexit in order to remain in the EU, and if the rUK proceeds with the harmful policy of leaving the EU's Customs Union, retailers are likely to start treating Scotland and Ireland as one market (which again might been seen as a subdivision of the Scandinavian or the French one), whereas the rUK will be seen as a rather distinct one. It would make the products in Scottish and Irish shops more similar over time, and less similar to the ones found in England and Wales.
It's worth bearing in mind that the EU's Customs Union is almost ten times as big as the rUK's one, so although it will be annoying to lose some of the English and Welsh products in the supermarkets, the consequences for Scotland will be much worse if we leave the EU together with the rUK.
I'd much rather Westminster decided to remain in the EU's Customs Union, but if they really are hell-bent on leaving it, it's yet another argument why Scotland should become independent within the EU.
As I've said many times before, the reason I don't believe in a federal UK is because England is so much bigger than all the other parts put together that it would need to be split into two or more separate nations for it to work (and each part would need to have its own legal system, NHS, education system and football team in order for federal symmetry to be achieved), but the English clearly don't want to see their nation chopped up any more than the Scots would, so there is no practical way forward.
However, if the Republic of Ireland was willing, I would have nothing against being part of a federal country called the United Celtic Republics. I guess Ireland and Scotland would form it, but I reckon Northern Ireland would join soon afterwards, and I wouldn't be surprised if Wales joined eventually, too.
Crucially, none of the constituent parts would be able to dominate the federal parliament, which together with a proper constitution would be the best way to ensure that the country works for everybody.
One obvious advantage would be that it could inherit Ireland's EU membership, so there wouldn't be any worries on that front.
There might be some disagreement about the location of the federal capital, but there's really only one city that is both Irish and Scottish, so I think Glasgow would be the obvious choice.
Of course I don't really believe the United Celtic Republics will ever be formed, but I honestly think Scotland and the other Celtic nations could all thrive within it. The problem with the UK is that England is far too large compared to the rest, and the lack of a codified constitution makes the situation even worse. It's not being part of a union that makes me fight for Scottish independence, it's being part of an unequal and badly designed one.
I don't know much about Ireland, I'm afraid. However, the Brexiters seem to understand even less, and that worries me.
On the one hand prominent pro-Brexit ministers such as David Davis state they don't want a hard border post Brexit, but on the other hand the very same people are in favour of a hard Brexit, whereby the UK (incl. Northern Ireland) will leave the Internal Market, incl. the free movement of people and the common customs area. Something doesn't add up here!
Firstly, if for instance the UK wants to control the number of Poles entering the country, how does that work if they can freely travel to Ireland as EU citizens and then get the bus to Belfast, unless there is a hard border?
Perhaps the Brexiters will reply they don't want to ban Poles from traveling to the UK at all, but that they just want to control the numbers moving here permanently. Fair enough, but that requires a much more thorough system of work permits than what is being discussed at the moment. Different from what they promised during the Brexit referendum, they effectively wouldn't really control the border, but instead keep a tab on people once they're here. I don't have a problem with that, but they should tell us if that's the plan.
Secondly, if the UK and Ireland aren't in the same customs area, surely lorries can't just drive across the border. Even if the UK didn't care about EU products getting smuggled freely across the Irish border, I have a feeling the EU would have a problem with UK products getting through without import duties. In other words, even if you don't need to show your passport, you'll get your luggage checked.
Thirdly, almost all EU countries are part of Schengen, the passport-free zone. The UK and Ireland have so far refused to join, but it'll become much harder for Ireland not to do so when the UK isn't an EU member state any longer. If at some point in the future Ireland joins Schengen, a border becomes almost unavoidable unless the UK joins Schengen too (like Norway and Iceland).
The Brexiters often say that the UK and Ireland also had an open border before we joined the EU, which is true, of course. What they forget is the Ireland wasn't an EU member either at that point. This will be the first time ever that the EU's external border will divide the Emerald Isle. Stating that you don't want to create a hard border is simply not good enough when you're simultaneously campaigning for a hard Brexit.
This is the first ever guest blog on Arc of Prosperity, written by Ed "The Guero".
Ed is a thirty-something professional from Hamilton who has been travelling for the better part of 15 years in pursuit of work, love and life -- though not necessarily in that order! He is a proponent of assisted healthy living for children and improved social welfare. He tweets as @EdTheGuero.
Case studies, case studies, case studies. As an expat it pays to pay attention to case studies especially when preparing to return home accompanied by your foreign-born spouse and/or children. I say "foreign-born" in reference to those not of the EEA (European Economic Area) or the EU. One has to be mindful of the rules ensuring we dot all of the i's, cross all of the t's and, after what we assume should be a relatively straight forward process, we can expect our spouse to be granted a visa and welcomed to the UK as a well received extension of ourselves. After all -- this is what we should expect from 'Team GB' right?
Not so fast!
This piece is not an attempt to vilify Westminster nor is it an effort to sway a vote in the referendum, but my own situation grants me insight into what we might do better should Scotland be free from the overriding control of a Westminster, so out of touch that it leaves many of its citizens yearning to simply come home with the person they love.
Much has been said lately in the mainstream media and social networks regarding UK immigration policy. In recent years policies have been pushed, pulled and contorted in an effort to protect the UK from an influx of "benefit tourists" and relationships of convenience whilst at the same time providing an avenue for asylum seekers in their pursuit of security. The UK, in the latest policy change, seems to have adopted a rather elitist approach and in Westminster's efforts to "protect" they have cast a net so fine that British expats find themselves wrongfully affected, unable to feasibly come home with their family in tow.
Evidently, we are of secondary importance, an issue being missed in the haste to close Britain's doors to immigrants. Statistics, explanatory documents filled with tables, appendices, diagrams and equations can all be readily found should you feel the need, but as a Scottish expat married to a beautiful lady from some unspecified Latin American country, I can tell you that it comes down to nothing other than money.
There are minimum requirements to be met regarding finances and accommodation as you would expect. What irks me are the countless stipulations and the unrealistically high-set bar which take no account of economic relativity and engineers a scenario in which families are separated indefinitely. In the most common type of family member application, £18,600 is the magic number. As my wife's sponsor I must earn in the months prior to and after my wife's application £18,600 gross annual salary or have savings which supplement my income, have worked for my employer abroad for 6 months minimum and have a contract on the table back home. If I have savings - subtract £16,000, divide by 2.5 and that gives you the number I can add to my gross annual income to meet the minimum requirement. Who has enough savings to subtract £16,000 then... Never mind.
Basically you need a lot of money and now is a good time to point out the cost of application -- a whopping £851. When you struggle to meet a minimum requirement of £18,600 and face set-up costs back home, who has £851 (non-refundable on refusal)? You had best be certain your case is clad in iron.
There are two approaches here -- have your spouse apply whilst you are both overseas or whilst separated with you in the UK. I know it may be an arbitrary number to some but I earn a good salary and live comfortably abroad -- I still earn less than £18,600 per year! My wife earns similarly to myself, but that is not considered a factor in her application, and that leaves us with only one option.
If I want to come home I need to find a job in the UK and then have my wife apply for her visa from overseas when conditions are right. There is a golden ticket which we do not have, £62,500 in savings (subtract the £16,000, divide by 2.5 = £18,600) so it falls to me to accept that we may be apart a minimum of 6 months, realistically up to a year for some.
Are we to believe that this approach is suitable for a country with such disparity, where in London I can expect to earn X% more than in Glasgow or Y% more than in Inverness? Worth noting is of the 422 occupations listed in the 2011 UK Earnings Index, only 301 were above the £18,600 threshold. That's a lot of discrimination and one should consider the fact that Scotland traditionally has a lower average income than the South-East of England. According to the 2012 salary survey by the Guardian, care workers, hairdressers, bar staff, pharmacists, chefs, travel agents, florists, beauticians, cooks, fitness instructors, butchers, bakers and candlestick makers all earn less than the £18,600 minimum and that's before filtering by region.
The obvious conclusion is this: The further South & East you live, the more savings you have and the higher profile your profession, the easier it is for your spouse to obtain a visa.
Accommodation is a similar story, unfortunately. You are expected to either a) have a place set up and ready to accommodate your family or b) have someone provide you with accommodation. I don't know about anyone else but I am short on friends with a spare room, a letting agreement which allows them to sub-let, or an owned property with enough space so as not to constitute overcrowding.
So that's the crux of the thing. A British citizen's difficulty in obtaining a family visa from within the UK or without is long and arduous but the fun doesn't end there. We have the added anxiety in knowing we must do it again 2.5 years down the line because the road to a permanent visa is a 5 year process. Who can plan so far ahead as to know their circumstances will match those at time of original approval and what of a failed application? Is it acceptable that if already in the country many families find themselves separated due to the UK's insistence upon a refused applicant applying from outwith the UK? How does my partner support herself back home in such circumstances? What if she is the sole provider? It goes without saying that money spent on sending my wife to her country of origin only compounds the issue by pushing us farther from the minimum requirements. Then there is the frankly ridiculous "Life in the UK" test which, if the mock test is anything to go by, is as relevant to living in the UK as a Tunnock's tea-cake in France.
The UK immigration system is convoluted, irrelevant, discriminatory and not fit for purpose. The system in place seems to be upside down -- devised to inconvenience those "undesirables" who may not qualify to settle in the UK before serving those with a right to.
There is currently a legal challenge in progress concerning the minimum income threshold which has resulted on all applications that do not immediately meet the criteria to be put on hold indefinitely pending the outcome of legalities. Right now there are hundreds, possibly thousands, of families separated by British immigration policies and the best response on offer is: "I am prepared to consider whether we can put in place some rules that are not vulnerable to abuse" (Mark Harper, until recently Minister for Immigration). I propose that the level of abuse and method of controlling it should not take precedent over the rights of British Citizens and their families!
In my opinion there can be no abuse of such significance that keeping families apart for indefinite periods of time is justifiable collateral. Isn't it our right to return home, to bring with us our loved ones? I cannot accept that the abuse of a few should weigh so heavily against the rights of the many and it seems straight forward to me than even if I come home, my partner and I face an uncertain 5 years where we cannot feasibly plan for a settled life.
So what then?
Scots are travellers by nature and we ought to be allowed to return home, our families treated to the same rights and privileges as ourselves, not assessed on the basis of net burden! Perhaps an independent Scotland can see a future in which common sense and versatility are the tools used to sculpt a system whose primary objective is to protect the rights of its own whilst, secondarily, providing for the well-being of those who wish to join us. Perhaps through inclusion we may deter the "abuse" Westminster fears so diligently.
To restrict the movements of a spouse is to restrict the movements of a British citizen. The result of such a hard handed approach to international couples is simply that many expats who wish to return home are forced to consider alternative destinations. We have for instance considered returning instead to the Republic of Ireland where we would be free of the stress the UK immigration system causes.
If we want this country to be a progressive, modern and caring place to live, surely it would serve to pay attention to the welcome mat we present at the door, especially when it is a member of our family who comes calling.
It's a somewhat strange use of "British" (which is why I put it in quotation marks above) -- surely Ms May means "rUK passports" or "EWNI passports", given that it'd be a bit odd to use the word "British" to refer to somebody or something from the United Kingdom of England, Wales and Northern Ireland.
However, apart from her bizarre use of language, I think both sides are at fault here. Ms May and Better Together are making it sound as if people from Scotland -- as the only country on Earth -- will be denied British citizenship if they otherwise qualify, and some people on the Yes side seem to think that Scots should qualify for rUK passports in perpetuity, even if they have no connexions to the rUK whatsoever.
As is often the case, it's wise to look at Ireland. According to Wikipedia, this is the current situation:
Irish citizens seeking to become British citizens are usually required to live in the UK and become naturalised after meeting the normal residence and other requirements, unless they can claim British citizenship by descent from a UK born or naturalised parent. An Irish citizen who naturalises as a British citizen does not automatically lose their Irish citizenship.
I therefore suspect the situation after independence will be as follows:
Scottish citizens seeking to become EWNI citizens are usually required to live in the EWNI and become naturalised after meeting the normal residence and other requirements, unless they can claim EWNI citizenship by descent from a EWNI born or naturalised parent. A Scottish citizen who naturalises as a citizen of EWNI does not automatically lose their Scottish citizenship.
Of course, just like people from the Republic of Ireland, Scots will most likely be allowed to live and vote in the rUK/EWNI without becoming citizens of that state:
The right of Commonwealth and Irish citizens to vote is a legacy of the Representation of the People Act 1918, which limited the vote to British subjects. At that time, "British subjects" included the people of Ireland — then part of the United Kingdom of Great Britain and Ireland — and all other parts of the British Empire. Though most of Ireland [...] and the majority of the colonies became independent nations, their citizens have retained the right to vote if they live in the United Kingdom.
It's also possible that there'll be increased access to acquiring EWNI citizenship for a limited time, or for Scots born before a certain date. Looking again at Ireland, older people can claim British subject status, but the "facility for those born before 1949 to claim British subject status does not confer British citizenship, although it gives an entitlement to registration as such after 5 years in the UK."
Perhaps the saddest aspect of Ireland’s current difficulties is the number of bright young things leaving the country for better prospects abroad. One could argue that this isn’t a road that Scotland would want to go down through independence and, yet, that is precisely what is happening now. (I know this from experience as I moved to London strictly because Scotland couldn’t provide the PhD that my partner wished to study. Wales, incidentally, could).
The Irish population in 1961 was 2.8m. The population today is 4.5m.
The Norwegian population in 1961 was 3.6m. The population today is 5.0m.
The Icelandic population in 1961 was 179,000. The population today is 318,000.
The Scottish population in 1961 was 5.2m. The population today is 5.2m.
There is clearly only one stagnant, problem child in the above list and that is because there is an historic, corrosive brain drain taking place in Scotland that is damaging growth from both a population and an economic viewpoint. It is little wonder that ‘London-based parties’, to use an unfortunate phrase, are championing the continuation of the UK when it is London that is the prime beneficiary of this very brain drain.
Kids wanting to get away from it all in Sweden move to Stockholm, kids wanting to get away from it all in Norway move to Oslo and kids wanting to get away from it all in Iceland move to Reykjavik but too many kids wanting to get away from it all in Scotland move to London, and we are haemhorrhaging talent and creativity as a direct result.
I decided to have a closer look at this. Using figures from Wikipedia (look for the articles called Demographics of …), I've made two graphs.
The first one (top right) shows the populations of Scotland, Ireland, Denmark and Norway from 1900 to 2010. In 1900, Scotland was by far the most populous country of the four, with almost as big a population as Norway and Denmark combined. Scotland and Ireland had almost stagnant populations for the following decades, while Norway and Denmark grew rapidly. A while after Ireland became independent, the Irish population suddenly exploded, and it has now almost caught up with Denmark. Scotland seems to have experienced modest growth after the introduction of the Scottish Parliament in 1999.
The other graph (on the left) adds Sweden and England, but instead of using absolute numbers, the graphs are relative to the populations in 1900.
The second graph clearly shows a difference between non-independent Scotland and pre-independence Ireland on one hand, and the independent countries (or the dominant part of the union, in the case of England) on the other.
If Scotland had experienced the same relative population growth as Denmark since the year 1900, the population in 2010 would have been around 10.1m instead of 5.2m. Would this have happened if Scotland had regained her independence under Queen Victoria, or are there other reasons why Scotland would never have been as fertile as Denmark?
To what extent is Britain (or the British Isles) the same kind of construct as Scandinavia (or the Nordic countries)?
Both Britain and Scandinavia have a long and complex history, with periods of political unification and others with separate kingdoms and plenty of wars.
Scandinavia's united period was a long time ago (1397–1523), while Britain only started falling apart when Ireland became independent again less than a century ago. On the other hand, the British Isles are to some extent more heterogenous than Scandinavia – the former is a mixture of Celts, Anglo-Saxons and Norman French, while the latter consists of the descendants of the Vikings with some Finns, Lapps and Germans thrown in.
In both cases in can be hard to pinpoint exactly what Britishness/Scandinavianness means. For instance, John Major's description of Britishness – “Britain will still be the country of long shadows on cricket grounds, warm beer, invincible green suburbs, dog lovers and pools fillers and, as George Orwell said, 'Old maids bicycling to holy communion through the morning mist'” – is so clearly a description of England that does not apply to Scotland and Ireland. In the same way, it's very hard to define Scandinavian culture in one sentence. And yet, Scandinavians do recognise the similarities intuitively, and Scandinavians abroad tend to hang out together, for instance at international conferences.
So there are definite similarities. And just as Scandinavia does exist in spite of having been separate countries for half a millennium, Britain will always exist whether Scotland becomes independent in 2014 or not. Actually, Scottish independence might actually lead to a reevaluation of the concept, so that it ceases to be about a political construct and starts being about what actually binds people on these islands together, whether they live in Ireland, Wales, Man, Scotland or England.