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.
I used to think that David Cameron was secretly trying to engineer a Leave vote. There were so many signs, e.g., (1) making demands from the EU that could never be met, (2) disenfranchising EU citizens and long-term British residents in Europe, (3) holding the referendum just after the Scottish, Welsh and Northern Irish elections (leading to a lot of election fatigue in these areas), and (4) also holding it during Euro 2016 (when national pride is always running high).
However, the way he didn’t do any Brexit contingency planning and simply threw in the towel now makes it clear that he just was naïve and arrogant enough to think that he’d achieve a Remain vote no matter what.
I’ve even seen it mentioned that he bragged to Juncker that he was going to achieve a 70% win for Remain, which was clearly delusional.
Never attribute to malice that which is adequately explained by stupidity!
I flitted to Scotland in 2002 because I got a job at Collins Dictionaries in Bishopbriggs. Because of the EU, it was almost a simple as getting a job at home — I simply applied for it, went for an interview and signed a contract, without having to apply for a work permit or anything. I had to get a national insurance number, but that was straightforward; the only real difficulty I faced was getting a bank account, which was a real pain.
To this day I’ve never had a work permit or any other piece of paper confirming that I have a right to live here — this is different from all the non-EU migrants who of course have to get such papers as soon as they move here.
I fell in love with one of my colleagues, Phyllis, and we married in 2009 (I was of course wearing a kilt, in the beautiful Buchanan tartan). In the same year, we set up a company together. Our life is here, and yet I’m only allowed to live here because of the EU — our daughters have dual nationality, but I’m still only Danish.
And yes, I could apply for UK citizenship, but until September 2015 it would have meant giving up my status as a Danish citizen because of Danish legislation (and my daughters would also have stopped being Danish at that point). I’m looking into it now, but it’s a complicated process which involves two exams, a lot of forms and a significant amount of money.
Denmark disenfranchises its citizens after two years abroad, so since 2004 I’ve only been able to vote for two parliaments: The Scottish Parliament in Edinburgh and the European Parliament in Brussels and Strasbourg. Neither the Danish Parliament in Copenhagen nor the UK Parliament in London wants to know what I think. And of course I can’t take part in the Brexit referendum tomorrow, because it uses the Westminster franchise.
If the UK votes in favour of leaving the EU tomorrow, one of the consequences will be that I won’t be able to take part in Scottish Parliament elections any more, and if there is another Scottish independence referendum, I won’t be able to vote in that, either. The mere thought is absolutely heartbreaking, given how much time and effort I invested in the last indyref.
Of course nobody knows what Brexit will entail. It could be that the outcome is a Norwegian solution, in which case the only real consequence for me will be losing my right to vote in Holyrood elections, but if it ends up as an acrimonious divorce, nobody knows what the consequences will be — EU citizens might for instance be charged to use the NHS, or we might lose the right to some benefits.
I really fail to see how Brexit will benefit normal people, and it has the potential to harm millions drastically. Voting Leave is not simply a harmless way to give David Cameron a bloody nose, but a potentially serious blow to the European Union — which, in spite of all its failings, has allowed normal people like me to get a work in another country and to start a family there without having to jump through hundreds of bureaucratic hoops.
The Leave and the Remain campaigns are united in dismissing the Norwegian solution. The Brexiters want to control immigration, which is incompatible with it, and the pro-EU side rightly argues that it’s a very much inferior solution compared with full membership, because it would require the UK to follow all the rules and pay a lot of money without having any influence.
However, nobody wanted the Norwegian solution in Norway, either, and yet that’s what they ended up with. That’s because that’s what you get when a majority of the population says No the EU while a majority of MPs say Yes. Without a referendum, Norway would simply have joined the EEC together with the UK, Ireland and Denmark back in 1973, and if not then, then together with Sweden and Finland in 1995. Forced to remain outside the EEC, the politicians opted for the second-best solution instead.
Something similar might happen after a Brexit vote: Pro-EU MPs have a huge majority at Westminster (everybody from the SNP and the Liberal Democrats, almost all Labour MPs, and at least a quarter of the Tories). This means that any attempt to cut the ties to the EU completely will be voted down, and the most likely outcome is some sort of Norwegian (or perhaps Swiss) solution. The Leavers might complain that people didn’t vote for that, but the Remainers will simply say that the voters were promised the UK would retain full access to the Internal Market, and this is the only way to achieve it.
If the Brexit referendum had taken place a decade ago, I’m almost certain the UK would have been offered a Norwegian solution, perhaps even with some nice little opt-outs.
However, in the current climate I fear many of the other EU countries will want to be tough on the UK. This is not primarily due to anger or a need for revenge, but because they’re afraid of the own Eurosceptics. In particular, the French establishment will want to frighten their voters away from voting for the Front National in next year’s presidential elections — and indeed this party is very keen to follow the UK out of the EU.
It’s still possible the UK will be offered a Norwegian solution, but it will probably be on a basis of take-it-or-leave-it, without any opt-outs. It’s even possible the UK will be forced to join parts of the EU that the British government has so far managed to stay out of, such as Schengen.
The Leavers won’t be very happy if this is the eventual outcome, but I reckon a majority of MPs would sign up to it if they realise it’s the only way to retain full access to the Internal Market. It’s almost certain none of the wild dreams of the Leave campaigners will be realised because they don’t have a parliamentary majority.
So if we’re lucky, a Leave vote will lead to very few changes (but a great loss of influence), and if we’re unlucky, it’ll lead to the UK being excluded from the Internal Market. It’s really a lose/lose situation, so please vote Remain!
I have the impression that my friends and family in Denmark are surprised that I haven’t been campaigning harder to remain in the EU, and I must admit that I had expected to be more active.
However, I’ve realised it’s really hard to have a good argument about something when everybody in the (physical or virtual) room agrees with you.
The independence referendum campaign was great because there were so many views and a real willingness to discuss them.
This time, on the other hand, most people in Scotland are in favour of continued EU membership, and the only people I know who are thinking about voting Leave are seeing it more as a tactical ploy to ensure we get a new Scottish independence referendum sooner rather than later. (I think this is a rather stupid and dangerous argument, but there you go.)
I can see there are genuine discussions down in England about what to do — for some people it seems to be almost as inspiring as the independence referendum was north of the border — but up here most people are simply watching the Johnson, Gove and Farage show with dread and fear.
I don’t think this blog has many Eurosceptic readers, so writing about Brexit feels like preaching to the converted.
It’s such a shame we lost the independence referendum, because it means we have to spend our time debating the issues that interest the Tories in England, and indeed it’s looking increasingly likely that the Little Englanders will drag Scotland kicking and screaming out of the EU. It’s so frustrating.
There are indications that the SNP leadership are trying to talk down the prospects of a quick indyref2 after a Brexit vote. For instance, this is what Humza Yousaf said recently according to The Herald:
Humza Yousaf, the Scottish Government’s transport minister, has made clear that, personally, he would not like a second referendum on Scotland’s future in such circumstances, noting how it would “make the argument for independence very difficult”.
[He] then added: “I do not want a referendum in those circumstances. It makes the argument for independence very difficult as well. It presents us with some additional difficulties and some additional challenges.”
I agree with Humza that it might be difficult to win a new indyref immediately after a Brexit vote, when voters are aware that a Yes vote will mean that the English-Scottish border will become the external border of the EU. I therefore very much hope that the UK votes to Remain in the EU.
However, if Brexit happens, it’ll only get harder to win a new indyref if we wait a few years, so unless we want to kick Scottish independence into the long grass, we’ll need to act immediately afterwards and hold a new referendum in late 2016 or early 2017, well before the (r)UK leaves the EU in the summer of 2018.
The reason for the urgency is that Scotland’s big chance is to vote to remain in the EU without ever leaving the bloc. If that happens, many companies will choose to relocate here from the rUK. On the other hand, if Scotland leaves the EU together with the rest of the UK, those companies will move to Ireland or another EU member state, and they won’t move to Scotland even if we decide to become independent a few years later. Even if just 5% of the companies currently domiciled in the rUK move to Scotland, it will be a huge boost to the Scottish economy and will lubricate the change from dependence to independence nicely.
It’s also likely many people in the EU will suddenly encourage Scottish membership of the EU so that not all of the UK is lost after Brexit. For instance, in a role-play organised by Open Europe, the “Netherlands predicted an effort to channel investment to Scotland, in an effort to peel it off from the rest of the UK.”
Furthermore, YouGov’s Peter Kellner has pointed out that there normally is a late swing towards the status quo in referendums, which is exactly what we saw in the 2014 independence referendum. However, just after Brexit, there won’t be a status quo — the alternatives will be to remain either in the EU or in the UK, but not both — and this might prevent this late swing from happening again. On the other hand, if we sit on our hands for ten years, a status quo will have re-established itself, which will benefit the pro-UK side.
In other words, a snap indyref2 will appeal to both risk-takers who believe Scotland can poach a lot of English companies as well as to the natural conservatives who are worried about what will happen if we leave the EU. Combined with those who are already convinced about Scottish independence, that might well be a winning combination.
Things won’t get easier over time. So long as England remains outside the EU, a vote for Scottish independence will be much more daunting than it was in 2014 when it was simply a question of turning the English-Scottish border into an internal EU one.
So yes, I’m pessimistic that we can win indyref2 after a Brexit vote, but our only chance of doing so is to have it almost immediately afterwards so that Scotland never leaves the EU and can become the natural new location for companies wanting to remain within both the EU and the old UK. After that, any hope of independence will be kicked at least twenty years into the future.
Of course I’d prefer the UK to remain within the EU, but given recent opinion polls, we have to be prepare to seize the moment after a vote to Leave.