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A reverse Greenland: the EU should let Scotland stay

Scotland voted overwhelmingly to stay in the EU. It should be allowed to do so.

The results across the UK: all of Scotland voted to Remain

It wasn’t close in Scotland. 62% of people voted to stay in the EU, the most decisive margin of any of the UK’s four main countries. A majority in every single Scottish local authority area voted Remain. In this context, the most democratic outcome would be for Scotland to stay in the EU. In fact, I’d go further. Just as it would be wrong for England and Wales to be forced to Remain against their will now that they have voted to leave, it would be wrong for Scotland and Northern Ireland to be forced out of the EU in the face of votes to Remain.

The obvious way for these things to happen are for votes on Scottish independence and a united Ireland, both of which are things I’m in favour of. But I think it would be a mistake to take the leaps into them without first exploring a middle ground; what I call “the reverse Greenland”. 

The Danish Realm, you see, is made up of three countries: Denmark, Greenland and the Faroe Islands. Of these only one, Denmark, is an EU member. The other two are part of Denmark, but not the EU. There is, therefore, a precedent for different countries within the same state to have varying relationships with the EU.

Of course, that situation is different. Denmark is by far the biggest part of its Union. Scotland (and Northern Ireland) staying without England and Wales would be unique in Europe. Representation at the Council of Ministers would presumably come from the Scottish Government (and perhaps the Northern Irish Executive). If the UK left the common market entirely, then it would be harder: Scotland couldn’t really be in both unions in that context.

Likewise, there would be some complex questions about borders, though it’s worth remembering that the Fresh Talent Initiative showed how you can have different work visa arrangements in Scotland and England without a suggestion that this means independence.

Perhaps it would be impossible to resolve these issues. But EU expert Professor Sionaidh Douglas-Scott thinks it’s possible. And with Scotland voting in the space of 19 months to stay within the UK and within the EU, it seems that we should all work to at least try to see if those two choices can be respected. If they can’t, it seems to me that a second independence referendum is the best option.

Of course, Londoners and Bristolians and Liverpudlians and Mancunians could perfectly reasonably say the same thing. When I started tweeting about this as the results rolled in, using the hashtag #letscotlandstay, various friends across the country responded with the equivalents for their cities in England. But whilst I don’t think there is anything particularly special about nations (London is surely an imagined community) or historic states (Wales was a country before it had any of its own governance structures), I don’t think it’s practical. Scotland and Northern Ireland have their own ministers already, who can sit round tables and negotiate. We have our own legislatures, schooling and healthcare systems, and recognition as historic countries.

There is no precedent for a major country like Britain leaving the EU. And so what is possible at a time like this is yet to be defined. Those rules that there are can be re-written, those conventions which exist don’t necessarily apply.

Scotland is an ancient European country. In 1707, we chose to go into a union with England and Wales, and in 2014 we chose to ratify that union. In 1975 we chose to join the European Community and in 2016, we voted overwhelmingly to ratify that choice.

The European Union will now be making decisions about how to approach two years of negotiation. Were they to ignore the simple fact that the United Kingdom is itself a union, and that two of the major parts of that union voted to Remain in the EU, then they would be failing to respect the outcome of the vote.

Let’s hope they let Scotland stay. It’s what we voted for.

About the author

Adam Ramsay is the Co-Editor of openDemocracyUK and also works with Bright Green. Before, he was a full time campaigner with People & Planet. You can follow him at @adamramsay.

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