Politics

Caught between two unions

Can Scotland and Northern Ireland somehow stay part of both the UK and the EU?

June 27, 2016
First Minister Nicola Sturgeon speaks to the media outside Bute House, Edinburgh, following an emergency Scottish cabinet meeting.
First Minister Nicola Sturgeon speaks to the media outside Bute House, Edinburgh, following an emergency Scottish cabinet meeting.
Read more: What to do about the referendum result?

The unexpected result of the referendum on our membership of the European Union will have profound economic, political and social consequences. Perhaps none is more difficult to disentangle than the implications for the different nations of the United Kingdom. The positions of Scotland and Northern Ireland were already under challenge in different ways. Now that each has voted to “Remain” in the EU, unlike England and Wales, these challenges are bigger, and the questions that they pose are much harder to answer.

It is widely acknowledged that the EU took the border question out of Northern Irish politics. Now, the Brexit vote puts it straight back in. Sinn Fein is already demanding that the Secretary of State for Northern Ireland, Theresa Villiers, holds a "border poll” on the unification of Ireland. But Northern Ireland is divided on confessional lines on this question, as on so many others. And the people of the Republic of Ireland would need to agree to unification too. We are back to the dilemmas of 1914. Could Dublin govern a province against the wishes of a large proportion of the population, and would Dublin want to? The carefully constructed edifice of power-sharing and the peace process has always been high maintenance, but will require much more work to survive this earthquake.

Less than two years ago Scotland decided to remain in the UK by a greater majority (55 per cent) than the UK has chosen to leave the EU. But last week Scots also decided firmly that they want to stay European. It now looks as though they must choose between one union and the other. Naturally enough, Scottish Nationalists are demanding another independence referendum (and Nicola Sturgeon has said that one is "highly likely" to happen). They point out that one of the arguments for staying in the UK was that it guaranteed continuing EU membership on the present terms. It's a fair point, though by no means the only issue.

But how could Scots make that choice? No one knows what Brexit means. In the Scottish independence referendum, the SNP presented its version of independence. It was subject to a lot of challenge and criticised as wishful thinking, but at least it was a proposition. By contrast, Brexit could mean anything from Australia’s status with the EU to Norway’s. The "Leave" movement’s proposition was essentially negative: get out of the EU. They crystallised a bundle of insecurities, resentments and fears, but had no coherent plan for the UK's new status. In truth, they never expected to win.

If indeed Scots—or the Northern Irish—are to choose between unions, they need to know the answers to some critical questions about the future of the UK-EU relationship. Would the UK be like Norway, and thus retain freedom of movement for people inside the British Isles, even though some of that territory was inside the EU and some not? Or will the UK be like Australia, so that Scots have to show their passports at a new Hadrian’s wall? And could Scotland still use the pound as their currency, even if the UK were outside the EU and Scotland in?

But even if all these questions were answered—and that could only come about after the two years of negotiation kick-started when Article 50 is invoked, or more—Scots face an unenviable choice. Today they are members of two single markets, not one. The UK is a fully functioning domestic economy, with the overwhelming majority of Scotland's trade with England, not the rest of Europe. There is also a fiscal union, so that Scotland's high public spending is supported by England's taxes as well as its own. The takeaway message from the independence referendum was that there was no sustainable plan for the economy of an independent Scotland. Leaving the UK is even more economically damaging for Scotland than leaving the EU will be for the UK. That hasn't changed.

This leads to a more intriguing question: is there a world in which Scotland and perhaps Northern Ireland can keep both a relationship with the EU and with the UK? Is there a constitutional structure which enables freedom of movement, sharing of currency and risk-pooling inside Britain, with access to the advantages of the EU for Scots and others who voted for it? In other words, can we maintain a relationship with both unions, and perhaps both markets, by designing new and ingenious constitutional architecture, and be British and European despite Thursday's vote? And might something similar be created for Northern Ireland?

Just a week ago such questions seemed absurdly theoretical. But they are suddenly concrete: it must surely be the duty of Scotland's devolved government and indeed for all those who believe in Scotland's European as well as British destiny to explore every option, and answer the conundrum that the electorate has set the country.