Scotland considers ‘bespoke’ EU options after Brexit

While independence is a possibility, the Scottish government is also examining options that would allow Scotland to remain within the UK while keeping strong EU ties once Britain leaves the bloc.

First Minister Nicola Sturgeon, in a speech this week, stressed that Scotland was in “uncharted” waters after it voted by 62 percent in favour of the United Kingdom staying in the European Union while the UK overall voted 52 percent to leave.

The result does not appear to have shifted Scottish public opinion in favour of independence, according to a YouGov poll released on Saturday in which a majority said they would favour remaining a part of Britain even if it leaves the EU as planned.

Sturgeon has said “bespoke possibilities” should be on the table, adding: “There’s no black and white. Let’s consider all the options with an open mind and work to develop the right outcome for Scotland”.

Alyn Smith, a European Parliament lawmaker from Sturgeon’s left-wing secessionist Scottish National Party, told AFP that independence was “not our first option”.

“We’ve just had a referendum,” he said, referring to the 2014 referendum in which Scotland voted 55 percent to 45 percent in favour of remaining within the UK.

“We see various examples EU-wide of one country, two systems,” said Smith, who received a standing ovation in the European Parliament after the Brexit vote when he called on fellow lawmakers to stand by Scotland.

Following are the three main options under consideration:

Reverse Greenland
Greenland, the largest island in the world, left what is now the EU in 1985 in a dispute over fishing rights but is still an autonomous country within the Danish realm, along with the Faroe Islands and EU member Denmark.

The prospect of Scotland remaining in the UK and also the EU while the rest of Britain leaves the bloc “is not as unlikely as some make it sound,” Sionaidh Douglas-Scott, a law professor at Queen Mary University of London, wrote in The Guardian newspaper.

“The EU has a history of flexible and variegated participation that does not always involve single states in homogenous EU memberships,” she said.

Douglas-Scott pointed out that the Isle of Man and the Channel Islands, which are British crown dependencies, are not part of the EU.

But University of Aberdeen professor Michael Keating, in a blog, ruled out a comparison with Greenland since in the case of Britain and Scotland “the larger part of the state would be outside the EU”.

Scottish Norway?
Under this scenario Scotland would no longer be in the EU but would retain far closer ties with the bloc than the rest of Britain — similar to those that Norway currently has.

Experts Anand Menon and Damian Chalmers wrote in a report for the Open Europe think-tank that such an arrangement was “constitutionally possible”.

Scotland could remain a part of the single market, retain most EU laws, make contributions to the EU budget and perhaps even have a place in the Committee of Permanent Representatives (Coreper), an influential grouping of EU ambassadors in Brussels, they said.

On free movement, Scotland could continue to allow EU citizens in by issuing national insurance numbers which would have validity only in Scotland while they would face restrictions in the rest of Britain.

People registered on the electoral roll in Scotland could then have free movement in the EU, they said.

Independence
Within hours of the Brexit vote result, Sturgeon warned that a new referendum on independence for Scotland was “highly likely”, although the ultimate decision on whether or not to grant one rests with Britain’s national parliament.

Sturgeon has indicated the vote — if it goes ahead — should take place before Britain actually leaves the EU.

Constitutional experts say there is a chance that Scotland could then “inherit” Britain’s EU membership instead of re-applying to join the union.

But the YouGov poll on Saturday indicated there is currently no majority opinion behind independence.

Fifty-five percent of Scots said they would rather live in a Scotland that was still part of Britain post-Brexit, against 45 percent who would rather live in an independent Scotland that remained in the EU, excluding “don’t know” answers.