A piece published by the DGAP's IP journal.
Will the EU accept a breakaway Scotland seeking to maintain the exclusions granted it in the United Kingdom? While we must not project onto Scotland expectations and hopes borne of frustration with the UK, we must equally be careful not to predict the policies of an independent Scotland based entirely on its current place in the UK.
The debate about Scotland and the EU focuses almost entirely on whether an independent Scotland could become a member of the EUand whether Scottish independence might encourage other breakaway regions in the EU to follow suit. As a result the debate largely overlooks three equally important questions: First, what would it mean for the EU to agree to the Scottish government’s aim for Scotland to keep the same terms of membership as the UK with assorted opt-outs and exclusions? This leads to a second question of how an independent Scotland might behave as a EU member. Finally, almost entirely overlooked with rare exceptions, is what Scottish independence could mean for the remaining UK’s relations with the EU.
An independent Scotland would be a positive, pro-European country determined to take its place at the heart of Europe. This was the message Scotland’s First Minister Alex Salmond delivered at the College of Europe in April. Britain’s leading euroskeptic party, UKIP, has traditionally lacked much support in Scotland. Scottish politics and political parties have tended to stay clear of the more hostile euroskeptic debate prevalent elsewhere in Britain. Remaining in the EU is seen as an integral part of the idea of an independent Scotland, a country long accustomed to playing a smaller part in a larger union. However, while an independent Scotland would lack a euroskepticism that wants to leave the EU, it could place itself in the slow lane of a multispeed Europe and by doing so make such a Europe more likely.
More often than not, Scottish opinion on the EU – as with so many other issues – is measured against opinion elsewhere in the UK. This creates a simplistic view of pro-European Scotland versus euroskeptic England when opinion varies across the UK – and within England. Polling shows voters in London – the UK’s economic heart and home to a population equal to that of Scotland and Wales combined (one-third of whom were born overseas) – are just as likely as the Scots to support EU membership. Polling also shows areas such assouthwestern and northwestern England are less hostile to continued EU membership. England is undeniably home to some of the strongest levels of support for UK withdrawal, a development seenincreasingly in connection with the rise of English nationalism. Then again, Wales – that other Celtic nation with a devolved government – has also seen growing support for UKIP.
Also, opinion in Scotland should not be taken for granted. When the UK held a referendum on whether to remain in the then EEC in 1975, the Scots were amongst the least enthusiastic with only 58.4 percentvoting to stay in compared to a UK average of 67.2 percent, and an England average of 68.7 percent. Today polling shows support in Scotland for staying in the EU hovers between 53-61 percent, not far from what it was in 1975.
Even the differences between England and Scotland can be exaggerated. Analysis from “What Scotland Thinks” shows the proportion who would vote to leave the EU is six points lower in Scotland than in England. This is a difference, but as John Curtice, professor of politics at Strathclyde University, argues, it is not enough to suggest a groundswell of support for the EU in Scotland. For example, the euro is just as toxic in Scotland as it is in England, with one recent poll finding only four percent of Scots support the idea of an independent Scotland joining the euro. This is one of the reasons why Scottish nationalists are keener to retain a currency union with the rest of the UK than go near the euro.
There is also evidence that Scottish opinion on Europe might be hardening. In the 2014 European Parliament elections UKIP secured their first Scottish MEP. Despite this success UKIP’s overall support in Scotland might be relatively weak, but one wonders how a left-wing euroskepticism – one that attacks the free market, deregulatory, austerity agenda that dominates the EU – would be received in Scotland where left-of center politics tends to be more popular. The Scots might not want to leave the EU (although a majority support the idea of the UK holding a referendum on the issue), but they don’t currently seem in a rush to be at the heart of it.
It is therefore no surprise that the Scottish government has put some limits on its aspirations for an independent Scotland in the EU. “Scotland’s Future: Your guide to an independent Scotland,” the Scottish National Party (SNP) government’s manifesto, makes clear that in joining the EU an independent Scotland would seek the UK’s exemptions from the euro, Schengen, and some justice and home affairs legislation. Edinburgh also expects to secure Scotland’s share of Britain’s budgetary rebate that is much resented elsewhere in the EU. The Scottish government argues it would be impractical to reopen budget negotiations. But as others have made clear, the rest of the EU will be quick to try and ditch a rebate that could see them paying Scotland €354 million a year. The twist for Scotland is that if it does not secure its share of the UK’s rebate then it too will have to pay a €55 million share of the rebate to the remaining UK. More importantly, for some in the EU scrapping Scotland’s share of the rebate will be a way of limiting the potential for Scottish independence to spread a culture of opt-outs and exclusions in the EU.
But we should be careful before concluding that Scotland is destined to play the role of a Little Britain in Europe. Even as a part of the UK, Scotland has developed a distinct approach. Long accustomed to sharing its sovereignty within a larger union, debates in Scottish politics lack the absolutism that often dominates Westminster’s debates about parliamentary sovereignty and the EU. Despite the UK being one of the most centralized systems of government in the developed world, Scotland has long maintained distinct political, social, and economic institutions.
In pushing for independence the SNP, once opposed to the EU, has long since embraced the idea of EU membership and ideas of shared sovereignty, even if the latter is more vividly demonstrated in their desire to share the pound sterling with the rest of the UK than the euro. Scotland’s political parties lack the deep divisions over Europe that have plagued parties at a UK level. On immigration, Scotland’s need for people and its sparsely populated spaces has meant a less unpleasant debate about immigration compared to that of England (although Scottish opinion on immigration may be hardening).
An independent Scotland would also likely set out to distance itself from the UK, perhaps developing distinct policies over energy, fisheries, or the environment. In England, Europe has become a source of resentment, something that holds Britain – or England – back. Any politics of resentment in Scotland tend to be toward the UK and Westminster. The EU and Brussels could eventually take their place in an independent Scotland, but currently the EU is seen more as a way forward and part of a fresh start. This would be helped by the tone of Scotland’s independence referendum debate, which has been more wide-ranging than the narrow one of trade and sovereignty we can expect should the UK ever hold an in-out referendum on the EU.
Independence would also mean that as a smaller state, Scotland cannot expect to wield the same degree of power and weight as the UK. The UK struggles to balance a desire to lead Europe in the world with unease at leading in Europe. Scotland’s focus will largely be on leading in Europe. Public opinion could soften thanks to a political debate that loses Westminster’s more negative tone. Relations with the EU could also develop if relations with the remaining UK become difficult, for example over sharing the pound sterling. Scotland may give up its share of the budgetary rebate if membership negotiations demand it. It may also make a written commitment to aspiring to join the euro in the long run, although any such agreement will not be made on a Scotland-Brussels basis but emerge from ongoing tensions between the eurozone (i.e. Germany) and other non-eurozone members committed to joining such as Poland and Sweden. These states will have clear ideas and wordings in mind for what Scotland should commit to.
The question then arises whether public opinion can keep pace with such diplomatic necessities. Scotland could be less antagonistic diplomatically, but still be home to a people uneasy with the idea of further integration. Supporters of Scottish independence often look to Scandinavia as a model, and Scotland may find it fits into the varying degrees of membership and cooperation with European organizations. Norway, for instance, is part of NATO and the Schengen area, outside the EU but deeply bound by it; Sweden stands outside NATO, but is part of the EU, while not using the euro, but required to join eventually; Finland, outside NATO, is a member of both the EU and the euro. Scotland could take an approach similar to Denmark, a country outside the euro area but deeply connected with the EU, with mainstream political parties strongly pro-European and popular support lukewarm.
However, Edinburgh might also be drawn back to a UK approach of seeking opt-outs, especially if the remaining UK stays in the EU on the basis of a new relationship that grants it more exemptions. Scotland might, like some other EU member states have done in the past, hide its own unease about the EU behind London’s willingness to veto or say no to EU proposals.
Too often we have heard politicians from the UK promising to put their country at the heart of Europe only then to see them failing to do so. Salmond’s commitment to the heart will be popular with those who think that in Scotland they have found the pro-European part of the UK. But we should be careful not to project onto Scotland expectations and hopes borne of frustration with the UK. Equally we should be careful not to predict the policies of an independent Scotland based entirely on its current place in the UK.
The rest of the EU should also remember they will play their part in shaping Scotland’s attitude. A difficult membership process would poison relations. An independent Scotland will, like all other states – including the UK – play an active role in Europe. But as with other states, there will be distinct limits to this. Scotland’s limits couldreinforce of the idea of a multispeed Europe, one where Scotland positions itself in one of the slower lanes, even if it is slightly faster lane than that chosen by the remaining UK.
