Britain is headed for the exit. But some in Scotland want to stay, even if that means its own exit from the UK.
Whether Scotland separates from the UK or not, what is clear is that in an interconnected world, its experience as a nation would be heavily dependent on relations with the rest of Britain and with an EU trading bloc containing members hostile to independence movements.
So what are its options?
Icelandic legal expert Katrin Oddsdóttir has suggested that Scotland might be better off joining the unofficial league of small, independent, north Atlantic nations along with her home country and Norway.
The reverse Greenland
This is a model that would keep Scotland and perhaps other parts of the UK in the EU while allowing England to exit. It’s named after Greenland, a constituent part of the kingdom of Denmark, which was allowed to leave the EU in the 1980s while Denmark stayed in.
This is an avenue that Nicola Sturgeon is exploring. According to an EU official quoted by Reuters, the First Minister has discussed in Brussels the possibility of “getting special status within the UK to let it still be a member of the EU somehow”.
It’s not necessarily more than conversation at this point, however. “Scotland is a part of the UK,” a spokesman for the European Commission said. “All parts of the UK should sort out what they want to do.”
The Greenland precedent may not be seen to apply for many reasons: Greenland doesn’t share a land border with any part of the EU, its population is not much more than 50,000 and it’s 80 per cent ice. England and Wales are a bit different.
Independence + EU
This would involve a declaration of independence by Scotland followed by an application for EU membership.
There are many obstacles: Theresa May’s focus on the Union in her first speech at Downing Street and her swift visit to Scotland show that protecting the integrity of the United Kingdom is important to her. Just because David Cameron allowed a referendum is no guarantee that his successor will agree to one.
If Scotland calls its own referendum and manages to unilaterally declare independence from the UK, it’s likely to cause a lot of economic turbulence. It will also make it much more difficult to get into the EU past the opposition of Spain, which ignored a Catalan referendum result in 2014.
The Nordic model
Katrin Oddsdóttir, the legal expert who drew up Iceland’s post-crash constitution, suggested at Ireland’s Galway Arts Festival over the weekend that Scotland could have a prosperous future outside both the EU and the UK, as an independent country drawing inspiration from the likes of Norway and Iceland.
She said: “There is a great beauty and a great strength in being a small nation that is truly independent. Which means making your own decisions more freely.”
Given the obstacles to a Scotland joining the EU, this could become a de facto reality at least temporarily if events they strike out for independence without prior assurances from Brussels. But it’s not clear that it would be popular amongst any but the most hardened nationalists who see independence at all costs as a worthwhile goal.
Stay the course
Whether by choice or not, one of the most likely outcomes is that Scotland will remain part of the United Kingdom and will leave the European Union at the same time as the rest of the country.
What will this look like? Scots will find out at the same time as the rest of the UK.
Stay the course 2
The United Kingdom voted for Brexit, but Article 50 hasn’t been triggered yet, and until it has been, anything is possible. Could Scotland somehow stay in both the UK and the EU? It’s unlikely, but stranger things have happened.
This article originally appeared on our sister site iNews.