Great Britain’s Great Unraveling

Here’s how the U.K. could fall apart post-Brexit.

CARTER BAR, SCOTLAND - SEPTEMBER 14: (EDITORS NOTE: Image has been processed with digital filters) A Scottish Saltire flag flies on the border with England on September 14, 2014 in Carter Bar, Scotland. The latest polls in Scotland's independence referendum put the No campaign back in the lead, the first time they have gained ground on the Yes campaign since the start of August.  (Photo by Peter Macdiarmid/Getty Images)
CARTER BAR, SCOTLAND - SEPTEMBER 14: (EDITORS NOTE: Image has been processed with digital filters) A Scottish Saltire flag flies on the border with England on September 14, 2014 in Carter Bar, Scotland. The latest polls in Scotland's independence referendum put the No campaign back in the lead, the first time they have gained ground on the Yes campaign since the start of August. (Photo by Peter Macdiarmid/Getty Images)

I moved to Scotland in September 1997, a wide-eyed American graduate student. These were heady days. Newly-elected Prime Minister Tony Blair had just won referendums on devolution to Scotland and Wales; plans for a new Scottish Parliament were taking shape; and the European Union was preparing to introduce the euro. Four years later, I moved to Northern Ireland, arriving in Belfast a week before two planes crashed into the World Trade Center. I was embraced by people who were painfully familiar with the scourge of terrorism, yet bravely working toward a more peaceful future following the 1998 Good Friday Agreement. The Brexit vote has raised questions about all of these political projects, particularly the future of the United Kingdom itself.

The general consensus is that Scotland will leave the U.K. First Minister Nicola Sturgeon has already announced the Scottish government’s plans to prepare legislation for a second independence referendum, citing the “significant and material change in circumstances” since the September 2014 vote, when 55 percent of voters opted to stay in the U.K. While the pros and cons of independence were debated extensively before that vote, Brexit adds a dramatic new twist. With 62 percent of those in Scotland (including majorities in all districts) having voted to remain in the EU, Sturgeon now argues it is “democratically unacceptable” for Scotland to be forced to leave. Over the weekend, she suggested the Scottish Parliament could block a legislative consent motion required to pass legislation enabling the U.K. to withdraw from the EU.

The poll results aren’t surprising. Scotland has long been pro-European, with continental ties dating back to the “auld alliance” with France in 1295 that provided mutual assurance of support in the event of an attack on either country by England. Following the 1707 Act of Union that merged Scotland and England into Great Britain, Scotland retained its own systems of law (based on Napoleonic civil law, as distinct from English common law), church (Calvinist Presbyterian rather than Episcopalian), and education. Scotland has long embraced the EU and sought to ensure it has a voice there, establishing a Scottish advocacy organization in Brussels in 1992 and using its new parliament to promote Scottish views on European issues.

There remains debate over whether Scotland can remain in the EU following the U.K.’s withdrawal. In 2012, then-European Commission President José Manuel Barroso said an independent Scotland would have to reapply; two years later, in advance of the Scottish referendum, he said membership would be “difficult, if not impossible.” In the wake of Brexit, EU officials reiterated this position while Sturgeon argued the unique situation means “there are no rules.” During a Wednesday visit to Brussels, where Sturgeon met with European leaders on the margins of a summit to discuss the EU’s response to Brexit (with the U.K. notably absent), she found sympathy for her nation’s plight but no desire to negotiate with Scotland separately from the U.K. government. Given the need for unanimous agreement by all member states, Scotland’s admission to the EU wouldn’t be guaranteed, given concerns from countries like Spain about setting a precedent for their own aspirant regions. However, the Brexit vote has raised the prospect of Scotland’s application for EU membership being fast-tracked, which could make the prospect of saying “yes” to independence in a second vote more tempting.

Should Scotland pursue independence from the U.K., the same thorny questions would arise as in 2014. Scottish nationalists have long cited North Sea oil as part of their economic case for independence; notwithstanding the slump in global oil prices, leaders would need to negotiate how to split the revenues. Similarly, the U.K.’s sole nuclear submarine base is located off the Scottish coast; Scottish nationalists have opposed its presence and called for a nuclear-free country. Brexit would change the terms of separation, however, as an independent Scotland in the EU would presumably need to use the euro (as required of all member states — only the U.K. and Denmark had negotiated opt-outs) and close its border with England (given the Leave camp’s concern with migration).

The impact of Brexit on Northern Ireland is more worrying, as it could trigger renewed tension on an island divided since 1921. The root of the conflict is the constitutional status of Northern Ireland, with the unionist and largely Protestant majority wishing to remain part of the U.K. while the nationalist and predominantly Catholic minority wants to join the Republic of Ireland. After decades of political turmoil and violence (often known as the “Troubles”), the Good Friday Agreement was signed in 1998. It consists of two documents: an international agreement between the British and Irish governments and a multiparty agreement signed by most of Northern Ireland’s political parties. It addresses issues of governance, decommissioning of weapons, civil rights, justice, and policing. Voters in Ireland and Northern Ireland endorsed the agreement in referendums.

Since the agreement, Northern Ireland has largely been moving in the right direction and focusing on mundane questions of governance rather than contentious debates over identity, which has made it a beacon of hope for other protracted conflicts. The EU has made this tenuous peace more viable by eliminating barriers —physical, economic, and psychological — and building cross-border ties between Northern Ireland and the Republic of Ireland, a fact not missed by the 56 percent of voters in Northern Ireland who wanted to remain. Deputy First Minister and Sinn Fein member Martin McGuinness said the U.K. now has a “democratic imperative” to allow Northern Ireland to hold a referendum on whether it should leave the U.K. and unite with the Republic of Ireland. However, First Minister Arlene Foster, the Democratic Unionist leader who campaigned for Brexit, and the U.K.’s Northern Ireland secretary, Theresa Villiers, countered that the criteria for holding a border poll had not yet been met. (The agreement is vague on the criteria, enabling the secretary of state to call a vote “if at any time it appears likely to him that a majority of those voting would express a wish” for a change in constitutional status.) Prime Minister David Cameron reiterated that stance in Parliament on Monday.

There is currently free movement on the island under a common travel agreement that pre-dates the EU, with visitors generally unaware they’ve crossed into another country until they see Gaelic place names, kilometers, and euros. The creation of the EU’s single economic market and Irish peace agreements enabled the dismantling of customs posts, military checkpoints, and army watchtowers. However, the Leave campaign’s cry to block migrants will create pressure for a strong border to prevent Europeans from entering the U.K. via its new EU border. The rebuilding of walls after years spent tearing them down will be psychologically devastating. Given the challenge of policing this border during the height of the Troubles, it is unclear what mechanisms will successfully ensure the lawful movement of persons without triggering memories of the painful past.

In addition to physical barriers, Brexit will complicate cross-border political cooperation. Of particular significance is the North-South Ministerial Council, one of three institutional arrangements created by the Good Friday Agreement (along with an assembly and British-Irish government consultative mechanisms), which enables ministers from Ireland and Northern Ireland to coordinate policies such as agriculture and environment across the island. As the agreement enables those born in Northern Ireland to be a citizen of either — or both — the U.K. and Ireland, there has been a rush on Irish passports in recent days; following Brexit, people in Northern Ireland might be able to enjoy EU travel and employment opportunities that other U.K. citizens will lack.

In both cases, there will be a reckoning with England. Voters in Northern Ireland and Scotland supported continued EU membership by a margin of 10 and 15 percent, respectively, more than those in England, where just 46.6 percent voted to remain. Whereas English and British identities are often seen as synonymous, many in Northern Ireland and Scotland have long juggled their national identities with a sense of “Britishness” (or “Irishness” for some nationalists) and thus more easily accepted an added European layer. (While the Welsh also have a distinct identity, they have never considered political recognition to be as existential an issue. Wales has an assembly with fewer powers and voted in line with England by 53 percent to leave the EU.) For many Scots, the Brexit outcome makes the question of independence a qualitatively different one than two years ago. They no longer see themselves as leaving the U.K. but rather as having been abandoned by their southern neighbors. Similarly in Northern Ireland, many are angry over the perceived failure of the English to take into account the peace dividend brought by EU membership.

None of these questions will be answered overnight, particularly as debate churns over whether and when to invoke the EU clause (Article 50) triggering two years of separation negotiations. In the near term, the U.K. will turn inward as its leaders implement the referendum’s mandate and address its domestic consequences. Whatever the final map, Brexit will have altered not one but two unions

Photo credit: Peter Macdiarmid/Getty Images

Amanda Sloat is a Robert Bosch senior fellow in the Center on the United States and Europe at the Brookings Institution. She is also a fellow with the Project on Europe and the Transatlantic Relationship at Harvard Kennedy School’s Belfer Center. She served in the Barack Obama administration as the deputy assistant secretary of state for southern Europe and eastern Mediterranean affairs, as well as senior advisor to the White House coordinator for the Middle East, North Africa, and Gulf region. Twitter: @A_Sloat

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