An independent Scotland could look like a wee Canada

The closest parallel between Scotland and anywhere else is not Quebec, Ireland, Iceland, or Norway, but Canada.

Comparing a future independent Scotland to other places is all the rage. Visions of Scotland as a new Ireland or new Iceland have come and gone, their reputations as thriving small countries shredded by banking meltdowns and financial collapses. Comparisons with Nordic states are ongoing but sometimes require a shoehorn to make them fit.

The recent ‘Edinburgh Agreement’, which laid the groundwork for a referendum on Scottish independence in 2014, has unleashed a fresh set of comparisons - this time between Scotland and other places with independence movements.

Foremost amongst these is Quebec which is deemed to be similar to Scotland because it has already experienced independence referenda. However, the independence movement in Quebec differs from that in Scotland in at least two fundamental ways: creating a new country is not the same as restoring the independence of an old one and Scotland has no equivalent of the language issue that was so definitive in Quebec.

From a Scots-Canadian perspective the closest parallel between Scotland and anywhere else is not Quebec, Ireland, Iceland, or Norway, but Canada. Indeed, it is Groundhog Day for people like me who lived in Canada for many years and live in Scotland now.

Scottish government rhetoric in favour of multiculturalism and immigration distinguishes it from other parts of the British body politic, but is very familiar to Canadian ears. Ditto a recent consultation on gay marriage which unleashed exactly the same apocalyptic arguments against it that were heard in Canada before it was legalised there in 1995. Ditto the headline debate at the last Scottish National Party conference which confirmed party policy on withdrawing nuclear weapons from Scotland but voted in favour of membership of NATO. That debate raged in Canada from the 1960s until the squadron at Comox on Vancouver Island flew the last nuclear weapons back to the United States in 1984, leaving Canada a non-nuclear member of NATO.

This paralleling of the Canadian experience in Scotland has gone largely unnoticed on both sides of the Atlantic. Here comparisons between Scotland and Canada tend to be seen as historical rather than contemporary; in Canada anything with the words ‘independence’ or ‘referendum’ attached to it is viewed through the prism of Quebec.  

However, there is something going on, even if it is subliminal. It’s almost de rigueur for Scottish politicians to use the saying "Work as if you lived in the early days of a better nation" and attribute it to Scottish writer Alasdair Gray. In fact, Gray paraphrased it from a line in Canadian Dennis Lee’s iconic poem ‘Civil Elegies’: "And best of all is finding a place to be/in the early days of a better civilization". The real interest for Scotland, however, lies not in the attribution but in the context of Lee’s original poem.

‘Civil Elegies’ was published in the late 1960s and again in the early 70s when Lee was concerned about Canadian identity and the possibility that Canada would simply replace one form of cultural hegemony (British) with another (American). Happily for Lee (and Canada generally) this was one of those rare occasions when cultural and political interests conflated. Canadian Prime Minister Pierre Trudeau was busy reinventing Canada as a European-style social democracy with a unique maple leaf twist. Replace maple leaf with thistle and you have a serviceable description of where Scotland is fifty years later.

So rather than see the independence issue in Scotland as just another version of Quebec, it looks to me a lot more like the ‘small ‘n’’ Canadian nationalism of the 1970s onward: welcoming, inclusive, peaceful. Ironically, Scotland’s pursuit of this vision could see it pass Canada going in the other direction. Unusually, perhaps uniquely, certain sections of the liberal British press which once held Canada in the highest esteem are now openly accusing its right-wing government of deserting the principles that made it great.

For now though, it is all about precedents. From smoking bans to gay marriage to national literature in school curricula to minimum alcohol pricing, where Canada goes Scotland eventually follows where it can. The big vision stuff is another matter.  It’s tough to build Canadian style multiculturalism without the ability to adapt your own immigration policy to that end as Trudeau did; tougher still to rid your territory of nuclear weapons without any power over foreign affairs.

The inclination to compare Scotland with Quebec occludes the fact that Canada had its own gradual process of disengagement from the United Kingdom to undergo before it could re-engage with the world on its own terms. This was only completed in 1982 with the patriation of Canada’s constitution from Westminster and the creation of a Canadian Charter of Rights and Freedoms. Canada’s refusal to join the United States and the UK in an unsanctioned invasion of Iraq in 2003 was one notable assertion of its free will.

Scotland's First Minister and Scottish National Party leader Alex Salmond attends a Commonwealth Games event at Glasgow Airport. Photograph: Getty Images.

Harry McGrath is the online editor of the Scottish Review of Books and a former Coordinator of the Centre for Scottish Studies at Simon Fraser University in British Columbia.

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The 11 things we know after the Brexit plan debate

Labour may just have fallen into a trap. 

On Wednesday, both Labour and Tory MPs filed out of the Commons together to back a motion calling on the Prime Minister to commit to publish the government’s Brexit plan before Article 50 is triggered in March 2017. 

The motion was proposed by Labour, but the government agreed to back it after inserting its own amendment calling on MPs to “respect the wishes of the United Kingdom” and adhere to the original timetable. 

With questions on everything from the customs union to the Northern Irish border, it is clear that the Brexit minister David Davis will have a busy Christmas. Meanwhile, his declared intention to stay schtum about the meat of Brexit negotiations for now means the nation has been hanging off every titbit of news, including a snapped memo reading “have cake and eat it”. 

So, with confusion abounding, here is what we know from the Brexit plan debate: 

1. The government will set out a Brexit plan before triggering Article 50

The Brexit minister David Davis said that Parliament will get to hear the government’s “strategic plans” ahead of triggering Article 50, but that this will not include anything that will “jeopardise our negotiating position”. 

While this is something of a victory for the Remain MPs and the Opposition, the devil is in the detail. For example, this could still mean anything from a white paper to a brief description released days before the March deadline.

2. Parliament will get a say on converting EU law into UK law

Davis repeated that the Great Repeal Bill, which scraps the European Communities Act 1972, will be presented to the Commons during the two-year period following Article 50.

He said: “After that there will be a series of consequential legislative measures, some primary, some secondary, and on every measure the House will have a vote and say.”

In other words, MPs will get to debate how existing EU law is converted to UK law. But, crucially, that isn’t the same as getting to debate the trade negotiations. And the crucial trade-off between access to the single market versus freedom of movement is likely to be decided there. 

3. Parliament is almost sure to get a final vote on the Brexit deal

The European Parliament is expected to vote on the final Brexit deal, which means the government accepts it also needs parliamentary approval. Davis said: “It is inconceivable to me that if the European Parliament has a vote, this House does not.”

Davis also pledged to keep MPs as well-informed as MEPs will be.

However, as shadow Brexit secretary Keir Starmer pointed out to The New Statesman, this could still leave MPs facing the choice of passing a Brexit deal they disagree with or plunging into a post-EU abyss. 

4. The government still plans to trigger Article 50 in March

With German and French elections planned for 2017, Labour MP Geraint Davies asked if there was any point triggering Article 50 before the autumn. 

But Davis said there were 15 elections scheduled during the negotiation process, so such kind of delay was “simply not possible”. 

5. Themed debates are a clue to Brexit priorities

One way to get a measure of the government’s priorities is the themed debates it is holding on various areas covered by EU law, including two already held on workers’ rights and transport.  

Davis mentioned themed debates as a key way his department would be held to account. 

It's not exactly disclosure, but it is one step better than relying on a camera man papping advisers as they walk into No.10 with their notes on show. 

6. The immigration policy is likely to focus on unskilled migrants

At the Tory party conference, Theresa May hinted at a draconian immigration policy that had little time for “citizens of the world”, while Davis said the “clear message” from the Brexit vote was “control immigration”.

He struck a softer tone in the debate, saying: “Free movement of people cannot continue as it is now, but this will not mean pulling up the drawbridge.”

The government would try to win “the global battle for talent”, he added. If the government intends to stick to its migration target and, as this suggests, will keep the criteria for skilled immigrants flexible, the main target for a clampdown is clearly unskilled labour.  

7. The government is still trying to stay in the customs union

Pressed about the customs union by Anna Soubry, the outspoken Tory backbencher, Davis said the government is looking at “several options”. This includes Norway, which is in the single market but not the customs union, and Switzerland, which is in neither but has a customs agreement. 

(For what it's worth, the EU describes this as "a series of bilateral agreements where Switzerland has agreed to take on certain aspects of EU legislation in exchange for accessing the EU's single market". It also notes that Swiss exports to the EU are focused on a few sectors, like chemicals, machinery and, yes, watches.)

8. The government wants the status quo on security

Davis said that on security and law enforcement “our aim is to preserve the current relationship as best we can”. 

He said there is a “clear mutual interest in continued co-operation” and signalled a willingness for the UK to pitch in to ensure Europe is secure across borders. 

One of the big tests for this commitment will be if the government opts into Europol legislation which comes into force next year.

9. The Chancellor is wooing industries

Robin Walker, the under-secretary for Brexit, said Philip Hammond and Brexit ministers were meeting organisations in the City, and had also met representatives from the aerospace, energy, farming, chemicals, car manufacturing and tourism industries. 

However, Labour has already attacked the government for playing favourites with its secretive Nissan deal. Brexit ministers have a fine line to walk between diplomacy and what looks like a bribe. 

10. Devolved administrations are causing trouble

A meeting with leaders of Scotland, Wales and Northern Ireland ended badly, with the First Minister of Scotland Nicola Sturgeon publicly declaring it “deeply frustrating”. The Scottish government has since ramped up its attempts to block Brexit in the courts. 

Walker took a more conciliatory tone, saying that the PM was “committed to full engagement with the devolved administrations” and said he undertook the task of “listening to the concerns” of their representatives. 

11. Remain MPs may have just voted for a trap

Those MPs backing Remain were divided on whether to back the debate with the government’s amendment, with the Green co-leader Caroline Lucas calling it “the Tories’ trap”.

She argued that it meant signing up to invoking Article 50 by March, and imposing a “tight timetable” and “arbitrary deadline”, all for a vaguely-worded Brexit plan. In the end, Lucas was one of the Remainers who voted against the motion, along with the SNP. 

George agrees – you can read his analysis of the Brexit trap here

Julia Rampen is the editor of The Staggers, The New Statesman's online rolling politics blog. She was previously deputy editor at Mirror Money Online and has worked as a financial journalist for several trade magazines.