FORMER Communities Secretary Alex Neil MSP is surely right. Brexit will create a whole new scenario for an independent Scotland, including the prospect of different trading conditions and some border checks with our nearest neighbour. Of course, Ireland, Britain and Northern Ireland will have crossed that bridge in a fairly consensual way before we ever reach it – hopefully providing a useful precedent.

But agreed. If England is out when iScotland heads back into the EU, there will be difficulties.

Yet quite apart from the fact the supposed status quo is hardly problem-free itself, there’s another big thing to say.

No-one’s talking about the biggest upside of the new, more complex post-Brexit situation – a possible bidding war between the two big European trade blocs for iScotland’s membership.

Once Britain has actually withdrawn from the EU, it’s likely that they and the smaller trade bloc EFTA will approach Scotland offering rival membership deals in the event of a vote for independence second time around.

Senior officials in Iceland have openly discussed the many advantages of having Scotland as a new member of the EFTA halfway house, thereby creating a powerful bloc with three contiguous North Atlantic states controlling vital sea routes, fishing grounds, oil and gas fields and a vast wind, marine and geothermal renewable energy resource.

Last year, academics at the Oxford conference on Rewriting the UK Constitution predicted the EU would make an offer to the Scottish Government once Brexit finally happens and there’s no further risk of offending Britain by wooing the Scots instead. And why wouldn’t the EU want us? Regaining five million generally progressive, pro-EU citizens in the wake of Britain’s acrimonious departure would be an important boost to the European project.

Correspondingly, any competition between EFTA and the EU for Scotland as a member would enhance the appeal of independence here and increase the demand for another referendum.

So, the EU or EFTA – which path to choose? Alex Neil favours EFTA.

This option was first substantially aired at a Nordic Horizons event held after the Brexit vote and enlarged upon in McSmörgåsbord, written by our Nordic speakers and co-edited by myself and the late Edinburgh University academic Paddy Bort.

The European Free Trade Association (EFTA) is an intergovernmental organisation, established in 1960, which has never envisaged political integration. It doesn’t issue legislation like the EU nor has it established a customs union. Ironically, that’s one reason most of its original seven founding members – including Britain – jumped ship in the 90s to join the more ambitious trade bloc that became the EU.

Today EFTA has just four member states – Iceland, Liechtenstein, Norway and Switzerland – and 26 free trade agreements covering 36 partner countries worldwide. So, they’re doing a lot better than poor bilateral deal-free auld Blighty.

The European Economic Area (EEA) is the mechanism that extends the EU’s internal market to EFTA’s three participating states – Switzerland decided not to join. It doesn’t require EFTA members to observe common EU policy frameworks on agriculture, fisheries, trade, foreign affairs, security and justice, harmonised taxation, the customs union, the Schengen agreement or the economic and monetary union. But it does give them access to the EU’s 500 million consumers.

EU access without EU institutions – but only up to a point.

EFTA member Norway abides by more EU regulations than full EU member Sweden. Indeed, some Norwegians refer to the EEA (regulations without participation) as the Nike deal – just do it! Still, a recent poll found only 18% of Norwegians would prefer full EU membership and no deal isn’t considered an option.

So, the halfway house lumbers on.

It’s not ideal, but it’s good enough for Norway.

Would it also be good enough for iScotland?

Of course, fishing is a much smaller part of Scotland’s economy, and Norway’s never been a full EU member, so it doesn’t miss what it never had. Scots, by contrast, have been EU members for more than 40 years and voted clearly to remain inside the EU in 2016.

So how to decide?

The clear lesson from the Nordic Horizons event is that each state must craft the relationship with the EU that best suits its own circumstances. So, Finland’s enthusiastic membership of both the EU and euro is explained by its geopolitical location – in the shadow of the Russian bear. The Finns have a constitutional bar on joining Nato to try and counter any Russian fears they might become a landing pad for American troops. The Finns’ fervent hope is that EU solidarity is a substitute for Nato membership. Some think that’s naïve; others point to EU’s recent support for Ireland during its Brexit battles with the UK. Whatever, full EU membership works for the Finns.

But Finland wouldn’t dream of suggesting that Iceland should follow suit, because the Icelandic economy is so dependent on fishing and Russian proximity is a much smaller concern.

Indeed, Denmark couldn’t impose EU membership on the Faroes and Greenland when it joined in 1973, because the fishing-dependent Faroese have been able to sign international treaties since 1946, when islanders voted narrowly for independence and extracted the world’s most powerfully devolved parliament from a shaken Copenhagen.

This is the kind of mutual respect and common sense that enters international relations once dogma and a sense of overweening ownership have been removed.

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So, what can Scotland learn from our Nordic neighbours?

Is Finland’s position analogous to Scotland which also sits beside a larger and more powerful nation? Just how important is our fishing sector compared to Iceland and Norway? What works best for Scotland dealing with a completely Brexited England and what do the Scottish people actually want?

Well Norway Plus – as EFTA was described when it became a last-gasp destination for the whole UK – is a perfectly viable option for us.

IT’S true that the three small member countries were hardly delirious about the prospect of their arrangements being upended by the stomping and opportunistic arrival of a panicking UK in 2018.

In March of that year, another Nordic Horizons event heard Professor Christophe Hillion, of the Centre for European Law at Oslo University, explain that Norwegians feared the UK Government would negotiate opt-outs from EEA rules – such as free movement of people – as they bulldozed their way in. He said such moves would “rock the boat” and risk making arrangements “dysfunctional” for the EFTA Three.

But Hillion didn’t envisage the same hurdles facing an independent Scotland because Scotland essentially “gets” co-operation and supports the benefits of single market participation.

He said: “There is some level of scepticism about UK accession to the EEA. It could be very different in the case of Scotland – not simply because Scotland is a smaller country, but because a majority voted Remain and thus to be part of the single market. So, the general attitude and circumstances are different between where the UK is coming from and where Scotland is coming from.”


It might well be possible for iScotland to devise a relationship with Scandinavia, the EU and rUK which no-one has yet charted – a dash of haggis on the smörgåsbord.

Many things are possible when we start examining the experience of other neighbours with a wealth of recent trade and relationship-building experience and then focus on which option serves the best interests of Scotland.

So, let’s not get bogged down in the difficulties.

Life is difficult.

And no party should be fearful of opening up the EU v EFTA debate.