The National:

THE constitutional challenges thrown up by Brexit are wreaking havoc in Scotland and Northern Ireland. The UK/EU departure energised the demand for independence in Scotland and the Brexit Protocol has brought tension to a tragic level in Northern Ireland.

While there is no quick fix there may be a long-term, win/win solution. By extending the NI Protocol to cover Scotland, the Irish Sea border would move to the Scottish/English border and Scotland, like Northern Ireland, would remain in the EU as part of the UK. This new "Celtic Protocol" could meet the needs of Scotland, Northern Ireland, the UK and the EU in one fell swoop and give both UK nations the best of all worlds.

In Edinburgh, it could satisfy the demands of those seeking Scottish independence who would see the Protocol as a "waiting room" for EU membership. It would also appease Scottish frustration at not being offered the same competitive advantage as Northern Ireland. As both nations voted to remain in the EU, they should be offered the same deal.

The National:

The wreckage of a Translink Metrobus on fire on the Shankill Road in Belfast

In Belfast, it would help calm loyalist concerns over the constitutional status of Northern Ireland by bringing Scotland into the equation. In London, It could serve as a means to mollify calls for Scottish independence by answering Scotland’s call for an arrangement similar to Northern Ireland. In Brussels, it would be seen as a means to stabilise peace in Ireland and finally lay Brexit to rest.

A new Celtic Protocol could have a positive impact on both a political and practical level. In purely logistical terms, the Scottish Border would be easier to police than the Irish border. It covers less than 100 miles with only a few main arterial routes while the Irish border is just over 300 miles long with dozens of crossing points where smuggling could be rife. By shifting the customs border to Scotland, the EU can keep a close check on English, Welsh and other goods entering the single market while Scottish trade with its southern neighbours would be unchecked and unchanged.

Although trade between Scotland and England is greater than its current trade with NI, a Celtic Protocol would protect Scottish industry allowing for a growth in exports travelling freely into the EU single market from Cairnryan to Larne to access a European market of more than 450 million consumers. This would be valid not only for the fishing industry but also for specialised exports, such as Scotch whisky. There is no doubt England and Wales would be at a disadvantage but, as the two nations which supported Brexit, they could look to the global opportunities which were promised.

READ MORE: Brexiteers bear sole responsibility for the chaos in Northern Ireland

Once the Celtic Protocol is in place and properly implemented, trade between England, Wales and elsewhere moving from Liverpool to Belfast would still need to be checked - but this could be done using sealed containers differentiating between NI-only goods and those destined for Ireland and beyond. As "exports", only the goods destined for Ireland would be checked in Belfast which would allow the NI-only goods to move freely and greatly reduce the need for large-scale customs operations at the port. Goods could also travel directly to Dublin from both Cairnryan and Liverpool.

In political terms, from the viewpoint of London, if the NI Protocol was extended to include Scotland, the Scots may be less inclined to want to go their own way. As the independence debate was galvanised by Brexit, this compromise may serve to reduce those demands and might even be regarded as a goodwill gesture from London. From the standpoint of those pushing for Scottish independence, the Protocol would allow the nation to retain EU rules and regulations and prepare an independent Scotland for a lengthy less radical change to become the 28th member of the European Union.

In Northern Ireland, the political consequences of Brexit are much higher risk. The border controversy has been at the heart of the Brexit process since the start. Fears that the stability of the peace process was at risk have been justified by rioting on the streets of Belfast and beyond. Those of us who lived through 30 years of "troubles" know only too well how far this can escalate.

The National:

There is a tragic irony to the story of Brexit that too few in the Unionist community are prepared to admit. The simple truth is that the UK/EU departure meant there had to be a customs border somewhere to protect the EU single market. The most likely place was the island of Ireland but, without a virtual iron curtain along the Irish border, there could be no way the EU could protect the integrity of its market. Checks on goods entering Northern Ireland by sea appeared to be the only answer. This was the thinking that led to the creation of the NI Protocol.

The sad reality was the Irish were seen to have won their case against a hard border in Ireland by using the risk of the eruption of violence as justification. The loyalist community saw no reason why moving the border to the Irish Sea would not also be seen to risk the eruption of violence. In spite of their warnings, the Protocol was put in place and trade between the two was disrupted. Loyalists felt Northern Ireland was cut adrift from the rest of the UK and their Britishness was being diluted by the Protocol while the Irishness of those who had won their case was enhanced.

If the UK and the EU agreed to extend the Protocol to cover Scotland, the "border" would be moved from the Irish Sea to the dividing line between Scotland and England. This would change the perception of Northern Ireland being cut adrift and divert the constitutional narrative away from a contested space to a new customs border where there is unlikely to be serious political friction. The history of grievance over the Scottish frontier is long past. If Brussels, London, Edinburgh and Belfast were willing to take the risk for peace, the Scottish solution may be the answer.

READ MORE: It seems there's a leadership vacuum as violence returns to Northern Ireland

The the fact that the Protocol entitles these nations to benefit from EU trading arrangements while remaining within their home country, serves to reduce the desire for independence or Irish unity. In the case of Northern Ireland, the demand for a referendum on a united Ireland would have been much stronger in the event of a hard Brexit. As it now stands, the Protocol has served to assure NI’s position in the UK for the foreseeable future, making space for the time needed for an in-depth debate on its constitutional position.

An interesting debate has begun on the coming together of Scotland, Ireland and Northern Ireland (SCINI) in a "Celtic Association" similar to the Benelux countries which founded the EU. A Celtic Protocol could help prepare that process. In economic, social and cultural terms, it could help boost the region’s tremendous renewable energy potential in advance of the global climate conference in Glasgow. It could also serve to regenerate age-old links between Scotland and Ireland, particularly the Ulster/Scots connection and the relationship with American Presidents. This would bring the US further into the equation, alongside the EU in a vital new partnership which could compliment the East/West/North/South, UK/Ireland, unionist/nationalist balance set out in the equality provisions of the Good Friday Agreement.

Always reluctant to interfere in the internal politics of a nation, the EU could not stand accused if the request for the Celtic Protocol came directly from both London and Edinburgh. There may be concerns that other EU regions, such as Catalonia or Corsica, would want to follow suit but the UK departure from the EU has set a precedent which is unlikely to be the case for other member states. If the Celtic Protocol doesn’t solve the problem, there could be another way. With the tide of UK public opinion turning in favour of rejoining the EU, a second referendum may put Brexit to bed for once and for all. With the Protocols in place, Scotland and Northern Ireland would be the first in the queue.