As Brexit unfolds in the British and European media, the two of us have been increasingly struck by how this could have been Canada if that slim majority of Québec citizens had voted to leave Canada in the 1995 referendum. Many of you will remember that October day over twenty years ago: the decision to have Québec remain in Canada (‘no’ to sovereignty) carried by a very slim majority of only 54,288 more votes than those who voted yes; or 50.58 per cent of the voters.
In both the Québec and the UK referendums there was an unclear question and a low approval threshold ─ accepted as 50 per cent plus one on a matter of tremendous significance. In most jurisdictions constitutional decisions would require at least a 2/3 majority but neither of these historic cases demanded a larger majority. The Government of Canada soon corrected that mistake with a Supreme Court reference and the 2000 Clarity Act establishing the conditions under which it would enter into negotiations with any province wishing to leave.
To this date it has remained unclear why David Cameron’s British Conservatives took the risk to be so negligent with the 2016 Brexit referendum process. We cannot understand why they did not look to Canada’s near death 1995 experience for guidance and thus any lessons that could have been learned prior to holding the referendum.
Looking to the Canada experience is important because there are so many similarities between the United Kingdom (UK) and Québec and their historic place in their respective unions. Both consider themselves as ‘exceptional’ and ‘unique’. They have almost always had one foot out the door. ‘Asymmetrical’ arrangements were routinely required to meet their unique needs.
Now that the UK is preparing to leave (with 51.9 per cent of participating citizens voting to leave the EU in their June 23, 2016 referendum) both sides are dealing with exactly the same questions that Québeckers and Canadians woure power across a range of issues. It required constitutional agreement between the constituent units to form the larger unions in the first place: Canada through the 1867 British North America Act and the EU through its various treaties, starting with the 1951 Treaty of Paris all the way to the 2007 Treaty of Lisbon.
We thought we would take the analogy one step further and try and match up the other provinces and EU member states for the sake of argument. Our main criterion was the provinces’/member states’ political culture in terms of their respective attitudes towards the centre (that is respectively the Government of Canada and the European Commission/Council), as well its population and relative economic ‘weight’ in the union in terms of share of Gross Domestic Product (GDP).
and are among the most left leaning parts of the union. While they see themselves as being ‘different’ from the others, unlike Québec and the UK their self-perceived ‘difference’ does not lead the government of the day to contemplate actually leaving the union.
Now it gets trickier. We might think of Alberta as Poland. Both have relatively large populations and see themselves as standing up to the centre and providing leadership in their regions. Saskatchewan could be seen as the Canadian Italy. In both there have been changeable politics over time and significant financial problems buffered by being part of the larger union. Manitoba and Austria share many similarities, being geographically in the centre of the political entity and acting as a mediator between the other players.
Because the EU has more member states than Canada has provinces, we have lots of choices for Atlantic Canada. Ireland and Newfoundland and Labrador have many things in common besides a shared heritage and the fact that both are islands that are geographically located at the periphery. New Brunswick and Nova Scotia may resemble Belgium and the Netherlands; all were there at the start of the union and remain quietly committed. Prince Edward Island could be like Malta – the smallest EU member state. Even though their populations are small, they have all the powers of the largest players, Ontario and Germany.
Why are we doing this? It is because we want Canadians (and Europeans) to think about the salience of comparing Canada to the European Union. Comparison is invaluable as it shines a light on one’s own practices and provides ideas that might not otherwise be considered. On both sides of the Atlantic the usual comparator that often comes to mind is the United States (US). But the US federal political system and value base do not bear the same similarities as those of Canada and the EU.
And these Canadian and European values will only grow closer with the implementation of the Comprehensive Economic and Trade Agreement (CETA) and the Strategic Partnership Agreement, not to mention the fact that the current politics of the day in the US under President Donald Trump seem to be in a league of their own.
Canada and Québec dodged a bullet in 1995 when Québec citizens decided to stay in the Canadian federation. Twenty years later Canada is a stronger albeit much more decentralized country. Yet Québec no longer wants to leave. The United Kingdom and the European Union negotiations are still in the early stages. The next couple of months will prove to be key as Theresa May’s Conservative government spells out its objectives and the European Commission solidifies the EU’s negotiation position. As Canadians we can only sit back and watch from the sidelines. Hopefully this note will help improve our collective understanding, on both sides of the Atlantic, as to what is at stake.
(with permission from the new Blog The Welfare Maters...https://donnaewood.wordpress.com/blog/)