Posted by on 06/15/2016

LONDON, UNITED KINGDOM - JUNE 15: A leave supporter is seen as fishing boats campaigning for Brexit sail down the Thames through central London, United Kingdom on June 15, 2016. A Brexit flotilla of fishing boats sailed up the River Thames into London today with foghorns sounding, during a protest against EU fishing quotas by the campaign for Britain to leave the European Union. (Photo by Kate Green/Anadolu Agency/Getty Images)

LONDON, UNITED KINGDOM – JUNE 15: A leave supporter is seen as fishing boats campaigning for Brexit sail down the Thames through central London, United Kingdom on June 15, 2016. (Photo by Kate Green/Anadolu Agency/Getty Images)

Last week in the United Kingdom, the first of two nationally televised debates on Brexit (the proposed British exit from the European Union) aired, with British Prime Minister David Cameron and U.K. Independence Party leader Nigel Farrage taking pointed questions from a studio audience.

Cameron stuck closely to his trump card argument, warning of the costs to the British economy if the “leave” campaign wins on June 23.

But he also sought to reframe a debate about Europe in terms of British patriotism, consistently saying that reform of Brussels was hard work, but Britons aren’t “quitters.” About midway through his presentation, Cameron offered a warning: “Frankly, I do worry about a second Scottish referendum if we vote to leave and you don’t strengthen your country by leading to its break-up. So I’m deeply patriotic. I think this is a case for a bigger, greater Britain inside the European Union.”

He went on to contrast his vision for further reform of the European Union, saying he hoped voters would reject “the Nigel Farage ‘little England’ option” in favour of “a Great Britain.” (Farage is basically what you would get if you combined Basil Fawlty or Mr. Bean with Donald Trump.) That language of “little England” versus “a greater Britain” no doubt spoke to a sense of patriotism throughout England; in Scotland, Northern Ireland and Wales, it was a brilliantly coded message about the United Kingdom being more than just the English majority.

The divisions within the country are striking and broader than most North Americans realize.

Simmering below the surface of the Brexit debate is a sense of great consternation in the smaller countries that make up the United Kingdom. Eric Grenier, writing in the CBC, suggests, “The most consequential division, however, may be between Scotland and the rest of the U.K.,” with support for the EU as high as 58 per cent in Scotland whilst in England, “leave” and “remain” are locked in something of a sea-saw polling battle in the mid-40s.

Having lived, studied and worked throughout the U.K. for the past two years, the divisions within the country are striking and broader than most North Americans realize.

For instance, one woman in Edinburgh confided to me recently that she and her friends think Cameron only called the EU referendum “to punish us for having our Indy Ref,” referring to 2014’s polarizing referendum on Scotland’s independence from Great Britain.

This sense of the English majority forcing the rest of the country to leave the EU, regardless of how Scotland, Northern Ireland and Wales vote, is a legitimate source of irritation across the British Isles.

Indeed, a recent Survation poll found that 60 per cent of Scots believe withdrawal from the EU requires an overall majority vote in each of the four constituent countries of the U.K. Nicola Sturgeon, the Scottish first minister, has said it would be “democratically indefensible” if a majority vote in England forced Scotland to leave the EU.

In Wales, meanwhile, support for Brexit is lower than in England, but not as lopsidedly pro-EU as in Scotland. Leanne Wood, the leader of Plaid Cymru, the Welsh nationalist party, even backed Sturgeon, warning of a “constitutional crisis if English voters were to railroad the rest of the United Kingdom into leaving the European Union,” according to the Telegraph.

Northern Ireland, of course, has the unique worry of potentially managing an actual land border with the EU, should the U.K. vote to leave, with fears such a process risks reversing the progress made since the Good Friday Peace Accords in 1998. The Republic’s Prime Minister, Enda Kenney, calls Brexit “a strategic risk” for the Irish Republic.

Indeed, the Irish ambassador in London has gone so far as to rather publicly call upon some 430,000 Irish ex-patriots in Britain to vote to remain. As far back as January when I was in Dublin, the front pages of Irish newspapers were raising concern over the EU referendum, with the Financial Times summarizing the situation in the Republic as “Ireland frets about a Brexit vote it cannot influence.”

For all the consternation in the smaller countries of the U.K., those in the “leave” campaign, particularly in England, seem blissfully ignorant of concerns from their Scottish, Irish and Welsh compatriots.

An intriguing counter-factual, however, has been raised by Buzzfeed UK: what if the “leave” campaign narrowly wins in England, but the smaller countries overwhelmingly vote to stay, ensuring a narrow win for “remain” across the U.K.?

Canada has dealt with similar issues in our referenda past, with the Clarity Act now allowing for the federal government to enforce the Supreme Court’s dictum, “the Constitution ensures that minority interests must be addressed before proposed changes which would affect them may be enacted.”

(I outlined how a British version of the Clarity Act would be a wise piece of legislation to adjudicate referenda results given the multinational nature of the U.K. in a blog for the Federalist Trust.)

Unfortunately, no such guidelines as our Clarity Act exist for adjudicating a referendum in Great Britain, so expect instead to see increasingly dire warnings about national unity from the “remain” camp to English voters as the polls narrow in advance of the referendum on June 23. In that sense, Cameron’s comments in this week’s televised town hall might represent just an opening salvo.

(Originally published in The Huffington Post.)