There is a little-discussed Danish quirk of the European Union, which goes like this: the Kingdom of Denmark is a member of the EU. Greenland and the Faroe Islands are self-governing countries within the Kingdom of Denmark. Greenland and the Faroe Islands are not members of the EU.
This is largely a matter of fish. Both countries have historically depended heavily on the fisheries, and the prospect of uncontrolled Spanish, Portuguese or (insert Atlantic-coastal EU country here) trawlers off their coasts was too much to bear. Ireland, of course, knows a thing or two about that. Thus the Faroes secured an opt-out from what was then the EEC when Denmark joined in 1973. Greenland followed by leaving in 1985.
Faroese and Greenlanders carry their own passports: they bear the Danish crown, but read "Føroyar" or "Kalaallit Nunaat" above "Danmark." In this way they look like the passports that the UK issues to residents of the Isle of Man or the Channel Islands. Unlike those, though, the Greenlandic or Faroese documents are not EU passports.
EU flexibility
This gives a sense of the degree to which arrangements about EU membership are in practice more flexible and multifarious than many realise. One way to arrive at a solution that respects the will of
Scotland
and
Northern Ireland
to determine their own fate with respect to Brexit might be for the big country (England) to sit outside and the two smaller ones to stay in.
My suggestion, despite the exotic northern locales involved, is born of pragmatism. The will of the people of Northern Ireland and of Scotland to stay in the European Union is a democratically expressed certainty. The best way to ensure this expression is honoured is to deal with it directly, not to attach it to separate questions about independence or reunification. Both the EU (via Greenland and the Faroes) and the UK (via the Isle of Man or the Channel Islands) have a track record of dealing with this kind of variability.
Make it work
Now is the time for everyone to take a deep breath, put aside dismissive attitudes about places like Greenland and the Faroes being too small to really mean anything to anybody. We must think hard about new ways multistate federations like the EU can engage with multinational states like the UK. That is, if the UK really has the will to remain a multinational state.
Jerry White is Canada research chair in European studies at Dalhousie University in Nova Scotia