Sunday, 1 May 2016

Norway is the Puerto Rico of Europe

Puerto Rico has to obey laws made in Washington, but has no say in shaping them. Sound familiar?

Over the past two years, Puerto Ricans have been reeling from a government debt crisis that is throwing the island into near chaos. But for their fellow American citizens, it has gone largely unnoticed.

The incomparable John Oliver did a segment about the crisis last week, and like a lot of Americans I found myself watching it with a sense of embarrassment. I also hadn't heard anything about the crisis before.

Continental Americans have a disconnected relationship with the American territory to their south. Many do not know that it is part of the United States, and even those that do know often forget.

Puerto Rico has been part of the United States since 1898, when it was wrested from Madrid during the Spanish-American war. Over the ensuing century the other spoils of war - Cuba and the Philippines, gained independence. But Puerto Rico remained a US territory, along with others such as Guam and the US Virgin Islands. Since 1950 Puerto Ricans have been full US citizens.

But there is one important caveat - Puerto Rico is not one of the 50 US states. And because of this, Puerto Ricans cannot vote in US elections. They have no representatives in the US Congress and cannot vote for US President.

This is because there are technically no national elections in the United States. Only individual states organise elections. Even the presidential race is organised through the electoral college, meaning that each state organises an election to determine how its handful of electors will vote. Since 1961 DC has been given three votes in the electoral college. It is the only non-state to have any. 
(This is, incidentally, why us expats have to "pretend" to still live in a US state in order to vote in the presidential election by absentee ballot. It's not possible to vote if you don't feign residence in a particular state, because there is no actual federal vote.)
Other territories that are not part of states also have no representation in Congress. The most notorious example is Washington, DC - the only part of the continental US that is not part of a state. Residents of the nation's capital have no say in the national laws created by congress in their own city.

Yet both Washington DC and Puerto Rico are subject to the federal US laws they have no hand in shaping. They have to pay federal income tax into the US budget and are subject to the whims of decisions by the US Congress, with sometimes disastrous consequences (as detailed by John Oliver in his segment).


In the case of Puerto Rico, all of this has been by choice. Puerto Ricans voted by referendum to maintain their non-state status in 1967, 1993 and 1998. The plurality results in these three referenda are complicated and controversial, and a disputed 2012 referendum added to the confusion. But there has never been a clear vote of public support for the idea of Puerto Rico becoming a US state.

The Norwegian model

Regular readers of this blog probably already see where I'm going with this. To me, the Puerto Rican referendum results of 1967, 1993 and 1998 make about as much sense as the Norwegian referendum results of 1972 and 1994.

In those two referenda, a slim majority of Norwegians voted not to become a member state of the European Union (52% in 1994).

Norway has come to occupy a central place in the Brexit debate, with eurosceptics holding it out as an example of the kind of relationship that the UK could negotiate with Brussels. 

Watching the news about what's been happening to Puerto Rico, I was struck by how similar its arrangement with Washington is to Norway's relationship with Brussels.

Although it is not an EU member state, Norway must still pay into the EU budget and follow EU laws. Along with Switzerland and Iceland, it is in the European Union in all but name. 

The nickname in Brussels for these countries is the 'fax democracies'. Dictates from Brussels go to Oslo, Bern and Reykjavik, and these countries have no way to oppose or shape the laws they're instructed to follow. While EU member states can work to defeat or shape legislation through their representatives in the European Commission, Parliament and Council, the fax democracies have no such representatives.

The governments of all three of the fax democracies have in the past applied to become EU member states. But like the Puerto Ricans, the Norwegian, Icelandic and Swiss voters wanted to preserve the illusion of sovereignty rather than gain greater influence in their own lawmaking.

Yes, the three 'pseudo-EU' states have ring-fenced certain areas of policy in which the EU cannot get involved (for example fisheries for Iceland or banking for Switzerland). But the trade-off for their having access to the EU common market (an economic necessity for them) is that they have to follow the rest of EU law and pay into the EU budget. 

In Norway's case, the country has to follow at least 75% of EU law (and in reality it opts to follow most of the rest). Norway has to pay roughly the same contribution to the EU budget as if it were a full member state.

Puerto Rican businesses have access to the US market. Puerto Ricans can go work in any state of the union without needing to obtain a visa (in the same way that Norwegians can work in any member state of the European Union). In exchange, Puerto Rico has to follow US law. But it's status as only a pseudo-state means that it too is a fax democracy.

Opinion polls have shown that Puerto Ricans are increasingly unhappy with this arrangement, and the current crisis is exacerbating this feeling. Perhaps because they are a poor island that has never been an independent country, they are more conscious of the drawbacks of their situation than are Norwegians, who have had an independent nation state for 110 years.

But the fact remains that the situation for both places is very similar. So in the Brexit debate, perhaps we should start talking about the 'Puerto Rican model' instead of the Norwegian one. 

I have a feeling such a model might sound a lot less appealing to the British public.

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