Two photos speak volumes about the striking similarity between Hong Kong and Puerto Rico, one an island and peninsular former colony of Britain, which conquered and held onto it since the Opium War in 1841, now returned to China, but still existing in a kind of neo-colonial relationship to that country, the other an island colony of the United States ever since the US conquered it from Spain during the 1898 Spanish-American War. Both places today contain hundreds of thousands, even millions of angry citizens demanding freedom and a right to control their own destiny.

The two photos, showing hundreds of thousands of protesters in the street demanding the resignation of their respective leaders, Chief Executive Connie Lam Jehng Yuet-ngòh in Hong Kong and Governor Ricardo Antonio Rosselló Nevares in Puerto Rico, are equally astonishing displays of raw citizen activism by people in the position of colonial subjects fed up with the corruption and subservience of their compromised puppet leaders, and with the governments that are controlling them in Beijing and Washington, DC.

Hong Kong, for nearly two centuries a colony of Britain — one in which for most of that time racist British officials lorded it over Chinese people who were often banned from government positions, restaurants and elevators, humiliated and prevented from gaining residence in the “mother country” — is now a kind of “colony” of China. The territory, now euphemistically called a Special Administrative Region of China, technically has local autonomy and a legal system based on British Common law, but it is ultimately subordinated to the government of China in Beijing, with its laws trumped by Chinese law, particularly when it comes to national security issues. Puerto Rico, a Spanish colony dating almost back to the 1492 arrival of Christopher Columbus until the end of the Spanish-American War, later became a colony of the US. The relationship of the island to the US remains a colonial one, though the name in 1952 was euphemistically changed to “Commonwealth” of Puerto Rico, or in Spanish the Estado Libre Asociado de Puerto Rico.

In Hong Kong, local citizens elect half the members of their Legislative Council (Legco), with the other half chosen by so-called “functional constituencies” — basically various professions from lawyers to bankers to industrialists and labor. The successor to the British colonial governor is now the Chief Executive. Where the governors were appointed by the British government, the new top position in Hong Kong is filled by Beijing, which hand-picks a selection panel of some 1000 people for the purpose. In Puerto Rico, the people on the island get to elect their legislature and their governor, but they have no elected representation in the US Congress.

In both Hong Kong and China, the residents of these places were declared citizens of the “mother country” — China in Hong Kong’s case in 1997, the United States in Puerto Rico’s case in 1917 — whether they wanted to be citizens or not. But in both cases it is a citizenship of a peculiar sort. Hong Kong residents cannot just move into and out of China freely, and have little say on the Chinese government’s policies affecting Hong Kong. Puerto Ricans have full US citizen rights if they move to the continental US, but when they are in Puerto Rico, they have no right to vote in US elections, don’t receive the same government benefits, and receive, as we saw in the wake of the disastrous 2017 hurricane season, far less in government aid than any state would get.

In both places, things have gone reasonably smoothly when the economy has been humming, but when times get harder, the heavy hand of the “mother country” — whether in Beijing or Washington — and the incompetence, corruption and basic political weakness of the local leadership leads to frustration and anger among the public.

In Hong Kong, we’re seeing this frustration and anger in the incredibly huge demonstrations — as many as two million in a city of eight million people recently —calling for everything from the resignation of Chief Executive Lam to outright independence from China. The spark that ignited this month-long series of massive demonstrations and marches was an annual commemoration of the 1989 June 4 violent crackdown by the Chinese People’s Liberation Army on student and worker demonstrators in Beijing, which morphed into broad protest against a proposed new law introduced by Lam that would for the first time allow for the extradition of people wanted for prosecution in China, including for political “crimes.”

Puerto Rico for its part was devastated by two back-to-back disasters over the past decade, one economic and one natural. The first, a man-made disaster, was the elimination by Congress of a federal tax incentive program under which Puerto Rico was able to lure US companies to shift production facilities there and escape federal taxation. Ending that tax break caused many big employers to flee the Puerto Rico and that gutted the island’s tax revenues. That forced Puerto’s “commonwealth” government and many of the island’s municipal governments to turn to massive borrowing, in order to make of for the lost revenue, and then to find themselves unable to continue making the payments when interest rates rose. As revenues vanished, so did many professionals from doctors to teachers. Then came a natural disaster: a one-two punch by two huge, record hurricanes, first Irma which struck San Juan and the north coast, and then Maria, a Category 5 storm which hit the island head-on, crossing the entire island and causing massive destruction, over 3000 deaths and leaving roads and electricity out for months across the entire island. To make matters worse, Congress, instead of bailing out Puerto Rico, or allowing the island and its cities to declare bankruptcy to escape their debts, passed a law creating a Financial Control Board, composed primarily of Wall Street bankers, whose goal has been keeping the lenders whole.

In Hong Kong’s case, China, during its negotiations with the British as their lease on most of the territory of Hong Kong was due to expire in 1997, promised to honor the degree of democracy achieved through long struggle by Hong Kong’s residents of the British colony, and even to expand it, leading eventually to a Legislative Council (Legco) fully elected on the basis of popular vote and to an elected, not appointed Chief Executive Officer, subject to “conditions” in Hong Kong. China also promised “50 Years No Change” in Hong Kong’s laws and freedoms. But those promises, especially for increased electoral democracy, were quickly broken in the years that followed.

Britain, violating an agreement on pre-handover developments negotiated with China in 1984, once it knew it was being ousted in 1997, moved to make the 70-member Legco members all fully elected by universal suffrage in 1995, two years before China would assume sovereignty over the territory, so. (This was after decades of bitterly opposing democracy in its colony.) China responded to this deliberate move by Britain to hand over a fully democratic fait accompli, by terminating the whole elected body on the night of the handover on July 1, 1997, replacing it by a group all hand-picked by Beijing in 1997. Gradually, China has subsequently allowed an increasing number of elected members to the council, with half the members (35) now elected by universal suffrage from geographic districts. But the other 35 still represent so-called “functional constituencies,” as was the case under the British before 1995. These functional constituencies are industrial, commercial, banking, legal and other occupational groups, including labor, which elect representatives from their leadership or membership. In the end, the current system allows Beijing to maintaining a working majority of supporters of its policies on the Legco. The territory’s chief executive, who was supposed to eventually be elected by citizens of Hong Kong by this point, remains appointed by Beijing, Lam being the fourth and current holder of the top position.

In Puerto Rico, the US military ruled the island with an iron fist for almost two decades following its capture from Spain. Then, under pressure from independence activists who had been pressing for more local control since having the dream of independence from Spain ripped away following the conclusion of the Spanish-American War, Puerto Rico was gradually given some local governance powers. In 1952, the colony of Puerto Rico was granted “local autonomy” and the right to elect its legislature and its governor (this was largely a propaganda gesture motivated by the Cold War, as the US tried to avoid being cast as a “colonial power” in an era of national liberation movements around the globe). But Puerto Rico has remained, like Hong Kong half a world away, with only a crippled and pinched “autonomy.” Just as Hong Kong’s government is severely constrained in what it can do by what Beijing will allow, in Puerto Rico, Congress has the absolute authority to override any law passed by the island legislature, the federal court system oversees and can over-rule local courts, and an appeals court, The Court of Appeals of the First Circuit, in Boston, handles any appeals of Puerto Rican federal district court rulings. And of course the US Supreme Court has the final say over Puerto Rican court rulings.

The similarities between Hong Kong and Puerto Rico carry over to their future. While some in Hong Kong may long to be an independent city state like Singapore, it seems like a pipe-dream. China will never allow the wealthy port city of Hong Kong to go its own way, nor could any foreign power ever succeed in wresting it away from China.

Likewise Puerto Rico seems doomed to remain a US colony. Efforts at rebellion in the past were quickly crushed by the US military which has a heavy presence on the island. And while there is strong emotional support for independence, and also strong support for going in the other direction and seeking to become the 51st state, neither of those options seems likely either. Independence has a hard slog, since so many people on the island manage to survive because of the meager welfare benefits — especially Food Stamp assistance — which they receive from the US. Many also have family spread out across the US, and would not want to be cut off from them by independence. At the same time, statehood, which would produce a new state with five new members of the US House of Representatives, and two US Senators, all or most of whom would be reliably Democratic, would be a hard sell in a Congress where Republicans and Democrats are fairly close in number. The US Constitution doesn’t specify any procedure for admitting a new state but by tradition it has required a majority vote by the local population, and a petition to be admitted as a state, and then a majority vote by both houses of Congress.

Republicans would likely oppose Puerto Rican statehood or might include a measure insisting that the official language of the new state be English, a rider which would cause huge dissension on the Island, perhaps preventing a majority popular vote for statehood.

We can certainly expect more unrest in both places as time goes by, as the citizens of both Hong Kong and Puerto Rico endure the continued humiliation of colonial or quasi-colonial status under the thumb of remote central governments a thousand miles away. The astonishing numbers we see on the street in both places prove that these are not “manufactured” events being manipulated by outside agents.

And despite the almost insurmountable odds against independence for either place, I will say this: As someone who lived in Hong Kong for five years (and China for one and a half), and as someone who also knows a good deal about Puerto Rico’s struggle against Spanish and US colonialism, and about the passion of this small island’s people for their language, culture, and history, I can confidently predict that the struggle for political agency and for at least cultural independence in both places will continue, and perhaps even grow in strength.