In its 5,000 word submission, the Church expressed its continued opposition to the imposition of this legislation and restated its view that matters relating to abortion provision should be respected as devolved issues. It also states its concern that the proposals take a ‘maximalist’ approach to the implementation of legislative requirements and that in the rush to eliminate barriers to access to abortion services, essential safeguards, which provide protection for women and girls, are being removed.
In making its submission the Church, said that it is ‘well aware of the deep human tragedies that lie behind all crisis pregnancies’. It also stated that the issue was not simply ‘a theological or academic exercise for the Church’, as many of its ministers, and others in congregations, ‘had journeyed alongside women and families who have experienced a pregnancy crisis and have been presented with difficult decisions.'
With regard to medical and health professionals who will be directly affected by the introduction of the new legal framework, the consultation states that ‘Although conscientious objection is not the sole preserve of people from different faith backgrounds, it is likely that most conscientious objection will come from people of faith.’ The Church calls on the NIO and the Department of Health ‘to produce a model of service delivery, that protects the right of those tasked with the delivery of the framework to conscientiously object, whilst ensuring patient safety.’
Rev Daniel Kane, convener of Council for Public Affairs, which is making the submission on behalf of PCI, said, “At the heart of this consultation is a question about the kind of society we want to live in. The impact of these changes on our population may not be truly felt for a generation, but have the potential to be profound.
“No matter how we view abortion, I’m sure that the overwhelming majority of people in Northern Ireland would agree that these proposals go too far. We trust that the Secretary of State will seriously consider all the submissions received on the details of this consultation and seek to create a society which points to a better story, one of hope and human flourishing, of life and humanity, even in the most difficult of circumstances.”
10 key points from the Presbyterian Church in Ireland’s consultation submission
1. Consideration of abortion, and matters relating to it, are of ethical, legal and pastoral concern. Many of our ministers and others in congregations have journeyed with women and their families who have experienced a pregnancy crisis.
2. The current position of PCI is that “human life begins at conception and therefore believes that from that moment the human embryo should be treated in a manner in accordance with full human dignity”. PCI is therefore opposed to the new legal framework for abortion services as proposed by this consultation.
3. Unrestricted access to abortion up to 12 or 14 weeks goes far beyond what is required legally and may have the unintended consequence of providing the conditions where a woman might be coerced to seek an abortion, or allow domestic abuse to go undetected.
4. Proposals to provide what is in effect unrestricted access to abortion up to 22 or 24 weeks exceed the legislative requirement, and create a significant differential to provision in the Republic of Ireland, and most other European countries.
5. In 2017 the United Nations Committee on the Rights of Persons with Disabilities recommended that ‘women’s rights… should be respected without legalising selective abortion on the ground of fetal deficiency’. It is the view of PCI that the proposals regarding a diagnosis of severe impairment run contrary to this recommendation, and allow for a subjective judgement to be made on the quality of life of a baby born with an abnormality. This also perpetuates stereotypes towards persons with disabilities.
6. A process of certification by two doctors, should be put in place to provide safety for women and protection for medical professionals, which is the standard in the rest of the British Isles.
7. Anticipated high levels of conscientious objection on behalf of medical, or health professionals, should not be used as a reason to reduce safety for women. It is for the Northern Ireland Office and the Department of Health to produce a model of service delivery, which protects the right of those tasked with the delivery of this framework to conscientiously object, whilst ensuring patient safety.
8. PCI is concerned that no separate consideration has been given to the particular needs of girls under the age of 18 and deemed to still be children in the eyes of other state providers, or of women and girls who lack capacity for decision-making.
9. A duty should be placed on the Department of Health to ensure that non-directive counselling is available both pre- and post-abortion.
10. Against the backdrop of the current, and increasing, extreme pressures on the NHS, the Church is concerned that this new legal framework for abortion services in Northern Ireland has the potential to place additional strain on a system that is at breaking point. We are hugely concerned that the system will not be ready to implement these changes as required by 31 March 2020.
You can read the full submission here.