How reassuring is the PLF 'pastoral reassurance'?

With a prescience that says much about the depth of his insight, it was over a month ago that Dr Martin Davie was able to provide the most succinct of summaries of where he believed the Prayers of Love and Faith (PLF) process had arrived at,

“It is now fairly clear what the next stage of the Prayers of Love and Faith process will be. In July the House of Bishops will propose that stand alone services for the blessing of same-sex couples (including those who have entered into a civil same-sex marriage) will be permitted under the terms of Canon B5 and will also propose that the current discipline forbidding clergy to be in same-sex marriages will no longer be applied in at least some dioceses.

“It is also clear that, at the moment, the bishops are absolutely intransigent in refusing to even consider the possibility of either a provincial settlement to meet the needs of traditionalists as requested by CEEC, or even some kind of non-provincial transferred episcopal arrangements for traditionalists. The maximum they seem prepared to offer is some kind of regionally arranged delegated episcopal oversight, which would still leave traditionalists under the ordinary jurisdiction of their diocesan bishops regardless of where that bishop stands on the sexuality issue.”

Martin Davie is to be commended for so accurately predicting the destiny of the entire 7-year LLF/PLF pathway in just 166 words. His forecast has been all but confirmed in what has emerged from the most recent discussions of the House of Bishops, although it has taken them 31 pages. Even the “Executive Summary” of General Synod paper 2358 (GS258) is twice as long as Davie’s own, but can be reduced to this extract,

“The core elements of those emerging proposals are:

•     To remove the restrictions in the current pastoral guidance on using the Prayers of Love and Faith for a three-year period of discernment.

•     To introduce alongside this a model of specific and defined delegation of episcopal ministry, so that those on all sides of the debate, who feel they require it, can request care from a bishop whose ministry they are in conscience able to receive, supported by an Independent Review Panel to assess where practice departs from agreed principles.

•     For more work under the aegis of the Faith and Order Commission on the nature of doctrine to enable further conversations on whether to remove current restrictions on clergy being in same-sex civil marriages, for decision by the House of Bishops in early January 2025 and to be presented at the February 2025 General Synod.”

Regionally Arranged Delegated Episcopal Oversight (RADEO)

Of the three components Dr Davie identifies: “experimental” stand alone services, (diocesan) removal/non-enforcement of discipline and regionally arranged delegated episcopal oversight (RADEO), it is the final one which this blog examines.

What Davie calls “RADEO”, + Martin Snow, the Lead Bishop for PLF calls, “specific and defined delegation of episcopal ministry” para 2/pg 2), or “extended (delegated) episcopal ministry” (para  3/18/19/55/pg 18), “extended episcopal ministry (para 26/47), “symmetrical extended episcopal ministry” or “shared/extended episcopal ministry” (pg 18). Later in GS2358 it is clear that Martin Davie was right to foresee the regional element (para 19),

“This model would require national consistency of outcome but allow for the opportunity of contextual regional implementation in how to achieve this, with extended (delegated) episcopal ministry at a local level (as some regions are already exploring).”

There is also talk of, “…a nationally led regional model” (para 23).

Dr Davie was, of course, entirely correct to identify that RADEO is not the type of provision/pastoral reassurance sought by the Church of England Evangelical Council (CEEC), The Alliance and others, as it would leave traditionalists under the ordinary jurisdiction of their diocesan bishops. The unacceptability of this has been reiterated following the publication of the Synod papers. The National Director of CEEC, Revd John Dunnett has said that his organisation cannot support this sort of provision because it: treats PLF as adiaphora, depends on the goodwill of the diocesan and is not a structural “firewall” or without limit of time.

To some that may be the beginning and ending of the matter. In the absence of a (quasi-) Provincial solution or at least Transferred Episcopal Oversight (TEA) clergy will be left to accept serving under diocesans who are compromised on the issue of human sexuality and they will simply not be able to do so. If the position doesn’t change that will be the end of their ministry of the Church of England. It is also worth remembering that lay people have bishops too and some will simply vote with their feet. Others will need time to consider the implications.

A quick history of 'delegation' in the CofE

Neither the intransigence Martin Davie describes, nor the consequent inadequacy John Dunnett explains are surprising - a feature of the earlier negotiations surrounding the consecration of women to the episcopate surveyed the same terrain of provincial solutions, transferred, extended and delegated oversight.

The outcome then was as it appears now - the refusal by diocesan bishops to consider anything that would impact upon or dilute the absolute nature of their Ordinary jurisdiction. The notion that there could be any "holing out” of the jurisdiction, sometimes derided as the “Swiss cheese” model of episcopacy, will simply not be countenanced.

In pursuit of a deeper understanding, it is worth considering that history a little more. In particular, to understand what happened and what as a consequence is meant by “delegation” and particularly when that is further tempered by use of the word “extended”. This is not least the case because the new PLF proposals so closely mirror in other respects those deployed in relation to female bishops – a Bishop’s Statement, Code of Practice, Pastoral Guidance, Review Panel, “…some level of legislative underpinning” (para 26), which is indeed referred to as a partial precedent (Annex B - para 12).

In the process and implementation of introducing women to the episcopate it has become clear that:

• A “canonical oath” is relational, that is to say, albeit only “in all things lawful”, it is to the person of the bishop, not merely the office. While some still try to suggest that the oath still does not expect recognition of an individual, it is a strained interpretation to make an oath explicitly stated to be,  ‘… a recognition of the pattern of relationships which underpins the exercise of ministry by those who make and those who receive the oath’, mean that. And that is merely confirmed by the fact that most Diocesan’s certainly don’t have that understanding rather, to the contrary, that the oath is, a vital acceptance by every clergyperson that the diocesan bishop is “their” bishop. The acceptance of delegation only came accompanied by a “clarification” of the personal role of the diocesan in respect of every member of their clergy.
  

• Delegation by a diocesan to a Provincial Episcopal Visitor (PEV) included the unfettered right to refuse to delegate anything. And, as Revd Dunnett seems to understand, that has happened. Attempts to make parishes or clergy entitled to delegated oversight, “as of right”, upon request were comprehensively ruled out in 2012-2014.  This notwithstanding, Revd Dr Andrew Goddard writing on the present PLF proposals has said that, “…it is not clear whether [such delegation] will be required or discretionary”, but the former seems surpassingly unlikely;

  • First, strikingly, the paper does not give a definition of “delegation” or of any of the related phrases used. That could be merely a lack of rigour but it is much more likely that the authors assume the reader already knows with sufficient adequacy what the term means in such a context.

  • Second, and related to the above, it would require a re-definition and re-application, perhaps for several purposes, of what “delegation”, has meant to the House of Bishops for a decade.

  • Third, delegation which is “required”, “as of right” or “compulsory” is not delegation at all. Delegation is, by definition, voluntary.

  • Fourth, if GS2358 meant that oversight would be automatically “transferred” (by some form of TEA) it would surely both say so and not use, no fewer than twenty times, the qualifier “extended”- which is the accurate description of the positions of the PEV’s.

  • Fifth, “delegation” as a concept, has a well-established history in Anglicanism. “Delegated Episcopal Pastoral Oversight” (DEPO) was the path by which The Episcopal Church of the USA (TEC) did “good disagreement”. Under DEPO the diocesan bishop invited a bishop from another diocese into his/her home diocese to assist in providing sacramental and pastoral care to a congregation whose relationship with the diocesan had been severely damaged. The agreement was worked out between the two bishops and the petitioning congregation in a way that was mutually agreeable via “regular conversations”. The affected congregation remained a part of the diocese, its clergy continued to function within the structures of the diocese and with fellow clergy. The parallels to what +Snow now proposes are obvious and some radically different understanding of “delegation” therefore improbable. (Of course, DEPO did not turn out well, even for a bishop as gentle and conciliatory as +Bill Love).

• Delegation would only ever be “ad hoc”- thus without any necessary consistency, uniformity or permanency and as such, at any one time, and in any single instance or on any occasion, wholly at the discretion of the Ordinary.

• Delegation could therefore also mean “demand” i.e. for the diocesan to concelebrate, co-consecrate, preside, preach etc alongside the PEV as part of the provision of delegated oversight for the rest of the service.

• Delegation has to be sought, which can make the congregation a target for unfavourable treatment especially if the request is maintained during a period of interregnum/“pastoral reorganisation”. The suggestion in GS2358 that “… requests for pastoral provision could be monitored during a discernment period to inform further work for formal consideration…” will seem more sinister than reassuring to some.

Lest there be any doubt about the diocesan bishops’ intent that no PLF “provision” will impinge on their jurisdiction, amidst all the ambiguities of the proposals, it is nonetheless unequivocally asserted in GS 2358 that, whatever else might be up for discussion, “retained by the Ordinary” would be, “Overall oversight of the whole life of the diocese. Safeguarding. Discipline.”

Accordingly, unless the House of Bishops reverses course, all the problems outlined above would exist for traditionalists within the proposed PLF arrangements.

But that is only the start of the difficulties.

Who might offer RADEO?

It is not clear at the moment what would qualify a bishop to provide RADEO to clergy who are theologically conservative on the issue of marriage. There is a spectrum of possibilities of what might be regarded as being “orthodox” on the issues which might form a range something like this:

• A bishop who while using the Prayers themselves, is sympathetic to those who won’t.

• A bishop who while willing to use the Prayers themselves, takes a “self-denying” ordinance not to use them for the sake of unity, rather than conviction on the issues- someone such as Justin Welby.

• A bishop who has used the Prayers as a presbyter but elects not to do so as a bishop.

• A bishop who will not use the Prayers at present because they are not sure about the innovation but might do after a period of “reception”/ ”experimentation” etc.

• A bishop who believes that the Prayers are wrong in the Church of England but would or has, for example, consecrated a man as a bishop in another jurisdiction who intends to be in a same-sex marriage or served in a jurisdiction with a contrary view.

• A bishop for reasons of conscience cannot ever anticipate using the Prayers but will not seek to actively oppose others using them now or in the future.

• A bishop who believes that the Prayers are wrong and will vote against them if and when there is a vote under Canon B2.

• A bishop who is committed to calling the Church of England to repentance for the missteps on issues of human sexuality, including in relation to Civil Partnerships/Marriages for lay people.

What is clear, however, is that, wherever they fall in this spectrum, any bishop providing oversight by way of delegation must be willing to accept:

• Submission to a diocesan who is heterodox on issues of sexuality.

• Being in a national (and perhaps regional) College of Bishops with bishops who support the use of the Prayers, and quite possibly the whole gamut of revisionism on issues of sexuality. That is to say a bishop for whom such matters are not adiaphora nonetheless being willing to be in Communion and share the episcopate with those who take a diametrically opposing view.

For some, where a bishop could be understood to stand in the spectrum of orthodoxy would also have to be considered in the light of how the RADEO bishop regarded and navigated these two issues.

Thus, the issues of 'what' might be delegated and 'how' are compounded by 'to whom' the delegation is made and 'in what' circumstances.

Given all these issues, and probably many other unforeseen consequences, it is almost impossible to imagine any national uniformity as to what traditionalists might be entitled to expect or as to what they will be offered. And what they are offered might change at any time as personnel, situations and actions change.

What are the implications for parishes?

How a parish is supposed to address these complexities and ambiguities is difficult to see - a PCC having a potentially divisive or unwanted discussion about the “known unknowns” and “unknown unknowns” of their potential oversight is unlikely to help anyone. All the more so, if it is an ever-changing picture that has to be revisited time and again. Those problems will simply be multiplied for clergy with more than one parish. It is easy to imagine half a dozen churches each with very different expectations, served by a number of clergy with very different needs.

Even deeper problems would appear to exist for those parishes - both complementarian and Anglo-Catholic who presently received the delegated oversight of the existing Provincial Episcopal Visitors. They provide delegated oversight specifically in relation to issues of gender and their care can only be sought in respect of those issues, not those of sexuality. Moreover, as has been seen, there is no guarantee that any parish can access them at all or on an acceptable basis.

It is not hard to imagine a scenario where the provision offered in respect of the Prayers is from a bishop unacceptable to a church on issues of gender - whether that is because they are complementarian/Catholic, or the opposite. Likewise, that a PEV holds a particular view on gender does not necessarily mean they are orthodox on issues of (non-sacramental) marriage. Perhaps there might be delegation (perhaps on different bases) to different bishops on the different issues but that is hardly a model of episcopacy to inspire anyone.

Will there be an ongoing supply of orthodox bishops?

Delegated episcopal oversight also requires, in each region an ongoing supply of orthodox bishops. Primarily that is likely to mean suffragan bishops and therefore dioceses willing to appoint them. That is something over which the Church of England nationally has no control and which proved impossible to effect when seeking to appoint a conservative evangelical who did not ordain women - hence the appointment of a PEV.

It is a strange thing to expect heterodox bishops to appoint as their suffragans those who they believe to be prejudiced and perpetrating injustice. It is an even stranger thing to expect them to override their conscience and compromise their integrity for the sake of the consciences and integrity of others. The ongoing supply of orthodox suffragans (and therefore potential diocesans) cannot be secure in such circumstances.

A parallel, but not equivalent, difficulty arises for orthodox diocesans who might be expected to appoint, or at least delegate to, suffragans who they believe to be false teachers. It is not equivalent because it is surely easier for a diocesan who believes the issue at hand to be adiaphora, is content with “plural truth” and prioritises institutional unity above all else to show flexibility, than one who does not believe the issue is adiaphora, in plural truth or unity as all. It was this which proved the final straw for Bishop Love in the USA.

Moreover, it is hard to see how an orthodox diocesan could realistically delegate any of his or her oversight when it is not a part of their oversight which they believe to be proper, or perhaps even possible.

At present there are probably no more than a handful of diocesan bishops who for reasons of conscience will not use the Prayers and thereby ensure that the issues for orthodox clergy are reduced, at least while they remain in post. But even then the position is not without concern. It would seem that such bishops will have to both accept the use of the Prayers in their diocese and, with the problems just described, ensure suitable delegated oversight for those who do use them. Those are significant steps towards the compromise of conscience and/or the issues being adiaphora in practice if not in theory.

Presumably, these issues for orthodox diocesans will be “solved” in the future by only appointing diocesans for whom they are not concerns - that is to say heterodox ones. Thus, the chances of orthodox diocesans continuing the supply of truly orthodox suffragans and there being diocesan bishops that new suffragans are willing to serve under would reduce all the time.

Why haven't the issues been addressed already?

None of the issues highlighted in this piece are new and certainly not to anyone involved in the controversies of the Church of England over the last 15 years - a good number of whom are to be found in the House and College of Bishops, with more who have been the beneficiaries of the approach that has been taken. As such, all the points raised here could have been addressed, not least in the relevant appendix. The decision not to even acknowledge them surely stems from a desire not to have to confront them.

Which all adds-up to the inevitable conclusion that the Church of England Evangelical Council and their fellow travellers have been right in consistently stating that the provision for traditionalists must be Provincial, or something akin to it. They have with equal tenacity pointed out how anything else would constitute a long-term and ever-increasing muddle with all the scope for unhappiness and conflict with which that comes.

Given the choice of themselves sacrificing even a modicum of their totally monarchical episcopacy, let alone what CEEC desire, or creating for many an utterly malfunctioning episcopacy, the House of Bishops have presently chosen the latter. Dr Goddard must be right when he puts it this way,

“One problem here is that while the different perspectives in Synod are being urged that they need to give up something if there is to be a settlement, the bishops who urge this are seemingly unwilling to give up anything significant themselves.”

It is hoped that this post might offer some ideas for questions for the July sessions of Synod when they are submitted this week and, in any event, offer further credence to the stance that CEEC and others have been compelled to adopt.

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