A new legal framework for abortion services in Northern Ireland

[Submitted on behalf of Affinity - Gospel Churches in Partnership, December 2019].


What is your organisation?
Affinity - Gospel Churches in Partnership [representing some 1,200 UK churches, including several in Northern Ireland].

Section 2.1, Part 1 - Early terminations of pregnancy
Question 1a: Should the gestational limit for early terminations of pregnancy be up to 12 weeks gestation (11 weeks + 6 days)?
No.

Question 1b: Should the gestational limit for early terminations of pregnancy be up to 14 weeks gestation (13 weeks + 6 days)?
No.

If you answered no to 1a and 1b, what alternative would you suggest?:
'Everyone’s right to life shall be protected by law' [Article 2 of the European Convention on Human Rights]. Abortion, the taking of early human life, is therefore always legally and morally wrong, whatever the gestational age.

Moreover, legalising abortion 'without conditionality' would allow terminations on additional grounds, such as gender and disabilities. That is a step too far.

The alternative would be to enact the majority will of the people of Northern Ireland, who in both the 2016 Assembly vote and in various polls, have rejected such radical legalisation.

Section 2.1, Part 2 -Early terminations of pregnancy
Question 2: Should a limited form of certification by a healthcare professional be required for early terminations of pregnancy?
No.

If no, what alternative approach would you suggest?:
All medical procedures require fully informed consent. Without a robust certification process this is impossible. 'Limited certification' would, for example, not only put some young girls at risk of additional sexual abuse, but all girls and women would be denied the opportunity to discuss alternatives to abortion, such as counselling and practical support.

Rather than a limited certification, the government should be seeking to strengthen certification in order to protect and enhance the best interests of pregnant girls and women. This issue demands further discussion.

2.2 - Gestations beyond 12 or 14 weeks
Question 3a: Should the gestational time limit in circumstances where the continuance of the pregnancy would cause risk of injury to the physical or mental health of the pregnant woman or girl, or any existing children or her family, greater than the risk of terminating the pregnancy, be 21 weeks + 6 days gestation?
No.

Question 3b: Should the gestational time limit in circumstances where the continuance of the pregnancy would cause risk of injury to the physical or mental health of the pregnant woman or girl, or any existing children or her family, greater than the risk of terminating the pregnancy, be 23 weeks + 6 days gestation?
No.

If you answered ‘no’ to both of the above, what alternative provision do you suggest?:
If abortion at any gestational age is wrong, then discussion about its proposed upper limits is academic and futile, if not macabre.

Moreover, the physical and especially the mental sequelae to abortion, though well known, have been consistently discounted by abortion providers and other healthcare professionals.

The option to '... leave the issue of the term limit on abortion to medical discretion' would permit abortion up to birth. This possibility, favoured by some abortion campaigners, is an appalling prospect that should be quashed immediately.

2.3 - Fetal Abnormality
Question 4a: Should abortion without time limit be available for fetal abnormality where there is a substantial risk that the fetus would die in utero (in the womb) or shortly after birth?
No.

Question 4b: Should abortion without time limit be available for fetal abnormality where there is a substantial risk that the fetus if born would suffer a severe impairment, including a mental or physical disability which is likely to significantly limit either the length or quality of the child’s life?
No.

If you answered ‘no’ to either or both of the above, what alternative provision do you suggest?:
In an age when we are legally compelled to accept and even celebrate human diversity and equality, it is surely contradictory and discriminatory, as well as inhumane, to encourage search-and-destroy missions against the unborn who may suffer some fetal abnormality, be it mental or physical, or minor or major.

We all suffer from mental and physical disabilities. And who can satisfactorily define terms like 'substantial' or 'significantly'? These and other similar vague terms should never be used to pronounce life or death.

All human life has intrinsic value and dignity. Any society that cares for and supports all its citizens, including the weak and vulnerable, must be commendable. Northern Ireland now has the opportunity to become a champion of such a civilised society - the practice of eugenic abortion will condemn it.

2.4 - Risk to the woman or girl’s life or risk of grave permanent injury
Question 5a: Do you agree that provision should be made for abortion without gestational time limit where there is a risk to the life of the woman or girl greater than if the pregnancy were terminated?
No.

Question 5b: Do you agree that provision should be made for abortion without gestational time limit where termination is necessary to prevent grave permanent injury to the physical or mental health of the pregnant woman or girl?
No.

If you answered ‘no’ to either or both of the above, what alternative provision do you suggest?:
Routine abortion has the premeditated intention of taking the life of an unborn child. Such abortions should never be regarded as life-saving procedures.

However, there are limited circumstances where the pregnant mother's life is under threat. Good medical ethics and practice dictate that if the lives of both her and her unborn child cannot be saved, one may be sacrificed. Evidence shows that it is sometimes the mother's and sometimes the child's life that is forfeited. This is NOT routine, intentional abortion, rather it is good medicine.

This somewhat vague and ambiguous aspect of the Consultation must never be used to expand the grounds of routine abortion.

2.5 - Who can perform a termination
Question 6: Do you agree that a medical practitioner or any other registered healthcare professional should be able to provide terminations provided they are appropriately trained and competent to provide the treatment in accordance with their professional body’s requirements and guidelines?
No.

If you answered ‘no’, what alternative approach do you suggest?:
The 1967 Abortion Act originally required the involvement of two medical practitioners for good reason - such a life-ending procedure was historically forbidden by the medical profession and therefore to be undertaken only after all alternatives had been exhausted. A second opinion was useful for both patient and doctor. Abortion therefore required the knowledge and skills associated with the most highly-trained medical professionals.

If 'any other' persons were involved it would lower the threshold of potential care and support for pregnant girls and women/clients. The lowering of these aspects is the opposite of what is required by good medicine.

2.6, Part 1 - Where procedures can take place
Question 7: Do you agree that the model of service delivery for Northern Ireland should provide for flexibility on where abortion procedures can take place and be able to be developed within Northern Ireland?
No.

If you answered ‘no’, what alternative approach do you suggest?:
Again, the provision of abortion in 'a place approved' was for a good reason - to ensure women and girls were given the best clinical care.

'The optimum model of care' would be one that excludes the practice of abortion. To make abortions more accessible under the guise of 'flexibility', 'wider range of settings' and so on, is to move in the wrong direction. Surely we all want to see abortion become rarer.

2.6, Part 2 - Where procedures can take place
Question 8: Do you agree that terminations after 22/24 weeks should only be undertaken by health and social care providers within acute sector hospitals?
No/yes.

If you answered ‘no’, what alternative approach do you suggest?:
Sadly, since abortion is to become more widely available in Northern Ireland, the procedure needs to be tightly controlled. Abortions after 22/24 weeks are performed on those who are 'capable of being born alive'. Such late-term abortions are therefore particularly heinous. Such a child can not only be 'born alive' but also survive.

If, and when, such abortions are permitted, then only the best medical personnel and venues are appropriate.

2.7, Part 1 - Certification of opinion and notification requirements
Question 9a: Do you think that a process of certification by two healthcare professionals should be put in place for abortions after 12/14 weeks gestation in Northern Ireland?
No.

Question 9b: Alternatively, do you think that a process of certification by only one healthcare professional is suitable in Northern Ireland for abortions after 12/14 weeks gestation?
No.

If you answered ‘no’ to either or both of the above, what alternative provision do you suggest?:
Since abortion is wrong no process of certification can be conceived of as being suitable. Furthermore, these allied Questions 9a and 9b are seeking to widen access to abortion in Northern Ireland. The unannounced objective of this Consultation is clearly to offer abortion as cheaply and as widely as possible.

The old rule of ‘two registered medical practitioners’ should be retained, even though it has often been abused. It was precautionary in nature. Now where are the safeguards? Where are the precautions?

This Consultation appears to be using Northern Ireland as a test-bed to rush headlong towards the decriminalisation of abortion not only in the Province, but also elsewhere. Frankly, it is frightening.

2.7, Part 2 - Certification of opinion and notification requirements
Question 10: Do you consider a notification process should be put in place in Northern Ireland to provide scrutiny of the services provided, as well as ensuring data is available to provide transparency around access to services?
No/yes.

If you answered ‘no’, what alternative approach do you suggest?:
Whenever a new medical regime is introduced, of course, detailed data should be collected, analysed and published. However, because of the more unrestricted nature of the proposed abortion legislation it will be more difficult to obtain meaningful statistics and conclusions. Will it, for instance, be possible to gather new evidence of the physical and psychological harms that can result from abortion? Who will gather such data? How will they meet abortion clients?

2.8 - Conscientious objection
Question 11: Do you agree that the proposed conscientious objection provision should reflect practice in the rest of the United Kingdom, covering participation in the whole course of treatment for the abortion, but not associated ancillary, administrative or managerial tasks?
No.

If you answered ‘no’, what alternative approach do you suggest?:
Abortion is a contentious issue. A decent society allows freedom of thought, expression and action. No-one who objects to abortion should be forced to sear their conscience by enforced participation.

Conscientious objection is therefore 'a must' for all those across the whole of abortion procedures including medical, nursing, ancillary, administrative and managerial staff.

Northern Ireland now has the opportunity to establish a fair and thorough-going system of conscientious objection - it should grasp it.

Question 12: Do you think any further protections or clarification regarding conscientious objection is required in the regulations?
Yes.

If you answered ‘yes’, please suggest additional measures that would improve the regulations:
People are increasingly being denied the exercise of their conscientious objection. These incidents are occurring particularly in public services, such as education and medicine.

Because abortion is especially contentious, the conscientious objections of men and women within its ambit should be especially protected. A statutory right of objection and the right to opt out, similar to that of section 4 of the 1967 Abortion Act, but specifically on the grounds of religion and belief, should be established and maintained.

Northern Ireland has the unique opportunity to become an equitable world-leader on this important topic.

2.9 - Exclusion zones
Question 13: Do you agree that there should be provision for powers which allow for an exclusion or safe zone to be put in place?
No.

If you answered ‘no’, what alternative approach do you suggest?:
Laws already exist to protect people from harassment, alarm and distress. No new powers are needed - the police already have sufficient.

Moreover, those legally protesting and offering support outside abortion clinics have a right to freedom of expression. Some potential clients of abortion clinics have been grateful for such interventions.

There have been no successful prosecutions in England and Wales because the legal threshold of harassment has not been breached. The establishment of exclusion zones is therefore unwarranted and unnecessary.

Question 14: Do you consider there should also be a power to designate a separate zone where protest can take place under certain conditions?
No.

If you answered ‘no’, what alternative approach do you suggest?:
Following on from the answer to Question 13, there are no compelling reasons to designate separate protest zones.

Further Comments
Question 15: Have you any other comments you wish to make about the proposed new legal framework for abortion services in Northern Ireland? Enter answer here:

We understand that this Consultation is not primarily about the rights/wrongs of abortion. However, this Consultation exists because abortion exists.And Affinity wishes to underline its robust opposition to abortion.

 We are especially concerned about the haste and momentum with which the new abortion regime is being foisted upon the people of Northern Ireland. Until recently, Northern Ireland was just about the safest place in the world for the unborn child. In a few weeks, it is about to become the most dangerous.
 
This is despite the protests of the majority of people of the Province. They have consistently opposed any change to their laws on abortion. And yet extremist factions in Westminster have forced through these changes in an unseemly and undemocratic manner.
 
If the issue of abortion is contentious, its practice is more so. Yet the proposed new framework and this associated Consultation have seemingly one overwhelming purpose - to set pregnant girls and women on the abortion pathway, as quickly and as uncaringly as possible. No options, no discussions, no alternatives. Abortion is regarded as the only answer to unplanned and difficult pregnancies.
 
We are profoundly shocked and troubled by these moves. They will change Northern Ireland for ever, but not in a good way.
 
It is therefore with a deep sense of regret and foreboding that we, on behalf of thousands of our constituents, make this submission.
 
'Righteousness exalts a nation, but sin is a disgrace to any people.' [Proverbs 14:34]


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