www.byzcath.org Forums Faith & Christian Life Faith & Theology Contraception

Is it ok? Is it wrong? What does the Catholic Church teach? What does the Orthodox teach?

I will start with what I think the Catholic Church teaches HUMANAE VITAE [vatican.va]

I can't find on the internet an "official" teaching on the matter from the Orthodox Church. If there is such a publication please post it. Here is what I did find:
Orthodox Wiki [orthodoxwiki.org]

Further, I have read on the internet (please correct me if I am wrong) that the Ecumenical Patriarch stated,

So, what is the official teaching of the Orthodox Church on the matter? Who is right and who is wrong? Or, do both Churches teach the same thing?

You already know what we Orthodox think. Afterall, you quoted the patriarch of Constantinople:

"priests should not enter the bedrooms of the faithful."

I seem to have insomnia tonight. Much is on my mind and much of it is not forum related though some of it is. I do think that this is a worthy topic of discussion. But, before I respond I am just going to say that I seek to be as fair and objective as possible and the minute any of this turns into mudslinging, then I'm not discussing it anymore. My purpose is to help us understand one another better and not to cause divisions or provoke people to accusations against one church or another. Here are my initial thoughts in summary:

If one were to do a thorough study of the issue using primarily the primary sources of the Church fathers and also the best secondary scholarship such as John Noonan's "Contraception" which is the definitive study, one would find that the issue of what the Church teaches and ought to teach on this is rather complicated. Here is why.

The Church fathers, universally, condemned all contraception. That much is true. But, here are some additional facts. We know that almost without exception, the Church fathers taught that the only permissible use of sex was for procreation and that sex for the sake of relieving concupiscience was excusable, but still in some sense, was sinful. This view is unbiblical of course and has its roots in the Stoic and Platonic influences on the Church fathers, especially among the Alexandrians and, later, Augustine and Jerome. Also, it needs to be pointed out that almost all of the written documents we have come from ascetics who viewed this issue not from the point of view of a married laymen,but from the point of view of a monastic.

The next thing that is clear is that the church fathers universally would have condemned what we call Natural Family Planning and would not have made a distinction between NFP and artificial methods. Why is this the case? See the paragraph above. We know that there were penitential canons for those married couples who copulated while the woman was pregnant and for those who copulated during menstration (Ironically, both practices recommended to my wife and I by our NFP counselors when we were Catholics). Augustine explicitly condemns the practice of calculating the time of ovulation in order to avoid pregnancy. There is no reason, based on all of the evidence, to think that he is not speaking for the consensus.

Up until the middle of the 19th century, it would have never occurred to anyone to suggest the "rhythm method" to married couples. There was some discussion in the Vatican about what to do in confession with couples who confessed to abstaining when they thought fertility was likely. There was no clear concensus and so generally, it was suggested to leave them alone. As late as Pius XI's "Costi Cannubi" we see that the official teaching is that the only alternative to normal conjugal relations is complete abstinence. The first public mention of the rhythm method as being permissible for grave reasons is found in a locution from Pius XII to midwives. Humanae Vitae is actually a very novel document for two reasons. First, it explicitly gives permission to use the fertility cycle to prevent conception. Second, it teaches that there is a unitive end to the conjugal act that is intrinsic to it and equal to the procreative end. The Church fathers would have found this appalling.

Now, two other facts need to be mentioned about contraception in the early Church. First, most contraceptive potions were made by pagans using magical charms. As such, it was from the beginning, generally considered to be something associated with pagan magic. Second, the fathers did not sufficiently distinguish between abortifacient contraception and non-abortifacient contraception. Notice, I did not say that they did not distinguish at all. But , it was not sufficiently distinguished. In their minds, it was still all essentially murder because they believed that the life of the soul was transmitted through the male semen. St. John Chrysostom even says that contraception is worse than abortion, which is of course an absurd thing to say unless you think that contraception is, at the minimum, murder.

Today, the situation is different. First, contraception is no longer (and not even primarily) linked up with pagan magic. So the issue of sorcery and idolatry is not involved. Second, we have a much better understanding of how conception takes place and we can clearly distinguish between non-abortifacients and abortifacients. Third, even the Roman Catholic Church has recognized that the couple need not intend in every single act to procreate in order for it to be licit. So, contraception is licit. It is, allegedly, only artificial means of contraception that is not.

But what is this distinction between artificial and natural? And why is the fact that some contraception is "artificial" grounds for considering it intrinsically evil? The standard response is that natural family planning does not interfere with natural processes and so is open to life; whereas other means of birth control deliberately frustrate the natural purpose of the sexual act. I used to think that this was a sound distinction. But, I found it puzzling when our NFP counselors would brag about how NFP, when done strictly, was more effective than the pill. Artificial contraception does not render procreation absolutely impossible and, NFP, actually can be used in such a way as to be more efficient in not being open to life than a condom or the pill. I find this ironic.

Now, what in the world is natural about using a thermometer or examining oneself bodily (hence using science) in order to outsmart nature by taking advantage of the fact that it takes the body some time to bring forth another egg and get it in place for conception? It is really begging the question to think that God somehow designed the female body so we would figure out when the infertile times were. The simple biological answer is this: that eggs, like all material things, are subject to decay and so the body must continually replenish itself with new eggs. If conception hasn't happened after a period of time, then it is time to dispense with the older egg and replace it with a new one. Since the body cannot instantaneously transport an egg to the proper place, it takes time for the body to get the right signals, send the egg, and then have it in place. So, natural family planning is simply using science to take advantage of an inefficiency in biology. I remember once reading a criticism of Humanae Vitae saying that it forbid the use of chemistry in preventing conception but permitted the use of mathematics.

Now, another thing to consider is that we know that the woman is normally most interested in sexual relations during the fertile period. The fact that she is less interested during the infertile period shows that the body isn't fundamentally interested in sex during those times. Of course, with the male, who is always fertile, he is always interested.

Finally, let me just say this. In Genesis, it is certainly true that in chapter 1, God makes man and woman and blesses them saying "be fruitful and multiply." A straightforward reading of this text shows that this is a blessing, not a command. Also, it is something we share in common with the animals who are not commanded to be fruitful and multiply (animals have no free will), but are blessed. God is simply blessing sexual activity to make it fruitful. Notice in Genesis 2 that when God makes Eve for Adam, no mention of the need for procreation is present. God makes Eve for Adam because it is "not good for man to be alone." A careful reading of the whole passage shows that the unitive purpose of sex is the biblical purpose of sex. The procreative is primarily the biological purpose of sex, and while it is the natural consequence of fruitful union, it is never made the primary end anywhere in the biblical text. When St. Paul writes about marriage he either says, in 1 Corinthians, that one should get married so that one doesn't burn with lust (no mention of procreation) or, in Ephesians, that marriage is a symbol of the union of Christ and the Church (hence the unitive function is seen as the sacramental symbol). If one looks even at Orthodox Judaism, there is not this obsession with procreation as there is in the stoic-platonic mediated Christian tradition. I should add that we should also consider the Song of Songs and other passages in the wisdom literature of the bible that celebrate sexual love for its own sake.

So, my conclusion is that either the consensus of the fathers was right and there should be absolutely no attempt to avoid conception or we have come to realize that the Church was overinfluenced by stoicism and that a more healthy, balanced, biblical view of sex celebrates sexual pleasure and does not obligate the married couple to always avoid conception. If the prevention of conception is permissible, then it doesn't matter what the means are unless it is something involving murder (abortion) or mutilation (sterilization).

I would even suggest that in the spirit of the fathers, it would be most consistent to say that since we now can better calculate the fertility period, that we should have sex only during the fertile part of the cycle.

Now, I think that is a coherent position. I also think that is wrong and that there is nothing intrinsically wrong with non-abortifacient contraception. I think that the current position of the Roman Catholic Church is contradictory and incoherent.

What I'm giving here is basically the summary of a long article (perhaps part of a book) that I intend to eventually publish and argue for publicly in conferences. God bless.

Joe

What about God? Should he enter the bedrooms of the faithful?



For Joe, here's a puzzle: if contraceptive sex is ok, what's the matter with fornication? Homosexual activity? Once sex may be divorced from procreation, then there is nothing that ties it to marriage, or even to the opposite sex, is there?

Also, if you're going to write a book or article on this, you really ought to read "Love and Responsibility." Perhaps you already have.

An excellent contribution.
Hope you publish your book.
Until you do, I find "Marriage Sexulaity & Cleibacy A greek Orthodox Perspective" by Demetrios J. Constantelos a basic introduction.
For example, p. 38:
"In the spirit of the new Testament other Church Fathers were less legalistic. They felt that questions of intimate relations between husband and wife , who have been taught by the Church to believe and act like one body, cannot be legislated. Thus, when Dionysios of Alexandria (third century) was asked about when husbands and wives should refrain from intercourse, he said that the parties concerned ought to be sufficient judges of themselves."

Karl,

I've read "Love and Responsibility" "Theology of the Body" many other writings of the late John Paul II, Janet Smith's "Why Humanae Vitae was Right" and many other articles and books. You ask some good questions. Here is my answer in brief.

If you are going to argue that the procreative end is essential to each act, then to be consistent and coherent, you must say that to do anything at all (including timing the event) to avoid conception is immoral. That means that NFP is immoral; in fact, just as immoral as artificial contraception.

But, there is another way of looking at this. The Scriptures teach that man was made male and female to compliment one another so that each finds its fullness in union with the other sex. Homosexual sex intrinsically violates that complimentarity. Fornication does also since it is sex with the absence of the kind of committment that involves total giving to the other. Fornication is an act in which one shares an experience with another, perhaps even a genuine loving experience, but without the solemn and explicit committment to be completely bonded to the other. And, contracepted sex acts between men and women are still sex acts carried out in the natural way with the sex organs doing what they naturally do. Obviously, this is not the case with homosexual sex in which, without getting too descriptive, the sexual act is done in a way that is unnatural. By the way, this is also the reason why certain sexual acts done by homosexuals are also forbidden to married couples. In short, sodomy is wrong because not because procreation is impossible, but because it intrinsically violates the natural complimentarity between the sexes, even when it is an action done between a man and a woman.

That is the short answer. This will probably be at least a 30-50 pp. article and that is why it might turn into a book. I will likely take part of this argument and make it a paper to present at a conference, maybe the Society of Christian Philosophers. We'll see. And by the way, I respect the position that all contraception (including NFP) is immoral, though I don't agree with it. I almost came to that position myself and I know people (Catholic, Protestant, and Orthodox) who hold to that position. It is one that coherent, consistent, and heroic. Indeed, it is sublime. But, this is where the principle of "oikonomia" comes in. For a married couple to have relations only for the sake of procreation and to do so while remaining perfectly chaste is heroic. We cannot make what might be the ideal into the minimum. If so, then who can be saved? God bless.

Joe

By the way, I must give credit where credit is due lest I appear to be plagiarizing. What I've given you is an outline of my article, without citations and concrete examples. Much of the argument that I made here regarding the unitive end of marriage as the principle end of marriage and the complimentarity between the sexes, as well there being a lack of a real distinction between artificial and natural birth control is due to this article:

Pseudosex in Pseudotheology. By: O'Callaghan, Father Paul D.. Christian Bioethics, Apr98, Vol. 4 Issue 1, p83-99,

Joe

Miller,

I have read that book and it is excellent. Dionysios of Alexandria's view is exceptional really. I think it is more in line with reality. But if you were to read Clement of Alexandria's view, you would find that he disagrees with Dionysius.

Joe

Joe,

A few quick points before I get back to grading:

1) I must know lots of heroic people.

2) In what does the complementarity of man and woman consist? Is it simply a spiritual complementarity, and if so, why can't man and man be complementary in the same way? If it is physical, does it consist just in the "insert tab A into slot B", or does it have to do with the function of the parts? If the former (excuse me being graphic), then why not insert tab A into slot C? It fits, if you get my meaning.

3) How do you determine the meaning of "natural?" This is, I think, the crux of the issue; it's certainly where Fr. Meyendorff went wrong. The Catholic Church means by natural in accordance with reason. How, then, is homosexuality not in accordance with reason? I can answer that, because I attribute a telos to sexual relations that homosexual acts can't get to. But couldn't homosexual acts be unitive in the same way as marital acts?

4) I needn't say that any action to avoid conception is immoral; otherwise, vows of chastity would be immoral. Obviously, only immoral means of avoiding conception are immoral!

Back to grading.

Dear Friends,

My mother almost bled to death giving child birth, and lost a baby in 1968. Her doctor recommended that she tie her tubes, but her priest told her it would be a grave sin. My parents have not been regular church attenders ever since. I asked a very conservative priest here locally about it once, and he said that my parents should have been willing to go with out sex the rest of their lives. I think the priest may have also thought I was presenting to him an extreme case, in order to be impudent, but I wasn't, I was being very sincere. This episode really happened in the life of my family. My parents had suffered a lot; they had lost two of my siblings, one at 1 years old and another at 2 years of age, only a few years before my mother's brush with death.

I think at some level the ban on all artificial birth control can be hurtful to people, even oppressive. Jesus said that the man was not made for the sabbath, but the sabbath for man. Do we get to a point that we actually hold a principle in abstract over and above basic compassion and human lives?

I respect people who practice faithfully the principles of Humanae Vitae. There is a certain beauty to the teaching. There is a very lovely side to it.

When I was married, my wife and I were not in the church. I do not know how I would feel about birth control now if I was younger and married. I am older now.

Which brings up an obvious flaw in some people's reasoning- if we have to be open to life, should menapausal people be able to be married and make love?

Dear Lance,

Do menopausal people take any action to make themselves infertile, or is it simply a natural state? Excuse a tortured analogy, but there is a difference between dying and suicide. In the second, the action is willed.

In some ways, the phrase "open to life" is unfortunate, since it leads to the misunderstanding that every sexual act must be fertile. I would prefer to say that every sexual act must be a complete gift of self to the other, without reservation.

Personally, I have found the doctrine on contraception, or rather on the integrity of the sexual act, to be one of the most beautiful parts of Catholic teaching. It demands that one have a completely countercultural view of sex, which is also why it is viewed as so hard.

People will sometimes pose dilemmas to me where husband and wife will have to refrain from sex forever unless they contracept, as if that settled the debate; how could anyone think that abstaining from sex is good? Well, I can think that, and Christians can think that. It is because of our misunderstanding of sexuality, and our excessive focus on pleasure, that Catholic teaching on this becomes unthinkable. Is there anything more embarrassing to our culture than the proliferation of drugs to give old men erections?

Furthermore, if contraception is necessary to a healthy married life, as many people argue, does that mean that our ancestors had unhealthy marriages because they couldn't easily get contraceptive medicines or devices?

Karl,

Thank you, by the way, for participating in this discussion because you are a thinker with a formidable intellect and your presence raises the level of this conversation to what it should be. Let me see if I can address your points above. I am really more interested in points 3-4.

1. By heroic couples, I am talking about those who decide that since they do not desire to procreate, they completely abstain from all sexual relations (which was the expectation up until Pius XII). I am not talking about those who practice NFP which, while not easy, is not heroic. I know this as my wife and I have practiced NFP for years.

2. Your points and questions are excellent. There are at least a couple of possible ways of looking at this. First, I will tell you my real position on this. I don't think that the "natural law" is sufficient to determine that only heterosexual sex is morally licit. I think that the creation of man and woman as the intended pair for a sexual relationship is, from the beginning, something given by biblical revelation. At some point, I will post on why I think that the whole western, scholastic, natural law tradition is mistaken about the relationship between reason and revelation and how moral reasoning works. But I will save that for later.

3. The problem is, of course, that the word "nature" is subject to equivocal meanings. This is why there is so much confusion whenever there are any kind of arguments that appeals to natural law. But let's focus on what is most essential to a natural law point of view. You argue, rightly I think, that from the point of view of natural law, procreation is an essential part of the natural telos of the sexual act. Therefore, to use the sexual act in any way that frustrates that purpose would be immoral. But, how is NFP a practice that respects the telos of the act? When one practices NFP for the sake of avoiding procreation, one is explicitly and intentionally engaging in the sexual act in such a way as one hopes to prevent conception. One is still interferring with the natural telos by outsmarting the way that the sexual process is supposed to work. One is using calculation to render the act infertile. Yes, it is true that a sexual act engaged in during the infertile period is only accidentally infertile if we consider the act from a purely physical point of view. But no action can be considered from a purely physical point of view. Take the issue of killing. According to Humanae Vitae a contracepted act is intrinsically evil all by itself regardless of the intentions of the agents performing the act. Now, is it intrinsically evil to kill a human being regardless of the intentions of the agent committing the act? If the answer is yes, then it must be the case that all killing, even in self defense is immoral. Isn't it odd that a purely physical analysis of the act is used in the consideration of contraception, but no one analyzes the morality of homocide indepedent of the reasons that one did it? In fact, it is the intentionally that essentially distinguishes justifiable homocide from unjustifiable homocide. I find this quite ironic. As rational human beings, we do not engage in the sexual act the way other animals do. We do so with reason, hence with intentionality. If we were to abstract from intentionality, then we would simply have to analyze the problem this way:

a) Is is intrinsically illicit to take a hormonal pill that supresses ovulation? All moral theologians agree that the answer is no. Is it illicit to engage in sexual relations with someone who happens to be in a state of chemically induced infertility? Again, abstracting from all intentionality, the answer is no. I think that this is just the kind of analysis that is going on when Humanae Vitae analyzes the sexual act during periods of infertility as not intrinsically evil. And indeed, it is true that women, post-menopause are accidentally infertile. Indeed, it is true that the woman when she is not ovulating is accidentally infertile (the couple hasn't done anything to make her infertile). But, there is a crucial difference. The post menopause couple cannot do anything either way to intend anything with regard to the fertility of the woman. They have no freedom in the matter. Yet, in the case of the typical young couple, they are intending to take advantage and, in a sense, enjoy the sexual act at the very opposite time that nature intended them to do so according to the natural telos of sex.

Also, think of this. Take any action X. Is it morally licit to engage in act X in such a way that one intends to avoid fulfilling the natural telos of X? For example, can I eat food in such a way that I intend to avoid fulfilling the natural telos of eating food, which is health? Is procreation an essential natural telos of sex in the same way that health is an essential natural telos of food? I just don't see how it can be denied that a couple practicing NFP is indeed, intending to engage in the sexual act in a way in which it was not designed. Prior to the discovery of the fertility cycle, all sexual acts that were infertile were only infertile accidentally because the couple could not deliberately intend to time their intercourse. The goal of nature is fulfilled when couples engage in their normal coupling and after several tries, they eventually get a bullseye in terms of conception. What is essentially missing there is the aspect of intentionality. Let's push this a little further. Suppose that a couple discovers that the woman is infertile. Suppose that a new drug is invented that actually does reverse infertility. Is the couple obligated to use the therapy to reverse the infertility? Or, can the couple say, "Well, we aren't going to do anything to alter fertility either way, but we are just going to accept the fact that she happens to be infertile and engage in the sexual act?" Another couple that is fertile find themselves in a difficult situation and so the woman takes a pill that puts herself temporarily into the infertile state like that of the other woman. What is the difference? When they actually engage in the sexual act, what is the difference? The only difference is in intentionality, so it seems. Or is there really even a difference there? This is why the issue is such a gray issue.

4. Excellent point. So, the real issue is whether there is a real distinction between NFP and other forms of contraception that involve engaging in sexual relations. My contention is that there isn't.

And so I conclude with a just a few more remarks. The claim of Humanae Vitae is that the immorality of contracepted sex is something knowable by all human beings according to the natural law. The assumption is that all rational, decent willed, human beings know intuitively what is right and wrong. Everyone, except the depraved sociopath, knows that murder, theft, lying, breaking one's promises, adultery, and so forth are against the moral law. How is it that 90% or more of the decent, law abiding, sometimes even piously christian and traditional people in this world do not see at all that contraception is intrinsically and gravely evil (meaning that if you do it, you burn in hell for all eternity)? I just find it hard to believe that something could be intrinsically, gravely evil when it the justification of its immorality lies on a very particular conception of natural law that uses highly technical and controversial premises. After all, Humanae Vitae makes virtually no appeal to Scripture or explicit statements in the tradition. There really isn't a theological argument in Humanae Vitae at all. Even Pope John Paul II's encyclicals on the objective norms of morality and the "Gospel of Life" were filled with pertinent Scriptural quotations. I can't help but think that Humanae Vitae was actually one of the most poorly written and argued encyclicals in history. Later, I will post on deductive arguments, arguments from natural law, and divine revelation. But, one thing at a time

Joe

Karl,

This is what I think is a fundamental mistake in Pope John Paul II's phenomenology of sex. The holy father claims that in order for true intimacy and unity to occur in the sexual act that it must be a complete gift of the self, one to another, between the two people. If the sexual act is not a complete gift, then the couple is merely using one another for pleasure. The assumption here is that contraception necessarily and intrinsically reduces the sexual act to being mere pleasure; merely using one another. To be honest, I think this is absurd. It is simply not true. First of all, couldn't one say that to refuse to engage in sexual relations during the fertile period (in other words, practicing NFP) is, in fact, refusing to give one's fertility to the other? That is what contracepting couples are allegedly doing. If I engage in contracepted sex with my wife, then I am allegedly "withholding my fertility" from her. But how is practicing NFP not withholding my fertility from her if I am saying that we should only engage in the act during infertile periods? If one says, well, in the case of NFP it is mutual. Well? one assumes that the contracepting couple is agreeing mutually to use contraception. What is the difference? Also, a couple contracepts. Suppose they are engaging in the act because they want to feel close to one another, to embrace one another. Is that really reducing the act to mere pleasure and using one another? Can you really treat the unitive, intimate union of the sexual act abstractly through physical analysis alone? Spiritual unity is precisely the kind of thing that involves shared emotions and feelings. To say that all sex other than sex for the sake of procreation or contracepted through the use of NFP is only for pleasure and a matter of using one another is nonsense, I think. I just find it unintelligible. It is only intelligible, I think, in the context of that old stoic bias against pleasure that still looms in the background of Christian thought.

On the subject of viagra, I would ask a couple of questions. Is the man who suffers from ED due to certain medications he has to take merely engaging in frivolous pleasure because he takes viagra so that he can share intimacy with his wife? What about the elderly couple where the man also suffers from ED? Is his taking viagra so that he can engage in the "accidentally infertile" sexual act in order to please his wife and share unity merely doing this for pleasure and trivial reasons? And what does viagra and these other drugs do anyway? They do not stimulate desire. They are not aphrodisiacs. I am not going to go into detail concerning what they do. Let's just say that they make it possible for the act to actually occur. One can, actually, be filled with sexual desire and suffer from ED. This, I can tell you, is a terribly frustrating and humiliating condition. I don't think that this has anything at all to do with hedonism.

Now, with regard to our ancestors. First, they lived in an agrarian society where having lots of children was a boon, a necessity in many cases. And, society was structured in such a way to take account of that. Also, infant mortality was high, so chances were that a good number of your children weren't going to live long anyway, so you may have 6 or 7 or more children and within a few years be down to 2 or 3. You'd have the large number of children just so you could hope that a couple of them survive. Also, the rate of maternal death in childbirth was very high. It was not uncommon for a man to be married 2 or 3 times, getting a young wife each time. In fact, there are studies out now that suggest (plausibly) that one reason for the dramatic increase in the divorce rate is due to the fact that people live longer and that maternal death in childbearing has dropped dramatically. So, whereas for most people they only had to live together 5 to 15 years since the wife usually died, now people need to expect to live together for 30 or more years. These are all undeniable historical and sociological facts.

Of course, it must be said that all of these considerations are incidental to the actual discussion itself of whether it is always intrinsically and gravely evil to engage in contracepted sex.

Joe

It as been suggested that the person who wrote this three part series on their blog:

http://ochlophobist.blogspot.com/2007/02/orthodoxy-and-contraception-part-i.html
http://ochlophobist.blogspot.com/2007/02/orthodoxy-and-contraception-part-ii.html
http://ochlophobist.blogspot.com/2007/02/orthodoxy-and-contraception-part-iii.html

Write or re-write the Orthodoxwiki article. The blog entries and comments are worth reading. I have not had time to read the posts in this thread, but will later.

On this topic I have a few basic thoughts:

- It is primarily a pastoral issue.
- The patristic position does not allow for any sort of method of controlling or avoiding conception and regards the purpose of sexual relations as procreative and not unitive.
- The Catholic and majority Orthodox Churches do not adhere to the patristic tradition in this regard, and though saying different things, in actuality the hierarchs of both churches basically handle the matter in basically the same way.

I really don't want to engaged in this discussion as I am VERY tired of talking all the time about sex and especially so during the fast ... but I did want to point out that scholars are by no means unified in their views of what the fathers actually taught about contraception, etc. So while what Joe wrote is one scholarly opinion, it is not the only defensible position for a scholar (for example, after much study I have a different opinion of what the fathers taught and disagree with Joe on several fundamental issues).

I wanted to make sure that people in this Forum understood the complexity of this issue.