There is a perception that this point has been hashed through thoroughly by this time, but that perception is mistaken. While statements have been made on the subject from time to time, they have not been directly answered. The closest to an answer that we have seen was in a paper delivered to the official General Pastoral Conference in 2006, entitled “An Exercise in Parsing.”
I understand the knee-jerk reflex that some will have when this topic is touched upon: “Quick! Quote the relevant part of the adopted statement, and wash our hands of the matter!” However, that reaction doesn’t qualify as doctrinal discussion. Whether we like it or not, genuine discussion includes the possibility that either side might be won over, however strongly-worded their arguments may be. Quoting “the adopted doctrinal statement” is an attempt to end discussion, equivalent in effect to pulling rank. The only way to “win” in a theological discussion is to agree with clear scripture. Hopefully, both sides “win” in the end.
So read this thoughtful explanation of the term “representative ministry” from a certain controversial figure in recent ELS history:
[There is an opinion] that the public or official ministry of the church exists by means of a delegation of the private authority of every individual Christian to preach the gospel, administer the sacraments, and forgive and retain sins. We may call this the “representative ministry” definition, because it claims that whenever one Christian uses God’s word or sacraments “on behalf of” other Christians this is the divinely instituted public ministry of the word. According to this opinion, every time one person exercises the keys (or uses the means of grace, or teaches the word — the language varies) on behalf of believers, this is the divinely instituted public ministry of the word, whether it is a “full use” of the keys or a “limited use” of the keys. In either case it is representative ministry and that is what is divinely instituted, according to this opinion.
That quote came from a certain controversial writing, but has been mostly ignored because of the inordinate amount of attention lavished upon another paragraph (to the detriment and sorrow of all).
Another writing from a month prior says this, explaining the problem the author had with the concept of a divinely-instituted “limited public use of the keys.”
These texts allegedly address the matter of the church calling someone to exercise a limited part of the public ministry of the Word but none of them does. Nowhere does the New Testament speak of the church assigning the responsibility of teaching God’s word to someone who is forbidden to preside over the congregation, preach publicly, and administer the sacraments. What the specific duties of the deacons were is uncertain, but the Scriptures nowhere say that anyone taught God’s word but was not permitted to teach the entire congregation. Simply put, the very concept of a limited public use of the keys as this is set forth in the PCM document is foreign to the Scriptures. Nevertheless, these texts are cited as biblical proof that “the extent to which one is authorized by the call of the church to exercise the keys publicly is the extent to which one is in the Public Ministry of the Word.” Being “in” the Public Ministry of the Word to this or that “extent” is quite impossible if this office is the concrete office of preaching of the gospel and administering the sacraments.
Whereas the texts cited to prove a limited public use of the keys in the Bible don’t teach this, these texts do show that the Holy Spirit moves freely in giving His gifts to men. The Wauwatosa Gospel teaches that it is the evangelical activity of the Holy Spirit here and now in the hearts of Christians that constitutes the divine institution of the office in whatever form it may take. Here we see the Wauwatosa influence on the PCM document. John Schaller put it this way: “For whatever the Christian congregation decides upon to further the preaching of the gospel it does at the instigation and under the guidance of the Spirit of Jesus Christ.” The PCM document puts it this way: “But it is by divine right that one exercises that work on behalf of the Christians through whom the call has come.”
What is divinely instituted is representative ministry in whatever form it may take. When I argued at the microphone during the convention against applying Romans 10:15 (“how shall they preach unless they are sent?”) to the calling of a parochial school teacher I said that nowhere in the New Testament is a woman told to preach. The President of the Synod took issue with me and cited Mark 16:15, words that were spoken to the “eleven.” But the exegetical tradition to which we have become bound insists that this text teaches the giving of the means of grace to all Christians. The fact that nowhere in the New Testament is a woman told to preach must yield before this tradition. The fact that AC XIV refers to the call of men who are ordained and hold the concrete office of preaching the gospel and administering the sacraments must be reinterpreted to accommodate the new definition of the office. [emphasis added]
It should be noted that the author has focused in these quotations on part II.B of the PMW and any statements elsewhere that support it.
This is how the concerns were addressed in the 2006 GPC paper:
God permits, approves, blesses, and works through those external vocational arrangements that are made in an orderly way for the purpose of carrying out public activities that he wants to be carried out. But this does not mean that God has directly instituted all such external vocational arrangements. In fact, he has not. The PMW document acknowledges this when it says that those offices which have only “a limited public use of the keys” exist as distinct positions of responsibility — if and when they do exist — because of the church’s sanctified judgment, and not because of a divine command. If God has directly instituted something for the church, this would mean that the church cannot ordinarily do without it, and that the church would in fact be sinning against God’s will if it declined to have that divinely instituted thing. According to God’s will and institution, the church cannot do without the public use of the keys. More specifically, the church cannot do without the full public use of the keys. But the church often can do without specific external offices of one kind or another that are set up for the purpose of carrying out only a limited public use of the keys, or only a limited part of the Public Ministry of the Word. Such positions of responsibility are not commanded for the church of all times and places, and they are therefore not indispensable for the church of all times and places. [emphasis original]
Section II B of the PMW document is an elaboration on, and an explanation of, the “Public Ministry of the Word” in its wider sense. The focus and purpose of this section must be kept in mind when we consider the meaning of antitheses 8 and 9, which appear within it, and which can be a source of some confusion if they are not interpreted and applied according to their context. These antitheses state that “We reject the teaching that only those qualified to carry out a full use of the keys are in the Public Ministry,” and that “We reject the teaching that the Public Ministry is limited to any one divinely fixed form, that is, limited to the pastoral office to the exclusion of other teachers of the Word.” Understood contextually, these statements are simply reaffirming that there is indeed a legitimate “wider sense” of the phrase “Public Ministry,” which refers to the public use of the keys as carried out to any degree or level, from within any and all ecclesiastical offices. These statements should certainly not be understood as repudiations of the teaching that appears in section II A of the document: that the “Public Ministry of the Word” in its narrower sense does in fact refer exclusively to “the exercise of spiritual oversight” that is carried out (by divine design) only from within “the pastoral office”; and that the “Public Ministry of the Word” in its narrower sense does in fact require competency for a full public use of the keys. [emphasis original]
But let’s not forget that the “divinely instituted Public Ministry of the Word” — which is synonymous with the “divinely instituted preaching and teaching office” — includes two senses or meanings. From the perspective of the narrower sense of the phrase, we can say that when Jesus trained and sent the apostles, and entrusted to them the full public ministry of Word and sacrament, he was thereby inaugurating in and for the Christian church the full public use of the keys. This continues to be a defining trait of the Public Ministry of the Word in the narrower sense. Whenever the full public use of the keys is being exercised in an orderly and proper way, this is an example of the Public Ministry of the Word in the narrower sense — and of “the pastoral office,” from which, according to God’s command, the full public use of the keys is carried out. From the perspective of the wider sense of the phrase, we can say that when Jesus trained and sent the apostles, and entrusted to them the full public ministry of Word and sacrament, he was thereby inaugurating in and for the Christian church the public use of the keys. This continues to be a defining trait of the Public Ministry of the Word in the wider sense. Whenever the public use of the keys is being exercised in an orderly and proper way — either to the full extent by pastors, or to a limited extent by other ecclesiastical office-holders — this is an example of the Public Ministry of the Word in the wider sense.
The full public use of the keys includes within it, at least potentially, any and every limited public use of the keys. There is no divine institution of a limited public use of the keys per se. There is a divine institution of the public use of the keys, as a whole and in all of its parts, from which, in the church’s freedom, limited public uses can be vocationally extracted and entrusted to qualified individuals, according to the church’s needs and circumstances. Section II B of the PMW document explains that when the church in this way calls individuals to fill positions of responsibility involving only a limited public use of the keys, it is thereby separating, “by human right,” a “limited portion of the office” to such individuals, and is authorizing them to exercise or carry out only a “specific” and “limited part of the Public Ministry of the Word.”
The answer given in this paper does not provide the scriptural basis for a divinely-instituted limited public use of the keys. It says that such a thing does not exist. Instead, there is a divinely-instituted use of the keys (not “limited public”), and the Church has freedom and authority to entrust a limited part of that use to certain individuals.
Is that “representative ministry?” Yes, in a sense. (See how nuanced this discussion can be?) It is representative ministry, with the caveat that it is not divinely instituted. In other words, we may call it ministry simply because we need a word for it, and we want to call it that. By definition, it is ministry because it is a kind of service.
I have wondered why our doctrinal statement would take such care to describe what is more a matter of our choice than a matter of doctrine. That is, why not just let II.B say that the Church has freedom to entrust certain ministerial duties to individuals alongside the “office of oversight,” and call it finished? Do we have to pollute a summary of biblical doctrine with descriptions of what the Church has elected to do in her freedom? In my mind, this is one of the most important criticisms of the PMW. In its current form, it leaves itself open to the charge of teaching human traditions as though they were the Word of God.