Four of these amendments are still technically open and pending, one is closed and has failed by its own terms, and one is closed and has failed by the terms of the resolution proposing it. All totaled, approximately 11,539 measures to amend the Constitution have been proposed in Congress since 1789 (through December 16, 2014). Proposing amendments Article V provides two methods for amending the nation's frame of government. The first method authorizes Congress, "whenever two-thirds of both houses shall deem it necessary", to propose Constitutional amendments. The second method requires Congress, "on the application of the legislatures of two-thirds of the several states" (presently 34), to "call a convention for proposing amendments". This duality in Article V is the result of compromises made during the 1787 Constitutional Convention between two groups, one maintaining that the national legislature should have no role in the constitutional amendment process, and another contending that proposals to amend the constitution should originate in the national legislature and their ratification should be decided by state legislatures or state conventions. Regarding the consensus amendment process crafted during the convention, James Madison (writing in The Federalist No. 43) declared: Each time the Article V process has been initiated since 1789, the first method for crafting and proposing amendments has been used. All 33 amendments submitted to the states for ratification originated in Congress. The second method, the convention option, a political tool which Alexander Hamilton (writing in The Federalist No. 85) argued would enable state legislatures to "erect barriers against the encroachments of the national authority", has yet to be invoked. When the 1st Congress considered a series of constitutional amendments, it was suggested that the two houses first adopt a resolution indicating that they deemed amendments necessary. This procedure was not used. Instead, both the House and the Senate proceeded directly to consideration of a joint resolution, thereby implying that both bodies deemed amendments to be necessary. Also, when initially proposed by James Madison, the amendments were designed to be interwoven into the relevant sections of the original document. Instead, they were approved by Congress and sent to the states for ratification as supplemental additions (codicils) appended to it. Both these precedents have been followed ever since. Once approved by Congress, the joint resolution proposing a constitutional amendment does not require presidential approval before it goes out to the states. While Article I Section 7 provides