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G4EBT  > OFCOM    04.09.05 15:17l 170 Lines 6743 Bytes #999 (0) @ WW
BID : 0B0634G4EBT
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Subj: Ofcom & AmRad 1,000 responses!
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From: G4EBT@GB7FCR.#16.GBR.EU
To  : OFCOM@WW


On 26 May 2005, Ofcom published a consultation document on a proposal to
reform amateur radio licensing to provide a lighter, electronic licensing
process.
 
Any members of the public - radio amateurs, organisations representing
amateurs, companies involved in amateur radio - anyone, was free to 
respond to the consultation proposals, either online or by post.  

The consultation period closed on 18th August, 2005.

The Radio Society of Great Britain claims that Ofcom is "arrogant", and
scaremongering RSGB adverts in Practical Wireless and Short Wave Magazine
have recently cast Ofcom the role of the "Grim Reaper".

That advert was headed: 

             "Licence for Life = Deregulation.
    "Deregulation = Death of Amateur Radio in Five Years"

It went on: 

Quote:

Imagine a country where the "friendly" radio administrator says "I'm
feeling generous, you can have your amateur radio licence free and tell 
you what, for life as well.

Two years later, the friendly administrator says "Actually, this free
licence is expensive to run - no more licences are required. Anyone can
operate without a licence.

A little later, the not so friendly regulator says "these amateur radio
operators create all sorts of interference problems and someone else wants
to buy the spectrum - let's bin amateur radio and sell the spectrum.

COULDN'T HAPPEN HERE COULD IT? IT COULD!

So back the RSGB in the protection of Amateur Radio from any form of
Deregulation.

End quote.  

The background to the advert shows Ofcom HQ, with a picture of the "Grim
Reaper" standing in a hooded cloak, with a scythe in his hand ready to
swing it.

If it doesn't breach the Advertising Standard Authority Code of
Advertising Practice, it comes very close. It's highly irresponsible for
RSGB and the two main long-established magazines to feature such offensive
adverts. 

It will surely backfire on them big-style. Far from gaining new members, 
it will, and has, risked losing long-established ones - I'm not the only 
one to resign in disgust.

The RSGB statement demonstrates a woeful lack of knowledge of Ofcom
funding arrangements, and suggests that Ofcom - which has a statutory duty
to keep the spectrum clean, for which funding comes centrally - not from
the licence fee (if there is to be one) will allow chaos to reign over the
airwaves.

RSGB has royal patronage, and claims to "represent all radio amateurs",
whether members or not. It implies that Ofcom won't take any notice of
individual amateurs, but that's patently wrong.

There's a danger that because RSGB claims to "represent all amateurs", 
that it's views, and the adversarial style of its response to Ofcom, is
"representative of all amateurs". Thus, there's a risk we'll all get 
tarred with the same brush as RSGB.

I'm not alone is in saying that as a member of RSGB for more than 30
years, I don't want to be associated with this offensive style of
representation, and to distance myself from it I've therefore resigned.

The advert was the last straw in what's been a complete debacle by RSGB 
in its dealing with Ofcom for most of 2005. Months ago I gave up on RSGB
being able to effectively deal with Ofcom on a mature businesslike
footing. 

Like others, I've been in discussions and correspondence with Ofcom for 
some time about deregulation, and suggestions as to how the licence might
best be updated.

Far from finding Ofcom "arrogant" I've found their staff at every 
level to be courteous, approachable and professional. Maybe I've just 
been lucky? 

RSGB could, and should, have taken the opportunity, as a secondary issue, 
to engage in discussions with Ofcom about updating BR68 - The Terms and
Conditions of the Amateur Radio Licence, to bring it into line with
modern parlance, and to meet the needs of the third millennium.

The document is so shot through with gobbledygook, "legalese" and
ambiguous term that even senior Ofcom staff don't understand it without
recourse to legal guidance, so what chance does an amateur have  unless
he's a lawyer?

Try asking Ofcom what's meant by:  

"Without limitation to the generality of the foregoing" or "remarks of a
personal character". 

It's good fun to have the answers to hand to help them when their eyes
glaze over and they look baffled, but that only serves to illustrate what 
a mess the document is. It makes reference to various Statutory
Instruments which - even if amateurs had to hand, most wouldn't
understand.

Government departments are expected to write documents in plain English. 
Most sectors of the public service are aiming for the Crystal Mark, 
awarded by the Plain English Campaign. If ever there was a document 
that needed this treatment, it's BR68.

The Crystal Mark isn't a new thing either - it was introduced in 1990 
as the public's own "seal of approval" to encourage organisations to
communicate clearly with the public. 

The Crystal Mark is now firmly established in the UK as the standard 
that all organisations aim for when they produce public information. 

The mark also appears on documents in countries such as the USA, Australia
and South Africa. More than 1,000 organisations know that only Plain
English Campaign's Crystal Mark will be accepted by the public as a
guarantee of a document's clarity. (So should Ofcom).

The Plain English Campaign won't give the Crystal Mark to any document
unless their testing methods shows it can be read, understood and acted
upon by the intended audience.

And what does RSGB do?

Say's "it will fight any attempts at de-regulation". 
 
In response to recent correspondence I've had with them, Paul Fonseka of
Ofcom - obviously working late, rang me at home at 7pm on Friday last, and
e-mailed me minutes later. I don't call that arrogant - I wonder how many
RSGB staff were at their desks at 7pm on Friday in Bank Holiday week?

Paul advised me that there have been more than 1,000 responses to 
Ofcom's consultation process on deregulation.

With effect from January 2005, the Freedom of Information Act 2000 
allows anyone the right to ask for information held by Ofcom (or 
any other organisation). 

Hence, all of the feedback responses to consultation can be read online
and downloaded as desired in PDF format. More than 300 are anonymous - the
rest have names, and where stated, call signs.

A glance at a few will show that radio amateurs have responded sensibly, 
and in more measured tones, than has the RSGB. The responses can be viewed
at:

http://www.ofcom.org.uk/consult/condocs/aradio/responses/?a=87101


73 - David, G4EBT @ GB7FCR

Eddystone User Group Member
G-QRP Club Member No: 1339

QTH: Cottingham, East Yorkshire.

Message timed: 11:05 on 2005-Sep-04
(Registered).


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