Ofcom has announced a consultation on Citizens, Communications and Convergence.

This is based on a "discussion paper" that is hoped to "stimulate debate" about Ofcom's distinct duties to consumers and citizens.

My own views on this matter have been widely expressed and published.

I would briefly summarise these as being that any matter within the scope of Ofcom's responsibilities that cannot be resolved through the interplay between providers of telecommunications services and consumers of those services must fall under Ofcom's duties to citizens.

Ofcom's failure to classify those who provide services using "revenue sharing" telephone numbers as being providers of "premium rate services" means that they are not thereby classified as providers of telecommunications services. Ofcom therefore has no duty to those who purchase their services as consumers.

In the same way, those who receive Silent Calls are not consumers of those who call them (so far as Ofcom is concerned) unless the Silent Call is made by the victim's own telephone service provider.

Those who are interested to engage in discussion about Ofcom's role and responsibilities may be interested to participate, subject to well known concerns about the effect of Ofcom consultations. This is however only said to be a matter for discussion.

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Is this not defined in the Communications Act?

Dave wrote on Jul 12^th, 2008 at 10:08pm:

No. Not in detail, although the implications of what is meant may be derived from the declaration of specific duties and powers. That is not however definition.

The only relevant point is the clear distinction between the duties to a) citizens and b) consumers. These are said to potentially conflict and so must be distinct.

I have even researched the parliamentary debates on the Communications Bill, including the lengthy proceedings of the joint select committee that preceded its presentation. There is not much light to be found there either.

Ofcom clearly wishes to engage in "discussion" of this issue. This could be with good or with bad motives.

The closing date for this consultation is NEXT WEDNESDAY 8 October.

I am working on my response over the weekend.

There are no specific questions, so I am sure that any general comment would be accepted (subject to normal rules of courtesy). Ofcom's open invitation is as follows (my emphasis):

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