Both dedicated and novice Ofcom-bashers can have a go at the proposal contained in this consultation - Modifications to the Ofcom Metering and Billing Direction 2008.

On reading through one gains the impression that the proposed modification offers the potential for tolerated error rates to be compounded when multiple parties are involved in the billing process. A big clue is dropped by use of the word "materially" in paragraph 1.6.

It is not until one reaches paragraph 3.8 of the consultation document that this point is conceded.

The lesson is to never expect a "consultation" issued by an interested party to lay out the issues objectively. So long as everything is somewhere in the text, the "consultor" is free to summarise and present the material in any way it wishes. If there is a specific proposal then this will be done so as to achieve assent.

At only 25 pages and with only 13 items in the Glossary, this consultation is kindergarten stuff, suitable for beginners at Ofcom-bashing.

I am a firm believer in constructive engagement. I oppose the over-hasty and thoughtless attribution of improper motives, especially to junior personnel. Many of the problems with Ofcom are actually due to its constitution and role. Governments of all parties believe that the consumer interest in Telecoms is best served by the market mechanism, which Ofcom is required to support.

Anyone seeking to assess my personal credentials as an Ofcom-basher should review my writing and other comments more broadly than on topics covered within this forum. I am happy to connect my identity in the forum with my broader campaigning identity.

I am totally convinced that the progress which has been made on many issues covered in the forum is due to both the constructive engagement with Ofcom and the bashing which has been carried out by members, since long before I got involved with these issues. I look forward to further progress and am keen for beginners to get practised.