I thought our readers would be interested in a follow-up to Luke’s earlier post on the Ofcom consultation process and, in particular, his thoughts on ‘comments on comments’. Here is the relevant FCC regulation for comparison purposes (cite = 47 C.F.R. sec. 1.415):

Sec. 1.415 Comments and replies. (a) After notice of proposed rulemaking is issued, the Commission will afford interested persons an opportunity to participate in the rulemaking proceeding through submission of written data, views, or arguments, with or without opportunity to present the same orally in any manner.

(b) A reasonable time will be provided for submission of comments in support of or in opposition to proposed rules, and the time provided will be specified in the notice of proposed rulemaking.

(c) A reasonable time will be provided for filing comments in reply to the original comments, and the time provided will be specified in the notice of proposed rulemaking.

(d) No additional comments may be filed unless specifically requested or authorized by the Commission.

Note: In some (but not all) rulemaking proceedings, interested persons may also communicate with the Commission and its staff on an ex parte basis, provided certain procedures are followed.

Applying that regulation to Ofcom’s recent Voice Services consultation would be fairly straightforward. Simply advance the ‘comment’ period to October 29th or thereabouts and keep the November 15th deadline for ‘reply comments’. The result: The process is not delayed, and evidence-based claims and policy arguments are peer-reviewed.