Citizen participation in regulatory policy-making is an interesting concept. Of course, the commenter above is correct to some extent. Complex technical problems are perhaps best solved by expert organisations like Ofcom. Entities like Ofcom have large research budgets and skilled personnel. They also have the ability to coordinate otherwise fragmented resources and focus them on a particular problem or opportunity. Organisations like Ofcom can therefore presumably tackle problems that are often beyond the reach of ordinary people.

The commenter seems to suggest three things: (i) individuals make value judgments and that somehow makes them different from others (presumably governments and corporations); (ii) individuals are less equipped to deal with complex matters; and (iii) individuals do not typically have any claim to represent social groups. Each of these claims is true some of the time and false some of the time. But, consultation needs to be put into context. It is a source of information for the regulator, not a rationale for decision-making in its own right. Like any recipient of information, Ofcom merely needs to be open to persuasion, but critical.

Ofcom should give full weight to any comment, from any source, that makes cogent arguments for the position it advocates. It’s that simple. If a large organisation like the BBC makes poor arguments and a member of the public makes sound arguments, I would expect Ofcom to give the individual’s comment greater weight. And vice versa. I’ve probably read thousands of comments submitted to Ofcom, DCMS, the U.S. FCC, etc., in my career and I personally have never observed any correlation between analytical brilliance and the resources of the commenter.

Ofcom and similar regulators do not operate in a mistake-free environment. So, citizens can have a beneficial impact on regulation by pointing out problems, asking the regulator to consider an issue from another perspective, etc. Sometimes it takes a member of the public to get the regulator to focus on real-world problems instead of theorising about the future! Just consider the excellent work done by David Hickson to publicise (and analyse) the problems associated with silent calls. From my vantagepoint, Hickson was initially serving UK consumers on this issue more aggressively than Ofcom. Another example? James Enck regularly features brilliant analytical pieces about telecoms regulation on his website. In fact, the very existence of OfcomWatch supports the notion that ‘random members of the public’ can make a difference.

Finally, note the irony, folks. All of Europe’s media and communications policy-makers listen to the value judgments of one individual: Viviane Reding of the European Commission, InfoSoc.

I prefer James Enck.