Please complete this form in full and return to 080review@ofcom.org.uk.
| Consultation title | Consultation: Electronic Communications Code of practice |
| Full name | Stefanie Norman |
| Contact phone number | |
| Representing (delete as appropriate) | Organisation |
| Organisation name | Federation of Communication Services |
| Email address | snorman@fcs.co.uk |
Confidentiality
We ask for your contact details along with your response so that we can engage with you on this
consultation. For further information about how Ofcom handles your personal information and your
corresponding rights, see Ofcom’s General Privacy Statement.
| Your details: We will keep your contact number and email address confidential. Is there anything else you want to keep confidential? Delete as appropriate. | Nothing |
| Your response: Please indicate how much of your response you want to keep confidential. Delete as appropriate. | None |
| For confidential responses, can Ofcom publish a reference to the contents of your response? | Yes |
Your response
| Q1. Do you have any comments on our proposals relating to improving the clarity of the Code of Practice? |
Confidential? – N The FCS agrees it is important for the CoP to be clear, particularly for site providers who may not be familiar with the relevant legislation. The FCS agrees with the changes designed to improve the clarity of the CoP. The proposed CoP is however longer than the old one and care must be taken that it doesn’t become too daunting a read, particularly for site providers. |
| Q2. Do you have any comments on our proposals relating to including legislative changes in the Code of Practice? |
Confidential? – N It is important that the CoP reflects the current legislative regime and so the FCS welcomes the updates reflecting recent legislative changes. |
| Q3. Do you have any comments on our proposals relating to the definition of ‘Site Provider’ in the Code of Practice? |
Confidential? – N The FCS is comfortable with the proposed definition of “site provider”. However, it will be important that landowners/occupiers identify with this description and it may be useful to review this point when the CoP is next revised. |
| Q4. Do you have any comments on our proposals relating to contact information in the Code of Practice? |
Confidential? – N The FCS is comfortable with the proposals in this area. |
| Q5. Do you have any comments on our proposals relating to professional fees in the Code of Practice? |
Confidential? – Y / N The FCS is comfortable with the proposals in this area. |
| Q6. Do you have any comments on our proposals relating to responding to a request for access in the Code of Practice? |
Confidential? – Y / N The FCS agrees that the proposals in this area reflect the legislative changes. The FCS believes that Ofcom should review the use of ADR as part of the process to understand the impact it has on overall timescales. |
| Q7. Do you have any comments on our proposals relating to electromagnetic fields exposure in the Code of Practice? |
Confidential? – N The FCS is comfortable with the proposals in this area. |
| Q8. Do you have any comments on our proposals relating to the sharing and upgrading of apparatus in the Code of Practice? |
Confidential? – N It is important that the CoP is updated to reflect the legislation in relation to sharing and upgrading of apparatus. Sharing and upgrading of apparatus is key to the efficient delivery of telecommunication networks and is particularly important to smaller CPs. Whilst not directly related to the CoP review, FCS members have raised issues citing difficulties with agreeing commercial terms for sharing, and the FCS believes that this is an area for ongoing Ofcom scrutiny. The tone of this section is slightly more legalistic than the rest of the CoP, which might reflect the subject matter. However, it is important that the CoP is accessible to all, particularly those who are not familiar with the legislation. |
| Q9. Do you have any comments on our proposals relating to ADR in the Code of Practice? |
Confidential? – N The FCS agrees that the changes reflect the legislative position. The FCS suggests that Ofcom reviews the impact of ADR on the timescales for settling disputes. |
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Q10. Do you have any overarching comments on our proposals for the Code of Practice (included in its entirety in Annex 2 above)? |
Confidential? – N The FCS believes that the CoP is an important document. It is important that the behaviours expected of both operators and site providers is clear. In particular, it needs to be a useful document for site providers who will probably not be familiar with legislation in this area. It is important that the document remains up to date and written in plain language to aid this understanding. |