Responses to Ofcom’s Consultation on Equalities Impact Assessments

The consultation by Ofcom on Equality Impact Assessments is a significant initiative that holds the potential to shape the future of UK broadcasting and media policy. It represents an opportunity to align the guidance with Ofcom’s current approach to assessing impacts, considering the varying duties across a broad range of sectors, and recognizing the importance of qualitative impacts in assessing some policy decisions. The proposed changes could have far-reaching implications for the broadcasting and media landscape in the UK, influencing how policy decisions are made and how their impacts are assessed.

However, it is disappointing to note the relatively low number of responses from organisations to this consultation. Given the importance of the issues at stake, a wider range of perspectives and inputs would have been beneficial. The limited response could potentially result in a less comprehensive understanding of the potential impacts of the proposed changes, and may limit the effectiveness of the new guidance in achieving its intended goals.

This situation underscores the importance of active engagement by all stakeholders in such consultations. It is crucial for organisations in the broadcasting and media sector to participate in these discussions, to ensure that their views and concerns are considered in the shaping of future policy.

Here are the summaries of the documents submitted and listed by Ofcom:

  1. Belong: Belong, a national charity promoting cohesion, highlights the need for the guidance to consider the impact of all forms of communication on social cohesion, both nationally and locally, and in relation to specific groups. They suggest that Ofcom should be more mindful of ‘place’ and consider local areas as well as national perspectives. They also express concern over the decline of local impartial sources of information, which makes it difficult to counter negative and divisive voices.
  1. Better Media: Better Media agrees that Ofcom’s impact and assessment processes have important consequences for citizens and consumers. They believe that Ofcom should act in accordance with the terms of the Equality Act in all its operations, particularly those that affect minority communities who have limited access to lobbying and engagement with Ofcom. They also suggest that Ofcom should regularly review its intervention strategies as changing circumstances may necessitate different approaches.
  1. BT: BT’s response to Ofcom’s consultation document on impact assessment was issued on March 17, 2023. The document is non-confidential, and the issue version is v1.0 as of May 17, 2023. BT suggests that Ofcom should consider the impact of its proposals on investment, which is a key driver of longer-term innovation and competition. They also recommend that Ofcom backs up qualitative assessments with evidence.
  1. Communications Consumer Panel and ACOD: The Panel and ACOD support the review as a cornerstone for a fair communications market for consumers, citizens, and micro-businesses. They raised points to Ofcom colleagues, including the ongoing statutory duty to promote equality of opportunity, considering intersectionality in equality of consumer outcomes, and the need for responsibility at Board-level to embed impact assessments across the organization.
  1. Degnan P: A 64-year-old disabled man has criticized Ofcom for failing to consider the impact of their actions on individuals like himself. He purchased a DAB radio for the launch of SSDAB in Leicester, but it did not work, and he has not received a response to his email. He believes Ofcom is unfit for purpose and treats the general public with contempt and bias.
  1. Leicester Community Radio: Leicester Community Radio has submitted a response to Ofcom’s Impact Assessment Guidance consultation, highlighting their unsuccessful attempts to gain a license to cover the Leicester Urban Area and the lack of locally based community or commercial stations serving their unique demographic. They argue that all parties should have equal access to spectrum and that deprived socio-economic groups should have access to programs and services that cater to them.
  1. Name Withheld: The respondent supports equal access to the spectrum but asks Ofcom to remember minority groups who may be disadvantaged in obtaining broadcast licenses. The respondent works with minority groups who see radio as an essential lifeline and is concerned about their exclusion from the airwaves.
  1. Openreach: The document could not be summarised due to technical issues. It wasn’t possible to extract a summary from the Openreach response document due to its content structure. It seems the document might contain non-textual elements, or the text might be formatted in a way that makes it difficult to extract meaningful information.
  1. Vodafone: Vodafone has responded to Ofcom’s consultation on revised impact assessment guidance, stating that Ofcom’s independence is crucial for its effectiveness as a regulator. Ofcom should align with the government’s approach to regulation, draw clearer distinctions between sectors, and have a bias against intervention. Impact assessments should be subject to earlier and independent scrutiny, and summaries should be provided for transparency. Ofcom should publish an impact assessment for all guidance issued and post-evaluate to achieve a better regulation regime.
  1. Vodafone Annex: The report discusses Ofcom’s approach to impact assessments, providing guidance on best practices for conducting them. It examines Ofcom’s approach to consumer switching for fixed and mobile services, simplifying non-geographic numbers, and enabling people to share data with innovative services. The report concludes with a summary of findings and recommendations, along with a draft template for summarizing impact assessment decisions.
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