They did a nice little summation of the response I sent them (see here for it in full) which comes out as
• One research organisation/consultancy submitted a response. They felt all costs should fall to copyright owners and that there should not be a fee for appeals. In their view the ’flat fee’ approach was flawed and the estimates of damage to the creative industry similarly flawed. Indeed they had serious reservations over the accuracy or methodology of the consultation and the Digital Economy Act.
Of course, they also lumped it in with “Individual and other intermediaries” in a 7.7MB pdf file , and again, discriminated against the disabled, and those wishing to make best use of the responses by importing them as images. So no screen-readers, or text enhancers (for the partially sighted/blind) and no way to copy text or follow links given as sources (and on page 10 some of the sources are cut off). From the quality, it's clear that they printed out the submissions, and then scanned them in as images, making a pdf document from that.
Incompetence isn't the word – it's not strong enough – to describe altering documents so they're less accessable, less usefull, harder to read in general, AND a larger file to top it off. No wonder they make such stupid decisions from the consultations, when even the basics of document handling are beyond them.
As for the decision, well, they've kept the 25:75 cost split. That means whenever a copyright holder decides their copyright is so valuable to them, that it needs enforcement, the ISP has to pay 25% of the enforcement costs (but not the detection costs at present, thankfully) That's right, the copyright holder decides, and yet the ISP has to pay, which means in the end all ISP subscribers will pay. Oh, and it'll cost the economy something like £500Million to implement this, to save £200Million. How does that make sense?
It doesn't. There is only one way it came about, and I'd like to stress that this is a statement I personally stand 100% behind, and you can quote me on it!
This is another example of the blinkered and back-assward methods typical of MPs who have a complete lack of common sense, but have a rabid desire to brown-nose to media darlings and the influential, even to the cost of selling out the country and substantially hampering any ability to restart the economy. This much would be – should be – obvious to anyone with even the most basic of education, but is clearly beyond the intellectual scope of the UK Government, both under a Labour Cabinet, or a Conservative/Lib-Dem coalition.
At least they've withdrawn their proposals to charge people for the ability to appeal, FOR NOW. Yeah, they're still keping it as an option, saying
“However, the Government will retain a power to impose a fee should there be a significant number of vexatious appeals.
It should also be noted that the issue of appeals fees may need to be revisited if and when technical measures are introduced.”
They're so worried about vexation appeals, and yet there's not been a single word, NOT ONE, dealing with vexatious accusations. Personally, I don't see this going far without a legal challenge that will scrap much, if not all of this stuff. Which will be another blow to the economy as all the money on this will be wasted., but then again, financial competence isn't a government virtue, anywhere around the world.
Note - the response document I'm sharing with is, in order
- The British Library,
- an unnamed individual,
- William Tovey from the UK Pirate Party,
- another unnamed individual,
- the Joint Academic NETwork, aka JANET,
- Law society of Scotland,
- Society for Computer and Law
- Universities and Collages Information Systems Association
If you were the person behind 2 or 4, let me know.
And of course, if you have a P2P detection system, I stand by my response, where I'd evaluate it independently, at cost - feel free to Contact Me.