Thursday, 9 April 2015

The EU And Telecoms (Part 2)

Following from part 1 we continue with part 2 where we explore more fully EU telecoms regulations and its current situation especially regarding Flexcit.

As happens in other areas of EU competence, laid down by the treaties, member states must adhere to the telecommunications chapter of the EU acquis and are bound together by network governance and by harmonisation measures as a consequence. These span shared policies and legislation, implementation and regulation, standards and the accreditation of qualifications.

It's interesting that what is often overlooked is the EU is a project not yet finished. It currently remains a work in progress following the engrenage (gearing) principle - the well established method to engineer another leap forward in integration, the slow, salami-slicing approach adopted by Jean Monnet.

This principle has the consequence that
while it continues a process of hollowing out member states competences and trying to move them up to EU level that there often occurs a period of absence of any competence at all. In this we are reminded of Booker's comment on a criticism of evolution:
Years ago...Attenborough himself [claimed] to 'prove’ Darwin’s theory by showing us a mouse and a bat, explaining how one evolved into the other. He seemed oblivious to the obvious point that, as the mouse’s forelegs evolved by minute variations to wings, there must have been a long period when the creature, no longer with properly functioning legs but as yet unable to fly, was much less 'adapted to survive’ than it had been before.
For the regulation of network industries there have been delegations of powers by governments of the member states to EU institutions, notably to the European Commission (EC), but also to their own domestic National Regulatory Authorities (NRAs). This was somewhat ad hoc and piecemeal in the 1980s and 1990s, however from the 1999 Electronic Communications Services review (COM(1999) 539 final, 10.11.1999) the intentions and the outcomes increasingly concentrated on a more systematic approach.

Yet there continues to be considerable variations between member states which the European Commission and the European Parliament sought to reduce the disorder and to complete the single market for telecommunications.

As we previously noted the UK regulator Ofcom - determined to breakup BT's monopoly further - used competition law powers under the Enterprise Act 2002 - itself a result of EU Directives - to come to an agreement with BT over a separate network access division called Openreach which would offer its wholesale products on an equivalent basis to both external customers and itself.

The establishment of Openreach and its relationship to external customers at the time was unique to the UK within the EU and its experience was studied by regulators in other European countries who experienced similar competition problems arising from the presence of a large incumbent telecommunications operator, such as France Telecom.

Viviane Reding, the European Commissioner who in 2006 was in charge of telecommunications regulation, took inspiration from the UK in forcing the "structural separation" of incumbent telecom operators into service and infrastructure divisions across the European Union.

With this in mind Reding unveiled proposals aimed at not only extending competition among telecom operators, but also the the idea of one single EU wide telecom regulator, to act as an umbrella organization for Member States' national regulators. Reding's proposals became the "review of EU Telecom rules: Strengthening Competition and Completing the Internal Market" which argued that:
"The most effective way to achieve a real level playing field for telecom operators across the EU would of course be to create an independent European telecom regulator that would work together with national regulators in a system, similar to the European System of Central Banks. In such a system, national regulators would continue to act as direct contact points with operators and could directly analyse the market. At the same time, a light European agency, independent from the Commission and from national governments, could ensure by guidelines and, if necessary, instructions that EU rules are applied consistently in all Member States."
Here Reding sought to achieve "a real level playing field" by tackling what she called the three issues; Firstly the need for more internal market integration for a more effective use of radio spectrum. Falling back on the traditional EEC/EU arguments of fish, pollution or 'climate change' which knows no country boundaries as a reason for extending EU competences Reding relies on this regarding spectrum:
Radio spectrum itself knows no borders, but it is managed at national level, normally in an administrative, bureaucratic way that creates scarcity by prescribing in detail what every part of the spectrum may be used for in that Member State.
I also believe that we need to put the idea of a European spectrum agency on the table...we have to recognise the competitive disadvantage the EU faces because, instead of having one single regime for spectrum management and spectrum licensing, as they do in the US, we have 25 different ones.
Reding also argued that with the "switch from analogue to digital TV there is a one off opportunity to re-use the analogue frequencies for new technologies". The second issue she addressed was better regulation:
"...a more consistent application of the EU telecom rules". In the telecom sector, where neither technology nor economic interest nor consumer behaviour know national borders any more, I see a clear, long overdue need to make the internal market a reality also in regulatory terms".
The third proposal was that there should be no "regulatory holidays" in the face of technological advances and with the liberalisation of the telecoms market should come “structural separation”:
Structural separation means that telecom regulators could require a dominant operator to provide non-discriminatory access to all operators by separating infrastructure provision from service provision to a greater or lesser extent. Today, the EU rules in force do not foresee structural separation as a regulatory remedy on the telecom markets. But I see that the United Kingdom, which has opted for a form of structural separation at national level, has made good experiences with this remedy. 
Her legislative proposal was for a European Electronic Communications Market Authority (EECMA) in which the EC sought a formal cooperation structure to remedy the lack of coherence within the internal market, which included “a fragmentation of European markets” and the absence of mechanisms for authorising cross-border services (e.g., mobile and IP-based services).

This proposal was significantly reshaped by the Parliament (which increased its own influence as a consequence) and the Council and, via Regulation (EC) No 1211/2009, became the Body of European Regulators of Electronic Communications (BEREC):
The main objective of this body is to enhance cooperation among national regulatory authorities (NRAs) and to strengthen the internal market in electronic communications networks.
BEREC consists of NRAs members where each is nominated per Member State. (NRAs from the European Economic Area (EEA) States only have observer status and are represented "at an appropriate level"). Thus BEREC consolidated the “official” status of NRAs despite having no democratic credentials.

BEREC itself conducts its business in secret and it attempts to justify this by claiming that there is often a special requirement to avoid public scrutiny and stakeholder involvement. We can see this secrecy, or 'independence' officially laid out under Regulation (EC) No 1211/2009 Article 4: Composition and organisation of BEREC:
The members of the Board of Regulators shall neither seek nor accept any instruction from any government, from the Commission, or from any other public or private entity.
In addition, there is a lack of clarity whether its decisions and opinions can be challenged in the EU courts alongside that it is unaccountable before the EU parliament, giving it a democratic and judicial deficit. Even the mechanism for engagement with BEREC is through consultations on terms determined by the organisation itself.

Aside from BEREC, further complications in European telecoms governance arise from earlier attempts at European harmonisation mechanisms via European Regulatory Networks (ERNs).

ERNs were established particularly with network sectors in mind; designed to respond to the multiplication of regulators and their uneven development. ERNs were an attempt to address by the need for greater co-ordination in implementing  regulation by member states. 

However within the institutional design of ERNs lies their genesis. Their design reflects acutely the difficultly of trying to move from national governance to one of supranational governance. Having been given grandiose tasks, the European Commission and national governments still maintained many powers. Here then we see the creation of double delegation, with powers "delegated up" from the NRAs and "delegated" down from the EU with the inevitable result of dissatisfaction:
The EU’s ‘double delegation’ to IRAs and the EU Commission has led to major and as yet unresolved problems of coordination and implementation.
Thus this means that ERNs can be seen as a ‘second best’ method of dealing with implementation of EU regulation; a compromise between EU 'colleagues' pressing for greater European integration and those member states, especially national governments, reluctant to endorse it fully. The compromise inevitably means that while more uniform regulation by coordinating approaches and functions was the intention, there has been little evidence of success in harmonisation and no attempts even to measure the effectiveness of the measures.

But within ERNs remains legacy EU regulatory telecoms governance that sits alongside and is distinct from BEREC, and this is apparent in the various EU bodies such as the Radio Spectrum Committee (RSC);
The Radio Spectrum Committee (RSC) is responsible for specific technical measures required to implement the broader Radio Spectrum Policy. The RSC is composed of Member State representatives and chaired by the European Commission.

Established by the 2002 Radio Spectrum Decision (676/2002/EC), the Radio Spectrum Committee (RSC) is assisting the Commission for the development of technical implementing decisions to ensure harmonised conditions across Europe for the availability and efficient use of radio spectrum.
...and the Radio Spectrum Policy Group (RSPG) which enables Member States, the Commission and stakeholders to coordinate the use of radio spectrum.

Here we can see that unlike the secret nature of BEREC, bodies such as the RSC and the RSPG within ERNs involve extensive consultation amongst all stakeholders, which include "regulatory authorities and the ministries having responsibility for radio spectrum related matters in each Member State", manufacturers, network operators and users.

RSC and RSPG are also part of the comitology process which allows the Commission to discuss its proposals with national administrations before implementation in order to ensure that any measure is optimised to the various national situations. Thus under these rules the following associations are permitted to be consulted:
Consumers:
The European Consumer Organisation (BEUC) - which brings together 40 European consumer organisations from 31 countries (EU, EEA and applicant countries). 
International Telecommunications Users Group INTUG - an international association of business users of telecommunication.
Operators:
European Communities Trade Mark Association ECTA - which in addition to having close links with the European Commission and the Office for Harmonization in the Internal Market (Trade Marks and Designs) (OHIM), ECTA is recognised by WIPO as a non-Government Organisation (NGO).
European Telecommunications Network Operators' Association  ETNO - who are pan-European operators and has been the voice of Europe’s telecommunications network operators since 1992

GSM Association GSMA- is an association of mobile operators and related companies devoted to supporting the standardising, deployment and promotion of the GSM mobile telephone system.

Manufacturers:
Digital Europe
We can see therefore that even under EU telecoms governance and the comitology process there is extensive consultation with international associations. A further example can be seen with the European Conference on Posts and Telecoms (CEPT). CEPT extends far beyond the EU, including the countries of the former USSR and currently includes 48 countries in its membership.

And it is with international relationships with the EU we will examine further in part three. But first we will look at the EEA agreement where although there is commitment to adhering to the EU telecommunications acquis there is more flexibility with regard to the implementation as per the EEA agreement.

And it's with the EEA's relationship regarding telecoms and the EU where we turn our attention to next.

Saturday, 4 April 2015

Comment Moderation

Rather tediously I've managed to attract an anonymous troll who seems to have been prompted by my previous post. 

With blogger, there's an option to ban anonymous posts - some kind of registration is required instead. However I refrain from that, largely because I want to allow comments to be as hassle free as possible and I very much welcome feedback even if it is critical.

But it is with some reluctance I've had to turn on comment moderation. This means that while all genuine posts will be published, there may be a slight delay in publication.

I apologise for the inconvenience.

Friday, 3 April 2015

Quote Of The Day

I thought the following quote rather wonderfully summed up the current mood on the general election campaign and the leaders' debates. This from a fellow Swindon Town fan:
Well, this leaders debate hasn't really helped much in revealing the best candidate has it.

You've got the self serving rich boy party, the racist party, the liar party, the tree hugging party, the hi-de-hi party, the braveheart party, and the 'not even the best Milliband' party.

Meh.
Quite.

Tuesday, 31 March 2015

UKIP: Thanks For Nothing

We've noted before on this blog UKIP's increasingly toxic tendency to blame "everything on immigrants". Previously it was Farage's assertion that he was held up on the M4 motorway due to the fact that "open door immigration has meant that the M4 is not as navigable as it used to be'".

That he was traveling by car early evening on a Friday around a notorious bottleneck on the M4 wasn't taken into consideration. Thus "bloody immigrants" was dog whistle politics writ large.

With this in mind it therefore comes as no surprise to see that Farage believes that immigrants are to blame for children not playing in the streets:
Britons are so ill at ease with levels of immigration in their towns that their children do not play football with their neighbours in the streets, Nigel Farage has said.
The UK Independence Party leader said people in eastern England felt a “deep level of discomfort” about the millions of immigrants who have settled in the UK in the past decade.
He said: “I want to live in a community where our kids play football in the streets of an evening and live in a society that is at ease with itself.
And I sense over the last decade or more we are not at ease"
It's not unfair in our view to believe that Nick Griffin would have been proud of these sentiments. That children may not, or cannot, play in the streets is often down to a myriad of factors, not least its illegal, it's unsafe and that many roads simply have too many cars - ironically Farage's children couldn't play outside his own house, in the street, for this reason alone.

In trying to remove ourselves from the EU however Farage's language is toxic. With what began as a eurosceptic party, has been hijacked by a man who has turned it into a self-promotional vehicle and is prepared as a consequence to condemn the eurosceptic movement in terms which hinder significantly the argument of getting out. So much so that we are set to lose before we even start.

With such language and thus with effectively a self-imposed glass ceiling on support, no wonder the media have begun to catch up with bloggers by noticing belatedly that UKIP's trend is on a downward trajectory.

With so-called 'UKIP strategy' we get a measure of the man when we see this:
“If we went to every town up eastern England and spoke to people about how they felt, their town, their city had changed in the last 15 years, there is a deep level of discomfort, because if you have immigration at these sorts of levels integration doesn’t happen.” 
Note the words "eastern England". It's an odd statement to make for a leader of a party named the United Kingdom Independence Party. What about Scotland, Northern Ireland and Wales where immigration is not necessarily such a vote winner - immigration has an uneven effect across the country.

But within "eastern England" is the constituency of Thanet South; where Farage is standing to be elected as an MP. It's also next door to where UKIP held its Spring Conference in Margate which had no mobile signal nor internet access.

A professional party with workable facilities at its conference less important than Farage's own campaign it seems. So no policies, no strategy, no exit plan just dog-whistle soundbites to get Farage elected.

Perhaps in this sense it will work and this will please the cult, but in getting us out of the EU no chance.

What a waste of 20 odd years...

Friday, 27 March 2015

An Ending



The Lib Dems used, rather ironically, Brian Eno's 'An Ending' music in a party political broadcast five years ago.

I guess given the state of the party going into the 2015 election and the sacking of Jeremy Clarkson, now is as good as time as any to revisit a classic and now relevant Top Gear segment.

Wednesday, 25 March 2015

Why A 2015 EU Referendum Cannot Happen (Update).


Following on from our previous post regarding the impossibility of a 2015 referendum, we contacted the Electoral Commission to try to clarify a number of further potential technical issues.

While, like most quangos, the Electoral Commission displayed a deep reluctance to commit themselves to answering certain questions posed, their first response confirmed our initial points that, contrary to Farage's assertion, a referendum cannot happen in a few weeks (quoted from the Electoral Commission's email):
Currently, we cannot say how the designation process will work at any future referendum until Parliament passes the legislation setting out the rules for that referendum. 

Our role is to regulate the referendum and designate campaigners under the rules for each referendum. The rules that applied at previous referendums required the Commission to designate campaigners that sufficiently represented those campaigning for the outcome they support, or, if more than one, represented those campaigning to the greatest extent.
This reiterates precisely our point that it means campaigning groups can't begin to officially campaign until they submit bids for the official "in" and "out" campaign and have been approved. With Scotland a campaign period of 16 weeks was the recommendation.

However the approval process is likely to take six months as also recommended by the Electoral Commission. This six month process cannot happen until after the referendum bill becomes law which in itself at best will take months.

Thus with the Electoral Commission's recommendations which considered the experience with Scotland (for recommendations, read demands) it becomes clear that a 2015 referendum is simply out of the question.

Saturday, 21 March 2015

If You Want To Be Strictly Accurate...

An interesting phenomenon which becomes apparent when being an established blogger is the nature of the readership - it never fails to amaze who actually reads the bog. Despite being dismissed as "electronic version of pub gossip", bloggers can sometimes make a real difference.

With this in mind it's interesting that for the first time this blog has had readership from the European Parliament. Since my previous post was published yesterday on why a 2015 EU referendum cannot happen the hit rate from the EU Parliament has been very significant.

It's hard to pin down influence of course, but sometimes media reports which belatedly begin to write about very familiar themes in similar language can be difficult to explain away as mere coincidences.

An example would be in a piece in today's Telegraph; 11 things we've learned about Jeremy Clarkson. The piece relates to Top Gear's Stig delivering a petition to the BBC's London headquarters to call for the return of the show's host, Jeremy Clarkson, while being transported on this - pictured below:


The vehicle is virtually identical to the one which was used during a protest outside the UKIP Spring Conference in Margate back in February:


It was universally described as a tank, however as EUReferendum noted:
If one wonders just how naff the Daily Mail can become, one just needs to visit the headline of their piece on the Ukip spring conference in Margate. There, we are told, the Ukipites were "gatecrashed" by "NAZI dancing troupe goose-stepping through Margate in front of a Second World War tank".

Notwithstanding any other errors, the vehicle in question is not a tank – it is an Abbot FV433 self-propelled gun. And it is not of World War II vintage. It was actually introduced into British Army service in 1965. I remember it well as, about that time, I was nearly flattened by one when it came hurtling down a track on which we had pitched our tent (don't ask).
Therefore and rather interestingly half way down Telegraph piece today, we have this by the author of the piece Anita Singh, Arts and Entertainment Editor:
A man dressed as Top Gear's Stig has delivered the petition to the BBC's London headquarters in a tank (or self-propelled artillery, if you want to be strictly accurate).
This provokes two interesting observations. One that given the media as a whole have described it as tank, that Anita Singh acknowledges accurately it might be something else such as self-propelled artillery - of where there is only one source to report this - suggests strongly blogs are read.

The second is the dismissive tone of describing self-propelled artillery as "if you want to be strictly accurate". These are two completely different types of military vehicle.

To give an analogy, in the spirit of Clarkson and Top Gear, we could say that the car pictured below is obviously a Mercedes-AMG GT which has 4.0-litre V8 biturbo and produces 462hp. This allows it to achieve 0-60 mph in as little as 3.8 seconds.

But of course "if you want to be strictly accurate" we would note the picture is actually one of an Enzo Ferrari.

What a good example that is of a newspaper publicly acknowledging that "being strictly accurate" is an optional extra.

Friday, 20 March 2015

Why A 2015 EU Referendum Cannot Happen.

As noted in the Independent last Sunday, Nigel Farage has indicated that he will support a minority Conservative Government if Prime Minster David Cameron promises a referendum in 2015:
"The terms of my deal with the Tories would be very precise and simple. I want a full and fair referendum to be held in 2015 to allow Britons to vote on being in or out of the European Union. There would be no wiggle room for 'renegotiation' somewhere down the line'.

"The EU is facing an existential crisis and, given that it only takes a few weeks to launch and organise a referendum, it should be held in 2015.”
Although we would largely agree with the sentiments of a "full and fair" referendum, we would take issue with the "very precise and simple" demand that a referendum should be held in 2015 and "given that it only takes a few weeks to launch." For the very precise and simple reason that it can't be done. Farage is offering impossible terms on the practicality of timescale.

To support Farage's demands comparisons are sometimes made with the 1975 referendum where it is claimed that it is possible to have a referendum in a few weeks, the timeline often quoted is as follows:
December 1974: Harold Wilson requests renegotiation of EEC membership terms.

European Council agreed to new terms for UK in Dublin by 11 March 1975 and renegotiation largely ended.

26 February 1975: White Paper announcing referendum to be held after result of renegotiation was known

26 March 1975: Referendum Bill published.

31 March 1975: White Paper setting out the results of the renegotiation of the UK membership of the EC.

9 April 1975: after a three-day debate on the Government’s recommendation to continue Britain’s EC membership, the Commons voted 396 to 170 to continue in Common Market on the new terms. At the same time Government drafts Referendum Bill, to be moved in case of a successful renegotiation.

On 22 April 1975 the House of Lords approved continued membership by 261 votes to 20.

Post-legislative referendum held 5 June 1975. Referendum not directly related to White Paper on renegotiation, but preamble referred to renegotiation. Question much broader: “Do you think the UK should stay in the European Community (Common Market)?” The result was 67 per cent in favour on a 65 per cent turnout.
As we can see in 1975 the passage through Parliament to holding a referendum took circa 10 weeks (26 March - 5 June) from publishing the Bill to holding the Referendum. The 1975 Referendum book though notes (p.66):
"But the real reason for the unexpectedly easy passage of the Bill was political: pro-Marketeers were in an overwhelming majority in the House of Commons and they had belatedly realised that the referendum would go their way."
Even with an easy passage it still took two and half months to have a referendum. The election in 2015 is in May, then there's a summer recess so we can expect it to take longer. Especially when we consider that due to the complexity of an EU that has significantly evolved in over 40 years of UK membership and the less certainty of a referendum result, that its passage through Parliament will be more turbulent and difficult.
 
We have noted before regarding trying to win a referendum, 1975 is not 2015. The country has moved on in forty years. Procedures are now different, for example in 1975 the campaign started in January 1975 long before the Referendum Bill had been passed - with self-appointed "umbrella" groups.

However unlike 1975 referendums are now the responsibility of the Electoral Commission, which was established under Political Parties, Elections and Referendums Act 2000. Thus on that alone the timescale in comparison to 1975 has changed.

With the establishment of the Electoral Commission it means that campaigning groups can't begin to officially campaign until they submit bids for the official "in" and "out" campaign and have been approved. This process cannot happen until after the referendum bill becomes law.

There has to be a reasonable period to allow the Electoral Commission to invite submissions and make the designation, and then the lead organisations must be given time to organise themselves.

As we can see from the Electoral Commission December 2014 report on the Scottish Independence Referendum held on 18 September 2014, it recommends (my emphasis):
... that in planning for any future referendums, not only in Scotland but also those held across or in other parts of the UK, governments should aim to ensure that legislation (including any secondary legislation) is clear at least six months before it is required to be implemented or complied with by campaigners, the Chief Counting Officer, Counting Officers or Electoral Registration Officers.
Thus "a reasonable period" according the Electoral Commission amounts to six months, as it argues to allow for (again my emphasis):
The benefit of this additional time was passed on to campaigners, EROs and COs in preparing for their respective roles at the referendum:
Campaigners were able to engage constructively with the legislative process and had time to develop an understanding of the relevant guidance and rules, before they came into force. EROs and COs benefitted from sufficient time to put robust plans in place for the delivery of their responsibilities under the legislation, from targeted public awareness activity to the booking of polling places and the training of staff.
In addition the Electoral Commission also recommends (again my emphasis):
2.39 Following the 2011 referendum on additional powers for the National Assembly for Wales and the Parliamentary Voting System for the House of Commons, we recommended that for future referendums the detailed rules should be clear at least 28 weeks in advance of polling day, based on a statutory regulated referendum campaign period of 16 weeks.
Although the Electoral Commission cannot demand, where it recommends will be taken into account should there be a challenge to the Bill and it goes to a Judicial Review as undoubtedly it would should there be any form of corner cutting or fast-tracking.

Yet even with a relatively smooth process by the Electoral Commission's recommendations there would be a ten month delay between an Act of Parliament and a vote: that obviously takes us well into 2016.

In addition Farage thinks he can determine the referendum question:
 "Do you wish to be a free, independent sovereign democracy?"
Despite the fact that the Electoral Commission has already put forward its proposals for the referendum question - its full report is here, Farage's suggestion wouldn't even pass the unambiguity test let alone the neutral one.

At this point I don't know what to conclude. Either Farage is very poorly briefed which is a reflection on a lack of a decent research department despite having (now) 22 very well paid MEPs or he knows this and is deliberately demanding conditions that Cameron (or indeed anyone else) cannot possibly meet.

The latter of course allows UKIP to put forward the criticism that Cameron cannot be trusted which conveniently helps prop up Farage's position. If one is to be cynical there's nothing better than having a perpetual enemy to oppose to justify your own existence, especially in the absence of any party polices.

Either way the eurosceptic movement is being very poorly served by UKIP.

Tuesday, 17 March 2015

Captain Ranty


Going by twitter it appears that the blogger Captain Ranty has sadly passed away. Captain Ranty was a vigorous and very honest blogger and his blogging popularity was vividly highlighted to this blogger by the fact he was simply one of the biggest traffic sources to this blog via his blogroll. The hit rate was staggering.

Captain Ranty's philosophy and belligerence of "Freeman stuff, Lawful Rebellion stuff and Random stuff was always an inspiration. However it's been clear for some time that his recent posts have expressed a deep personal sadness. Perhaps in this context he's done something silly. I don't know.

Although I never had the pleasure in meeting him, he will be much missed in this corner of the internet. But we'll carry on the fight in his name.

Goodnight Captain...

Why The Pro-EU Telegraph Uses The Term 'Norway Model'

A recent Telegraph editorial, which is an unashamedly pro-EU paper, not unsurprisingly includes information from the recently outed pro-EU think tank Open Europe:
At first blush, then, today’s report by the think tank Open Europe on the costs of EU regulations to Britain should push the prime minister to head for the exit. The burden of the costliest 100 regulations to our economy is £33 billion, it says. And while the apparent benefits total more than £58 billion, some £46 billion of this derives from three items “which are vastly over-stated”. Financially, it seems, we are losing out.
By reducing the argument down to cost and economics means that it becomes divisive for the eurosceptic movement to its detriment as Richard North notes:
The trouble is that EU regulation, and how much money we may or may not save from leaving the EU, constitute the type of "biff-bam" arguments that the media love to report. But the two sides getting bogged down in such arcane details is precisely the wholesale turn-off for the general public that we need to avoid. If we are going to make any progress, the economic issues should be neutralised and "parked", not endlessly chewed over by a bunch of hyperactive think-tank wonks and ill-briefed politicians.

What we are seeing, therefore, is incompetent campaigning from both sides – although the need to overcome the status quo effect imposes greater demands on the "out" campaign. Equal incompetence means we lose. Either way, though, the anti-EU movement is being poorly served. And if we can't even trash the OE nonsense, we deserve everything we get.
Similarly arguing that the EU can be reformed has the same effect when trying to win a referendum. No wonder the pro-EU Telegraph is so enthusiastic in adopting such tactics.

Interestingly, and far more dangerously, Business for Britain whose Chief Executive is Mathew Elliot who is very keen to be the official out candidate for a referendum uses precisely the same arguments and terminology as pro-EU Open Europe and the Telegraph. Business for Britain's daily email briefings are virtually identical to Open Europe's.

No doubt Tory central office will be over the moon if Elliot would be the official candidate for the out campaign in a referendum.

Any genuine euroscepetic knows that the EU hides in plain sight that its raison d'etre is all about political union and has been from the outset. To ignore that as a eurosecptic movement could be described as dishonest. Thus by neutralising the economic arguments it allows us to concentrate on the fundamental principle that the EU is all about political union by its own admission.

Neutralising the economic arguments involves invoking the Norway Option, and more specifically Flexcit, by adopting the off the shelf EEA solution as a temporary measure allows us to negate the inevitable FUD threat in a referendum.

And it is a threat that the pro-EU press such as the Guardian and City AM fully recognise. If they didn't they wouldn't spend so much time in trying to undermine the argument.

With this mind, it is interesting that the Telegraph uses the phrase "Norway model" rather than the usual term "Norway Option";
The so-called “Norway” model – leave the EU but remain part of the European Economic Area.
A quick internet search suggests why; a search for the term 'Norway Model' is likely to result in links to copious pretty Norwegian women:

Conversely a search for the 'Norway Option' results in this and this:

This is cynicism by the Telegraph of the highest order, and this is an example of the dirty tricks we face. The eurosceptic movement as a whole needs to wise up...otherwise we will lose.