The latest report from Ofcom reviewing the BBC’s performance highlights three main areas of ongoing concern. The way that young people engage with the BBC’s services, the way that the BBC represents all of British society in its programming, and the way that the BBC affects commercial activity in the marketplace. Ofcom has a legal duty to provide oversight of the BBC and its role as the major public service broadcaster in the UK, and is asking the BBC to be more specific in its planning and reporting about how it intends to deal with these challenges.
It is reported by Ofcom that the BBC faces losing a generation of people, and asks how the BBC intends to make their media services more relevant to younger people. The BBC have cited ongoing content produced on-demand, such as the BBC content on the iPlayer and the introduction of BBC Sounds as a destination for sound-based content, including podcasts as well as radio. As the report states
“As well as securing its future sustainability, broadening its appeal to young people is critical to ensure that it remains a universal service and that all audiences across the country are benefitting from the public value that the BBC’s content should be providing to them and it delivers its remit to serve all audiences” (Ofcom, 2019, p. 14).
What strikes me about the framework that Ofcom has set, and the BBC’s response, however, is that they are missing some essential issue that need to be explored in greater detail and given a critical focus that comes from outside of the traditional thinking of broadcast and mainstream media services.
For examples, the report doesn’t identify if opportunities exist for young people to get involved in the decision making, editorial and production processes themselves. In the long-term, surely it would be better to open the BBC up to a greater sense of involvement by younger people, not just as a forms of consultation, talent spotting or public relations, but as an integral part of the process by which the BBC operates as an inclusive organisation with young co-producers given equal weighting in the commissioning and production processes?
Another issue that is not taken into account by Ofcom is the state of media studies in the UK, which has tended over recent years to follow a skills and preparation for industry path, and has not instigated a more general civic and social capability for people who live in a multidimensional media world. Ofcom seems to report that the BBC should seek to give their audiences what they want, and does not apply a wider public interest case of identifying what young people will need in the future.
For example, climate change coverage is largely driven by political or technical coverage in news or documentaries, and there are few opportunities for younger people to explore and discover the practicalities and responsibilities of shaping the publics perceptions of the climate crisis.
Afterall, shifting the public’s perception of what needs to be done to face the realities of climate change can’t be left to the people who have been responsible through their actions in the past to bring this crisis about. But if young people don’t get the opportunity to lead and take charge of the decision-making process, and the programme making process, then they will ever learn to take risks or make inventive and creative content that engages the wider population.
Fundamentally, Ofcom’s framework is wrong. It leaves too much that is of great social concern to the marketplace, which only leads to a race to the bottom. Ofcom and the BBC both need to be much more active in promoting media capabilities and literacies, as an active and independent social and civic responsible activity, rather than simply saying that young people will be subjected to aggressive, transnational and corporate market forces, which the BBC is only enabled to skirt around.
The BBC has a responsibility to provide a universal service, and the Ofcom report reinforces this idea. As Ofcom state
“We expect the BBC to provide much richer evidence of how it represents and portrays the diverse communities of the UK in future years. As part of this, it should also set out how it is addressing the concerns of our review of representation and portrayal” (Ofcom, 2019, p. 17).
The problem, however, is that in order to retain this element of its remit, there is little work being done to explain what universal services are important. The BBC is increasingly asked to demonstrate that it can appeal to demographically segmented audiences, who are characterised by their social diversity. The problem with this approach, however, lies in the way that it is integrated, and that programming becomes self-referential and fractured, and which only suits selected parts of our society at any one time.
The BBC still prefers to model its programme planning around an audience satisfaction model, which is too narrow a tool to give a more complex view of what the BBC’s role is in effecting change in people’s lives. Audience satisfaction is a limited way of measuring the social importance of a service or a programme which is dependent on top-down information mining and data extraction based on passive media consumer models. This approach ignores the need for civically engaged and empowered communities to shape and define the kinds of programmes that suit their needs.
What is ignored by Ofcom in its report, is the expectation that the BBC is subject to the flaws, distortions and conflicts in society as much as anyone else. It is impossible to maintain a universalist BBC ethos without connecting this with civic society challenges more generally. The BBC can’t be expected to pick-up the pieces for social dysfunction that is caused elsewhere, and which can only be alleviated by government policy in other ways, i.e. social, civic, educational and economic.
The way this universalist model is implemented, however, runs the risk of becoming a technocratic and managerialist paradise of compliance and policy review processes, and not an expression of national social identity. Ensuring that diverse audiences are served by providing specific sub-cultural programming that might be something that can be pointed towards in an annual report, with lots of graphs and diagrams to explain them, but they don’t promote a sense of common understanding or social cohesion.
Indeed, the risk is that they will exacerbate differences and create cultural ghettos which the general population will lose sight of. Simply seeking to “reflect all UK communities back to the country” (Ofcom, 2019, p. 19) will not be good enough, and the BBC needs to go much further in being involved in the social process that forms and sustains those communities in the first place.
Underpinning the Ofcom report, then, is a conceptual framework that sees regulation largely in market and commercial terms. Which buys in to the idea that the BBC is a distorting presence in the market. This is a political preference that has been made by successive governments for many decades now. As the report states
“The BBC is required by the Charter to have particular regard to the impact of its activities on competition and seek to avoid adverse impacts on competition which are not necessary for the effective fulfilment of the Mission and the promotion of the Public Purposes” (Ofcom, 2019).
Media is almost wholly defined in terms of the creative industries and their potential for global economic impact. The narrowness of this regulatory framework, however, ignores the needs of pubic value, and approaches policy decisions in terms of commercial displacement. This narrow view explodes the role of public service media in many ways that are of equal importance, such as public health and wellbeing, civic engagement, independent learning and literacies, cohesive and self-determined communities, and so on.
The public and social sector is excluded from the impact analysis of BBC activity, even though these might give overriding pubic justification for activity that impacts on the market. The public value model that has been introduced into the procurement of government services in the last decade, means that the bottom line is no longer the only consideration in procurement decisions made by public bodies.
Instead, local authorities and public services can take decisions that are in the wider public interest, and which will impact on the autonomous development and sustainability of communities as co-producers and collaborative decision-makers. Ofcom is not required to apply this framework in its regulation of the BBC, and so only gives a one-sided analysis of the BBC’s potential impact, despite the report stating that
“There need[s] to be transparent and rigorous processes that allow the views of affected parties to be considered” (Ofcom, 2019, p. 23).
The use of quantitative data/audience analysis techniques, for example, also gives a skewed view of the role of the BBC’s services output, because it only tends to define social change in passive terms, or as subject to technological change that is imposed on communities from outside. Perhaps a civic-engagement and social value model would give a richer picture of the importance of the BBC’s output to make it more relevant to people’s lives, which would be a strong counter balancing dataset to the commercial sector’s needs.
Fundamentally, however, the Ofcom report is flawed in one crucial respect. IT makes no suggestion or gives no direction that the BBC should be opened-up as a transparent organisation that is founded on direct public participation in the decision making and governance processes that it operates. Yes, Ofcom suggests that the BBC should be more transparent about how decisions are taken, but this is not the same as saying that these decisions should be opened up to people to get involved in the process.
The use of citizens panels, for example, to help define editorial and policy priorities for the BBC at each level of operation would transform people’s expectations of who the corporation is trying to serve. The professionals and insiders who run the corporation, or the public who pay for it? Ofcom states in the report that the BBC ‘sells’ the licence fee. This is a minor but important slip of the tongue, because the BBC is not an organisation that sells services, and should not be measured against similar objectives that other organisations are defined by. The BBC is a public service payed through an form of public taxation. The least that we, as licence fee payers can expect, is to be included in the process of planning and deciding how those public services get spent and turned into content.
To summarise the key points I’ve taken from the report:
Public Value
- The BBC public purposes framework is too narrow in regard to competition, so it defends its services on the grounds of commercial displacement, not public value.
- Who is included in the assessment of this commercial displacement is too narrow, and does not include members of the civic and social sector, education organisations, research groups, and does not use a social-needs analysis methodology to justify activity in market sensitive areas.
- There is a fundamental lack of transparency, and no opportunity for viewers, readers and listeners to get involved with an open process of engagement, co-development and governance.
Young People
- Lack of opportunity for young people to get engaged in the decision making and production process for BBC content.
- Lack of comprehensive and progressive media studies curriculum to help shape greater understanding of challenging media content.
- Leaving choice to the market, and reducing the responsibilities of market players only leads to a race to the bottom, and a decline in public service capacity.
Representing All Society
- Audience satisfaction is too narrow a tool to use to measure the social take-up and role that the BBC plays in people’s lives.
- A universalist model cannot itself cope with splits and difference in society.
- The centralisation of the BBC, with its target-driven culture is itself a problem, as it undermines local accountability by creating a culture of compliance with the centre.
Ofcom. (2019). Ofcom’s Annual Report on the BBC 2019. Retrieved from London: https://www.ofcom.org.uk/__data/assets/pdf_file/0026/173735/second-bbc-annual-report.pdf
