THE BROADER MEDIA CONTEXT
2. As an introductory comment, we question the general thrust of the Strategy Review. We believe it can be characterised as a defensive and unambitous strategy for the Corporation. Far from anticipating and deflecting hostile criticism of the BBC, we believe it will simply invite a further and even more critical response from commercial rivals and from those political forces which ultimately seek to limit public service broadcasting and to support a more dominant role for commercial broadcasters.
3. We broadly agree with the document’s analysis (p17-19) that there are major developments in the media landscape which are undermining the existing broadcasting model ie the shifting balance of industry funding away from advertising; the emergence of new roles in the value chain with the growth of new platforms and gatekeepers to content; the rising cost of content and distribution including increased competition for rights and content; and regulatory uncertainty.
4. However, we believe the correct response is to emphasise the unique strategic role of the BBC as the cornerstone of our broadcasting system and the benchmark for all competing broadcasters. We believe that, far from being defensive, we should emphasise the BBC’s strength and relevance in the emerging digital landscape and its unique role which commercial broadcasters simply cannot match.
− Commercial non-PSB broadcasters such as BSkyB have a simply abysmal record of investment in original programming.
− PSB broadcasters, led by the BBC, are responsible for over 90% of the investment in original UK content.
− This is despite the fact that the BBC’s licence fee revenue is dwarfed by commercial revenue flows. The BBC has in recent times had three times less revenue than commercial broadcasters as a whole and yet has produced a far greater amount and range of high quality original content.
− The BBC sustains a huge additional amount of activity in the independent sector (valued in the paper at £1.4b) and underwrites highly significant investment in areas such as training and technical research which benefits the whole broadcasting sector. Deloittes acknowledges that the BBC contributes an estimated £7.7b to the economy as a whole – double the value of the licence fee.
5. Far from a strategy of self-sacrifice, we believe the BBC should respond vigorously to the blatantly self-interested criticism from venal commercial rivals such as News International and their political clients. Rather than invite a future in which the BBC humbly accepts a residual role – akin to PBS in the US – of providing services that commercial broadcasters find unprofitable, we believe the BBC should have confidence in its essential future role at the heart of our broadcasting system – a role which commercial rivals can simply never match.
THE SPECIFIC STRATEGY PROPOSALS
6. We acknowledge the broad headings in the strategy paper: Putting quality first; Doing fewer things better; Guaranteeing access; Making the licence fee work harder; Setting new boundaries. We set out our own response under the same headings – focussing on issues of particular relevance to our members rather than on every issue raised.
‘PUTTING QUALITY FIRST’
7. As a preliminary comment, we believe that ‘Putting Quality First’ is precisely what our members believe they are currently doing and have consistently been doing throughout their working lives at the BBC.
8. We note the five priorities set out in the paper; the ‘reprioritisation’ of £600m to invest in higher quality content; and the commitment to spend 90p in every £1 on the creation and distribution of high quality content.
9. Leaving aside the issue of the cuts which produce the reprioritised funding (dealt with in the next section), we can acknowledge the individual merits of the priorities identified, including the following points:
− We would welcome a shift in the balance of spending away from overheads and infrastructure and back towards content. We therefore agree with the more specific goals of 90% of net expenditure on content creation and delivery and at least 80% on content creation.
− We would support an increased emphasis on ambitious UK drama and comedy, including the specific proposals set out on p29.
− Given our long-term concerns about the decline in original UK content for children, we welcome the proposed increases in investment in this area from 2013 although we continue to regret the failure of commercial broadcasters in this area.
‘DOING FEWER THINGS BETTER’
10. We note the ‘tough choices’, specifically including the proposed cuts in BBC Online (spending ‘25% less ... by 2013, with a corresponding reduction in staffing levels’) and the proposed closure of Radio 6 Music, of Asia Network and of BBC Switch and Blast!
11. For all the reasons set out above in the section on ‘The Broader Media Context’, we oppose this self-defeating strategy of cuts in BBC services. We believe instead that the BBC should emphasise its constructive and successful role underpinning all areas of our broadcasting sector, including those areas now suggested for cuts – for which we see no strategic benefit or justification.
− We welcome the strong and impressive response from listeners opposing the closure of Radio 6 Music a popular and distinctive service but we believe the other areas targeted for cuts are equally worthy of support, even if they may lack some of the eye-catching publicity attracted by the music community.
− We remain unconvinced about the empty and vague indications that the closure of the Asian Network will lead to the redirecting of resources to serve Asian audiences in other ways. We suspect this simply would not happen at any equivalent level. We further note that when the Asian Network had a settled base in Leicester, with purpose-built premises, tied to a community with a significant Asian population and with a clear editorial brief it was, in our view, an enormous success. We believe that the decline following the move to London was almost self-fulfilling and that the proposed remedy is totally inadequate.
− Given the BBC’s own acknowledgement of the need to place greater priority on children’s content, we believe proposed cutbacks in services for young people such as Switch and Blast! is inconsistent and contradictory. The contradictions are compounded by the Trust’s apparent refusal to accept consultative responses from under-16s ie from the very segment of the audience that Switch and Blast! are aimed at in the first place.
− We note the widely recognised contribution of BBC Online and remain completely unconvinced that cuts in this area will be matched by compensating initiatives from commercial companies, which have been deficient in providing public service online content of any kind. We therefore oppose the proposed 25% cut in spending on the BBC website.
− We further note that all newer BBC services have already been subject to a rigorous assessment process before being established in the first place, including the issue of their impact on the commercial sector.
− We note that the hundreds of potential job losses in these areas would take place in a context in which the BBC has already enforced thousands of job losses across the Corporation within the last 5 years. A strategy of continuing cuts – especially in content orientated areas – is completely self-defeating, leaving the Corporation ill-equipped to undertake its future public service role.
12. We of course note and welcome the positive aspects of this section of the paper, including the comments on the main BBC television channels and on BBC Radio. We fear that these positive points will simply be lost to public view in the negative publicity generated by the BBC’s self-generated focus on cutbacks and alleged failings. Sadly, in so far as the Strategy Review has set the terms for future debate, it has done this in an overwhelmingly negative way.
13. We can support a number of the paper’s aims in this area, including the following:
‘UK audiences can always:
− Get BBC services free at the point of use, in ways and on devices that suit them.
− Catch up on programmes for free on the BBC’s website, at home and on the move (p45).
‘BBC services should be available without a subscription and without advertising to all audiences across the UK, in ways that meet audience expectations for quality’ (p48).
Services should be ‘universally available to every household on at least one platform’ (p48).
14. However, we have concerns about any blanket commitment to open the BBC’s ‘current and future programme library’ with a view to making it a ‘publicly accessible permanent collection.’ We acknowledge the potential benefits of public accessibility. However, we seek assurances that the interests of individual creative rights holders (eg directors, writers, designers) will be fully protected. Furthermore, we do not believe that the BBC should unnecessarily forego potential income streams from parts of its programme library.
‘MAKING THE LICENCE FEE WORK HARDER’
15. We note the aim of reducing overhead and infrastructure costs by a quarter from 12p per licence fee pound to under 9p and by redirecting savings into content. While we have no issue with prioritising content we note, as the paper acknowledges, that this is in the context of an already rigorous programme of cost cutting and efficiency targets throughout the BBC and a major effort to relocate production away from London.
16. We welcome, in principle, efforts to reduce senior management numbers, pay and bonuses and to redirect resources to content. This is entirely in line with our own pay strategy at the BBC, where we maintain that no-one should earn more than 5 times the mean salary (including all aspects of remuneration in the definition of earnings). Furthermore, we specifically support the aim that ‘more management talent will be trained within the BBC, rather than relying on external hiring’ (p51). However, in contradiction to the aim of reducing management costs, we understand that 2 new senior management positions are being created at BBC Online at the very time that a 25% cut in overall spending in this area is being proposed.
17. We question the assertion that outsourcing or ‘competitive procurement’ necessarily produces cost-savings. Even leaving aside spending on independent production (which we continue to maintain is excessive under the WOCC approach), the outsourcing of ancillary services can involve additional transaction and management costs compared to in-house services. Moreover, the strong and well-attested experience of our members in that most instances of outsourcing have resulted, from a staff perspective, in inferior services which are harder to access and yet involve greater costs. Far from ‘seeking further savings’ from outsourcing, we believe the BBC should be addressing the case for bringing services back in-house.
18. We specifically disagree with the emphasis on needing a new and more flexible ‘employee proposition’, with workers facing ‘constant change’ and the clear implication that long-term employment at the BBC will become unusual if not positively discouraged.
19. As a trade union with a very significant proportion of freelance members, we have extensive experience of the ‘flexible’ labour market in the media sector. Its primary characteristic for the workers involved is not one of increased opportunity but of chronic job insecurity. The classic flexible labour market experience is not one of independent choice but of fear of unemployment – compounded by uncertain employment rights, the failure of enforcement regimes, intense pressure to be compliant within any given employment relationship, long-hours working and exploitation (especially of young people and new entrants).
20. Employers, predictably, see great benefits in flexible labour markets. Workers, generally, do not. Our members have been positive in responding to the BBC’s previous requests for multi-skilled and multi-platform working but we believe a limit of reasonable flexibility has already been reached. We will therefore oppose any strategy geared to reducing job security or undermining conditions for BBC staff. On the contrary, we believe the BBC should invest in the long-term training and development of its workforce as well as making an appropriate contribution to industry-wide training.
‘SETTING NEW BOUNDARIES’
21. We note the aims of limiting activity and reducing spending in areas such as imported programmes and sports rights. We further note the commitment to ‘clearer BBC behaviour’, including consideration of market impact on commercial services.
22. We understand and to some extent share the motivation behind the proposals to cap spending on imports and sports rights. However, we believe that this should be tempered by a recognition that viewers will still expect to enjoy some high quality programming from abroad as well as key sports events and tournaments.
23. Further, we remain disappointed that the BBC chose not to pursue its bbclocal strategy despite very considerable preparatory work and research indicating that regional TV audiences and local radio audiences value local coverage and want more of it. The BBC’s apparent retreat from any kind of positive local strategy appears to us to reflect an unjustifiably greater sensitivity to the interests of commercial competitors than to the preferences of audiences.
24. We are completely unconvinced of the need for even further emphasis on the BBC’s competitive impact. Fair trading principles are already strongly embedded in the BBC. Far from needing greater scrutiny of BBC activity, we believe media policy makers should place a much stronger focus on the failure of the BBC’s commercial competitors to invest in original content despite, especially in pay TV, much stronger revenue flows. We believe that the BBC’s future strategy should clearly prioritise the interests of audiences rather than of commercial competitors.
25. We hope that the BBC Trust will take note of our views, especially on the need for an approach based on confidence and assertiveness rather than of deference to political critics and commercial competitors. We look forward with interest to the future progress of the Review.