Failure to Engage – Why is the BBC Not Required to Consult?

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When a community radio station wants to change its key commitments, Ofcom holds a consultation and invites comments from the public and other interested parties. The station has to justify its changes and explain why it intends to make them and for what reason. If Ofcom agrees with the request, they must publish an analysis of why their decision is justified, both in relation to the law, and the fairness of the decision to other radio station operators. As of this morning, there are at least two consultations for a change of key commitments by community radio stations that are active on the Ofcom website.

When a public authority wants to change its service and restructure its operations, these are generally put out to consultation with the public. NHS Trusts, for example, undertake extensive public consultation exercises to help them shape their future service provision, ensuring that patients groups and the public are satisfied that they have had meaningful input to the design and implementation of their plans. The public are asked to help set the priorities for future local health care provision, alongside the professional needs of service providers and the policy priorities of the public policy managers

So, why is the BBC not doing anything similar in relation to their proposals to consolidate and shut down local radio services in England? The public information available about the BBC’s proposals amounts to a couple of press-releases and a single appearance before a committee of MPs in parliament. This is hardly meaningful public consultation! Where is the data-pack with the results of an extensive public consultation process across England? Where can we go to see and listen to BBC Editors as they explain the proposed changes to their local listeners and service users?

Where is the consultation with civic leaders and managers of public service providers, many of whom sung the praise of BBC local radio during the pandemic? Afterall, it wasn’t long ago since the BBC’s Director General was saying, “Local Radio is there for you.” Likewise, where is the economic analysis that guarantees the BBC’s changes won’t destabilise the local media markets in each area?

From the limited evidence of public engagement that has attracted the attention of the public, one might be forgiven for thinking that the BBC is acting as an independent commercial entity, free to trade based on private finance. I’ve had to search through unverified information via message boards to get any recent information about how the proposals have been updated. The BBC, however, is paid for from a universal licence-fee, which is effectively a tax. I’ve paid the BBC licence fee all my adult life, and I’ve never once been asked what I value about the BBC’s services, and as far as I am aware, there is no public consultation infrastructure in place to do this systematically, and universally across the UK.

As a publicly funded media provider, the BBC must meet higher standards than other media service providers. The BBC’s remit is agreed by government, and is supervised by Ofcom. But surely the BBC also has a moral obligation to consult with the public in more meaningful ways than this? I can understand the frustration of BBC employees, many who feel they have had their hands tied behind their backs for years. Consultation with unions about possible redundancies is a legal requirement, so why isn’t consultation with service users also a legal requirement on the BBC?

What is often said is that the BBC has underinvested in local radio content provision because BBC managers are obsessed with centralised organisation, marketing and branding, which has led to the homogenisation of content. This has been compounded by the belief that digital-first content is the future, and that analogue radio services are therefore a hindrance.

The shutdown of Absolute Radio’s AM service has been presented as a fait accompli, accelerated because of electricity price increases. This just shows why we need a commitment to universal BBC services. Significant numbers of people still listen to analogue radio. Why should they be forced to pay a DAB tax just to receive a radio service they can access already? The BBC’s income is guaranteed to maintain broadcast as an essential service. Shutting down transmitters means that millions of people who are not well served by digital media will be deprived of options for listening. It’s worth noting that HMV is profitable once more because it sells more vinyl albums than CD. Who said analogue is dead?

The BBC is riven, it seems, by its top-down and managerialist culture. Open data systems on the internet have proven that aggregated and distributed information management is now common across society and the economy, with schools, hospitals, businesses and local authorities all using open information management approaches to develop live responses to changes in society. Why can’t the BBC do something similar?

Before the BBC makes cuts to its radio stations, it should be forced to explore and consider alternative service development models, based on open and transparent engagement with the public. There are many ways that local BBC radio stations can be revitalised, so they are relevant to the future provision of local media. Couldn’t the BBC be reorganised as a federal structure, with each independent local station providing essential news, information and entertainment services that are locally relevant? Why has media not been included in the Levelling-Up policies of the major parties?

Civic engagement isn’t new, and there are plenty of organisations that would happily share their experience with the BBC. Each station could establish citizens panels to guide the priorities they see are most relevant in each area. The question is, what do listeners in each place want? It’s not that difficult to ask people and establish a dialogue that is inclusive of different community’s needs and identities. Local authorities and community radio stations constantly do this. Local feedback and consultation should be common practice across the BBC, with expertise delegated to the lowest level, unless there is a clear justification that expertise needs to be pooled at a higher level.

If community radio stations have to consult the public via Ofcom about the changes they want to make to their services, the BBC should be volunteering to do this. Otherwise, what’s the point of paying a licence fee if the voices of the citizens who pay that tax is so easily disregarded?