Ofcom have launched their consultation on BBC Sounds. Is there any potential to make a submission as Better Media?
Yes, if you’re volunteering to draft a response @RobW
I would be happy to, it might be useful to identify some key issues and themes first?
The BBC lacks civic input, so the commissioning process is dependent on a top-down and managerialist outlook. Should there be a requirement to establish online governance?
Should there be an obligation for BBC Sounds to carry content that is independently produced outside of the BBC’s structures?
Is the BBC Sounds app distorting innovation from alternative media providers?
Is the BBC Sounds content and production representative of UK diversity?
Fran Unsworth, the rather controversial head of BBC News, has suggested that BBC News Bulletins might go to on-demand services only via BBC iPlayer and BBC Sounds? How would that impact on the commitment to universality and plurality?
BBC Sounds is pitched largely as a music, drama and content app, but not as a news platform, so how would the provision of different services integrate with the BBC’s obligations to inform and provide news?
Ofcom and the BBC use a model of audience development rather than audience involvement to develop broadcast media policies, with an app however, there is a built-in participative aspect, does the BBC need to be pushed towards changing it’s approach?
As more services are moved online, what happens to the BBC’s commitment to established and legacy platforms? Will they move to remove AM/FM transmission services, for example?
What happens to the data and the usage profiles?
Who can access the app, if it is restricted to licence fee payers only, then large parts of the population may be ignored and overlooked?
When do the developers of the App and its services ever put themselves forward for public scrutiny about how they determine the priorities of the app, and the algorithms that support it?
The BBC’s and Ofcom’s commitment to media literacy is passive, they do not support a media capability, access and engagement model, how would this continue to determine the ethos that BBC Sounds is developed from?
Can we think of any additional points to start to look at?
Can we identify where there is evidence of where the app is causing clear problems?
My hunch is that it will be reviewed, but given a clean bill of health, but will be monitored by Ofcom. Our objective should be to get invited to any working parties, monitoring groups, research bodies, and so on, so that we can play a role in keeping both Ofcom and the BBC accountable.
We can also probable be a lot more radical about a commitment to the Commons, Open Source, decentralised production and distribution as well.
DCMS have also announced that they are looking at Music Streaming services, which of course have a nock-on impact with other forms of media, such as podcasting, especially with the drive to garden-wall them and monitise them.
I’ve written up a response to the Ofcom Consultation on BBC Sounds. It has to be submitted by 5pm on Wednesday 11th November. I can’t upload it as a document, so I’ve posted it to Google Docs and posted it below. It’s not perfect, and there are a lot more interconnected issues that could be covered, but any review of typos, clarity of points, and so on would be appreciated
This submission is on behalf of Better Media, which is a members-based organisation, campaigning for openness and transparency in media policy, pluralism in media ownership, and access to media platforms as a civic right. https://bettermedia.uk/
1 BBC Civil Accountability
While the terms on which the BBC operates are established in UK statute, and are supervised by Ofcom, the opportunity for citizens to engage in any scrutiny and development of BBC services, management and governance is limited and remote. Better Media notes that any further devel-opment of BBC Sounds, which has been identified along with the BBC iPlayer and BBC Online as the primary mode of future development for access to the BBC’s media content, must be subject to frequent review using citizen engagement, participation and consultation principles.
Better Media recommends that the BBC should be compelled to use in their governance and cor-porate development, mechanisms such as citizen panels and juries, online civic engagement plat-forms, and deliberative facilitation practices, in order to bring together different views, experienc-es and opinions that are representative of citizens across the whole of UK society. These delibera-tion principles should have the primary aim of collating differing views from individual citizens, al-lowing them to express their opinions and talk about their social needs, as they themselves per-ceive them, and not as BBC managers perceive them, or as political parties perceive them, or as lobby organisations and management consultants perceive them.
Better Media recommends that civic and social sector organisations, including charities and mutual aid groups, not-for-private-profit groups, cooperatives, and so on, are also actively included in the process of deliberation and co-development. These groups must be invited to assist setting the terms of any civic deliberation in relation to the issues and social problems that citizens may wish to address. This process of deliberation must report regularly and provide updates to stakeholders and the public, both on the process and outcomes of this engagement. These updates must indi-cate how the findings of these deliberations will be incorporated into the policy principles and de-velopment practices of the BBC.
In addition, Better Media recommends that these consultation processes must demonstrate clear separation between the BBC and competing media organisations, including commercial and corpo-rate interest groups, private lobby groups, and trade associations. All consultation must be under-taken using arms-length and transparent consultation principles, with any professional and corpo-rate lobby groups required to openly report the terms and provisions of their engagement, while simultaneously being subject to the aforementioned public and citizen scrutiny process.
2 Content Accountability
Better Media notes that the BBC also lacks civic input into the content commissioning process, the programming editorial process, and the editorial dispute resolution processes. It is Better Media’s view that the BBC is overly dependent on top-down and managerialist structures. The BBC’s cen-tralised corporate management approach is the principle mechanism for determining the editorial policies and priorities of the BBC across all of its corporate services. These processes are only sub-ject to occasional review by parliament, Ofcom and intermittent judicial enquiries. We note, there-fore, that BBC content and editorial policies are not subject to citizen interrogation, review or dis-cussion. Better Media recommends, therefore, that the BBC should be compelled to establish civic governance processes and mechanisms for the development of editorial content and program-ming. These engagement process must take place both in-person and online, and must draw wide-spread and inclusive involvement from citizens and social groups of all types across the United Kingdom.
3 Alternative Providers
Better Media notes that there is a growing network of independent content produces that are us-ing a wide array of online media platforms to offer alternative and independent audio and media content services. While Ofcom has mentioned large-scale providers of online media services, such as Spotify, we would draw attention to the many individuals and collaborative groups who are us-ing social media platforms to offer services outside of the mainstream commercial media ecosys-tem. We note, therefore, that the growth of BBC Sounds may not just impact on the large-scale and corporately funded media organisations, but that it may have a significant effect on small-scale and independent content providers. Better Media recommends, therefore, that Ofcom commis-sions research into the likely effect that the expansion of BBC Sounds might have on these emerg-ing alternative service providers. These content providers are not represented by any industry body and most often operate outside of the terms of regulated media platforms using creative commons and open source models of development. We recommend that any research commis-sioned by Ofcom looks at the emergent nature of operators in this sector, and seeks to understand the terms on which they perceive themselves as independent operators, before seeking to meas-ure the likelihood that they may become economically sustainable in the future. This research can be aligned with the work of NESTA and it’s modelling of the future economic impact of digital ser-vices and platforms.
We note that many emerging online content providers do not fit within established models of me-dia delivery and associated platforms, such as broadcast radio. Instead they utilise hybrid and inte-grated approaches for engagement that operate across multiple platforms, which foster relation-ships with audiences as communities. These emerging producers are often entrepreneurial and innovative and operate within the social economy model. We recommend, therefore, that any economic impact assessment is not solely undertaken from the position of established markets, but identifies and projects forward to new economic paradigms based on decentralisation, circular economy and SROI principles.
Better Media notes that the regulation of the commercial radio sector in the UK, with its high levels of consolidation and centralisation, are drowning-out independent radio providers, and thereby reducing access to locally produced radio content. Ofcom’s principles of economic investigation and regulation, therefore, must take into account the need for civic and economic plurality in the emerging independent online media sector. The dominance of BBC Sounds, with it’s narrow edito-rial model of content, will inevitably crowd-out innovation from this emerging sector if it is not pro-tected and recognised as a designated alternative model of public media, as has been established for Community Radio.
While it might be argued that the BBC should be given an obligation for BBC Sounds to carry con-tent, or link to content that is independently produced outside of the BBC’s structures, Better Me-dia believes that this would amount to an act of corporate colonisation, and would be regressive. The principles for supporting these emergent online content providers therefore must be aligned with civic participation principles, media pluralism principles, as well as economic diversity princi-ples. The economic dominance of the BBC, and the international corporate media networks that have become rooted in the media economy in the UK, has the effect of monopolising audiences and supressing diversity of supply and engagement. The effect of this monopolisation has been to reduce the viability of emergent alternative producers. Therefore, any public subsidies of content, platform management, and regulatory safeguarding, such as that provided by the Audio Content Fund for example, must be subject to a Social Impact Test in addition to any economic impact tests. Content producers and providers must be expected to demonstrate the Social Value of their prod-ucts and services, as defined in the Social Value Act 2012, if they are to receive regulatory and eco-nomic support from government, either directly or indirectly.
4 News Provision
Fran Unsworth, head of BBC News, has suggested that BBC News Bulletins might in the future transition to on-demand services only. Better Media notes that there is no indication yet from the BBC as to how these news services might be delivered via BBC iPlayer and BBC Sounds. Our con-cern is that any move away from a universally provided news service would be regressive, and would reduce the ability of citizens to access high quality news and information across all of the BBC broadcast and online platforms. BBC Sounds is marketed largely as a music, drama and con-tent app, with a focus on lifestyle consumerism, and not as a news or deliberation platform. We would caution that any obligation by the BBC to carry universal news services will be further diluted if audiences are encouraged to turn to separate content applications and platforms.
Our recommendation is that BBC must be obliged to maintain services that are integrated, interop-erable, and which are able to provide accessible and objectively produced news and information. The present model that the BBC appears to be developing is a reaction to market segmentation in other parts of the media economy. We believe that this is an example of the BBC following market trends, rather than forming a strong, distinctive public service remit for itself that the public under-stands and trusts. The BBC must be empowered to resist the market segmentation of its content provision, and should be provided with regulatory support to maintain the BBC’s well-established role as the provider of accountable universal public service broadcasting.
5 Audience Development Model
As technology and media platforms change, so do the expectations of users and audiences. Better Media notes that Ofcom and the BBC are continuing to use models of audience development, ra-ther than seeking to move to models of user involvement and participation. While the audience development model was reasonably suited to the broadcast media age, it cannot be carried for-ward to the online and digital services age. Better Media recommends that Ofcom commissions research and innovation testing to establish and demonstrate how the affordances of social media and social networking can be integrated into the structure of the BBC. BBC Sounds could be a good test-case for this enquiry, and could be used to provide open-research and open-platform devel-opment frameworks that would encourage innovation and economic renewal as new media pro-ducers, agencies and social groups are brought into the media economy, for the benefit of the public. The BBC once played a leading role in supporting the development of broadcast technology for radio and television when these were emergent systems. Better Media believes that the BBC should be asked to lead on this role once again, by taking a leading role in the emerging open standards and open information digital media economy.
The BBC, as a publicly funded and accountable organisation must, however, be accountable for the way that these services are developed and implemented. Better Media therefore recommends that in addition to content regulation and platform regulation, that Ofcom establishes an Office of Data Regulation for the BBC. This office must ensure that the data that the BBC uses and producers across all of its services is recognised as a public resource, and that it is safeguarded and protected on the basis of democratic principles of data integrity, open research, open platforms, personal privacy, civic empowerment and open source engagement.
Better Media recommends that any data that the BBC presently produces, and may produce in the future, is unambiguously made subject to statutory oversight, public scrutiny and civic determina-tion. It is not acceptable for the BBC to run online and data-driven services without public scrutiny. The algorithms and systems that the BBC operates, and intends to develop in the future, must be subject to the same civic scrutiny principles that we have identified for organisation governance and content development. Individuals and groups within society must be able to engage with the BBC and co-develop the policy principles on which data services are developed. The BBC is not a privately owned market competitor, but a public service that must demonstrate transparency and legitimacy in the way data-driven services are developed and applied.
6 Legacy Services
In addition, the move towards these online services will have an impact on existing and legacy ser-vices that the BBC may argue are no longer sustainable. Any planning and modelling of the sustain-ability of traditional broadcast services must be undertaken in the light of public scrutiny, and should be subject to review according to the civic engagement principles outlined here. The BBC must not be allowed to remove legacy services without assessing the impact of any changes, communicating with those involved, and supporting and providing those affected with accessible and comparably costed alternatives. For example, and move to close BBC Radio services on AM, and replace them with digital services must be accompanied with a publicly scrutinised impact as-sessment. The work of Good Things Foundation provides exemplary data on how these engage-ment processes may be managed.
7 Media Capabilities
Given the changes that are indicated above, of which many more might be identified, Better Me-dia recommends that Ofcom reviews the Media Literacy model that it presently operates. We be-lieve that this model is passive and consumerist. In effect it views people as consumers and audi-ences first, and not as active citizens. The media literacy model must therefore be replaced with a media capability model. The primary principles of this model, we believe, must drive access and engagement which expands the opportunities that citizens have to represent themselves, and to share content and stories that are representative of their own lives, and not those that are per-ceived by corporate producers. The development of BBC Sounds cannot be considered in isolation to other parts of the media ecology. Due consideration must be given, we believe, to participative and civic engagement models of media, such as those practiced in community media networks.
Moreover, Ofcom must make a determination as to the sustainability of the present media litera-cies model which informs audience engagement policies within the BBC and other public service media organisations. Better Media believes that this model is no longer fit for purpose. The BBC is therefore using an outdated model of development for BBC Sounds which excludes many com-munities from developing their own voices, and it restricts the ability of communities to represent themselves in across different media platforms. A change to the media literacies model will enable new research and investigation to come forward that focusses on social development and civic col-laboration between the BBC and the communities that it serves. BBC Sounds cannot be evaluated in isolation from these wider developments, and so any review by Ofcom, perhaps working in col-laboration with NESTA, ought to anticipate these changes and the future directions of develop-ment that they indicate. If the BBC is allowed to maintain its present model of development, then we are likely to find that audiences will gravitate to platforms and services that only suite their own individual needs, and which mean that they will lose sight of the benefit of the universal services that the BBC is famed for, as they prioritises community, social and national identities.