The Children’s Media Foundation (CMF)

Distinctiveness and the BBC

Last month, CMF Board member Jeannette Steemers and Exec Group member Ashley Woodfall attended an Ofcom seminar on the BBC and Distinctiveness. The background to this is the Government’s desire to hard-wire ‘distinctiveness’ into the Charter, with the new Royal Charter and Framework agreement having it written into the BBC’s mission, purposes and regulatory framework.

The Government’s position on this has been that the BBC should be distinct from its competitors and offer content that can’t be found on other channels.  It could be argued that this is already inherent in the existing BBC Charter without it being deliberately stated and that the BBC already draws on its creativity and talent to provide world class distinctive content. A hard reading of the requirement to be distinct, with the BBC positioned ‘to avoid adverse impacts on competition’ suggests the BBC should provide only what other channels don’t.  This ‘market failure’ understanding of the BBC’s purpose, if read at a top-line level, has been encoded into the Charter, with content that competes in a commercial environment, such as ‘Strictly Come Dancing’ problematically close to breaching the Charter and the BBC potentially left to focus solely on niche and minority interest output.

On this note, it is slightly worrying for the future that the word ‘Entertainment’ is not mentioned once within almost 500 words of BBC’s Public Purposes.

Even though it would be worth reflecting on how distinctiveness and avoiding an adverse impact on the market came to be written into the Charter, facing forward we should stay alert to who might draw on the 'hard' reading of distinctiveness to promote their own agenda – whether they come with a particular neo-liberal ideological stance or commercial interests of their own.  Where the BBC lead, others tend to follow; opening up markets for others to flourish within.  Picture how the BBC are currently pushing 4K and experimenting with VR in a way that leads through content and excites the public.  It is worth pausing here on a possible scenario in which the BBC, under a ‘market failure’ model of distinctiveness, could be obliged by the charter to exit these areas if common players (like Google or Netflix) step in to claim the BBC are impacting the market. This all feels very familiar to those who might recall a post-2004 Graf Report period in which the BBC withdrew from multiple areas where others lobbied that the BBC was causing an ‘adverse market impact’. Similarly, we might recall that Project Kangaroo, which could arguably have led to UK content succeeding on a global (Netflix-like) scale, was blocked in 2009 by the Competition Commission.

Given the task of promoting the BBC’s public purposes, Ofcom has conducted audience research under the headings of Quality, Creativity, Innovation, Diversity and UK Specificity.

When addressing audience perceptions of distinctiveness, they devised 15 platform-led indicators – 5 each for TV, Radio and On-line. These indicators rather subtly focussed on whether content was perceived by the audience to be of quality, innovative, mixed, appealed to different audiences and was UK-produced (apart from in the case of the website and apps section, where one of the indicators was troubling, being framed around the BBC having ‘content that other websites don’t provide’). Here Ofcom have done some very nuanced work in trying to capture a wide and rich take on distinctiveness.  Even though these indicators were devised for the audience study, they clearly make useful scaffolding for the fuller measure of distinctiveness that Ofcom plan to build over time.

Ofcom appears to think that a hard reading of distinctiveness is too restrictive and potentially detrimental to the BBC’s output as a whole. And seeing the BBC as a whole usefully allows us to celebrate the popularity of its mainstream content, as well as enable the Corporation to provide a platform for specialist and minority interest broadcasting, with the BBC’s popular entertainment seen to power innovation.  Here we could argue that distinctiveness should be measured against the BBC as a whole, rather than against individual platforms or pieces of content. The Ofcom performance indicators don’t currently bridge platform, being old-platform bound (TV/Radio/Online) or reflect what the BBC does as a whole.  At this point all we need to do is reflect on sport, or other big cultural event content, to see how any platform led measure of BBC distinctiveness would fall short.

Distinctiveness can be understood in many ways and shouldn’t just mean specialist/niche content that the commercial sector can’t or won’t produce. The BBC should connect with mass audiences, it should provide a significant amount of original content, and content specifically aimed at UK audiences. Diversity, regionality and representation of different socio-economic groups clearly need to be considered, and here with our particular interest in children’s media, children should be able to recognise something of themselves on screen.  CBBC and CBeebies have long made that so – and for BBC trained programme and content makers it is part of what they do.

Intriguingly Ofcom’s perceptions of distinctiveness research found that the public aren’t concerned about distinctiveness as such. They just want good quality entertainment and drama like ‘Strictly Come Dancing’ and ‘Poldark’. This research seems to have given Ofcom the confidence to move forward without pinning themselves to a fixed set of indicators (most of which the BBC are already hitting). With measurement of diversity appearing nuanced and flexible to changing times, the key for Ofcom is to see the BBC from the audience’s perspective and to further evolve their subtle use of language in measuring its aims and purposes. As far as children’s content is concerned, children don’t tend to separate out their platforms, so it’s a difficult landscape to measure against.

However, the Ofcom current de-coding of ‘distinctiveness’ stands BBC Children’s in good stead. CBeebies and CBBC can be said to be creative, innovative, of high quality and diverse, providing original and UK specific content.  And thankfully Ofcom appear to favour dialogue, and a softer overall approach, rather than rigid rules that set the Corporation up to fail – or allow others to use a ‘market impact’ argument to undermine a widely respected creative, innovative and distinctive globally significant organisation.

Dr Ashley Woodfall
Prof. Jeanette Steemers
June 2018

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