Submission to the Ofcom BBC Performance Measurement Framework Consultation

Over the past few weeks, we at Better Media have been working on putting together a submission to the Ofcom consultation on proposed changes to the performance measurement framework (PMF) it uses to assess the BBC’s performance. The proposed new PMF is a welcome update to the existing framework from 2017, but in our view it is lacking in several respects. Our submission was completed and submitted on 23rd June.

You can read the full submission here, or read a shorter summary below.

Thanks and credit to Rob Watson, Better Media member and host of Decentred Media, who led on this work.

Summary of Response

The focus of our submission was on highlighting that the proposed PMF and Ofcom’s broader processes of assessing the BBC are not transparent or inclusive enough and do not facilitate meaningful public engagement with the BBC’s performance or purposes.

The BBC is a public service, but there is a lack of public understanding of and consent for the BBC’s defined Public Purposes and how it acts to fulfil them. Recent outrage around the BBC’s planned cuts to local radio services, and Ofcom’s lack of comment on that decision, provides a clear example of the BBC and Ofcom’s failure to meaninfully engage with the views of the public.

Ofcom should make it a priority to foster a more collaborative and inclusive approach to the BBC’s performance measurement, in order to facilitate the growth of public engagement with the BBC’s purposes and goals. In order to do this, it make the process more open and transparent, and bring it in line with its duties in relation to equalities legislation.

There are a number of methodologies for more open public engagement that Ofcom could draw on. In our submission we recommend a mix of online and offline engagement strategies, such as public consultations, surveys, focus groups, and town hall meetings. Through multiple forms of engagement, Ofcom could build up a broad, participative public forum that is inclusive and accessible to many different stakeholders and members of the public. This forum could then assist in the development of performance indicators and the PMF over time.

At present, Ofcom and the BBC are over-reliant on the ‘market research’ practices employed by private industry. These produce data that are highly technical and focused on administrative priorities, rather than on the actions and purposes of the BBC that the public have more awareness of and interest in. This problem is compounded by these data not being made available in the public domain.

Both the process of gathering data relating to BBC performance, and the data itself, should be made transparent and open to public scrutiny. This would allow for a much broader range of stakeholders to meaningfully engage in analysis of that data, to draw conclusions about the BBC’s performance that are more relevant to their interests and priorities. This in turn would make a wider range of interpretations available to Ofcom as it assesses the performance of the BBC.

Currently, the PMF does nothing to enshrine the principles and duties laid out in equalities legislation, such as the Levelling Up Bill and the Equality Act 2010. In our submission, we advocate for Ofcom engaging more directly with this legislation. Aligning the BBC’s performance with the objectives of Levelling Up legislation would help to start addressing regional disparities and promoting social and economic equalisation across the UK. In addition, incorporating performance indicators based on the principles of the Equality Act into the PMF will help ensure that the BBC’s content is inclusive and representative of the diverse communities it serves.

Lastly, our submission recommends that, in addition to its broader Public Purposes, the BBC should be given very specific and targeted social purposes around significant social issues, such as the climate crisis, social cohesion, economic renewal, technological change, civic engagement, and other matters of public and social concern, such as health and wellbeing and educational attainment. This will ensure that the broader mission to ‘Inform, Educate and Entertain’ is not just a motto, but a clear framework based on ideas of social good defined in consultation with the public.

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Read the full submission here, join the discussion on our forums here, and become a Better Media member on OpenCollective here.