Written evidence submitted by Mr Bays




I am a freelance writer, animation producer and creative consultant working predominantly in Children’s media. I worked at the BBC for 16 years before leaving and setting up my own company in 2016.


I firmly believe that public service broadcasting and, in particular, the BBC need to be protected at all costs.



The BBC is the heart and soul of the nation, it reflects and represents us, entertains and educates us, brings us together and is a bastion and exemplar of who we are and what it is to be British both for us and as a beacon and trusted aspirational source of truth and quality around the world.


The BBC has played a vital and an immeasurably important role in informing, entertaining, educating and bringing together the whole of the UK throughout its history and has stepped up to offer even more during the Coronavirus Pandemic. No other broadcaster, platform or service has been able to offer or achieve more or have greater positive impact on our culture or society. This has only been possible due to the unique way that the BBC is funded and run and the public service broadcasting system and remit that it operates under.


The BBC’s News and Current Affairs output is our most trusted source and has helped my family and everyone I know stay informed about the Corona Virus and all of the key events of the pandemic. It is also our voice in questioning the Government and holding ministers and experts to account.


The BBC and public service content has played and continues to play an enormous role in shaping and inspiring citizens and change-makers of the future in the UK. The key decisions I have made in my life regarding education and career were inspired by BBC content. I chose to study Biology due to my love of the BBC’s natural history documentaries and I chose a career in media due to being inspired by content made mostly by the BBC.


I know from experience and conversations I’ve had during 20 years working in the media industry that the BBC has driven, inspired and had immeasurably positively impacted on the development of people, content, broadcasters, platforms, media producers, television, digital products, video on demand and film in the UK and around the world.


I know from personal experience that the BBC is a training ground for the top media talent of the future – giving all who’ve worked there unique, world-class training, development and experience that is respected across the world.


The BBC creates and uniquely showcases national moments that have helped inform, shape and define many generations’ view of the UK and national identity, e.g. Royal Events like The Golden Jubilee, The 2012 Olympics Opening Ceremony and ground-breaking multiplatform coverage were stand-out events in my life; the BBC created a sense of togetherness and involvement that no-one else could.

BBC Bitesize has helped every family I know and provided invaluable support to the teachers in the schools that my daughters attend.


Who else would be able to, be trusted and motivated to provide educational resources to the children of the UK at any time, especially during a National Emergency? Only the BBC and only because it is our national public broadcaster. If the public service model was different, the BBC might not have the funding, reach, ease of access and capability to provide this extraordinarily useful service. The educational content that the BBC provides is not just limited to the amazing BBC Bitesize made and curated for the nationwide lockdown; it has consistently provided high quality, curriculum-based content throughout its history. The BBC is a trusted source of factual and educational content. This kind of content is not especially commercially viable except in a few outlier cases, e.g. Natural History, and so changing the public service model would put this kind of content – all public service content and the public service aspects of content – at risk because the BBC would have to change its priorities to survive and compete.


Due to the financial and political independence of the BBC, they are able to provide uniquely independent and globally trusted content and services, e.g. News, which is immeasurably valuable in a world now overrun with commercial, financial, political interests exerting influence in every area of media. Most of these interests and their aims are obscured from public view and scrutiny and this has sewn both a deep mistrust of media and allowed the proliferation of misinformation and hidden agendas with malintent. The BBC is one of our main protections and weapons against the insidious, cancer of fake news and the weaponizing of information and the instigation and proliferation of conspiracy theories that all threaten our society and democracy in so many ways.


As an exemplar of high-quality content, the BBC raises the bar and inspires every other broadcaster and platform in the UK and around the world to be better. The BBC creates technology that has led technological change around the world.


Due to the stable funding provided by the License Fee, the BBC is able to take calculated risks and to try new things from content to services and platforms, unlike anyone else. The BBC has taken a number of such calculated risks that have moved the broadcast, digital and technological industries forward, e.g. iPlayer paved the way for all VOD services and this way of experiencing content, immeasurably improving people’s experience of media.


The BBC is the cornerstone of the UK’s media industry which generates and attracts billions of pounds every year. Amongst many other things, the BBC commissions, funds and shows the vast majority of content for young people in the UK. In fact, without the BBC, there would not be a viable children’s media industry in the UK.


Investigative journalism from public service broadcasters and created under the system of public service broadcasting, e.g. Panorama, has exposed institutional wrongdoing, spoken truth to power, instigated extremely important legal and regulatory inquiries, highlighted issues that would otherwise have gone unnoticed and helped to right wrongs that would otherwise have been ignored. This has had significant impact from the national scale to the personal – helping to improve the standards at my grandmother’s care home, for example.

Consumer rights, protection and advocacy content created by public service broadcasters like the BBC – e.g. Watchdog, That’s Life, Rogue Traders, etc. etc. – has had an enormous and positive impact on many people’s lives across the UK – again, directly helping myself, a great many of my friends and family-members – and would only be commissioned, funded and shown by public service broadcasters.


Content like the above and that related to civics, citizenship and democracy, e.g. Crimewatch, Question Time, Any Questions, Any Answers, etc. offers immeasurable public and societal value sand benefit: providing unique forums and platforms for public engagement in civic life and society; promoting community engagement; presenting crucial opportunities for people to engage directly with Government; protecting people from harm; bringing people together; modelling, inspiring and encouraging positive citizenship values and behaviours.


This kind of content has never been deemed to have sufficient financial value/ commercial benefit to sVODS or most commercial broadcasters. The benefits and outcomes above are not priorities for advertisers, media-company shareholders and commercial interests. This kind of content is and will only be created by public service broadcasters; broadcasters and platform-owners whose priority is to serve and inform the British public rather than to serve and enrich shareholders and investors.


Having the BBC, where the singular priority is to serve the public is an extremely rare and precious asset to our lives, society, culture and our democracy that we must treasure, preserve and protect.


The regulations around the provision of children’s and young people’s media are not strong, binding or robust enough. For years now, ITV and Channel 4 have failed to meet even the basic obligations of their public service remit to provide content for children and young people. Providing ‘Family’ content is not enough; this treats children, young adults, mature adults and the elderly as if they had the same needs, questions and tastes. Amongst other things, it underserves and insults young audiences; robs them of quality content that speaks to them, represents them and shows them that they have value; removes chances to participate in culture and discourse amongst themselves and with other parts of society and diminishes opportunities to express and represent themselves and be represented and included in wider issues and on a national stage; reduces their opportunities for inspiration and education; ignores this audience’s specific needs and squanders valuable opportunities to reach, inspire and educate them and support their development at the most crucial time; diminishes the richness of content and our culture and disenfranchises a huge portion of the UK population. OfCom have not been given strong enough powers to enforce this and the Government seems to have turned a blind eye, instead appearing to allow and even encourage the prioritisation of business interests over public service and young audience interests.


The regulations on the BBC to control competition also seem overly harsh and put it at a disadvantage when now having to and trying to compete in an extraordinarily competitive media environment, causing both the public and the BBC to unfairly lose out. For instance, the BBC was forced to take down cookery pages and the groundbreaking ingredients-finder online tool so that independent business would not face too much competition; the BBC mothballed a flagship public service educational platform: BBC Jam after spending over £150 million (the majority of which went to UK companies who developed the content for the BBC) because it was deemed to be anti-competitive. Now this space is dominated by content from outside the UK, (e.g. Khan Academy, Google Classroom, Google Explorers) and content from private companies, (e.g. Purple Mash by 2Simple) so the money being spent in this industry goes to a small number of private interests and does not benefit the broader UK industry. If the BBC was allowed to create whatever content it deemed was in the best public interest and then the money would be shared out across the industry.


Changes to the regulations controlling the BBC and to the license fee (i.e. forcing the BBC to pay for BBC World Service and for free license fees for over-75’s) and to the structure of the BBC (i.e. causing the world class in-house production teams to have to be carved out and made into a separate companies – BBC Studios and BBC Children’s Studios) have already put the BBC under enormous strain, reduced its budgets for content and platforms and limited its ability to take risks, be agile and to compete at a time when it is already stretched and attempting to deliver value, stand out and compete in an extraordinarily competitive marketplace.


SVoDs should have to sign up to abide by the same regulation as other broadcasters and platforms in the UK, particularly with regard to diversity and paying tax to HMRC on the revenue they generate in the UK.


This question in the call for evidence presumes that changes are going to be made. What changes are being referred to? This question seems to prejudge the conclusions of the inquiry and is very concerning.


It seems that broad, diverse, niche-interest, under-represented topic-, religious- and regional- representation only exists and is only as good as it is because of public service broadcasting. Therefore, any changes that weaken, in any way diminish or remove funding or reach from public service broadcasters will damage and reduce all forms of representation. Online and subscription services rely on drawing in large audiences and depend on servicing commercial interests to survive and so use these to determine the content they commission and publish. This causes content to be driven to be more mainstream and generic and, thereby, decreases and diminishes representation. Without the PSB model there would be little or no representation; representation does not attract commercial investment or sell widely enough to drive and generate business and funding and so can only be funded, supported and furthered by public service broadcasters like the BBC.


Without or with less public service broadcaster funding and/or support, less- or non-mainstream issues and groups would lose a crucial method of sharing their messages and perpetuating themselves. They would no longer have a way to be heard and their ability to grow and add to and incorporate themselves into the rich cultural tapestry of the UK would be diminished and possibly severely harmed, potentially causing them to disappear altogether, significantly damaging and impoverishing our culture.



The BBC has been built for public service broadcasting and not for purely commercial operation and not to compete on the same commercial playing-field as SVODs. Therefore, like forcing a freshwater fish to swim in the sea, any changes that cause the BBC to have to behave, operate and compete more commercially and directly with SVODs will, at best, undermine and, at worst, irreparably and deeply damage the BBC: its output, capabilities and ability to operate; it’s platforms, content and services.


Reducing the BBC’s funding and/or changing the BBC into a purely online/app-based service or subscription-based service will cause the BBC to have to change its operating and decision-making priorities to focus on business and commercial considerations above public service priorities in order to survive. One important outcome of this is that the BBC will have to spend money it would have otherwise previously spent on activities aimed at serving, representing, educating and entertaining audiences on activities aimed at competing and being discovered (i.e. advertising, marketing and user-acquisition). Therefore, by reducing the BBC’s funding and/or changing the BBC into a purely online/app-based service, the value, impact and reach of the BBC will be diminished, potentially severely and possibly fatally.


There have been many alarming warnings of what a world without the BBC or with a diminished BBC would look like. Without the independent BBC as a balancing factor, a place to check and compare viewpoints and provide a reasoned, untainted, public-service focussed voice of equal, if not greater power, misleading, inaccurate information, partisan- and malicious- misinformation, fake news and conspiracy theories would proliferate unchecked. It is obvious that this would have a range of significantly negative impacts on the UK and, not least, on democracy itself.


Any weakening of the BBC brought about by changing it into an online-only or subscription-based service could very easily lead to an unstoppable vicious cycle where diminished reach, barriers to access and damage to discoverability and resultant decreasing viewership and subscriber numbers leads to decreasing income which causes the diminishment of volume and quality of content which decreases viewership and subscriber numbers and so on. In this way and due to the issues raised above, changing the BBC into and online-only service or subscription service or any kind of service where it has to compete directly for subscribers and funding against SVODs and commercial broadcasters and platforms is signing the death warrant for the BBC.


Making the BBC into a purely online/app-based service or subscription-based service will create barriers to entry and decrease the availability and accessibility of the BBC’s and public service content, causing problems both for the BBC and audiences. Many people will be denied vital information, inclusion and participation in national life. People with poor or no internet connection, insufficiently advanced devices or difficulty with technology would be at very (unacceptably) high risk of being cut off and disenfranchised. These issues could cause significant damage to society.


Currently, the public service model means that BBC profits are all ploughed back into the business. If the business model of the BBC is forced to change, it may need to supplement funding by taking on shareholders and investors all of whom will want to divert profits to themselves or risk being unable to operate. The BBC must be protected from having to do this/ having to operate under as different financial model so that all of the money it makes can go to creating content and supporting services and platforms.



Local BBC Radio and TV facilities should be opened up to involve, teach and train and be responsive to the local people they seek to serve.


Going forward, the BBC needs to be protected from party politics and political decision-making as this has historically led to politicians forcing change on the BBC that only serves the interest of their party or ideology. Governments have consistently used their power to re-negotiate and determine the License Fee settlement to bully, change, make new demands upon, diminish the funding and force the hand of the BBC, e.g. forcing it to pay for the BBC World Service and finance free TV Licenses for over-75’s.


This has, so far, only served to damage the BBC and cause its funding and the services and content it can offer to be diminished. The BBC is a key pillar of our society and so weakening the BBC only serves to weaken our nation. This is not acceptable.


It is imperative that the BBC is protected from Government influence.


Only the license-fee paying public should be able to influence the operation of the BBC.

All regulation should be entirely independent and a public panel should be formed to work with the regulatory body (e.g. OfCom/ a new Trust) in order that the voice of the public is represented and taken into account by them during all decision-making. There should be a regularly refreshed, randomly chosen central public panel and similarly run panels in the Nations and Regions to ensure optimal diversity and representation.


For the BBC to effectively serve the public; to be able to compete, survive and thrive in these and future extremely competitive times; to ensure it can maintain its crucial role in educating, entertaining and representing society; and, crucially, to retain its vital independence – beyond extraordinary circumstances – it needs to be made completely separate from Government influence.