The terms of the BBC Mid-Term Charter Review have been announced – and, as we anticipated in our briefing on the Broadcasting White Paper, it is being set up in yet another mechanism for government meddling. While the Review was originally designed as a routine check-up to look only at the BBC’s performance against its renewed 2016 Royal Charter, the terms are now far broader, including examining how the BBC handles complaints, its impact on commercial competitors, diversity, and editorial standards and impartiality. The Review is likely to run until 2024, and will be swiftly followed by the negotiations running up to the renewal of the Royal Charter in 2027. The BBC could therefore be facing five years of uninterrupted scrutiny of its actions by government – making a mockery of it supposed independence.

The Media Reform Coalition is not opposed in principle to the idea of reviewing the BBC’s operations; we have long been concerned about many aspects of how it functions, and have proposed a set of solutions to transform the corporation into a democratised ‘People’s BBC’. On the face of it, we share many of the Review’s areas of concern. However, given that it is being overseen by an extremely interventionist right-wing government (including a Culture Secretary who has made explicit threats to cut funding for the corporation as a punishment for negative coverage) there is little evidence that the outcome will be a more responsive or accountable BBC.

As Marcus Ryder outlined on Twitter, there are a number of concerning aspects to the terms of the review, often expressed in coded language. The evaluation of ‘diversity’, for example, makes no mention of protected characteristics under the Equalities Act and instead talk solely about increasing socio-economic diversity and ensuring ‘diverse perspectives’. Creating better routes for working class people to become media professionals is of course vital (journalism is one of the most elite professions in the UK), but these measures have to treated as part of schemes to address other kinds of disparities e.g. around race, gender and disability, rather than opposed to them.

Without this intersectional approach, as Marcus notes, socio-economic diversity becomes code for ‘white working class’, just as increasing ‘diversity of thought’ is code for ‘more right-wing views’. In any case, effective measures to improve working class access will be undermined by wider cuts to BBC funding, which will inevitably reduce the number of secure, well-paid jobs with reasonable hours that people who don’t come from wealthy backgrounds need to thrive in the media industry.

The language about assessing the BBC’s “competition and market impact” is also concerning. In the past competition concerns have been used to stymie innovation, such as shutting down the BBC’s education platform BBC Jam in the late 2000s following lobbying from private education resource providers (who then did little to invest in their own alternatives). A narrow conception of the BBC as a monopoly which needs to get out of the way of private interests also fails to account for the wider kinds of value it generates, and the positive impact on the overall media ecology of well-resourced public institutions which are able to direct technological innovation in the public interest.

The assessment of the BBC’s impact on its commercial competitors also seem to conflict with another area of the Mid-Term Review, which will be examining whether the BBC’s commercial arms are doing enough to “maximise revenue”. Over the past decade BBC Studios has expanded significantly and its revenues have plugged holes in the BBC’s budgets in the face of major cuts from licence fee revenue. This is a worrying development in itself, especially as vital services like Children’s Productions have been pulled into this commercial wing, and are now supposed to seek returns from global audiences rather than produce the best quality content for British children. The BBC seems set to be caught in a Catch-22, where it is simultaneously supposed to distort its own public service ethos in order to generate revenue through commercial activities, but then potentially faces punishment if it is ‘too successful’ in the marketplace.

Finally, we have the assessment of editorial standards and impartiality. Impartiality is a contested term within journalism, with some strands – such as peace journalism – arguing that being ‘impartial’ always in fact means being aligned with powerful interests. What is incontrovertible is that the idea of impartiality is increasingly being weaponised within the BBC. On the one hand, senior appointments within the BBC have been interfered with on the basis that the person has made ‘political’ statements and would not be sufficiently impartial, such as the attempt to block Jess Brammer’s becoming executive news editor because she had previously tweeted support for Black Lives Matter.

On the other hand, the government pushed extremely hard to appoint ex-editor of the Daily Mail Paul Dacre as head of Ofcom, even though his anti-BBC views are extremely well known, and have now installed Lord Grade, who was until April a Conservative peer* and who has spoken in favour of Channel 4 privatisation. We can anticipate that the assessment of the BBC’s impartiality within the Mid-Term Review will continue with this highly uneven and partisan interpretation, where holding political office for the Conservative party is seen as compatible with impartiality, and yet even anodyne statements in favour of equality are seen as indicating an unacceptable level of bias.

The BBC does face major challenges – in terms of technological developments, changes in audience behaviours, and an elitist culture that is increasingly out of step with many parts of society. The Mid-Term Review asks no questions about how to increase civic participation, address demoralisation among staff, or ensure that the BBC’s programming remains distinctive amidst the slew of commercial content available on streaming platforms. Its main purpose seems to be keeping the BBC on constant high alert and reinforcing the message that it exists primarily to serve the government, rather than the wider public.

*Lord Grade was appointed as a Conservative peer by David Cameron in 2011. Since taking the position at Ofcom he has become a crossbencher, and claims that he can now leave his “opinions at the door”.