There's no doubt that the House of Lords Communications Committee has hit the nail on the head when it says it's too complicated to complain to the BBC - but sadly, the solutions proffered by m'Lords are no answer. Here's an entertaining chart compiled by the Committee (who are clearly pleased with their work, and suggest the BBC should put it online straightaway).
The committee wants the Executive to "exec" (with the DG still as chairman, which will please Thompson and Patten); it wants the Trust to stick to "governance"; and Ofcom to be the "regulator". So major shifts would be required to make Ofcom the ultimate arbiter of complaints about "accuracy" and "impartiality".
I really don't mind who rules on "accuracy"; quangos CAN do it - and I've always admired the robust approach of the ASA to dodgy advertising claims. It is, however, impossible to measure impartiality, and the BBC has always struggled to find ways to "prove" that, particularly over time. An impartial course through difficult issues can change direction as the story unfolds, and is best steered by experienced editors within the organisation. The check and balance should be with the Trust, representing the licence-fee payers, not the quango OFCOM, representing the Government.
One suggestion from the Lords is naive and wrong - that all complaints be directed to BBC Audience Services. The listener/viewer these days is in constant contact with programme teams through email and Twitter - and producers have to make a sensible call as to when a comment is a comment; and when a comment is a complaint; and when a comment requires a correction - e.g. using pictures of Sian Phillips in an obituary of Margaret Tyzack. Output teams shouldn't be isolated from that immediate dialogue.
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