Introduction and Links to other pages Appeal to the Governors' Programme Complaints Committee (GPCC) 28 March 2006 Dear Sirs I am appealing a complaint regarding aspects of the 2005 series of Dr Who. My original complaint was dated 1 June 2005, and the submission to the ECU was dated 18 October. I enclose my additional letter to the ECU of 28 December 2005. To date, the implementation of the BBC's complaints process has fallen short of my expectations. Since it is within the remit of the GPCC to consider the "effectiveness of its processes" (Source) regarding viewer complaints and comments, I would like to make a number of observations that have a bearing on the handling of my complaint, and presumably many others. The complaints process is described on the BBC website as follows: "If your complaint is about a specific programme, and you believe it breached the BBC's editorial standards, you can ask the independent Editorial Complaints Unit (ECU) to investigate … If you dispute the ECU's ruling you may appeal to the Governors' Programme Complaints Committee". The above statement says "editorial standards", but the document to which it refers is called the editorial guidelines. I have read various sections of this document and, for the main part, it is as its title states: guidelines. There is very little mandatory content. While one can have "breaches" of standards, one cannot have breaches of guidelines. This is a contradictory use of words and one which appears repeatedly on the BBC internet site; for instance: "To ensure the highest ethical and editorial standards, all content producers working for the BBC are expected to adhere to the BBC Editorial Guidelines" And: "Producers have strict guidelines for dealing with issues of taste, sexual matters, violence and strong language" These sentences are non-sensical; one cannot "adhere to guidelines", nor can one have "strict guidelines". If the complaints process depends on guidelines then, by definition, the complaints process is a matter of questioning judgements of programme-makers (as opposed to applying standards). Consequently, the complaints process can only function meaningfully if the BBC responds impartially with regards to what constitutes the right judgement. There have been, however, instances at each stage of the complaints process which have raised questions in my mind as to whether the complaints process is working, or has value as presently constituted: » In correspondence with the Information Unit, my complaint was described as "highly subjective". If a viewer's complaint is subjective (opinion-based) then so too must be the contrary views of programme-makers. To describe a viewer's complaint as "subjective" or "highly subjective" without acknowledging that the views of the Dr Who office are equally subjective indicates a bias in favour of the latter. » The ECU's response of 10 November 2005 contained numerous indicators of partiality towards the Dr Who office, and I illustrated some of these in my letter of 28 December 2005 (copy enclosed). » On 17 January 2006, I received a letter from the GPCC itself which seemed to contradict the whole point of the GPCC's role in the appeals process. The GPCC will therefore understand if I feel the need to emphasise that there must be a much higher standard of independent adjudication at this final stage of the complaint process. If the complaints process is a matter of judgement and subjectivity, then the GPCC must be prepared to make an independent decision as to whose subjectivity is valid. It is not sufficient to reject the complaint on the basis that it is the programme-makers' right to make judgements, or that this is the only complaint. The GPCC must consider the reasoning of the complaint; this is especially important since many of the points relate to matters of principle. Complaint 1 - Reference to a living person I assume that there is no need for me to repeat the original complaint, since the GPCC will have referred to it. The defence offered by the ECU for the Michael Jackson reference lies, in part, on references to celebrities being commonplace "…across a range of radio and television programmes as well as newspapers and magazines and some everyday conversations". I do not dispute that Michael Jackson jokes are widespread; Spitting Image is one of many examples to which the ECU might refer. However, I suggest that such programmes and publications are irrelevant for purposes of comparison to Dr Who - for the simple reason that they are not Dr Who. Perhaps because of this, Mr Steel attempts to bring the Michael Jackson reference into the context of Dr Who by suggesting that Rose is the latest "feisty" companion. Dr Who did not, to my knowledge, rely previously on derogatory references to living persons to illustrate its fictional characters, and my complaint is that they should not do so now. With regards to the explanation for the reference (to connect the audience to the story), I have nothing to add other than that the reference was not necessary for this purpose, and any benefit derived is outweighed by the negative connotations (a joke about somebody's facial surgery). Dr Who is fictional/fantasy entertainment; reference to living persons represents an error of judgement. It is also a practice that is open to misuse. Complaint 2 - Political content There seem to be three logical aspects to this complaint that need consideration. First, Dr Who's purpose. The Information Unit has stated that Dr Who is "fantasy fiction"; the ECU has described it as "entertainment". It is produced by the Drama department. Since the BBC exists to "inform, educate and entertain" (Source), I assume Dr Who falls into the third category. I would be grateful if the GPCC would confirm this. Second, how Dr Who was used; was the use of the programme confined to the purpose of entertainment, or was it also used for political content? In its letter of 10 November, the ECU disputes the term "political" and uses "contemporary". I regard this word as inaccurate (see point 4 of my letter of 28 December 2005), but I do not think, ultimately, which of the two words is used makes a difference to this complaint. The question is whether the programme was used as a platform. I would have thought that Dr Who's use in this way was obvious. My letters of 1 June and 18 October 2005 provide examples that range from throwaway remarks to more developed posturing. The ECU's response is to cite one example (religion) which it regards it as a poor example, and then to reject all examples as though the example cited is representative of all. The ECU does not, for instance, mention WMD, even though this is referred to in my complaint. Further, production staff have said that the politicisation of Dr Who was their intention, so the examples provided are not the product of my imagination. In my letter of 18 October, I provided a lengthy quote from the writer-producer and I reproduce the salient parts here: "… there's a vital political issue burning away here … I've put it right at the heart of BBC1 primetime … It's agitation … You have to provoke … My work is done". The context in which Mr Davies says "my work is done" is not one of producing Dr Who as entertainment but of "agitating" and "provoking" the viewer in relation to an issue that is of importance to Mr Davies personally. Since submitting my complaint, I have seen a further quote, relating to the Dr Who Christmas Special. I did not see this episode but include the quote, taken from the BBC website, because it again indicates the writer-producer's intention: "It's Christmas Day, a day of peace," said chief writer Russell T Davies. "There is absolutely an anti-war message because that's what I think." Actress Penelope Wilton plays the Prime Minister in the hour-long show. In one scene she says of the US president: "He is not my boss and he is certainly not turning this into a war". Source Third: was the using of the programme in this way acceptable? Mr Steel has interpreted the term "acceptable" to mean acceptable to the majority of people sending in emails and reaches the conclusion that, since other people did not make the same complaint, it is acceptable. I did not, of course, use the word acceptable in this context; I used it in the sense of 'appropriate', i.e. it is not appropriate for BBC employees to use a programme for personal ends. Whether the BBC receives one complaint or one thousand does not affect the accuracy of this complaint, and I do not agree with the notion that a small number of emails or complaints obviates responsibility on the part of programme makers to act appropriately from the outset. Mr Steel refers to "creative freedom". In democratic society, we all enjoy freedom to speak our minds. However, freedom in the latter sense applies when people act in their personal capacities, and my complaint does not relate to what Dr Who staff do in their own time; it relates to their expression while in their employed capacity. The comments by Mr Davies quoted above indicate that staff thought, in effect: "We have some issues we want to get off our chest and we are going to use Dr Who for this purpose". According to its website, however, the BBC is "run in the interests of its viewers and listeners" (Source); it does not say "…and programme management". Yet, this is what happened; the Dr Who programme was used for the self-gratification of the people making it. Such actions do not, I suggest, constitute creative freedom, but a misuse of position and public facilities. Whether the programme was produced competently in other regards is not a justification. Complaint 3) Bad/sexual language The complaint here is that the distinction between delivery of language (accent, pronunciation, etc) and bad language (e.g. words that are unpleasant, or overtly sexual) was not respected as part of the Dr Who office's dispensing with "standard English". For the benefit of Governors who are not familiar with the original series, bad language was not used. The series sidestepped bad language entirely. The production of such programmes is important for viewers who, for whatever reason, have no particular wish to hear bad language on television. For viewers such as myself, bad language on television does not 'work'. When I hear the obligatory four-letter swearword in post-9pm programmes, I do not think to myself, "wow, that's so powerful"; I think, "how tedious". In Dr Who, four-letter content cannot be used (at least, not overtly); instead, the writers of the 2005 series used 'fart', 'bitch', 'oh, bol-' and so forth. The principle is the same, in that bad language proliferates and cannot be avoided. Such references may be regarded as having chic value for writers or producers wanting to 'break boundaries', but when I watch Dr Who (or any other programme) I want to feel I am watching the programme, not someone 'pushing against limits'. On page one of this letter, there is a quote from the BBC website that refers to "strong language". Depending on one's perspective, there is a distinction between "strong language" and strong use of language, that is, drama and humour that relies on ideas and situations. From this latter perspective, strong language is weak language. A very simple example of the distinction lies in that the 2005 series of Dr Who had lines such as: Oh my God, what was that? The equivalent line in the original serial might have been: What was THAT? The original series relied on provoking the viewers' interest in whatever that was. Anxiety of the characters was conveyed by the predicament in which they found themselves (thereby necessitating a high standard of story telling), and the actors' reactions. Bad language was not necessary because the drama or humour spoke for itself. The suggestion from the Information Unit that bad language makes programmes more modern or real has no bearing on this complaint since, for viewers of my perspective, bad language is not part of the drama; it is stuck on, intrusive, detracts from where the emphasis should be, and reduces the pleasure of viewing. Lack of appreciation of this perspective is illustrated by the Information Unit's letter of 28 July 2005 which refers to two categories of viewer; children, over whose head such references are said to go, and adults, at which swearing and sex gags are directed. There is no acknowledgement of the third category, which is adults of all ages who wish to be spared the swearing and sexual references. I do not see why viewers who constitute this third group should be treated as though they do not exist, or be excluded from the definition of a "modern audience". Very simply, I wish to be entitled to watch evening television without exposure to writers and performers who think that, because they use bad or blue language, the viewer should be impressed. I ask that the GPCC reads again point 10 of my letter of 28 December 2005. Yours sincerely, etc The GPCC sent this reply on 31 March 2006: Immediately following the appeal, the GPCC sent an update, dated 18 May 2006: I was unclear as to the relevance of the subject line "A New Dimension" and its reference to a five week period, so the following letter was sent back: 20 May 2006 Dear Ms Lucas Thank you for your letter dated 18 May 2006. Please could you explain the reference "A New Dimension" in the subject line of your letter. Is this the name of an episode? Also, I am concerned at the date range "26 March - 30 April 2005". My complaint did not apply to this period only but to specific aspects of the series, which ran from 26 March 2005 to 18th June 2005. I would be grateful if the GPCC could assure me that all is in order. Yours sincerely, etc The GPCC responded thus, on 23 May, 2006: For the result, click here.