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The BBC's Strategic Review can be characterised as "defensive and unambitious," the NUJ says in its final submission to a consultation by the corporation's governing body .

"Far from anticipating and deflecting hostile criticism of the BBC, we believe it will simply invite a further and even more critical response from commercial rivals and from those political forces that ultimately seek to limit public service broadcasting and to support a more dominant role for commercial broadcasters," the union says in its official feedback of the BBC's strategic review, seen by Journalism.co.uk.

Warning the corporation away from a "strategy of self-sacrifice", the NUJ says the BBC should respond vigorously to "the self-interested criticism" from commercial rivals such as News International and what the union calls its "political clients".

The NUJ, which launched a campaign against BBC cuts following publication of the Strategic Review earlier this year , is worried by the potential for "homogenised, bought-in programmes," that the proposed changes could bring.

Public service broadcasters, led by the BBC, are responsible for over 90 per cent of the investment in original UK content, it claims.

"Commercial non-PSB broadcasters such as BSkyB have a simply abysmal record of investment in original programming."

The BBC Trust will consider submissions to its consultation , before making a decision on the BBC's planned cuts as part of its Strategic Review. It closed to submissions on 25 May and according to its website, it plans to publish "provisional conclusions" on the strategy review proposals this summer, and a "final strategy" in the autumn.

"We're hugely disappointed by the strategy review," NUJ general secretary, Jeremy Dear told Journalism.co.uk. "In essence, it is a self-harming strategy for the corporation, intended to appease calls from its commercial rivals for a reduction in its scope.

"Already, that strategy has spectacularly backfired. Far from satisfying those commercially motivated demands, the BBC's proposals have simply increased those calls further."

Dear added this he is also concerned about 600 potential job losses that could result from the implementation of the strategy. The union will fight to ensure that there are no compulsory redundancies, he said.

But the submission does approve some cuts: the corporation could reduce management numbers and bonuses, to raise funds for content. No-one should earn more than five times the mean salary of staff, says the NUJ, adding that BBC director general Mark Thompson currently earns 24 times that benchmark.

Some of the objections

It specifically objects to the dismantlement of the Asian Network; it is concerned that the BBC's "real agenda" is to close down the Asian specific service altogether. The union welcomes the response from listeners opposing the closure of 6 Music.

The union's submission challenges plans to cutback the online operation, especially the proposed 25 per cent cut in budget. "This would irretrievably damage the BBC's online operation and the BBC reputation for quality," it says. "The website is envied by the rest of the world and is one of the most popular content websites anywhere.

"It has also been one of the most significant drivers in the take-up of online services across the UK. It is ludicrous for the BBC to be consulting on cuts to the Online operation without actually specifying where those cuts would be made and we urge the Trust to seek further detailed information on the BBC management’s plans."

The submission also opposes cuts at BBC Local Radio and plans to dismantle the set-up of BBC Worldwide, and claims that handing control of BBC magazines to a private company risks disastrous "editorial errors".

The NUJ is concerned about plans for a more flexible "employee proposition" and what it says is a "clear implication that long-term employment at the BBC will become unusual if not positively discouraged".

"Employers, predictably, see great benefits in flexible labour markets. Workers, generally, do not". Members have been positive in responding to the BBC's previous requests for multi-skilled and multi-platform working, says the NUJ, but the union believes "a limit of reasonable flexibility has already been reached and in many cases exceeded".

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