Trans Activism UK’s Official Response to Rhodri Talfan Davies, BBC Director of Nations

A couple of days ago, Trans Activism UK finally received a response to our open letter, signed by over 20,000 people, calling out issues of transphobia, poor sourcing, lies, and covered up counter-narratives in the article “We’re being pressured into sex by some trans women”.

You can read the BBC’s response in full by clicking here.

Their response continues a pattern of downplaying the harm done by their piece and pursues unwavering  justifications for its publication, while avoiding addressing the many remaining complaints about the piece, and trying to offer platitudes instead of owning up to the sheer scale of the damage done by the article. 

The BBC wants to callously pretend that they’ve properly addressed the issues with their reporting, properly owned up to their errors in a public manner, and have addressed all of the remaining complaints with the piece. 

So, we’re going to examine some of the claims in their response, identify the areas where we disagree, and the issues they have not yet addressed.

“BBC News content may provide a forum or starting point for topical discussion and exploration on a wide range of issues and, necessarily, this includes viewpoints that some audiences will consider challenging.”

The above sentence very clearly hand-waves away the fact that there is a difference between a challenging viewpoint, and a piece deliberately reinforcing a harmful and untrue stereotype held against a marginalised minority group, by pointing to individual cases as unbiased sources, published by a media outlet that is seen to be a bastion of impartial journalism. What you choose to investigate is meaningful, it suggests to the world that you think there’s something important happening of note, and that carries weight, and an implication of expertise.

You would not publish an article about gay men pressuring straight men into sex, based on the reports of two groups laser-focused on rolling back gay rights and one named individual who wasn’t a gay man, with a known history of sexually abusing straight men. You would recognise that, even if the piece said “some” sporadically, it platforms sources whose existing beliefs and group goals make their inclusion in the piece far from unbiased, regardless of the specific experiences of the individuals, and that the hypothetical article would likely lead to fearmongering needlessly about people’s safety around the wider gay community.

You would not publish the above, because we have reached a point where the BBC recognises there are no two sides to homophobia, and coverage that induces fearmongering, reinforces biases, and platforms those who want to roll back gay rights is morally wrong, insisting on “hearing the other side” would not be acceptable, and painting individual crimes against a wider group through implication would be discriminatory.

You are holding your reporting on transgender people to an egregiously different standard to your reporting on other, more societally accepted, minority groups.

Additionally, on your repeated instances of the BBC’s coverage being “impartial”, let’s call attention to OfCom’s definition of impartiality.

Contrary to popular misconception, Ofcom does not require true impartiality from the BBC, where all sides are given equal prominence on all issues regardless of context. Ofcom has a standard it holds the BBC to, called “Due Impartiality”.

“Due” is an important qualification to the concept of impartiality. Impartiality itself means not favouring one side over another. “Due” means adequate or appropriate to the subject and nature of the programme. So “due impartiality” does not mean an equal division of time has to be given to every view, or that every argument and every facet of every argument has to be represented. The approach to due impartiality may vary according to the nature of the subject, the type of programme and channel, the likely expectation of the audience as to content, and the extent to which the content and approach is signalled to the audience.

The BBC doesn’t platform racist perspectives on non-white people, homophobic views on the gay community, or other bigoted views on minority groups held by those with hateful views, because under due impartiality the BBC recognises that it is not in the public interest to platform those views, as they contribute towards harm to those minorities.

Platforming hate groups and those with known implicit biases is not due impartiality. You are not obligated to platform anti-trans hate groups, and in fact, choosing not to platform them would bring your treatment of the trans community in line with other minority groups you cover.

Under OfCom, true impartiality is not a defence for articles that are one-sided and propagate hateful attitudes toward minority groups, but a framework to ensure organisations take all due consideration when publishing articles. The BBC has a responsibility to treat the trans community with the same degree of due impartiality that it treats other minority groups, by not insisting on both sides debates with people who feel trans people should not exist.

“This article, which includes a range of testimony, is one piece in a body of work across the BBC which reflects many different issues and perspectives on the trans community and others.”

We are in the process of researching archived versions of the BBC’s historic coverage of trans people, and while we’re still working on that research, we can confidently state that this article is not a singular outlier in otherwise great coverage, but the latest in a long running series of pieces which platform known anti-trans hate groups uncritically, or are written in ways that reinforce harmful ideas about the trans community. Many pieces you publish platform those who describe trans women as men, without your writers correcting those statements, and without any comment or quote from a trans person on the topic.

That said, even if that was not the case, past positive coverage does not excuse the issues with this piece of coverage. We do not believe the BBC should be able to hand-wave away the harm done by this article, by pointing to positive work done in the past. Past behaviour does not justify the harm done today.

‘There is no carbon offset for bigotry.’

“A quick search on the BBC website will reveal just how many programmes and stories we do on trans issues. Many of those stories explore individual testimonies and how people express their identity. Some deal with legal and rights issues. But the totality of coverage provides a body of work which has featured many trans issues. Here are some examples:

Again, past positive coverage does not undo the harm perpetrated. If you’ve hurt, harmed, and upset someone today you don’t get to say “well, I’ve been good in the past” and pretend that undoes today’s harm.

It is frankly both laughable and insulting in equal measure that you were not able to directly provide even a single piece of evidence that supports your claim of impartiality via previous works after several weeks, and instead opted for providing links to a search for the word ‘trans’ on the BBC website, and a Google search for ‘transgender’. This truly speaks for itself in how little care you have for the subject matter, and how little respect you have for the 20,000 signatories. This is unprofessional to an appalling degree, an incredible lack of actual effort.

That said, we would actually like to discuss the first link you provided, the link to the BBC News site search for the word trans.

Setting aside that most of that first page of results you link to isn’t actually about transgender people, but rather stories that use the word trans in other contexts (highlights such as ‘Nairn Across Britain: Trans-Pennine Canal’ and ‘Giant puppet completes trans-European trek in Manchester’), I’d like to talk about the very first post that appears on that search, “Leo: Becoming a Trans Man”.

The BBC piece, which originally aired in 2017, does centre a trans perspective but does so using sensationalist and harmful language that perpetuates harmful stereotypes that not only harm the trans community but are used today by anti-trans activists to justify denying healthcare to trans people.

Firstly, the subheading that appears on the search page is “Teenager Leo makes the irreversible decision to become a trans man,” a video produced and published by the BBC in which a teenager is wrongfully presented in the preview text to be taking hormones whilst underage seemingly for shock value (“15-year-old Leo makes the irreversible choice to take testosterone”) only for the video itself to confirm that this is false (“When he turns 16.”)

He is already a trans man. The video is about Leo’s choice to start testosterone and he clearly intends this to portray his journey onto testosterone, which at no point should you classify as him “[becoming] a trans man”.

Secondly, to describe a trans man’s very first day on testosterone as irreversible, or transition generally as irreversible, is at best inaccurate and at worst active fearmongering. There are people who choose to detransition. Though rare, 0.4% of people who begin a gender transition go on to realise that transitioning is not right for them and stop, often due to factors such as societal hate received from the public post coming out, or lack of family support, but in some cases simply because it’s not right for them. The idea that people, particularly teens, are irreversibly forced to persist with transition if they start is untrue and used to scare parents into not letting their children explore transition.

In this regard we would like to highlight the importance of puberty blockers, thus mitigating the “worst-case” changes by allowing adolescents to “pause” puberty to allow them more time to explore their identity, reducing the likelihood they will start HRT and later regret that choice.

Thirdly, following puberty blockers, even if we’re talking about starting testosterone, some of those changes for a trans man will naturally reverse upon stopping testosterone, and some can be reversed with assistance. Electrolysis and laser hair removal exist, voice training exists to retain or regain a higher vocal pitch, coming off hormones will often restore fertility, many physical changes from testosterone can, in a worst-case scenario, be reversed to a reasonable degree.

Fourthly, by clicking on the link, you’ll see that the description under the video describes Leo as “born a girl”, further reinforcing the idea that he wasn’t always male, and that his being male only counts starting now”*¹ *². This video does not seek to use the correct terminology, consequently, this is transphobia, and is further damning evidence that the BBC has not been a bastion of long term ongoing impartiality on trans coverage.

Finally, you describe “his quest to become a man”, again further insisting that he is not yet a man and that the medical steps he is taking are required to be valid as a man.

These issues arise before even clicking on the video. This is the VERY first BBC piece to come up when you search ‘trans’ in the BBC search bar. This is the very first article to appear in the links you sent us. This is not making the case you think it is that the BBC has historically got things right when covering trans people, even on your more sympathetic coverage.

I could go through and list every piece so far we have found with these kinds of issues, but doing so would massively derail this response. Simply put, even your own links show that the BBC doesn’t know how to properly talk about trans people, even in the coverage you point toward as proof of your editorial balance. The fact that you sent the links you did without spotting issues with the very first linked piece shows a real lack of care and attention.

“We are clear throughout that the size of the issue is difficult to gauge and that there is limited research in this area. The article is thoroughly caveated, and uses the word “some”, so we clearly do not mean “all”. Others quoted in the article said: “there is currently little data” and “we don’t have figures”.

We also caveat the use of the survey in the article. It was conducted on social media and is therefore self-selecting. In addition, the author of the survey admits it may not be a representative sample. Furthermore, there is a link to the detail of the findings which enables the reader to make up their own minds about the replies the sample generated.”

Allow us to be direct here. Yes, this article legally stopped short of explicitly stating that all trans women are rapists of cisgender lesbians. We do not and have not argued that the piece literally says that “all” trans women are rapists. Some of the groups you have platformed believe that, but we are not claiming that your piece legally and explicitly says that.

Our argument is that the occasional use of the word “some” isn’t enough to justify publishing a piece that entirely platforms the perspective that trans women sometimes rape cis lesbians with no counter-narrative, presented by groups who literally believe all trans women are rapists, which will lead to more people believing that this is something they should fear about trans women as a wider societal group going forward.

“Some” could mean that 99% of trans women are sex criminals. “Some” just says there are exceptions, it doesn’t make it clear that this is a rare occurrence likely entirely unrelated to being trans, and something to explicitly not assume of most trans women.

Quoting sources saying “there is currently little data” and “we don’t have figures” also doesn’t go far enough. You need to be clear that there is no data that suggests this is widespread, and what data does exist explicitly says the opposite*³ *⁴ *⁵ *⁶ *⁷ *⁸.

It’s not enough to quote hate groups saying they have no evidence for their claims, but continuing to make them anyway while ignoring actual evidence that disproves their claims.

The groups who are sourced for this piece hold views that all trans women are the problem. If someone reads this article, with its “some” caveats, and wants to know more, they will be looking up groups who tell them actually, it is all trans women and they should be afraid.

Your piece never does the important work of letting a trans person, or a trans-positive cis lesbian, or anyone else for that matter, state in simple terms the fact that this is not widespread.

“It is terrible this has happened to some individuals, but as a general rule trans women do not want to sleep with people who do not see them as women. It’s dehumanising and upsetting to not be seen as yourself, and why would we want to coerce people who hate us into sex when there are so many people who do find us attractive we could sleep with instead.

We as a general group are not going to call you transphobic if you don’t want to sleep with us, or pressure you to do so. We condem any individual trans woman who has wielded transphobia to coerce someone into sex, but you can’t hold that against all trans women as a societal group.

Sexual abusers come from all backgrounds, the BBC’s article originally platformed an admitted cisgender sexual abuser with credible public allegations against her. Individuals commit crimes, not minority groups, and it’s important to not paint a whole group as potential criminals, explicitly or by tone of coverage”.

The above was written by Laura Kate Dale, one of our group’s members, who is a trans woman. You can include that quote from her if you like. It’s the kind of explicit denial of this being a widespread issue that this piece sorely lacks.

“We also believe that seeking the view of the LGB Alliance was a legitimate line of enquiry”.

We have made it very clear why we disagree. You can read our in-depth reasons why in previous statements we have made to the BBC, but to reiterate, the LGB Alliance appears to be actively breaking the rules of the 2011 Charity Act. 

A charity must act in the public good, use its funds toward furthering its stated goals, and not exist purely to further a political aim, such as impacting legislation.

LGB Alliance spreads huge amounts of anti-trans misinformation, which is not for the public good.*⁹ *¹⁰ *¹¹ *¹² *¹³ *¹⁴ *¹⁵ *¹⁶ Neither is their targeting of specific trans people on social media to direct hateful messages at *¹⁷ *¹⁸.

They are primarily stated to be an LGB rights charity but seem to exist purely as an anti-trans group. Their recent conference exclusively featured panels about trans people, they demonstrate a pattern of biphobia, and they do not actively fight for progress on matters impacting the LGB community, such as getting rid of all forms of conversion therapy. They do not even support same-sex marriage. 

They also explicitly seek to roll back trans rights legislation. They frequently speak to politicians in an official capacity and advise them to roll back trans rights.

In your response, you also conveniently leave out mention of Get The L Out, who we have highlighted to the BBC hijacked London Pride to hand out hateful bigotted leaflets, and scream slurs at trans people*¹⁹. You also failed to note that their survey contains not only conflicting information but is based almost entirely on unfounded anecdotal evidence from people with a clearly transphobic agenda. 

“48% of respondents reported visiting lesbian dating sites. Of those, 31% have been approached by “transwomen”. 12.5% have been on dates with “transwomen”, 6% of whom unknowingly. Four respondents report having had a sexual relationship with a “transwoman”: three with a “pre-op transwoman”, one with a “pre-op transwoman” and also with a “post-op transwoman”.

The quoted document, breaking down the Get the L Out survey, then goes on to state; 

“56% of the respondents reported being pressured or coerced to accept a transwoman as a sexual partner” under the heading of “Indirect sexual pressure”, a segment of the document that is referencing anecdotal online interactions with trans women, not physical and in-person like the BBC article seems to imply. 

5% of 80 respondents reportedly had a sexual relationship (consent or lack of consent is not confirmed) with a trans woman, and to present a 56% figure under a headline about trans women pressuring cis lesbians into sex feels like reporting deliberately skewed figures.

The “Findings” conclude with, “Many of the experiences above classify as rape although were not named as such.” This incredibly biased survey, only provided to “women-only” groups chosen by notoriously transphobic Get The L Out, is an insult to victims of sexual assault. 

Get The L Out took it upon themselves to classify a lot of things as rape that survey respondents did not necessarily classify that way themselves, in order to bolster up a figure they could weaponise against the trans community. Situations where a cisgender lesbian felt bad about saying no to sex, or were asked questions by cisgender partners about why they felt how they did about trans sex, were included under that figure. 

“as was seeking the view of Stonewall”

We are going to keep this point simple. It feels pretty rich to see the BBC try to point out their platforming of Stonewall here, in a letter sent the day after the BBC withdrew from the Stonewall Diversity Champions scheme and a few weeks after an in-depth documentary into issues with the charity.

You are not in a position to refer to your quotation of them with such pride right now.

You have been incredibly critical of a charity that is largely working in the interests of the full LGBTQ+ community, whilst refusing to be at all critical of a charity that is engaging in well-documented harassment of minorities on social media, and is pretty clearly guilty of breaking actual laws around how UK charities should function.

If you gave LGB Alliance even 10% of the scrutiny you give Stonewall, you’d probably realise that they’re not a great source to cite on what trans people are like as a group.

“The article was updated to remove a contribution from one individual in light of comments she published in blog posts in the days following publication. We have also acknowledged that an admission of inappropriate behaviour by the same contributor should have been included in the original article. But she was not a case study”

You very quietly removed Lily Cade from the article with zero fanfare, and zero public announcement. You do not mention her by name, and you massively downplay what she did. 

Lily Cade posted a genocidal manifesto calling for the deaths of individuals named trans women, saying that she herself would commit said murders or called for others to do so, asserted that ALL trans women are rapists and part of a paedophile cult, urged all trans women to commit suicide, and more.

“Comments she published on her blog” is a massive downplaying of the severity of what happened, and without naming her you do not give readers the tools to find out who was platformed, or what specifically was said.

Regarding the acknowledgement that the allegations against Lily Cade should have been included in the original article, you still don’t in this response name Lily Cade or ever actually state the relevant allegations against her. 

In the article itself, when talking about unnamed trans women, you are not afraid to label them as having pressured and coerced people into unwanted and nonconsensual sex, but when discussing Lily Cade you seem suddenly unable to talk in anything but vague euphemisms. To the outside observer that comes across as being unwilling to name the specific crimes committed when someone other than a trans woman commits them. It’s hard to see any other reason why the allegations against Cade, which she has admitted to, are not given the same level of specificity or attributed to her, other than because she is a cisgender lesbian and therefore it would not support the article’s transphobic agenda. 

You don’t address the fact that Caroline Lowbridge knew about the sexual assault allegations against Lily Cade by cisgender lesbians prior to the piece’s publication. You don’t address that you were made aware of the allegations by our open letter the day the article was published and dismissed the requests to add that context until Lily Cade’s manifesto was published. You waited until it was time to remove Lily Cade entirely from the piece to address the allegations you knew about at least a week prior, to avoid addressing in the article the fact that anyone, transgender or cisgender, can be an individual predator.

You have not acknowledged that failing to include that context comes across as a deliberate attempt to bury the fact that this piece makes it sound like exclusively trans women are commonly sex abusers of cis lesbians, when in fact it is proven fact that anyone from any group can be a sex criminal.

Also, let’s address the following about Lily Cade.

“She was not a case study”

“Her input was limited to providing context around the origin of the term ‘cotton ceiling’. And the use of the phrase “Gold Star Lesbian” helped position her on the spectrum of opinion on this issue.”

First of all, Lily Cade was absolutely a case study for this piece, you cannot simply state such fabrication and claim it as fact. She was presented as an example of a cis lesbian who didn’t want to have sex with a trans woman and claimed that she wasn’t initially aware that she was going to have sex with a trans woman, so felt misled by that, in a piece about the idea that cis lesbians are being forced to have sex they don’t want with trans women. 

The fact that Cade never makes the explicit claim that she was pressured into sex by that trans woman doesn’t change the fact that hers was an anecdotal account that fit the pattern of other case studies in the piece, and was framed to appear as an example of a trans woman pressuring a cisgender lesbian into sex.

You also failed to at any point platform Chelsea Poe, the trans woman and creator of the term ‘cotton ceiling’, who was interviewed for this piece. Perhaps for example, if you wanted a statement about the cotton ceiling you could have platformed the creator of the term, and their intent in its creation, rather than someone with known pre-existing transphobic views. 

There was a trans person who could have spoken on that point, who is not an accused sex abuser, but instead, the interview with them was buried. The fact that of the two people interviewed about the term cotton ceiling, the trans woman who coined the term was not included, but the transphobic person involved was included in spite of those allegations, with the piece then lying and pretending that the coiner of the term was never interviewed, seems like a very clear example of this article actively burying the chance for a trans counter-narrative to be part of the story.

Additionally, we don’t object to you talking about her being a gold star lesbian, we encourage it in fact, but we feel you provided a lack of context. You did not make it clear the elitist nature of the term, how it’s levied not only against trans-positive lesbians but lesbians in general, or what that might tell us about her wider views of both trans women and women as a whole. We agree that the information that she is a gold star lesbian is useful context, but we do not feel you gave the needed context to explain her position, and how it relates to and differs from the vast majority of lesbians.

Looking more generally at your response, it really seems like the BBC feels that past reporting justifies this piece being allowed to be biased and harmful, that it does not take our concerns about the groups platformed and the lack of context around them seriously, that it believes that a few uses of the word “some” changes the fact that this piece suggests that trans women are sexual predators and that it is a widespread issue, and that it doesn’t feel any duty to publicly own up to how harmful this piece was, or the fact of it’s journalistic failings on Lily Cade’s inclusion in the piece, and the subsequent removal of her, added to that harm. 

Trans women face high rates of physical violence, both in the UK and around the world, particularly in Brazil, a country for whom you translated and republished this piece. 2021 alone has proven to be the deadliest year yet for transgender and non-binary people globally, with the total number of recorded murders having reached at least 375.

Much of the violence perpetrated against trans people globally comes from the kind of fear-mongering that this piece perpetuates. Trans women as a wider societal group are painted as deceitful, coercive, forceful “men” who are rumoured to pressure you into nonconsensual sex and should be villainised as such.

This is based on discriminatory beliefs rather than facts, but this article undeniably stokes the fires that those fears rest upon, even with its caveats of “some”. To treat the topic as legitimate and worth a lengthy investigation that makes it to publication suggests there’s something genuine to the topic, that people should take heed. 

The fact that you’ve dug your heels in this hard, that you’re this unwilling to apologise for the article or properly own up to platforming a known abuser who posted a genocidal manifesto, suggests that the BBC is far more concerned with not admitting the depths of their wrongdoings than actually making this right, or examining the depths of its failures on this story.

Moving on from your response, let’s talk about some of our complaints that you still have not addressed. 

The BBC has still not addressed that Catherine Lowbridge actively lied when she justified not including a trans counter-narrative in the article by stating that she reached out to trans women, but none responded. The BBC has admitted that Chelsea Poe was interviewed. She was not included because she didn’t fit the anti-trans narrative Lowbridge wanted to build. 

This piece actively chose not to platform trans voices, and lied about that fact, in order to avoid trans people being able to counter the hateful narrative being spun about them.

It has still not been addressed that trans-positive cis lesbians were never platformed, giving the false impression all lesbians believe trans women are men.

The BBC has still not addressed why it never once criticises or corrects interview subjects in this piece who refer to trans women as men. Referring to trans women as men is transphobia. To platform those sentiments, and never push back against them, or even just somewhere say “these quotes misgender trans women, that is unacceptable” is a huge failing. This indefensible rhetoric is further confirmation that the BBC does not hold itself to the standards it defended itself with, in official replies to complaints, media enquiries and preceding reports. This reveals at best the BBC’s ignorance or at worst it’s complete bigotry when covering trans narratives. 

The BBC has still not addressed the article being localised exclusively for countries with incredibly high trans murder rates, such as Brazil, and the risk inherent in doing so.

The piece still does not contextualise that the only trans woman given prominent room to speak is known for backing up anti-trans perspectives, or that she shares a statement about trans women really just being straight men despite having no evidence for such a claim, without critique or balance.

This article has a plethora of issues that we have addressed, as have the many people who have submitted official complaints. Your response is inadequate and, in many places, outright unprofessional. 

This will be our final attempt to contact the BBC regarding these exhausted concerns, and if we do not see a significantly improved response to this email we will be escalating our complaints to Ofcom, as we have given the BBC ample time and opportunity to adequately respond to our criticisms, and have so far been brushed aside. 

















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