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針對明日(5/16)立法院交通委員會將進行的「媒體壟斷防制與多元維護法」審查，包括媒改社、媒觀、傳學鬥等三個媒改團體，呼籲儘速完成立法，以實質規範防制資本壟斷媒體的弊端，並在法案內提出促進媒體工作者專業自主與多元基金等具體作法，以維護媒體多元。
我們對於不同版本的草案，有如下之分析與主張：
一、反壟斷的除弊規定
1. 電視頻道的水平集中部分，根據目前各版本法條內容推估，除國民黨立委版本並未明訂實質紅線、缺乏管制效力因而不可取之外，其他版本所規劃的電視頻道集團數目，大致在3~4個之間(行政院版可能為4；[註1]民進黨版為3~4；反媒體壟斷聯盟版為3~4)。
2. 垂直集中或跨媒體集中部分之規定：(1)行政院版為各媒體經加權指數換算為電視收視率加以管制，不同媒體加權指數經由公開的聽證程序後訂定。(2) 民進黨版本禁止「系統與無線電視、新聞及財經頻道、全國性廣播或全國性日報之整合」，亦即禁止內容與通路（平台）垂直整合。
3. 綜合上述分析，我們認為，在廣電市場水平集中的規定上，除國民黨立委版本之外，三版本之間的實質差異並不大，若其中之一能付諸實施，皆能一定程度回應社會反對媒體壟斷之呼聲，因此首要之務為儘速依照三版本的相關原則完成立法。至於垂直集中或跨媒體集中的規定方面，行政院版必須在不同媒體加權數值上，確保程序的專業判斷與公開透明；民進黨等版本分離或規範傳輸與內容製作的具體制度，則建議除競爭觀點之外，必須再以促進閱聽人權益再做進一步評估。
二、維護多元的興利目標
1. 落實專業自主與公民參與：在行政院版、民進黨版、及反壟斷聯盟版中，包括「新聞編輯室公約」、「新聞倫理委員會」、以及「媒體�商業團體設置獨立董�理事」等三項主要作法，已經形成對於內容監理引入「工作者專業自主」與「公民共管」、以制衡商營媒體利潤導向問題的共識。我們建議延伸「參與經營」的產業民主概念，在本法與相關政策中進一步要求(1) 媒體採行「員工董事」制度；(2)將專業自主延伸至非新聞的傳播內容製作；(3)鼓勵媒體採行包括信託等方式「所有權與專業經營分離」原則等。
2. 落實媒體公共服務角色：行政院版本於憲法、通傳會組織法與大法官釋憲文，以及兩公約國內施行法，對於優良新聞及國際新聞製播、促進多元文化均衡發展，及提供公眾近用資源等提出承諾，應予肯定。然而，徒承諾無法自行，在本法的相關規定基礎上，對於維護多元所需資源、如何取得資源、以及資源由何種公共機制或媒體負責分配使用等，行政院都必須本於職責，在立法院通過法案後，合理期間內，提出明確的政策或配套法案加以落實。反壟斷聯盟版本則對此有進一步明確規範，要求設置多元發展基金並明訂財源，是值得肯定與推動的方向。
註1:行政院版本對於衛星電視頻道的壟斷”紅線”，主要有兩個。一是集團所擁有的頻道數限制(經營上限為10、新聞頻道為3，連同代理頻道計算的上限為20、新聞頻道為5)，二是合併後年平均收視率上限15%。根據收視率調查顯示，從1992至2012年間，台灣電視的年平均收視率總和，二十年來皆在10-12%之間、年度加總皆未能達到15%。不過若結合對於頻道數目上限的規定，從2012年電視頻道收視率統計推估前20名頻道的收視率總和（同時也考量無線電視台不能合併、及新聞頻道的數量限制等規定），行政院版對於水平集中的實質收視率門檻上限約為3.2%~3.9%左右。因此若以電視總收視率約12%計算，應至少有4個電視頻道集團。進一步說明請參見本社主張詳細版本之1.3.1。
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