Your Excellency,

The International Press Institute (IPI), a global press freedom organisation representing editors, publishers and leading journalists in over 110 countries, together with its affiliate organisation the South East Europe Media Organisation (SEEMO), is deeply concerned at a proposed draft media law containing provisions damaging to press freedom in Greece.

According to information provided to IPI, the proposed law titled, "Concentration and Licensing of Media Enterprises and other Provisions", is currently being discussed in the Greek parliament and is likely to be passed in the near future.

If this were to happen, the Greek media would be faced with a law that appears deliberately designed to actively hinder the regional media's economic development and exclude minority groups from access to information.

In particular, IPI would highlight Chapter C, Article 8, paragraph 10a, which states that the minimum disbursed capital, namely the money radio station owners have to keep on deposit as a guarantee, is 100,000 euros for radio stations broadcasting news. The figure is 60,000 euros for radio stations broadcasting music. Such a high figure is unlikely to be met by prospective local radio stations.

The figure of 100,000 euros is also aimed at regions with around 100,000 inhabitants giving the radio station a minimum disbursed capital to population ratio of around 1 euro for each inhabitant. When considering that these regions are some of the poorest in Europe this figure is disproportionate and would prevent smaller local media organisations from obtaining licenses.

Regarding the duty to broadcast, paragraph 13a states that the radio station must provide 24 hour programming regardless of whether the station is carrying information or otherwise. Once again, this will act as a disincentive for small media organisations seeking to provide limited, but essential programming for regional minorities.

This perception is further reinforced by an additional sentence in paragraph 13a stating that the main transmission language must be Greek. IPI believes that this flies in the face of the Greek government's duty to uphold minority rights and breaches the country's international duties in this area, particularly Article 27 of the International Covenant on Civil and Political Rights.

Aside from these requirements, paras 14a and 14b force news and music radio stations to employ a certain number of full-time journalists and other administrative and technical staff in accordance with labour agreements and social security legislation. Para 14b goes on to state that radio stations carrying news and information should have at least 20 members of staff overall, while for music stations this figure is five staff members. Full-time employment under the draft media law is calculated at 20 days of employment per month.

These provisions are similar to the already existing Law 3548, which contains a provision for the print media stating that publishers must hire at least three full-time staff members. IPI strongly believes that these provisions are a barrier to economic development because they demand that media organisations must enter the market at a predetermined size and with a certain level of capitalisation.

This provision is not only anti-competitive, it also prohibits low circulation media, minority or community papers, cultural or special interest products, among others, from having access to the market place. The basic right for a free flow of information should not be tarnished by administrative or bureaucratic measures.

The Greek government is therefore seeking to directly influence the media market through the manipulation of the law.

In consequence, IPI believes that the measures are against freedom of expression and the right to publish or broadcast freely and unhindered by bureaucratic measures. Since your country is a member of the European Union, and has accepted the commitments of the Council of Europe, the OSCE and UNESCO, we intend to inform these institutions by copy of this mail.

We thank you for your attention and appeal to you as President of the Parliament.

Yours sincerely,

Johann P. Fritz
Director

Spiegelgasse 2/29
A-1010 Vienna
Austria
Tel: + 431-512 90 11
Fax: + 431-512 90 14
E-mail: ipi@freemedia.at
http://www.freemedia.at

Oliver Vujovic
SEEMO Secretary-General

SEEMO - South East Europe Media Organisation Spiegelgasse 2/29 1010 Vienna Austria
Tel: +43 1 512 90 11 12
Fax: +43 1 512 90 15
e-mail: info@seemo.org
http://www.seemo.org

CC:
Karolos Papoulias
President of Greece
Vassileos Georgiou II 2
10028 Athens,
Greece
Fax: +30 210 7232342

Kostas Karamanlis
Prime Minister of Greece
Irodou Attikou 19,
10674 Athens,
Greece
Fax: +30 210 671 53 40

Rene van der Linden
President of the Parliamentary Assembly
Council of Europe
Avenue de l'Europe
F-67075 Strasbourg Cedex
Fax: +33-3-88 41 27 81

Koichiro Matsuura
Director-General of UNESCO,
7, place de Fontenoy
75352 Paris 07 SP
France
Fax: +33-1-45 67 16 90

Jose Manuel Durao Barroso
President of the European Commission,
1049 Brussels
Belgium
E-mail: sg-web-president@ec.europa.eu

Ambassador Marc Perrin de Brichambaut
OSCE Secretary General
Kaerntner Ring 5-7
1010 Vienna
Austria
Fax: +43-1 514 36 96

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IPI, the global network of editors, media executives and leading journalists, is dedicated to the furtherance and safeguarding of press freedom, the protection of freedom of opinion and expression, the promotion of the free flow of news and information, and the improvement of the practices of journalism.

SEEMO is a regional network of editors, media executives and leading journalists in South East Europe.