Okay. What this table does is set out a description of different methodologies which are used in Italy, Belgium, France, the UK -- and there are two measures for the UK. And what the table is trying to explain is my fundamental observation about -- particularly the UK framework is that it's subject to an unacceptable level of delays and challenge. One of the reasons for this -- not the only reason -- is the measures which are used.
There has been a long debate about what are the most appropriate ways of measuring media plurality, and I can say a bit more about that, but the -- for example, in Italy, revenue shares are used. This was the proposal you discussed yesterday in relation to Enders Analysis' proposal of a cap on revenue shares. That's the system which is used in Italy, which indicates a proportion of revenues within a specific media market.
In Germany -- and Germany's an interesting case, which might warrant looking at a bit more closely -- they have a different policy objective in mind. I think one of the more fundamental reasons that this policy area has been subject to so much challenge and difficulty is because of the lack of clear policy objectives, and in Germany the policy objective is not simply plurality of media sources; it is what they call "Meinungsmacht", power over opinion formation. And they measure, in relation to -- in particular, to television, exposure -- standard audience indicators for audience shares when they're taking into account -- when they're trying to work out if a television merger -- a merger involving a television owner breaches their limits.
It's interesting just to build on this a little bit to observe that -- for me, the fundamental issue is this issue of clarity of policy objectives. In the UK, we have a plurality system which -- and we've analysed this in a longer paper -- has the objective of promoting diversity, a different range of view points -- and I'm thinking of the Enterprise Act, section 58 description of what must be taken into account in the event of a merger. But it also has the objective, for example, of guaranteeing freedom of expression, accuracy, and a sufficient plurality of persons, which could be a proxy for opinion-forming power.
This contrasts in turn with the US approach, which is much more just concerned with diversity. I think in the UK, we have particular problems because we are asking too much of the merger tests and we're not asking them very clear things, and those things that we're asking the merger tests and the merger framework to achieve are sometimes in conflict with one another. This is going beyond the point about measures.
You can imagine a market, for example, where a decline in the number of providers would not result in a reduction of diversity -- and this has been empirically proven -- whereas usually a decline in the number of providers almost always provides a reduction in opinion-forming power.
So the fundamental problem, as well as the issue of measures -- and as I've said, the measure we favour is similar to the Ofcom share of references. We think audience measures are better, but the more fundamental issue is clear policy objectives and distinguishing between the objective of diversity of media content and the number of voices, which is, I think, a particular problem. I think this might be something that the Inquiry can help clarify.