The Broadcasting Commission of Ireland (BCI) has warned that proposals to change the way radio stations are licenced could seriously undermine its position.
The BCI, which licences radio and TV stations throughout the State, said proposals to set up a new appeals body to review its licencing decisions could have significant negative implications.
The suggestion that an appeals panel be set up to review licencing decisions was included in a Government-commissioned report published this summer known as the Ox report. The BCI's views are included in its official response to the Ox report.
The BCI states that any appeal system would simply "second guess" the deliberations of the BCI board. "Given that there are a number of subjective elements in determining applicants, consistency in decision making would become difficult," states the BCI's document.
"Furthermore, a danger would exist that every licence decision would be referred to the appeals board, thereby potentially undermining and questioning the necessity for the BCI board," it says.
"The BCI remains of the view that an appeals system, other than the courts, is neither workable nor appropriate."
This contrasts with the public position of the last Minister for Communications, Mr Ahern, who said stations which lost their licences had nowhere to go to appeal apart from the courts.
The BCI also says there may be "some merit" in the principle of the State taking some share from the sale or transfer of radio licences between companies.
It says the idea of ComReg charging for using the radio spectrum "may also be appropriate".
In its submission the BCI also states that it intends to consult the radio industry on whether the current requirement to devote a large segment of programming to news needs to continue.
"In this regard it is proposed to hold a consultation on the news provision."