RTÉ responds to government's proposed media reform

In response to the previously announced government consultation exercise, RTÉ has responded to the government's draft broadcasting bill with a fair amount of red ink. Politically relevant concerns are the following:

1. In order to fall under companies legislation, RTÉ is to be constituted as a single-shareholder company with one shareholder, a cabinet minister. RTÉ argues that this would mark the change from public broadcasting to state broadcasting, in that RTÉ has not, since the passage of the 1960 Broadcasting Act, been part of the state apparatus.
2. the general scope for intervention - whether by ministers or by the new Broadcasting Authority Ireland (BAI)
3. The chief executive of the BAI should be appointed by the minister after public consultation.
4. a new right-of-reply is far more generous than existing rights guaranteed by the Broadcasting Act 1990;
5. the provision for RTÉ's independence is couched with the qualification, "subject to the qualifications of the act", which, on RTÉ's reading, mean that RTÉ is not independent in many areas of its management;
6. The requirement that the director ensure "gathering and presentation [of news] which is accurate and impartial according to the recognised standards of objective journalism" - a phrase which I hadn't noticed before - is impossible vague.