Private radio and TV companies have said they would be willing to accept a system of fines or "penalty points" for breaches of broadcasting regulations.
The Independent Broadcasters of Ireland (IBI), which represents commercial stations throughout the State, said at present there was no flexibility when stations broke the rules.
The regulator, the Broadcasting Commission of Ireland (BCI), either wrote to stations warning of the breaches or removed licences altogether, said the IBI. The IBI refers to the issue in its response to the Ox report.
The Ox report was published earlier this summer and it examined the licencing of radio stations. For the last few weeks the Department of Communications has been accepting responses.
Last week the chief executive of the BCI, Mr Michael O'Keeffe, expressed concern over a suggestion in the Ox report that a new appeals system be introduced, outside the scope of the BCI. Mr O'Keeffe is responsible for the daily operation of the licencing system, but he has pointed out that far reaching changes would involve amending existing legislation or introducing new law.
The IBI said: "We share the concern expressed in the Ox report that existing powers are rather narrow and do not provide for a flexible range of responses to breaches of licence commitments".
"IBI would support the introduction of a penalty points or yellow card-type system. Fines may be appropriate in instances of blatant or repeated serious breaches," said the submission.
However, the submission warned that stations which did not break the rules should find it easier to get licences renewed.
"We believe that current licence holders should be subject to a performance review in the period prior to their licence expiring. If the BCI is satisfied with the performance of the station, their licence should be renewed without it being advertised. Where a station failed to measure up to the standard required by the BCI, their licence would be advertised and they would be free to compete against other applicants," said the submission.
The organisation said it noted the willingness of the Government to support a "fast track process" for stations which faced no challengers during the renewal period.
The submission also states that digital radio would soon become a critical issue. The spokesman for the group, Mr Willie O'Reilly of Today FM, said the Government should consider a digital system for television and radio.
"If the costs are right, it would be justifiable to develop a digital system for both media," he said. But he warned that great care should be taken in any promotion of digital audio broadcasting (DAB), which is popular in Britain. Mr O'Reilly is chief executive of Today FM.
"An expensive national infrastructure has been provided in the UK for eight years and yet the total number of receivers has only now exceeded 600,000. The UK-adopted system, Eureka 147 is now dated and newer systems can support twice as many stations," said the IBI submission.
