Media agencies, rival commercial broadcasters and industry bodies, which have all made a common and consistent argument against an ITV merger because of the power it will acquire by combining its sales houses, have accused Billetts of "muddying the water" and jeopardising their submissions.
There has been particular industry disquiet at Billetts' comments that it evaluates 41 per cent of the top 500 UK advertisers, and is therefore speaking on their behalf.
In its submission, Billetts, which is chaired by John Billet, says: "Billetts are very concerned about ITV's ability through a single ownership to isolate individual advertisers, advertising sectors, or agencies from its position of market dominance. A regulation-based solution could deter intimidation, but it would require far tougher and detailed sales house monitoring than currently exists."
The submission document goes on to propose that an independent regulator could enforce rules and penalties. "The regulator could, for example, audit the length of deals, or audit the penalties levied on late access.
These rules could force the publication of airtime revenues and prices for all stations. Market abuse would be quickly spotted and could be dealt with."
Billetts goes on to claim that such regulation would "further enhance transparency and deter sharp practice" and even that it could "enhance advertiser attitudes towards TV, bringing more money into the medium".
One agency source dismissed this as an attempt by Billetts to generate business from the merger, rather than add any real insight to the debate. No-one at Billetts was willing to comment.