The CRCA said it acknowledges the benefits of privatising Radio 1 and 2, which the European Media Forum report called for last week, but suggests the focus should be on ensuring licence fee payers receive genuine, value-for-money, public service broadcasting.
The CRCA said the BBC Charter review presents an ideal opportunity for licence fee payers to demand more from Radio 1 and 2.
BBC Radio 1 and 2 came in for strong criticism recently from the CRCA and various national newspapers, for spending "hundreds of thousands of pounds" on celebrity presenters such as Chris Evans, Vernon Kay, Jonathan Ross and Dermot O'Leary.
Lisa Kerr, external affairs manager at the CRCA, said: "Commercial radio is urging the government to make higher demands of BBC Radio than are currently set out in the draft charter and agreement.
"Simply to require that a programme is either high quality, challenging, original, innovative or engaging is a meaningless test for an organisation so richly endowed with public funds, since it would be passed by virtually any programme on virtually any station."
An independent research study commissioned by the CRCA claims that at peak listening times, local commercial radio stations deliver more speech output than BBC Radios 1 and 2, which, under the conditions of the Royal Charter, they are bound to deliver.
Kerr said: "On behalf of licence-fee payers, the government must use the opportunity of the charter agreement to demand more from Radios 1 and 2.
"The BBC must be required to deliver on the six new public purposes in a meaningful way during peak listening times when the maximum number of licence fee payers can benefit."
Last week's European Media Forum report claimed that the combined sale of Radio 1 and 2 could total £500m or more. The report stated such a sale would "rebalance the radio market and level the competitive playing field between commercial broadcasters."
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