Attacking the national broadcaster "does not constitute a viable business model", ABC managing director Michelle Guthrie has told News Corp's executive chairman Michael Miller and the chiefs of the Nine and Ten TV networks.

In an address to the ABC Friends, she named the trio, adding that their children and grandchildren should not be denied the right to watch Play School and Peppa Pig on an iPad "because Hugh Marks, Michael Miller and Paul Anderson are finding life tough".

The comments are Guthrie's most direct response to media campaigns criticising the ABC for competing with commercial media companies.

"There is no media and cultural diversity without the ABC and democracy would be very much the poorer in the absence of the national broadcaster," she said.

Australia's envied system envied has at its heart, a national broadcaster funded by the community and independent of government, sitting alongside commercial media companies.

"The dual system delivers a rich array of choice for all citizens - from live sport to ad-free kids' programs, from reality TV franchises through to hard-hitting investigative stories.

"The commercials deliver for their shareholders, the ABC for the citizens of Australia," she said.

Guthrie said that it was "somewhat perverse" that while technology had provided sea of content abundance, diversity was being threatened. Beyond the "tectonic shifts" resulting from digital disruption, no one was pretending that changes in ownership laws, "resulting from exhaustive and convoluted cross-trading with various senate voting blocs", would add to media diversity.

"It will, in fact, achieve the reverse,: she said.

She said the "clearly stated" objective behind the changes was to allow existing players to build scale to compete with the new global giants like Google, Facebook and Netflix.

"I wish them luck, but as a former Google executive, I question whether consolidating the number of local players to build size is the panacea the chief executives are proclaiming it to be."

The ABC had thought itself an interested bystander in the media law reform debate with "no skin in the game". But she said the ABC now found itself "very much impacted by the deal-making and with a real need to ensure that the public interest - as opposed to vested interest - is protected.

"Diversity on one side is shrinking. While on the other side, the role and ability of the ABC to provide real choice and a vital public good is being assailed."

Proposed changes to ABC Act "do not further the public interest" or improve the ABC. "They interfere with the right and ability of the ABC board to do its work and override the Privacy Act to force salary disclosures on our employees that no other public agency is required to do.

"There is no pressing need to change the ABC Act and its Charter, no matter how much commercial CEOs and their compliant media outlets argue otherwise.

"As (prime minister Malcolm) Turnbull remarked at the relaunch of the ABC Parliamentary Friends Association in 2014, while Fairfax and News Corp may have many problems in this new landscape, the ABC is not the cause of them.

"I would say the same for the commercial free-to-airs and to Foxtel, whose chief executives seem to spend more time whingeing about the ABC than addressing their own audience challenges. My advice to them is that attacking the national broadcaster does not - and will never - constitute a viable business model.

"Restricting the ABC's right to use digital platforms, which appears to be the clear intent behind pressuring the Government for a competitive neutrality inquiry, will not protect them from digital disruption. All it does is hurt the community."