I have never been a flash fan. I think the only good use for it is very small animation boxes on the page and a good alternative to the GIF banner. Other than that it is a straightjacket.
I agree with your comments, but they're nothing new. Everything you mention is well known by hard-core Flashers everywhere, and they all know the workarounds for the inherent problems of Flash site design.
It's easy to say what's wrong, and easy to say what not to do. Why not give advice on how you can overcome these problems instead of gratuitous fingerwaving.
I feel that flash is being abused in web design today.
I recently visited a portfolio site. The portfolio was made using flash only. It was 3.5 megs. This is ridiculous; all these flash designers need to remember their roots and also remember that not everyone is running around on cable modems.