I have ploughed my way through 171 pages of the Productivity Commission’s report on PRI’s, and it seems full of contradictions, research that has been slanted to support a particular point of view, and a disregard for more than 200 people and organisations who went to the trouble of compiling submissions in support of the publishing industry in Australia.
Although admittedly relevant research seems difficult to find, the Productivity Commission quotes statistics like the 2008 Starcom online survey, (ref: page 2.3 Productivity Commission Discussion Draft March 2009) which looked at the ‘buying and reading behaviour of 1200 readers aged between 16 and 65 years’. When you look at the size of this sample in relation to the number of Australian readers, it hardly seems representative.
WHAT THE PRODUCTIVITY COMMISSION HAS DECIDED
Even the commission concedes on page 1.4 of its Discussion Draft that, ‘The large majority of submissions support retention of the restrictions’. However, they seem to disregard this in their recommendations which are as follows:
*Australia’s Parallel Import Restrictions (PIRs) for books should be modified as follows:
- PIRs should apply for 12 months from the date of first publication of a book in Australia. Thereafter, parallel importation should be freely permitted.
- If a PIR-protected book becomes available during this 12 month period, then parallel importation should be freely permitted until local supply is re-established, or the expiry of the 12 month period allows for generalised parallel importation.
- Booksellers should be allowed to overtly offer an aggregation service for individual orders of imported books under the single use provisions.
All other aspects of the current PIR arrangements should continue unchanged, including the 30 day rule.
The commission further recommends that the ‘new arrangements’ be reviewed in five years time
* taken from page xxvii of Productivity Commission Discussion Draft March 2009
DISTORTION OF THE SCOPE OF PUBLISHING OPPORTUNITIES IN AUSTRALIA
Productivity Commission states (page 2.1) that there are 4,000 Australian publishers yet it’s not until page 2.12 (about twenty pages into the document, Productivity Commission Discussion Draft March 2009) that it mentions that the majority of these are self –publishers and consequently, not affected by PIR’s because they won’t be publishing their books overseas, and many of them offer their publications online, and don’t sell them through bookshops. So this figure of 4,000 Australian publishers provides a completely false impression of actual opportunities for Australian writers.
FINANCIAL SUPPORT TO AUTHORS
The Productivity Commission Discussion Draft March 2009 implies that authors don’t need financial assistance because 30% earn $1,000 a week or more. If you look at the Poverty Lines for the September Quarter 2008 figures provided by The University of Melbourne, Melbourne Institute of Applied Economic and Social Research http://www.melbourneinstitute.com/labour/inequality/poverty/default.html
(which provides figures after tax) you will see that $1,000 per week is not a great deal over the poverty line; and in fact most authors earn a great deal less.
The Productivity Commission claims that authors are already supported through grants, prizes etc, yet what % of the estimated 7300 ‘professional writers’ in Australia (ref: page 2.10 The Productivity Commission Discussion Draft March 2009 ) receive them? Possibly around 1%!
The report seems to consider that educational publishing only covers text books; it fails to even mention the reading schemes produced by Australian Educational Publishers that are keeping our kids literate, and aware of their own history and culture.
The whole position of the Productivity Commission on educational publishing seems contradictory. Page 2.6 of the report says that, ‘The factors influencing purchasing decisions for educational books are very different, (from trade books) with publishers typically seeking to market these books to educational providers rather than the ultimate consumer.
Then on Page 2.14 it says, ‘There are 8 local arms of multinational publishers and more than 20 Australian publishers supplying educational books to booksellers and educational institutions.’
THE TWELVE MONTH RULE
This means that, 12 months from the date of publication, Parallel Import Restrictions will come into force.
As the commission states on page 2.14 of The Productivity Commission Discussion Draft March 2009, ‘Libraries themselves are also large purchasers of new books’;
So, if an author is short listed for a CBC award for example; which means that their book is then in demand from libraries; these books will be subject to the twelve month rule. Libraries will be able to purchase cheaper copies overseas – and the author’s and publisher’s reward for having a book recognised as an important piece of work, will be to receive heavily reduced earnings.
GLOBAL FINANCIAL CRISIS
The media everywhere screams Global Financial Crisis, yet our government is going to change a law so that Australian authors, publishers, printers and agents will suffer reduced income and loss of employment.
On page 4.1 of its report, the Productivity Commission states, ‘Were PIR’s removed, books – particularly educational texts – could potentially be imported from Asia at substantially lower prices, and Asia could also serve as a greater source of books more generally in the future.’
How will the importation of books from Asia; putting local creators and printers out of business, help Australia to weather the Global Financial Crisis?
DISREGARD FOR DECLINING LITERACY IN AUSTRALIA
The Productivity Commission feels that money is being put into our industry that could be being put into others. Of course other industries are deserving of help, but surely an industry that shapes our children’s present and future education, is worthy of priority.
As an Australian author, I think one of the things I found most ‘dubious’ about the report was the section on Psychic Income; which is supposed to compensate for loss of ‘real’ income.
Page 2.11 of the Productivity Commission Discussion Draft March 2009 states, ‘In addition to the royalties (and related income) that author’s receive from book sales, the non-pecuniary rewards that many derive from writing – such as the “joy of self-expression” (Abbing 2002) – are widely acknowledged to be significant. In turn, such rewards may be a strong motivator for the generation of manuscript.’
I defy any of the Commissioners to serve up ‘psychic income’, at meal times and see how long it takes before their families succumb to malnutrition.
WHERE TO FROM HERE
Parallel Importation of Books
GPO Box 1428
Canberra City ACT 2601
Fax: Jill Irvine – 02 6240 3311
All submissions must be accompanied by a submission cover sheet which can be downloaded from the Productivity Commission’s website http://www.pc.gov.au/projects/study/books/make-submission
If you want to make a submission, but need help, feel free to email me at firstname.lastname@example.org