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If you’re like me and concerned about how removing Parallel Import restrictions on books is a terrible idea both domestically and globally, you can write to Federal politicians who will be debating the matter in Canberra in the very near future.

Here’s what I wrote to our Prime Minister, Mr Rudd:

Dear Kevin,

RE: PROPOSAL TO REMOVE PARALLEL IMPORTATION RESTRICTIONS ON BOOKS

I wrote to you back in April to express my concern at the proposal to remove Parallel Importation Restrictions on books.

At that time, I outlined in detail what I believed the cultural impact would be as well as the economic outcomes for all parties involved in the publishing industry.

Removing parallel import restrictions is supposed to benefit the reading public, yet we will be imposing overseas (in particular American) culture in an Australian context, and this will surely diminish representation of our own culture and language in our books. Some changes our readers might be subjected to include the use of:

  • faucet instead of tap
  • diaper instead of nappy
  • bro instead of brother
  • Mom instead of Mum
  • ketchup instead of tomato sauce
  • drugstore instead of chemist
  • jello instead of jelly
  • jelly instead of jam
  • gasoline instead of petrol
  • spyglass instead of telescope

In a country that already laments the deterioration of grammar in our schools, we may be subjected to y’all instead of all of you/everyone, off of instead of off, and other gems like gotten and putten and  winningest (having the most wins).

The entire basis for considering removing PIRs is predicated on the fact that it will put downward pressure on the price of books however, publishers and printers at the Melbourne Roundtable discussions asserted that the reverse was more likely to occur. Printers would have to recoup the same fixed costs, even though their volume of work had decreased, and publishers would need to increase costs to cover the increased risk on books that they might not ‘break even’ on.

And in fact, Dymocks, the bookseller pushing for these reforms, charges more than many other booksellers and earns at least five times as much as the author on any book sold.

Furthermore, the price of books is not one of the major factors affecting consumer’s book buying decisions. I know I buy books because of the author, subject matter, themes, or because they look interesting.

I have only ever bought two books on-line, and this was simply because they weren’t available here and I needed them for research. If the Australian market is flooded with cheap imports because they are more profitable, this will restrict the choice for consumers and many may be forced to buy more of their books online.

In fact, Dymocks, who advocates removing PIRs is forcing Australians to buy on-line already because they don’t stock some works by Australian authors; and rural customers in particular, are forced into this purchasing method.

I have been told that you recognise the valuable cultural contribution Australia’s literary sector makes to reflecting and celebrating our identity. As a proud Australian author, I ask that you protect it.

From a personal perspective, I am urging you to keep PIRs in place and not destroy the local publishing industry, and kill the careers of dedicated writers like me before they have had a chance to flourish.

I spent more than ten years writing my young adult novel, Letters to Leonardo – that equates to more than 2,000 hours and more than 1,000,000 words in print. Obviously, I did not do it for the money (an hourly rate of around $3.00) – I wrote because I had a story to tell and because I wanted to share it with young Australians.

On behalf of my children, I beg you to consider the damage to our history and culture that would eventuate from reforms to existing copyright laws.

I also ask that you consider the future of authors like me, dedicated to their craft and to telling their stories the way they need to be told.

But above all, I ask you to remember that books are not ‘mere product’ , they are something of special significance, a reflection of the country and times in which we live – something to be valued; not thrown on the scrap heap for the sake of making a few quick bucks.

Yours sincerely,

 

Dee White

Author

 

Write to Canberra and tell our politicians how you feel about the prospect of removing Parallel Import Restrictions on books. These are the specific Ministers/and Opposition who are dealing with this issue:

The Hon Kevin Rudd
Prime Minister
PO Box 6022
House of Representatives
Parliament House
Canberra ACT 2600

The Hon Julia Gillard
Deputy Prime Minister
Minister for Education; Minister for Employment and Workplace Relations; Minister for Social Inclusion
PO Box 6022
House of Representatives
Parliament House
Canberra ACT 2600

The Hon Chris Bowen
Assistant Treasurer
Minister for Competition Policy and Consumer Affairs
PO Box 6022
House of Representatives
Parliament House
Canberra ACT 2600

The Hon Peter Garrett, AM
Minister for the Environment, Heritage and the Arts
PO Box 6022
House of Representatives
Parliament House
Canberra ACT 2600

OPPOSITION:
Senator the Hon Helen Coonan
Shadow Minister for Finance, Competition Policy and Deregulation
GPO Box 3513
Sydney NSW 2001

Mr Luke Hartsuyker MP
Shadow Minister for Competition Policy and Consumer Affairs
(Deputy Manager of Opposition Business in the House)
PO Box 6022
House of Representatives
Parliament House
Canberra ACT 2600

Mr Steven Ciobo MP
Shadow Minister for Small Business, Independent Contractors, Tourism and the Arts
PO Box 6022
House of Representatives
Parliament House
Canberra ACT 2600

The Hon Malcolm Turnbull MP
Leader of the Opposition
PO Box 6022
House of Representatives
Parliament House
Canberra ACT 2600

Also contact the minority parties who hold the balance of power in the Federal Government.

If you want a lot more information … See  ‘How to get Politicians’ Attention‘  – from Electronic Frontiers Australia

You can also canvas your local Federal MP.  If you are not sure who your MP is, or how to contact them, or how to address them etc, look at this website which contains all that info! The most important thing is to show your MP how you personally could be effected by the repeal of Australia’s PIR’s – http://www.efa.org.au/Campaigns/lobby.html

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On 1st July, my debut novel, Letters to Leonardo was released by Walker Books Australia. What a fantastic time it was for me. The Cyber Launch was a blast, the blog tour was a whirl wind, but it didn’t take long to come back down to earth.

Less than two weeks later, the Productivity Commission released its findings on the removal of Parallel Import Restrictions, and since then, I’ve found it hard to celebrate my novel’s release – all I can think about is that the industry I’ve wanted to be part of since I was seven year’s old, is now in jeopardy.

Since the Productivity Commission’s latest report there have been so many lies and misinformation being circulated by the print media on the debate of the proposed removal of parallel imports on books.

Being passionate about books and writing, I have made two submissions to the Productivity Commission and attended the roundtable discussion in Melbourne, but the future plight of Australian authors seems to have fallen on deaf ears.

We are fighting the likes of Dymocks, Coles and Big W, and many members of the print media seem uninterested in accurately representing our story.

The Parallel Import Restrictions currently in place prevent overseas publishers from flooding our market with cheap imports of Australian books. These books are likely to be of inferior quality and would result in little or no income for Australian publishers, authors and printers.

USA and UK are currently protected markets so if they want to publish books by Australian authors they purchase the rights from the Australian Publisher and author who receive income from the overseas sales. This income not only helps support the author (Australian authors earn an average of $11,000 per year) in their difficult quest to make a living, but it also allows Australian publishers to nurture new authors and bring in important works from overseas, thus exposing us to cultural diversity.

Industry experts in both the USA and UK have expressed disbelief that we are even considering subjecting our book industry to an open market.

The move to abolish Parallel Import Restrictions is not supported by authors, publishers, printers or most booksellers. It is being pushed by Dymocks, Coles, Woolworths and the chains who stand to make the most profit. They are the ones who will be able to import in huge numbers – thus gaining big discounts. They will be able to charge discount prices for which the author may earn no income and the local independent booksellers won’t be able to compete – and will go out of business.

They will be able to import cheap books that won’t be printed to our high Australian standards. This is sort of like the current push to put independent service stations out of business. And on the subject of service stations – weren’t we told that petrol prices would go down when self- service came in?

None of this even takes into account the cultural ramifications of putting our publishing industry in the hands of America – a culture that is not the same as ours. Do we want our children to be reading about faucets, moms and opossums?

MISINFORMATION IN THE MEDIA

This the sort of misinformation that the Coalition for Cheaper books is deliberately spreading and some members of the print media are printing it without verifying its authenticity.

THE MISINFORMATION BEING PRINTED THE FACTS
That consumers will save $200 million per year on purchase of books if PIRs are removed.(THESE FIGURES HAVE NOT BEEN SUBSTANTIATED ANYWHERE!) Even the Productivity Commission concurs that there is no guarantee that prices will come down – and there is no obligation on the retailer to pass any discounts on. In fact, evidence suggests that the reverse will happen – and that prices will go up.

 

That authors are self-interestedly disregarding the interests of their readers. That it is greed that is driving our objections to the abolition of PIRs. This rumour is being perpetrated by the CEO of Dymocks who earns at least five times as much as the author yet they constantly charge more than the recommended retail price on book. On a $10.00 book, Dymocks earns at least $5.00 while the person who wrote it gets $1.00 and if the book is illustrated, author and illustrator earn 50 cents each.
That the Australian culture in books won’t be affected. It is already proven that when books are printed in the USA the language is changed to suit.Our children will be reading about Moms, faucets and diapers instead of mums, taps and nappies.
That abolishing PIRs in New Zealand has not had an adverse affect. This is so untrue. The New Zealand Society of Authors made submissions to the Productivity Commission asking them not to abolish PIRs because of their own experience of the resultant devastation to the industry.Since PIRs were abolished, all the book distribution warehouses in NZ have closed down. Many publishers and independent booksellers have gone out of business and new authors have struggled to get published.

 MY STORY

I have wanted to be an author since I was seven year’s old. For the last twenty years, I have taken whatever work I can that still allows me to write, but for the most part, have been financially supported by my husband who admires my passion for writing and books.

I am not crying poor – I am doing what I love to do – but I want people to know what the reality is for most authors.

And even those successful authors who are earning good incomes and speaking out against the removal of PIRs; they are not doing it out of self-interest;  the money doesn’t matter to them – they are doing it to protect people like me – new authors whose careers are at risk before they have barely started.

In July this year, after working for more than ten years on my YA novel, Letters to Leonardo, it was published by Walker Books. This book involved more than 30 drafts, around 2000 hours work and one million words on paper.

Finally, when I feel I am starting to make it as an author, the rug looks like it is going to be pulled from under me. Publishers like mine, won’t be able to stay economically viable by taking risks on new authors like me. To survive they will have to focus on the tried and true – the bestselling authors – the established ones. So what happens to writers like me – who dreamed of being authors all their lives?

What makes me even sadder about all this is that my 10yo is a very talented writer, contemplating the possibility of a similar career, yet how can I encourage him when the jobs just might not be there?

For my ten years work, I will earn under $6,000 if 3,500 copies of my book are sold – and this is a standard print run for a first time author. Dymocks will make at least five times that – and our government will make the same money as I do through their 10% GST.

THE LONG TERM FUTURE IF PIRs ARE REMOVED!

We have seen so many manufacturing businesses move overseas because of economic rationalisation. Many Australian publishers are owned by overseas companies who could very well ditch their Australian branches if PIRs are removed and it becomes more economical to do everything from their overseas head office. This would not only lead to huge job losses in Australia, but the whole content of our literature would change.

The point is that the people accusing us of greed earn five times as much as we do for what we create – and authors are now copping a lot of vitriol because of the campaign against us by Rupert Murdoch’s Australian newspaper and Don Grosvnor the Dymock’s CEO. Rupert Murdoch has been pushing the abolition of PIRs in his newspaper, The Australian, yet has failed to declare his conflict of interest – and the fact that he owns organisations who are part of the campaign to get rid of Parallel Import Restrictions.

Dymock’s CEO claims that authors are ripping off the Australian reader, but as a matter of interest, here’s how Dymocks prices compare with A & R on the books that were on the front of The Australian on Wednesday:

BOOK TITLE A& R AMAZON DYMOCKS
Finger Lickin Fifteen $22.99 $21.50 $32.99
Breath $20.99   $24.95
Breaking Dawn   16.25 29.99
The Scarecrow $22.99 22.90 32.99

If A & R can sell them to the Australian public for that price, why can’t Dymocks? Who’s really ripping off the Australian Public?

Don’t believe the propaganda. Do you really think these big companies want to save YOU money on books?

Look at the facts and decide for yourself. If you don’t support the abolition of Parallel Imports on books, write to your local politician. Make your vote count.

If you are not sure who your MP is, or how to contact them, or how to address them etc, look at this website which contains all that info! http://www.efa.org.au/Campaigns/lobby.html

or refer http://savingaussiebooks.wordpress.com or https://blottedcopywritersissues.wordpress.com

for more information on this issue.

Dee

Letters to Leonardo cover

My first YA novel, Letters to Leonardo is coming out with Walker Books Australia on 1st July.

But under proposed changes to the Parallel Import Restrictions, it will be extremely difficult for new authors like me to get their work published.

If Parallel Import Restrictions are removed, publishers will not have the resources or funds available to foster new talent in Australia.

It’s not too late to have your say. Even if you miss the Productivity Commission’s 17th April deadline, you can still write to the Prime Minister, relevant ministers involved in this issue, or your local politician.

Some contact details are listed below:

Julia Gillard as Education Minister.
The Hon Julia Gillard
Deputy Prime Minister
Minister for Education/Minister for Employment and Workplace Relations/Minister for Social Inclusion
PO Box 6022
House of Representatives
Parliament House
Canberra  ACT  2600

Your local Member of Parliament,
You can find out current MP’s addresses at:
http://www.aph.gov.au/House/members/memlist.pdfAny or all of the following:
The Hon Kevin Rudd
Prime Minister
PO Box 6022
House of Representatives
Parliament House
Canberra  ACT  2600

The Hon Chris Bowen
Assistant Treasurer
Minister for Competition Policy and Consumer Affairs
PO Box 6022
House of Representatives
Parliament House
Canberra  ACT  2600

The Hon Peter Garrett, AM
Minister for the Environment, Heritage and the Arts
PO Box 6022
House of Representatives
Parliament House
Canberra  ACT  2600

WHO CAN HELP WITH YOUR SUBMISSION?

As reported in childrens’ writers online newsletter, PIO (www.jackiehosking.com),

1.   Author Marianne Musgrove has made up a document where every page is set out like a letter, with each relevant politician, their ministry and address. There is space to write your own views on parallel importation. If anyone would like a copy of this document, please email Marianne and she will  forward  it to you. All you need to do is save it, write a couple of paragraphs outlining your concerns, add your contact details, and post it off. Snail mail makes the biggest impact.
marianne@mariannemusgrove.com.au

 

2.   Author Kathryn Apel has prepared a document for teachers.

She has drafted a short letter that can be used by a group of teachers to register their support for Australian literature in Australian classrooms. The letter does not have to be used as is – but it might be a helpful springboard for your own thoughts. (Or you can print as is and you’re done!)

 

If you would like to receive a copy, please email katswhiskers@skymesh.com.au with Requesting Letter for Teachers in the subject line and she will happily send it out.

 

A copy of my letter to Kevin Rudd is posted at my blog: http://deescribewriting.wordpress.com

 

At the Melbourne Roundtable Discussions on April 7th November, members of the Productivity Commission, publishers, printers, agents, authors and other interested parties met to examine the ramifications of removing PIRs or modifying them as per the PC’s Discussion Draft.

The issues discussed were:

  1. The cultural story
  2. Price
  3. Competition issues
  4. The possible consequences of the 12 month rule
  5. The possible consequences of introducing the 12 month rule.

It is difficult to discuss these issues separately as many of them are interlinked. For this reason, I have based my report on the brief provided by the Productivity Commission with relevance to the issues that they were seeking feedback on. This is my response to both the Productivity Commission Discussion Draft and the Melbourne roundtable discussions.

THE COMMISSION HAS NOT CAPTURED THE FULL SCOPE OF ARGUMENTS IN THE DISCUSSION DRAFT?

I’d like to start by saying that the Productivity Commission has paid little regard to the Children’s Book Industry in its Discussion Draft.

The whole basis for reform seems to be predicated on the assumption that removing or limiting restrictions on the Parallel Importation of Books will put downward pressure on pricing, and consequently provide consumers with cheaper books. The Discussion Draft does not provide sufficient research to represent the reader’s/consumers point of view – no real evidence was provided to prove that this is what the consumer wants.

Apart from the odd submission by people like Linda Moody, there has been little or no feedback from the people these changes are supposed to benefit.

As Morris Gleitzman pointed out at the roundtable discussions in Melbourne, responses have not been sought from major book consumers like teachers and librarians to see if they are prepared to sacrifice culture, history and the damage to the Australian publishing industry – all for the sake of the possibility of cheaper books.

And as McPherson Printing, Penguin Publishing and others pointed out, removing Parallel Import restrictions won’t necessarily lead to cheaper prices.

All roundtable delegates currently working as publishers, printers, literary agents and authors agreed that removing the restrictions would inevitably lead to loss of jobs and talent within the industry. Publishers would be forced to produce fewer titles – meaning printers would also have reduced volumes of work. If the 12 month rule proposed by the Commission is brought in, this would also lead to fewer reprints.

Printers have both fixed and variable costs involved in their business. Even if volumes declined, printers would still have to bear the same fixed costs and the only way to do this would be to put up the price of their printing in the short term – and possibly go out of business altogether in the long term. This ramification has not been captured in the existing Discussion Draft.

The changes are being pushed through so fast and the issue is so complex for the average consumer that they need time to understand it and its complete ramifications. It’s only in the last few weeks as they have begun to get their head around what’s involved, that consumers (for the most part, teachers, librarians and parents) have started to approach me about the issue and express their concerns as readers and buyers of books that there will be a deterioration in the quality of reading materials available to them.

It seems to me that the Commission needs to take far more time to allow the issue to be properly researched and debated before coming to ANY conclusion.

THE ACCURACY OF THE GENERAL BASES FOR THE COMMISSION’S ANALYSIS AND RECOMMENDATIONS

The Commission’s analysis and recommendations fail to take into account what consumers really want. It is also quite contradictory in how it applies the meagre data that it does have.

1. What Consumers Really Want

The Commission centres most of its arguments for abolishing/reducing PRI’s on the fact that:

  a)  It will lead to cheaper books.

  b) Consumers want cheaper books. Some do – but most buying decisions for books are based on: subject matter, content and author.

Clare McKenna, owner/manager of independent bookshop, Aesops Attic says,

My experience with book sales is that customers don’t purchase books based on price. Purchases of books are based on interest, author, topics, reviews and recommendations. For children’s book purchases; reading level, age illustrations, author , series, topic, content and size of book all play a part in purchase.

Advertising and reviews on radio and in newspapers has a much greater impact on sales than price does. Purchase price rarely comes into play and only seems to be with pensioners, and when a book has to be posted as the postage has to be considered as part of the total cost of the purchase.

Even the Productivity Commission concedes this on page 2.1, Most Australians read regularly and for various reasons. Hence, their book purchasing decisions are influenced by a range of factors additional to price.’ So why, is price the only issue that seems relevant to the Commission?

Surely if other reader needs for cultural content, authors of their choice etc aren’t met, then buyer demand for books in Australia will fall – and this will have ramifications for the economy and the industry.

2. Contradictions and inadequacies of data

On page 5.1, the Commission states,

As noted in chapter 4, to the extent that the Parallel Import Restrictions (PIRs) lead to higher priced books…. It also talks about the price-raising effect of the PIRs.

Then on page 7.12, it says, First, given the uncertainty about the overall price raising impact of the PIRs… If there is this uncertainty, why state it as a ‘given’ – and why not put off making any recommendations until the appropriate research has been undertaken so that they can be ‘certain’ about the ‘overall price raising impact of the PIRs – and that it won’t completely decimate our industry?

On page 2.3, the Commission refers to a Starcom online survey that looked into the buying behaviour of 1200 readers aged between 16 and 65. How in it’s numbers surveyed or terms of reference, is this representative of the reading population? It doesn’t take into account anyone younger than 16 (so doesn’t include children’s books). And it also ignores people over the age of 65 – a large reading population.

Furthermore, it excludes people who don’t have online access or the skills or confidence to complete such a survey.

3. The New Zealand Experience

According to the Commission (page 5.5), Other industries that have had their parallel import protection removed – the music industry in Australia and the book industry in New Zealand – do not appear to have suffered major detriment due to the removal of the PIRs.

I refer the Commission to the submission by The New Zealand Society of Authors (submission number 28) which states that a 2007 review by LECG found that removing parallel importation restrictions had resulted in a slowing in industry growth and the withdrawing of distribution infrastructure in direct response to the market conditions.

In its submission to the Productivity Commission, The New Zealand Society of Authors (submission number 28) has stated, It is clear from this September 2007 Review that a detrimental effect on the publishing industry has been experienced since the introduction of Parallel Importing in NZ.

According to a NZ Trade and Enterprise’s 2004 report New Zealand Book Publishing Industry Development Issues, ‘New Zealand publishers face an inherent problem in that the domestic market is swamped by imports.’ New Zealand Publishers listed the ‘dumping of children’s books’ as a major issue.

After taking these reports into account, on what basis does the Productivity Commission maintain that: ….the book industry in New Zealand – do not appear to have suffered major detriment due to the removal of the PIRs.

At the roundtable discussions, many publishers attested to the fact that prices of books in New Zealand have not dropped as a result of the removal of PIRs, and in fact, many publishers have closed their doors.

WHAT OTHER CONSIDERATIONS ARE RELEVANT?

1. The fact that consumer choice will actually be more limited.

In spite of the fact that the Productivity Commission refers in Box 3.4 (page 4.18) to the fact that consumers could save a lot of money through remaindered books being sold in Australia, the Attorney-General’s Department expressed concerns on this same issue in its fact sheet produced in 2000 on Copyright Reform: Parallel Importation of Books and Other Published Works. The fact sheet stated that: Books are generally ‘remaindered’ because they have not met with consumer acceptance.

The fact sheet goes on to say that they are not what people want to buy… So in reality, consumer choice may be restricted by the bookseller’s idea of what will make them the most money.

2. Failure to take into account the higher cost incurred by the Australian publisher to produce the local edition which is then replicated by overseas publishers.

On page 4.3 the Commission states,

But when shielded from this potential source of direct competition, a publisher can charge booksellers a price which is above the cost of an equivalent foreign edition, certain in the knowledge that it cannot be undercut by such an edition.

This statement fails to take into account the fact that the Australian publisher has every right/need to charge a higher price because they have made the intial investment in the author and their book – they have put in the initial work of producing the book – the editing, research, fact checking process etc as outlined below:

Information supplied by Walker Books Australia regarding the editing and production of Letters to Leonardo

EDITING PROCESS

  • This has involved three editors and the publisher.
  • These hours include time for: reading, discussion, marking up manuscript, writing reports, fact checking, phone conferences  and half day meeting with the author.
  •  First structural edit and report 17 hours
  • Second structural edit and report 30 hours
  • Copy edit 24 hours
  • Proof reading (3 readers) 27 hours

TOTAL: 98 hours (13.1 working days)

PRODUCTION

  • Cover & internal design
  • writing of copy and typesetting

TOTAL: 45 hours (6 working days)

This doesn’t include a similar amount of time spent by the Publisher to market me as a new author.

By the time/if my book Letters to Leonardo is published overseas, all the hard work will already have been done by my Australian Publisher at their expense. So if Australian books are to be written, edited and published to the highest standard, it is logical to expect that the Australian Publisher would have to charge more in order to recoup these costs.

HAS THE COMMISSION CORRECTLY CAPTURED (IN CHAPTER 5) THE KEY WAYS IN WHICH THE INDUSTRY IS AFFECTED BY THE PIRS AND MIGHT CHANGE IF THEY WERE REFORMED?

I refer to the Commission’s section on Remainders. It states on page 4.17: To the extent that the bulk of sales tend to occur in the initial period after the release of a book, the amount of pressure that remaindered editions could place on prices in Australia would be limited.

This fails to take into account the interests of new authors who may take over 12 months to become a known presence in the marketplace, and also any award winners – who may see most of their sales occur following a CBCA short listing – which could come more than 12 months after publication.

Both publishers and authors present at the Melbourne roundtable agreed that a publisher invests in an author for the long haul, and it may take years for either party to reap the rewards of their books.

It is quite common for books to be reprinted when the author’s new book comes out – and this is often more than twelve months after the original was published.

Particularly with children’s picture books, authors/publishers rely on the longer-term sales to cover costs of books. Removing PIRs takes away the ability for picture books to recoup costs – which will have major repercussions for the children’s publishing and education sectors as picture books are vital particularly in junior classrooms.

ARE THERE ANY OTHER LIKELY EFFECTS OF REFORM THAT ARE PERTINENT?

Disadvantage to independent booksellers

On page 4.3, the Commission states that: In the absence of PIRs, local booksellers or buying groups could source legally produced foreign editions of that title from whichever international supplier had the lowest cost or best value-for-money edition.

Independent booksellers however would not have the buying power to take advantage of this, and consequently would be even further disadvantaged.

Authors are big book buyers

Another thing the Commission states (page 4.18) that:

Australian authors typically receive 10 per cent of the RRP of books sold in Australia. Thus, were the book in the example cited by Spinifex Press an Australian-authored book being sold at its RRP, the importance and sale of the remaindered foreign edition would result in a loss in royalties to the Australian author of around $2.50 – assuming that the sale displaced another sale of the work. (In comparison, the Australian consumer in that example would save over $20 – that is, the consumer would need to pay only the small price ($3 in the Spinifex example) for the parallel import, rather than the $24.95 price of the Australian edition).

This report is clearly about consumer welfare, and not author welfare, but it fails to take into account the fact that authors are big buyers of books, and if they are paid no royalties instead of $2.49 (10% of $24.95) per sale, then they will no longer be able to afford to buy books by other authors in the quantities they had been.

WHAT LOCAL ADVANTAGES DOES THE BOOK INDUSTRY HAVE THAT WOULD REMAIN IF THE COMMISSION’S RECOMMENDATIONS WERE IMPLEMENTED?

Publishers still couldn’t afford to the take the risk on new authors because of the amount of time and effort invested in them. (information supplied by Walker Books earlier in this submission)

As a new author, it will take me a lot longer than 12 months to get a presence out in the reader’s marketplace, and this is what I’m doing to make that happen

  1. 16th May – SCBWI talk Talk about the writing process involved in my book
  2. End of May Talk to librarians at Reading Matters Conference in Melbourne
  3. 1st July Book release
  4. 1st July Cyber launch
  5. 4th July Melbourne Book launch
  6. 24th June to 7th July Blog Tour
  7. 7th August Byron Bay Writer’s festival – possible workshop
  8. 12th September Queensland launch at CYA conference.
  9. February 2010 Attend SCBWI conference in Sydney
  10. 1st July 2008-2009 Bookshop signings and appearances

Hopefully, in 18 to 24 months time, my second book may be due out, and I will have some market presence – and this might lead people to go back and buy my first book.

ARE THERE SECTORS THAT WOULD BE PARTICULARLY AFFECTED OR UNAFFECTED? PUBLISHERS AND WRITERS

As the Australian Publishers indicated on page 5.5 of the report: In this environment, publishers will change their strategy, with some 40% indicating that they would need to reduce their annual output of new Australian titles…

This would lead to fewer opportunities for local authors, and some smaller publishers may go out of business all together.

It would also make surviving publishers less likely to take risks with new authors like me.

Furthermore, when the Commission refers to Psychic Income on page 2.11 of its report, it cannot substantiate its assertion that authors may keep generating manuscripts anyway, just for the ‘joy of self-expression’. I am in a strong network of new/emerging/established children’s authors; many of whom are women with children. If opportunities for publication are further reduced, these authors will be forced into full time work in other occupations simply because ‘psychic income’ does not put food on the table or pay for our children to go to school.

As the Commission states on page 3.1, The Australian government currently supports the books sector through grants and literary prizes, but only a very small % of writers ever gets the benefit of them. The rest must rely totally on getting their work published and sold.

INDEPENDENT BOOKSELLERS

As mentioned earlier, independent booksellers would not have the buying power to take advantage of cheaper overseas books – especially bearing in mind freight costs etc.

PRINTERS

As outlined in the Commission’s report, this could lead to job losses in this area, and printers eventually being forced to close their doors.

EDUCATORS & PARENTS

In recent months, many teachers have expressed their concern to me that removing Parallel Import restrictions will force Australian publishers to focus on a more global market, and this will reduce the number of books that speak authentically to young readers in our country.

Parents have expressed literacy concerns – that if the books produced in our country are not relevant to how they live, their kids will be more reluctant to read them.

Parents also worry about the loss of future career opportunities for talented children who wish to work with words.

The issue of relevance for readers and the need for local cultural content was also raised by Morris Gleitzman at the Melbourne roundtable discussions – and his concern was for the young readers in this country – the people he writes for.

READERS

As outlined previously in this submission, there is no evidence to support that books will become cheaper or that any cost savings achieved by booksellers will be passed on. According to industry experts, it could even lead to an increase in prices.

Furthermore, it seems likely that consumer choice will actually be more limited when it comes to buying books.

HOW IN PRACTICE, WOULD THE INDUSTRY RESPOND TO IMPLEMENTATION OF THE RECOMMENDATIONS? 

  •  Publishers have already indicated they would be forced to produce less Australian books.
  • Publishers would not be prepared to take the same risks with new authors and innovations.
  • Authors would BUY less books because they would have less disposable income.
  • Authors and publishers would pursue alternative careers and their talents would be lost to the industry forever.
  • New authors like me would have even less chance of having their work published. Publishers would be less likely to have my book reprinted – and if restrictions were placed on the amount of time they had to recoup the money they had invested in me, they may be reluctant to publish further works until sales have been proven.
  • Booksellers may be able to buy books more cheaply, but there is no guarantee that this will be passed on to the consumer. (When 30% sales tax was replaced by 10%GST, how many retailers passed the savings on to their customers?)
  • Nobody disputes that shelf space in bookshops and department stores is limited. Because they make their stocking decisions on what will earn them teh most profit; not what consumers want, bookselling chains and bulk buyers may force consumers to go on-line rather than buying from bookshops. They will prefer to stock large quantities of cheap, quick profit books rather than quality Australian literature, and buyers may be forced to go on-line to get the books they want.
  • Already, major book chains only stock minimal quantities of Australian authors.
  • In the long term, publishers with overseas head offices may find that their unprotected Australian branches are no longer as profitable. Accountants, who are not interested in culture, history or literature, may follow the example of companies like Pacific Dunlop, and ship all their Australian interests overseas for the sake of ‘the bottom line’. This will not only mean a great loss of jobs and talent in the local industry, it could ultimately lead to higher prices paid for books in Australia due to lack of competitive forces in the local market.

WOULD THERE BE ANY PRACTICAL DIFFICULTIES WITH THE REFORMS?

  • Ensuring discounts were passed on to consumers.
  • Monitoring to ensure that booksellers waited the required 12 months before importing overseas editions of the book.

GIVEN THE DISCUSSION IN CHAPTER 7, IF THE PIRS ARE TO BE REFORMED, ARE THERE ARGUMENTS FOR ALTERNATIVE APPROACHES?

Even the Productivity Commission concedes (page 7.12) that there is uncertainty about the overall price raising impact of the PIRs.

The Commission also recommends that the outdated 5/6 year-old research into the book industry be updated – that the Australian Bureau of Statistics should undertake a review as soon as possible.

A manufacturer intending to produce a new technology does not do so until it has measured the needs of its potential market and how best to proceed. It conducts its research before taking action.

It seems to me that doing comprehensive research involving ALL relevant stakeholders is the logical step to take before any recommendations are implemented or even considered that will change the existing position on PIRs.

This will allow us to more accurately assess the impact on the industry before the damage has been done and it’s too late to turn back.

CONCLUSION

Even if the facts didn’t show that removing PRI’s would do irreparable damage to literature and literacy in this country, I don’t believe the Commission has sufficient data/information at its disposal to make any changes to the current legislation on Parallel Importation of Books.

Furthermore, the Commision has not proven that under the proposed changes to the copyright laws:

  • books will become cheaper;
  • that the representation of Australian culture in future books won’t be irreparably damaged;
  • that any price savings made will be passed on to the consumer;
  • that any economic benefits gained from downwards pressure on book prices won’t be offset by the costs of loss of jobs and income for publishers, printers, authors, booksellers and literary agents;
  • that talents lost due to contraction of the industry can ever be recovered;
  • that book prices won’t increase because of the changes;
  • that the decimation of the publishing industry in New Zealand brought about by the removal of Parallel Import Restrictions won’t apply here;
  • that future generations will be able to earn their living as Australian authors and publishers;
  • that consumers actually want this change.

As the Commission states on pages 2.1 & 2.3,

The books sector is of considerable importance to the Australian economy and community. Sales of new books are currently around $2.5 billion a year, providing an income and an outlet for the work of several thousand authors and supporting the activity and employment of publishers, printers and book retailers….

So why in a climate of ‘Global Financial Crisis’, is the government even considering putting these things at risk?

The Commission goes on to say,

Moreover, as well as being sources of information and entertainment, books can be tools of earning or learning, repositories of history of even markers of cultural identity. And reading books improves literacy, which is fundamental to individual well-being and to the smooth functioning of society and the economy.

To me, this begs the question, why is anyone even considering tampering with an industry that obviously has so much to offer the consumer in its present form?

The Productivity Commission is holding ’round table’ public discussions on the subject of parallel imports in Sydney and Melbourne in early April.

I’ll be attending the Melbourne event on 7th April so I’ll be holding off finalising my submission until then. My complete submission to the Productivity Commission will appear on this blog on or around 9th April.

If you want to go to one of the public forums, you can email your interest to the Productivity Commission at books@pc.gov.au

I have ploughed my way through 171 pages of the Productivity Commission’s report on PIR’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%!

EDUCATIONAL PUBLISHING

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.

PSYCHIC INCOME

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

This week I will be working on a new submission to the Productivity Commission and you’ll be able to view it at my blogs: https://blottedcopywritersissues.wordpress.com or http://deescribewriting.wordpress.com

Post:
Parallel Importation of Books
Productivity Commission
GPO Box 1428
Canberra City ACT 2601
Fax: Jill Irvine – 02 6240 3311
Email: books@pc.gov.au
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 deescriber@optusnet.com.au

I recently received a US Children’s Magazine in the mail that I had not subscribed to.

It arrived with no covering letter; just the magazine, writer’s guidelines and a packing slip advising that I would be billed at a later date at $3.50 (US) per issue.

The magazine is a christian publication called ‘Pockets from the upper room’, and arrived in an envelope labelled ‘Upper Room Ministries, 1988 Grand Avenue Nashville’.

Somehow, these people had my postal address, and seemed to know I was a children’s writer. I wanted to let other writers know about this and urge them to check any invoices they receive to ensure they are for publications that they have actually subscribed to.