5 August 2015
Submission by the
Nursery and Garden Industry Victoria (NGIV)
RE: Proposed new Public Holidays in Victoria
Prepared by:
Craig Taberner
Chief Executive Officer
Nursery and Garden Industry Victoria
Email:
Phone: 9576 0599
OVERVIEW
Nursery and Garden Industry Victoria Limited (NGIV) is a peak state not-for-profit public company limited by guarantee.
NGIVas the the peak industry body for the State’s ornamental horticulture industryhas a member base which covers production, wholesale, retail and allied trades, and our association represents the interests of an industry worth over $1.6 billion and employing more than 11,000 people.
As a well-established membership representative body having been in operation for over 110 years, we have witnessed dramatic change within the Victorian business sector and specifically the horticulture industryas it progresses towards an innovative and sustainable industry. Hence NGIV are aptly qualified to comment on the horticulture sector.
Our members showcase the largest Australasian Horticulture Industry event, the Melbourne International Flower & Garden Show (MIFGS), held annually at the Royal Exhibition Building and Carlton Gardens. MIFGS is one of the most successful non-sporting events on the Victorian major events calendar with an audience of over 105,000+ patrons.
NGIV are aware of the Governments 2014 election commitment to declare two additional public holidays:
-Easter Sunday
-the Friday before the Australian Football League (AFL) Grand Final
We also understand Government engaged PricewaterhouseCoopers Australia (PwC) in its capacity as advisor to the Victorian Department of Economic Development, Jobs, Transport and Resources toprepare a regulatory impact statement (RIS)on the proposed holidays.
To this end the NGIV welcomes the opportunity to comment on the review, which following assessment of the RIS, in conjunction with an evaluation of the potential impact to our industry, we believe that adoption of the additional holiday(s), particularly the Friday before the AFL grand final is not in the best interests of our members and Victorians.
Accordingly, NGIV on behalf of its members provides this submission to the Victorian Governmentfocusing on the impact to our sector if the proposed Friday before the AFL Grand Final was declared a public holiday.
COMMENT
NGIV acknowledges the premise behind the Governments position to implement two additional public holidays, however as per the RIS we are of the opinion that the additional holidays are financially detrimental to the Victorian economy, and specifically the Friday before the AFL Grand Finalwhich will add significant and undue additional cost to our sector.
Accordingly, our submission will focus and make comment on the proposed holiday prior to the AFL Grand Final rather than Easter Sunday.
GENERAL
-The RIS clearly outlines that the introduction of the new public holidays is estimated to cost the Victorian economy up to $898 million per year in lost production.
-An additional two holidays will result in Victoria having an Australian high 13 public holidays.
-The new public holidays would also result in increased wage payments of up to$286 million annually to those people who work on the public holidays.
MEMBER RELATED
Increased labour costs
-Public holidays attract a loading of 250% under the 2010 Nursery and Garden Industry Award.
-A high percentage of our members are small business operators with less than 10 employees, an increase in wage related costs will financially impact them.
-As production wholesale growers one off labour costs cannot be passed onto consumers, surcharges are usually only applied to service related businesses, not wholesale nurseries.
Additional leisure time
-Our members will not be recipients of any additional leisure time, September/October depending on when the grand final falls is one of our industries busiest times. Regardless of the potential opportunity to have a day off, spring means business as usual.
Increased tourism and enhanced sporting reputation
-Public holidays may provide opportunities to increase tourism, but again this has no impact on our industry and is difficult to quantify. The AFL Grand Final does already reacha capacity audience, therefore it is questionable for the RIS to state that it will increase tourism and or Victorians reputation as leaders in sport given its pronounced reputation.
Reduced economic activity
-Given the time of year, it is likely that a large percentage of our members (employers) will operate on the Friday before the AFL Grand Final, so there is a limited loss of economic activity or output. It will however as already highlighted increase production costs.
Analysis
-It is disappointing to note that no consultation in developing the RIS occurred with the Agriculture and or Horticulture sectors.
Small business impact
-As a number of our members are smaller businesses they are likely to be negatively impacted by additional public holidays. As per the RIS this is because for many small businesses, wage costs form a greater proportion of overall operating costs, meaning penalty rates amplify the costs of opening by a greater amount than it does for larger firms for which staffing costs form a smaller proportion of overall operating costs. Put simply, it is likely to be harder for smaller businesses to absorb the costs of additional wages than it is for larger businesses.
-Given the time of year our small business owners are likely to remain open, which as explained will place extra financial strain on them.
Alternatives proposed
-The alternative approaches as proposed are only short term fixes. In our view these will still cause financial harm to our members, so cannot be supported.
Increased expenditure
-The potential for increased spending might support tourism, but not for our sector. We feel the focusof the holiday will remain the same, football and socialising, not gardening and purchasingof plants.
SUMMARY
Our submissionclearly highlightsthe financial impact to the horticulture industry in Victoria should the Friday before the AFL Grand Final be declared a public holiday.
NGIV are aware of the various social reasons,such as additional leisure time,as to why Government is considering providing Victorians two additional public holidays, however we are concerned that the financial impact outweighs the social benefits.
Industry growth, the requirement to become more innovative, coordinated and committedwith the supportof the Victorian Government is a goal of all Victorian enterprises including our sector, we should not be forced to absorb additional costs.
In line with RIS and as per the financial impediments identified, NGIV on behalf of its members does not support the proposed public holiday before the AFL Grand Final given the:
- Financial impact to our members
- Increased cost of labour / production
- Limited qualification over the leisure time
- Minimal opportunity for our members to utilise the time off
- Debatable increase in tourism
- Questionable enhancement to Victoria’s sporting reputation
- Limited consideration to analyse the Agriculture and or Horticulture sectors
- Impact on small business
- CONCLUSION
NGIV on behalf of its memberssee the proposed public holiday before the AFL grand Final as being financially detrimental to not only the Horticulture sector but to a large percentage of Victorians. Without true factual and statistically sound evidence, how can the Victorian government categorically state that adoption of the additionalholiday is in the best interests of Victoria when the RIS as presented by PWC clearly presents a financial case not to proceed?
While the NGIV understands the Governments desire to implement its election commitments, as per our submission and the RIS, the costs of the proposed public holiday(s) clearly outweigh the benefits to the Victorian community and to our sector.
In closing, we welcome the opportunity to provide this submission and await the outcomes with interest.
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