National Footwear Retailers’ Association Limited ABN 54 005 569 184
Website:
4 August 2015
Mr Roger Arwas
Executive Director
Small Business Victoria
Dept of Economic Development, Jobs
Transport and Resources
GPO Box 4509
MELBOURNE VIC 3000
Dear Mr Arwas
Re: Public holidays RIS
The National Footwear Retailers’ Association is a national industry association representing
independent and small chain store retail footwear businesses. The majority of our members
have been in business for approximately 20 – 30 years and are mainly family businesses.
We welcome the opportunity to make a written submission to this RIS process.
It is important to the footwear retail sector that government is made aware of the impact that
the introduction of these two new public holidays will have on our members who do not
perceive any obvious trading advantage in these gazetted public holidays. Our members are
already struggling with overseas online competition which does not attract the costing imposts
that bricks and mortar stores have to contend with.
Our members are not supportive of this initiative for the following reasons:

With the summer season looming it is an important time of the year for a family shoe
store and it is estimated a trading loss of between $4000 - $5000 would be sustained
for the Friday Grand Final Public Holiday. This is the written opinion of a member
which is supported by a large percentage of our members, who are already struggling
with the high costs of labour and rentals just to survive.

Footwear retailers traditionally have not imposed a surcharge on sales for a gazetted
public holiday as opposed to businesses engaged in the hospitality sector such as
hotels, restaurants and cafes which are traditionally comfortable with this practice.

The Executive Summary indicates the enormous imbalance between the holiday
revenue and holiday costs and this point in and of itself should indicate the foolishness
of the proposed action. It does not pass the commonsense test.
.../2

The perceived benefits from increased tourism and sporting reputation are
hypothetical and not substantiated by logic. It is highly probable that many
Melburnians will take advantage of the long weekend to leave Melbourne and watch
the final on TV.

For our country retailers the extra trading cost is not offset by an increase in sales.

Family businesses where possible will reduce costs by rostering family staff members
as opposed to paying penalty rates which means that they will not be enjoying an
additional leisure day, at a time when, regardless of rhetoric, retail businesses have
not been trading strongly over the past 18 months.
Our members are struggling to see the advantage of this public holiday and perceive it as a
political carrot devised by the now Premier for the last election campaign.
As a national industry association we have a very good understanding of the retail sector’s
perspective and we have no objection to our submission being published on the
department’s website.
Yours sincerely
Peter Parkinson
President