Madam, - I refer to the letter from Patrick Lyons (April 7th), former chairman of the Competition Authority, and to the subsequent letter from Barry Brennan, group marketing director of Independent Newspapers (April 26th).
I was a member of the Independent Newspapers team that met Mr Lyons and his Competition Authority in the mid-1990s. I was also a member of the Newspaper Commission, under the chairmanship of Mr Justice Finlay, that reported to the Government in June 1996.
One of my abiding memories of Mr Lyons and his team was our first meeting with them. We arrived on time, and as the authority members entered the room, we rose to greet them with the words: "Good morning". Answer came there none.
I was straight down to business, and business consisted of a grilling from three men who appeared to have very fixed views on the matters under consideration. Both the tone and the content of the questions persuaded us that there was little room for debate.
It was therefore no surprise to any of us when we read the Competition Authority report. Thus:
1. "The Authority considers that the market can be divided into (seven) distinct markets". The authority seemed determined to argue that UK titles occupied a separate market to Irish titles. Eventually, and "with considerable reservations" it conceded that "an argument can be made" that Irish and UK tabloids compete for the same audience. But the authority insisted that Irish quality dailies and Sundays were in different markets to their UK counterparts.
2. "The evidence does not indicate that News International was engaged in predatory pricing behaviour within the State". National Newspapers of Ireland (NNI) presented data to the Authority to show that both the Sunday Times and Sun were being sold in Ireland below variable cost. But these data were "strongly disputed by News International". Furthermore, such a strategy "cannot be considered rational". I wonder what Mr Lyons would have said about the 20p Sun which hit the newsstands in the late 1990s. I can assure him that the Star was then, and I imagine remains today, in full frontal competition with the Irish editions of the Sun and the Mirror.
3. Independent Newspapers ... could force [its rivals] out of the market altogether" and: "The possibility cannot be ruled out that in a relatively short period of time the only remaining Irish-published newspapers would be those owned in whole or in part by Independent." In the nine years since Mr Lyons's report, the Cork Examiner had become the Examiner and gone national; the Sunday Business Post has prospered ; and Ireland on Sunday has been launched and is still with us, although the price of survival has been UK ownership.
During this same period, UK-owned titles have exploded their share of the Irish national newspaper market. Mr Brennan's figures show that on Sundays they now occupy 45 per cent, up from 36 per cent in the mid 1990s; and that the daily share has grown similarly, to over a third.
By contrast to the Competition Authority, the Newspaper Commission divided the Irish market into morning dailies, Sunday papers, evening papers, and weekly papers - a division to which all of us who work in newspapers can relate. I felt at the time, and I feel even more strongly in the light of events, that the Newspaper Commission's definition of the Irish newspaper market was right and the Competition Authority's was wrong.
Sadly, not one of the Newspaper Commission's recommendations was implemented - including one that "the Government should as a matter of urgency introduce legislation to outlaw below average marginal cost selling of newspapers". I still believe that the long-term survival of a prosperous and plural indigenous national newspaper industry in Ireland requires action against below-cost selling by its UK competitors. - Yours, etc.,
DAVID PALMER, Executive Director, Independent News and Media, 994-2002, Lancaster Gate, London W2.