RE: Draft EPA Documents

[Sue.Darcey, Pesticide Report <sdarcey@erols.com>]

Jim of SOCMA:

Me and a couple of other environmental regulatory reporters with
entrepreneurial urges have been pushing our publishers (Bureau of
National Affairs, Business Publishers, CRC Press, Aspen Publishers,
etc.) for a couple of years now to start up less expensive, "lite"
versions of our more massive, business-oriented, $1,000 per year
regulatory newsletters that would be geared to more general audiences.  
We know that the potential audience is out there, among state
regulatory agency people, small environmental consulting firms,
environmental groups, academicians, librarians, etc., who cannot
afford the high prices that these companies now charge for their
daily, weekly and biweekly pubs.

In theory, it could be done -- we could get the costs down for
subscribers to about $79 - $99 per year, maybe $149 per year max
-- it we could get enough subscribers.

But there are certain barriers.  The economics of newsletter
publishing go like this:

a) Marketing departments of the big publishing companies don't want
to take the financial risk of starting up any pub that cost less
than $400 per year, because they believe that the target audience
for these things out there is too small to provide them with the
annual revenue they need (I've been told revenues of $100,000 -
$150,000 per year are needed, at minimum, because you need 25% to
pay the reporter, 25% for marketing, 25% for infra- structure,
support staff, supplies & expenses, etc., and 20-25% profit for
the publisher).  Specific complaints I've heard from marketing
people:  "Where do we get the lists of people to promote to?", and
"small environmental groups aren't reliable -- they won't renew
year after year like a business or trade association will."

They also view any "lite" version of an existing 20-page or 30-page
monster newsletter, even when it is produced in their own shop, as
competition.  "Why would a company or institution spend $1,000 on
my cash cow, 'Air Pollution Week,' when they can buy 'Air Pollution
Highlights Monthly' from us for only $199??"

b) Part of the need for the high revenues is driven by what I think
of as "the new greed" in the journalism field.  Publishers, like
every other business, have been gradually consolidating their
businesses over the last couple of years, and the new bosses
operating the companies are using the same tricks being used in
other industries --firing older, more experienced reporters, editors
and managers and bringing in recent, cheap J-school grads to replace
them, running the circulation and marketing departments on a
shoestring, slashing marketing budgets, and increasing subscriber
rates on existing pubs.  The Wall Street "Gecko" types now running
publishing companies aren't interested in low-revenue startups --
they just want to squeeze every drop they can out of the big,
existing, cash-cow regulatory pubs.

c) Marketing costs are too high.  To make a profit with a paper
publication, you have to market, market, market, either through
direct mail, by parading your pub around at conventions and other
places where people in your field meet, or via the Internet.  All
these methods cost time and money.  With direct mail, you usually
have to send samples of the pubs out to 100 people to win over one
or two subscribers.  Very expensive, in terms of postage and printing
costs.  You are lucky if you break even, even if you have a good
renewal rate and make lots of bucks in subsequent years.  Going to
a lot of conventions/meetings also costs in terms of staff costs,
travel, convention fees, etc.  If you run a website, you have to
hire a full or part-time staff person to "shepherd" the site, to
make certain that fresh information is put up every day, that all
Email queries are responded to, and then there is also the fees
you have to pay your Internet "host."

d) Newsletters make their money via subscriptions, not through
advertising revenue. And actually, this is the way all journalism
should be -- there should always be an iron curtain between the
marketing department and businesses who buy ads in your pub, and
the editorial department, or else your stories start getting biased
in favor of your advertisers.  The Internet, ironically, has taken
its toll on paper publications. Everybody now is interested in
receiving their newsletters online, yet they also have this mentality
that "if it's on the Internet,it must be free," which makes any
publisher who wants to make a profit hesitate to put his or her
pub online. The fear is that one person in a group will simply buy
a subscription, download it into his own files, then mass produce
and send it out to all his buddies or favorite Listserve, who won't
have to pay for a subscription.  Some people were already doing
this with their paper newsletters, in violation of Copyright laws,
but it is a lot more trouble to xerox 8 pages of a newsletter and
mail it or fax it to five buddies, than it is to click a couple of
buttons on a computer mouse and send an article or two out to
everybody on your favorite listserve.


My personal dream would be to put out a monthly or biweekly on
pesticides or toxic issues that would cost subscribers only $99
per year.  As a matter of fact, after making that suggestion and
hitting walls with the marketing departments in publishing firm
after publishing firm that I've worked for as an editor, I finally
decided that the only way to realize my dream would be to go solo,
and start my own business.

I've done this twice in the 1990s -- from 1992 - 1995, when I put
out the biweekly "State Solid Waste News", to cover all the
state/federal garbage collection, solid waste disposal, and recycling
rules and programs; and currently, with the biweekly "Pesticide
Report", which I started in May 1997 (at $199 per year) to cover
Federal Insecticide, Fungicide & Rodenticide Act and Food Quality
Protection Act rules/policies/decisions on pesticides, as well as
IPM, pesticide adverse effects, the growth of the organic food
industry, etc. (previously, I was editing "Pesticide & Toxic Chemical
News" for CRC Press, which cost, in 1997, about $899 per year).

The bottom line?  I'm making a living producing "Pesticide Report,"
but barely, and I have to supplement my income by writing freelance
stories for other publishers.  In April, I had to increase my
subscriber rate for new subscribers from $199 per year to $299 per
year, just to keep up payments on the business loans I took out to
pay marketing costs to start up "Pesticide Report" in 1997 and
1998.

I'd like to put my newsletter online, but from what I've seen with
what happens with other newsletters, you lose money and quality
goes down, because instead of spending your time reporting stories
for a gradually increasing base of subscribers who you marketed
to, you spend your time cutting and pasting what other people have
put online, for a subscriber base of strangers that have been sent
your articles for free, and see no need therefore to buy a subcription
themselves.

I swear, there are young newspaper and newsletter reporters out
there who have never attended a meeting, cultivated a source, worked
the phones or used a fax machine -- they just regurgitate other
news stories that they've cut and pasted from other Internet sources.

Those are some of the reasons why it's so difficult for the private
sector to produce a cheap, high quality, hard news environmental
regulatory newsletter for the public.

Sue Darcey, Pesticide Report