The House of Commons Business, Innovation and Skills Select Committee has launched an inquiry into open access. The terms of reference of the inquiry can be found on the parliament.co.uk website.
Submitted 7th February 2013
1. The Geological Society is the UK’s learned and professional body for geoscience, with more than 10,500 Fellows (members) worldwide. The Fellowship encompasses those working in industry, academia and government with a broad range of perspectives on policy-relevant science, and the Society is a leading communicator of this science to government bodies and other non-specialist audiences. It organises research conferences and public information meetings, and is a globally significant not-for-profit geoscience publisher producing about 11,000 pages of peer reviewed content annually. These are disseminated online and in hard copy through four journals which we own in whole or in part, and three which we publish on behalf of smaller kindred societies; and as books, principally the highly acclaimed Special Publications series (state-of-the-art collections of papers on cutting edge areas of geoscience) and Memoirs.
2. The Geological Society supports the principle of Open Access (OA), and believes that publications based on publicly funded research should be made as widely available as reasonably possible. It welcomes the recommendations of the working group led by Dame Janet Finch, which reported in 2012. It is vital that implementation of OA be planned carefully; and that it be carried out on a timescale which allows authors, funders and publishers to understand clearly what is proposed, and to modify their business models and research and publication practices accordingly. There is significant risk of disruption and possibly irrevocable damage to the UK’s complex research system if insufficient attention is paid to possible unintended consequences of policy changes, or if these changes are not well understood by all stakeholders, or if they are introduced too rapidly for stakeholders to prepare adequately.
3. Our interest in Open Access is both as a publisher, and as a learned society representing a significant UK research community. We are a member of the Association of Learned and Professional Society Publishers (ALPSP), and have seen the ALPSP submission to the present inquiry, which we support. That submission is helpful in setting out many of the functions which learned society publishers carry out (and hence the costs they incur), as well as some of the important roles of learned societies in the broader research system.
The Government’s acceptance of the recommendations of the Finch Group Report
4. In her evidence to the House of Lords Science and Technology Committee on 15 January 2013, Dame Janet recognised the potential financial risk to some learned society journals, and the need to give learned societies sufficient time to adjust. It is not only societies’ publishing programmes that are at stake. Rather, many societies including the Geological Society depend on modest surpluses generated by publishing to fund many of the other activities they support, which contribute significantly to academic, professional and public life in the UK. In our case, these include studentships, research grants, travel bursaries, reduced conference registration fees for students and academics, extensive public outreach and education programmes, and provision of geoscience advice to policy-makers. If publishing surpluses are eroded more quickly than we can substitute them with alternative income streams, continuation of these activities will be at risk.
5. We are very concerned that the Research Councils (RCUK) are introducing their OA policy at such short notice, especially as there is widespread confusion regarding aspects of this policy, both among publishers (including ourselves) and academic researchers in the geoscience community which we represent. In order to remain competitive as a publisher to UK geoscience academics, we are having to settle now on a new business model and publicise this to our community rapidly, based on very partial information and a high degree of uncertainty as to how researchers’ publishing behaviour will respond to the new RCUK policy.
6. The Finch Report recommended caution with regard to Green OA embargo periods, and government supported this approach in its response to the report. For journals which do not offer Gold OA, RCUK will require embargo periods to be no more than six months (in science and engineering subjects). This appears to be inconsistent with government’s statement that suitable embargo periods in these subject areas could be up to 12 months, and with the Finch Report’s recommendation that it would be unreasonable to impose an embargo period of less than 12 months where APC funding is not available. It is not clear what conditions will be placed on embargo periods of any journals which accept both Gold and Green OA papers.
7. As recently as 29 January, the chair of RCUK reportedly told the House of Lords Science and Technology Committee that RCUK intends to be ‘relaxed’ about policing their stated policy on Green OA embargo periods for the first five years (see http://www.timeshighereducation.co.uk/story.asp?sectioncode=26&storycode=422563). While this apparent relaxation of the policy is welcome, RCUK’s new position is far from clear, adding to publishers’ and researchers’ confusion. We are not aware of any subsequent announcement from RCUK regarding what embargo period they will enforce during this time, if any.
8. In considering what embargo period is appropriate, it is important to recognise that the effective ‘half-life’ of published research (judged by citation and other measures of use) varies greatly, not just between natural science, social science and humanities, but also among natural science disciplines. In much of geoscience, research often remains current and relevant for many decades, while in biotechnology, for instance, this is very rarely the case. If embargo periods are as short as six months, libraries may be more likely to pay subscriptions for journals in subject areas with a shorter half-life, where the perceived value attached to immediate access to content may be greater.
Rights of use and re-use in relation to open access research publications, including the implications of Creative Commons ‘CC-BY’ licences
9. Some researchers among our Fellowship have raised concerns at the loss of control of intellectual property which will ensue from publishing under CC-BY licences. This is consistent with the concerns raised by ALPSP in their submission about the suitability of such licences for research publications.
The costs of article processing charges (APCs) and the implications for research funding and for the taxpayer
10. Despite the announcement of RCUK’s policy in July 2012, and announcements regarding funding mechanisms later in the year, it is not clear to us how institutions will administer and make decisions about how to distribute funds provided to pay for Gold OA Article Processing Charges (APCs). What is clear is that the funds allocated by RCUK to pay for APCs will not be nearly sufficient to pay for publication of all research papers resulting from RCUK-funded research. Most institutions will hold insufficient funds to cover APCs for their full research output, and many authors will therefore be obliged to publish their work under Green OA terms. In an effort to maintain both the quality and quantity of papers we publish, we will therefore be offering both Gold and Green OA publishing options from 1 April 2013, although we have little idea of what the uptake of either option will be, nor of any impact there may be on income from subscriptions to our journals and book series as a result of some of their content becoming freely available.
11. Whatever system and criteria universities use to distribute the funds available to pay for APCs, the additional layer of bureaucracy that this will necessitate is a highly inefficient use of scarce public resources. These funds should be distributed directly to researchers by the Research Councils, by including them in research grants.
12. It is incumbent on RCUK to ensure that researchers fully understand their obligations, and the choices available to them. Authors and publishers urgently need to know how funds will be apportioned and accessed, in order for the UK’s scholarly publishing system to operate with the minimum of confusion, disruption and delay. In particular, papers without APC funding will need to be identified as such prior to submission to the publisher. With less than two months remaining before RCUK’s mandate comes into force, it is not clear how this will be done.
Concluding remarks
13. We were pleased to note that Dame Janet’s committee included representatives of three learned societies – the Institute of Physics, the Society of Biology and the Royal Geographical Society. Although all are relatively large institutions, the committee’s recommendations reflect an understanding that learned societies differ widely, and the challenges and impacts of OA are likely to vary significantly depending on societies’ size and subject area. For instance, larger societies may benefit from greater economies of scale, allowing them to offer APCs more competitive with those of large commercial publishers. They may also be better able to fund innovative business initiatives to attract researchers to publish with them.
14. Dame Janet’s report recognised the potential risks to learned societies of implementing OA without due care and attention, and with insufficient time for societies to adjust, and she has subsequently reiterated the importance of these considerations. David Willetts also recognised these potential risks, and the importance of avoiding them, in correspondence with the Geological Society in July 2012. Nonetheless, as set out above, we have serious concerns on exactly these grounds regarding the way in which RCUK has sought to implement government’s recommendations regarding OA. In common with many other learned societies, we are doing our best to adapt our business model during this rapid transition, but the impact it will have on us is highly uncertain. It is essential that the effects on researchers and on learned societies are carefully monitored.
15. Despite the central role that publishers will play in enabling authors to comply with RCUK’s mandate, we are aware of little if any direct communication between RCUK and publishers, including learned societies, as it has developed and communicated its policy. Anecdotal evidence from academic geoscientists indicates that they and their institutions have similarly struggled to establish meaningful dialogue with RCUK regarding development and implementation of its policy.