Session 2012-13
Open Access
OA 89
Written evidence submitted by the Royal Geographical Society
(with IBG)
Executive summary
The Government’s OA position with regard to scholarly publishing takes its lead from the recommendations in the Finch Report. The Society broadly endorses those recommendations and the BIS acceptance of them. The Society also notes the clear references in Finch to the need to monitor the position of learned societies for unintended consequences and to recognise that not all disciplines are the same. In particular the humanities and social sciences (but not exclusively so) have very different publishing profiles and contexts to the bio and life sciences that have, to date, been the majority areas of Gold open access publishing.
The Society’s concerns rest mainly with the fact that the RCUK policy was published without consultation, and sets out an intended end point, open access routes and embargo periods that are all, to some degree, divergent with the spirit and recommendations of Finch for the so-called transition period. Currently, RCUK policy introduces an unacceptably high level of risk for learned societies, and their publishing, in giving priority to access over the two other equally important planks of Finch – sustainability and excellence.
In a setting where evidence is limited at best and the risks are high, a more flexible and cautious policy approach that fully reflects Finch (including 24 month Green embargos for journals in humanities and social sciences), and that builds in a timely independent review of the policy impact after four or five years, is much to be preferred. We recommend a clear new policy is reformulated to address the current shortcomings; rather than reworking the guidance around the current policy, especially as the RCUK is advocating its policy actively to other nations.
One size does not fit all with regard to open access, including licensing. The Government should consider allowing the non-commercial and non-derivative licensing options to apply to all open access publications in the humanities, arts and social sciences.
It is a fine judgement as to whether the substantial costs of pushing ahead of the rest of the world for a number of years, and with an emphasis on Gold OA, will yield benefits sufficient to outweigh costs, other than possibly in the oft-cited area of bio / life sciences. We ask if this cost-benefit analysis has been undertaken?
The Royal Geographical Society (with IBG)
1 The Royal Geographical Society (with The Institute of British Geographers) is the UK’s learned society and professional body for geography. We advance geographical science, and in doing so we support, develop and promote geographical research and scholarship, field science, education, public engagement and knowledge exchange with policy makers. As a charity, the society’s work currently engages between two and four million people per year.
2 The Society receives no government funding, in common with most UK learned societies, and is funded by a combination of members’ subscriptions, operations iincluding conferences and publishing income), enterprise activities, and fundraising.
3 The Society owns the title and publishes, with its commercial publishing partner Wiley, three of the world’s leading international journals in geography. They are hybrid journals in the sense that they offer a Gold option to the normal route of papers sitting behind a subscription paywall; authors are also allowed to self-archive a pre-publication version of their paper. The journals were cited as one of a number of important lines of evidence in enabling the ESRC International Benchmarking Review Panel to reach the conclusion that British Human Geography research was world leading. This report is to be published in March 2013.
4 The Society’s Director, Dr Rita Gardner CBE, was a member of the Finch Review Group (one of three learned society representatives), and is the chair of the Academy for Social Sciences CEOs Working Group on Open Access.
Learned Societies
5 Learned Societies and subject bodies number well in excess of 300 in the UK. The Learned Societies play a key role in the research ecology of the UK, supporting disciplines and their practitioners, sharing knowledge, and engaging schools, policy makers and the wider public beyond the academy (Appendix 1). Their work reaches tens of millions of people each year. A number also offer professional accreditation to sustain standards in the practice of their disciplines. The Learned Societies together, excluding the medical Societies, invest hundreds of millions of pounds sterling per year in supporting UK scholarship and in helping to ensure that UK research has a strong international presence.
6 Learned Societies journals are often among the world leaders and, in many cases, are not the very high cost journals of the fully commercial publishers. The Learned Society journals feature leading UK (and international) scholarship and also promote the worldwide reputation of UK research in their disciplines.
7 Most Learned Societies generate a significant portion of their income from publishing activities, on average around 50% for the 65 leading Learned Societies in the UK; the range being 0 to 97.5%. The majority of the income from journal subscriptions (between 80% and 90% in many cases) comes from overseas. Further, indirect, income is also tied to publishing, notably members who subscribe to Societies in order to receive the journals, and income from JSTOR for access to archive papers.
8 The net income generated is reinvested to support Learned Society activities since the majority are charities and operate on a not-for-profit basis.
9 Thus, Learned Societies are a key part of the research ecology of the UK and provide a very substantial intellectual, public and reputational good, at the heart of which is support for their discipline and its practitioners in the UK academy. They achieve that with income generated, often in large part, by successful publishing of scholarly journals that earn subscription income mostly from overseas; and in the process they do not place a drain on the UK public purse.
10 Many of the Learned Societies already welcome and support the principle of open access publishing by offering Gold OA pathways in their (hybrid) journals. The challenge is that OA publishing must work for them on a larger scale than at present, and on a sustainable business model for the future if they, their journals, and the reputation of UK scholarship that they promote overseas, are to survive and continue to flourish.
11 Unlike the commercial publishers, the Learned Societies, with possibly one or two notable exceptions, do not have the flexibility, economies of scale, global business opportunities or investments to fall back upon to sustain them during a time of transition to open access publishing. Income streams are typically limited in number. Learned Societies do not lack for innovation but they are, by their constitutions and their status as charities, risk averse. Perhaps that is why they have so successfully supported UK scholarship for 150+ years in many cases.
Evidence and recommendations
A. Government’s acceptance of the recommendations of the Finch Group report – Accessibility, sustainability, excellence; how to expand access to research publications, including preference for gold over green.
12 The Society fully supports the three pillars of Finch, namely Access, Excellence and Sustainability. These too are at the core of Learned Societies; and getting the balance right between the three is paramount. We do not support access at the expense of sustainability or excellence in publishing, which is what we believe the current RCUK policy on Open Access is likely to do.
13 The Finch Group successfully negotiated the complex issues associated with Open Access and generated a considered series of recommendations, with agreement from many key stakeholders, including funders, publishers, university administrators, libraries and learned societies. Through this, there was recognition that all stakeholders had to make compromises.
14 While Gold (a) clearly was the stated preference, it was recognised in the Finch Report that hybrid publications would exist for the foreseeable future (if not indefinitely) with the Green route also explicitly being an acceptable one for Open Access. A negotiated position was agreed over shorter Green embargos in journals that did not offer a Gold route (b); with longer Green embargoes (12 months for STEM and 24 months for H&SS) being acceptable in journals that did offer Gold but where the researcher did not have the funds to pay (c). (These three different routes, a,b,c, to OA publication have since been set out visually in the Publishers’ decision tree diagram.)
15 The Society’s view is that the Green route may well become the dominant route to Open Access, especially in the humanities and social sciences (H&SS), since there is unlikely to be sufficient money to meet Gold costs for all or even a majority of UK publications unless the government commits significant new money to pay APC charges. (e.g. 50% of the academics submitted to the last RAE exercise were in H&SS and yet only 10% of the research funding is given over to these areas by the Research Councils, meaning that much research in H&SS is conducted using QR funds.) The APC funding position will be even worse if HEFCE policy requires that all REF 2020 publications are open access and with a preference for the Gold route. The USA and a number of European countries and others are also showing a greater interest in Green than Gold.
16 Green embargo routes rely on the income from journal subscriptions to pay for the costs of production and access, including peer review process, marketing the journal, providing an online platform and aids to discoverability, archiving for posterity, and so on. For such journals to have a sustainable business model the embargo periods need to be sufficiently long for subscribers not to cancel their subscriptions and wait for the material to appear ‘for free’ and yet not so long that the whole purpose of Open Access is negated. While there is little firm evidence on sustainable embargo lengths, 24 months seemed to the Finch Group and to other independent commentators to be a reasonable starting point for embargos in the Humanities and Social Science disciplines, in which articles have a long term currency and much less immediacy than in the bio sciences. A 12 month or less Green embargo in H&SS, in the absence of any evidence to the contrary, is felt to be unsustainable and would undermine the business model.
17 The Society strongly supports the conclusions and recommendations of the Finch Group and was pleased that BIS accepted them in full (with the exceptions of the recommendations on VAT which were referred to the Treasury). We had, not unreasonably, expected that the Research Councils would come into line with the spirit and details of Finch in their policies on open access, not least because they were properly represented on the Finch Group.
18 The key issue we have is in the flawed interpretation and implementation of Finch Report recommendations by the Research Councils (RCUK), as set out in their policy. This has stipulated Green embargos of 6 (STEM) and 12 (H&SS) months and envisages an end point where one-size fits all (ie 6 months Green embargo in all disciplines); does not include all three OA routes consistent with the Publishers’ decision tree; and sets an unrealistically short review period. Moreover, there was no consultation with the academic, university, publisher or learned society communities in formulating this policy, and scant evidence on which to base it, especially for disciplines other than the bio and life sciences which have led in terms of open access but which have very different funding, readership and citation patterns from most other disciplines.
19 With the UK aiming to lead the world, RCUK is putting pressure on other nations to implement similar policies to ourselves. By pursuing a flawed policy and encouraging the rest of the world to follow it, that is further compounding the difficulties of sustainability in journal publishing for the learned societies.
20 The Research Councils are now in the process of formulating more flexible guidance around their existing policy, we understand, but in our view this is not sufficient as most people will read the policy rather than the guidance.
21 The Society recommends that RCUK produce a clearly stated, five year, transition policy that is aligned with Finch and which recognises and welcomes all three OA routes on equal terms, and includes the longer 12/24 month embargos.
22 The commitment by RCUK to review policy in 2014 is too soon for the impacts of the policy to have been felt by the universities, publishers, learned societies and other key stakeholders. Libraries are currently making choices, for example, as to which journals they will take in 2014. So, while a 2014 review may be helpful in looking at the extent of policy implementation, we recommend that a further review in 2016 is undertaken to assess impact and to inform any policy shifts as a result. All reviews should be independently managed and engage representatives from the full range of stakeholders.
23 In summary, with the UK going ahead of the rest of the world there are inherent risks for all concerned in seeking an acceptable balance for all stakeholders between access, excellence and sustainability in open access publishing. A flexible and cautious approach, with a clear transition policy and independent and well-timed reviews is the prudent way to proceed, as opposed to what appears to be an ideologically driven and fixed policy end point.
B. Rights and re-use in relation to open access publications, including the CC-BY licenses
24 As set out in the ALPSP submission to this consultation, CC-BY was not designed for the scholarly publishing system and it comes with clear advantages and disadvantages.
25 In our view, the key here is that one size does not fit all. It seems a reasonable argument, if independently supported by the business and researcher communities (neither of whom were represented on the Finch Group), that a license that allows commercial re-use could be sought in those circumstances where government pays for the research and for APC costs and where data mining and economic growth are overriding contexts.
26 We are unclear as to whether there has been any consultation with the business or researcher communities in formulating RCUK policies on CC-BY, and what recommendations have been made by the Governing Bodies (Councils) of the Research Councils when considering open access strategies and policies. We would hope the latter have been fully consulted and have drawn upon the commercial expertise that exists within them.
27 In our view, it makes little sense for a CC-BY type of approach to be applied in disciplines where there is modest, if any, economic benefit (but much social and environmental benefit and policy relevance) in the majority of research findings; where third party images and other content in articles renders CC-BY difficult to administer; where large data sets are not produced by the research and where data mining has little relevance other than in terms of making use of already public data sets such as the census in the research itself; and where the currency is in ideas rather than in scientific ‘discoveries’. These circumstances relate to the arts, humanities and social sciences (H&SS) and to some of the STEM disciplines. In the H&SS disciplines JISC sponsored research (OAPEN UK) has shown that 79% of academics feel that a non-commercial and non-derivative license would be the right one (CC-BY-NC-ND). The Society endorses that view.
28 The Society recommends that for all Open Access publishing in the humanities and social sciences the CC-BY-NC-ND license (or an equivalent) is the normal standard expected of all Gold and Green OA articles; but that authors may request a CC-BY license if they wish.
C. Cost of APCs and the implications for research funding and the taxpayer
29 For many years to come it is likely that the UK HEIs will pay more to publish and access journals than in recent years owing to the need to pay for Gold APCs and to continue to subscribe to journals because the Green route will be a significant player in the mixed economy for both UK and overseas authors. (The UK academics contribute some 7% of world output of scholarly articles.) Allowing for the fact that the publishers have committed not to double-dip, and that they have made a strong and coherent case to share subscription reductions across the whole of their national and international subscriber base, there will be continuing and significant costs to the implementation of this policy as long as the UK is leading the world in requiring Gold OA publishing. The Finch Report provided some outline estimates of the order of those additional costs and urged the government to pay them, but we ask if a full cost-benefit analysis has been undertaken to inform RCUK / HEFCE policy development?
30 There are clear implications, depending on where this ‘extra’ money is sourced from, for either a reduction in funding available for research or greater costs on the tax payer. If the rest of the world did decide to go Gold, then if a sound evidence-led case can be made in terms of OA fostering economic growth, it may be a price worth paying, especially for the life and bio sciences (but less so for other disciplines). If, as current signs suggest may happen, the rest of the world either does not embrace open access or tends towards Green, it becomes seriously questionable as to whether this is a price worth paying over an unknown period of time for a matter of principle; all the more so if the ‘public’ can gain free reader access to all journals through their local libraries, as is the plan
D. The level of Gold OA uptake in the rest of the world versus the UK and the ability of the UK HEI to remain competitive
See comments above.
Dr Rita Gardner CBE
Director, Royal Geographical Society (with IBG)
7 February 2013
Appendix 1 Learned Societies
What Learned Societies do
Learned Societies are distinct from the national academies (British Academy, Royal Society, Royal Academy of Engineering) in three ways. First, they advance, support and promote an individual discipline and its practitioners in the UK. Second, they receive no core government funding for their work, which is undertaken on a not-for-profit (charitable) basis. Third, their membership is open to all who qualify and, typically as charities, their activities are undertaken for public benefit.
Learned Societies’ income is normally generated by some combination of membership subscriptions (including professional accreditation in some cases); income from publishing scholarly journals, conferences and professional development events; enterprise income (eg from hiring out rooms in their premises); and fundraising. The balance of income between these different sources varies from Society to Society, as does their size and annual budget. At the extremes, and excluding the medical Learned Societies, annual budgets range from less than £100k to more than £40m. In some cases more than 90% of the income comes from a single source – typically either membership subscriptions or scholarly publishing. The 65 leading Learned Societies from across the sciences, social sciences and humanities, generated on average half their income from scholarly publishing. This included those with both large and small incomes. All net income, after costs, goes back into supporting the charitable work of the organisation.
Learned Societies play a fundamental role as part of the research ecology of many nations, and are very well developed in the UK. Many have distinguished histories, extending to the early C19th century, and well deserved national and international reputations. Today their value in developing and supporting their disciplines and research communities, and in helping to meet government agendas, lies in seven main areas, not all of which apply to every Society:
1. Nurturing and promoting discipline-based research communities
2. Sustaining the UK national research profile and international leadership of the discipline
3. Sharing and exchanging knowledge within and between academic, professional user and policy communities
4. Accreditation and certification to uphold standards, competence and conduct of professionals in their fields
5. Inspiring the next generation and their teachers
6. Serving the public interest by acting in advisory, consultative and representative capacities
7. Informing and engaging the public
In doing so, societies typically provide the following (and more) activities:
· national and international conferences and seminars;
· specialist research groups and sub-discipline networks;
· dissemination of knowledge through publishing of internationally recognised scholarly journals;
· advising on standards (eg HE subject benchmark statements);
· professional development and accreditation;
· discipline leadership;
· holding, and making accessible, subject-based collections
· advocacy and expert advice to government and others;
· knowledge exchange activities between academia and the public, schools and policymakers.
· facilitation and co-ordination of community responses to consultations;
· provision of grants for research;
· recognition of excellence through awards;
· provision of expert contacts for the media and others;
· demonstrating the impact of the discipline;
· support for teaching and learning in HE;
· support for teaching and learning, and careers advice, at school;
· liaison with business leaders and other employers and research users;
· raising awareness of the value of science and research;
· monitoring the health and vulnerability of disciplines and sub-disciplinary areas;
· a range of public-facing activities from lectures to magazines, exhibitions to field visits.
Learned Societies’ publishing
· UK Learned Societies are major publishers. Most have one or more journal titles that they own. Based on the analysis by Morris (2007), about 55% of scholarly journals worldwide are linked with non-profit organisations.
· A small number of Learned Societies have set up their own large commercial publishing companies (eg Institute of Physics: 60 journals, turnover c. £30m), but this is the exception rather than the rule.
· Many Learned Societies depend on publishing as a significant or major source of income.
· Non-profit association publishers and journals stand out: they launch fewer journals; are less likely to close journals; hold historic long-running journals as well as ‘newer’ ones; and they predominate among the most highly cited journals (Morris, 2007)
· Some UK Learned Societies publish independently, but increasingly in recent years they have entered partnerships with commercial publishers owing to the need to manage risk and gain access to marketing expertise, technology, purchasing consortia and ‘bundle’ deals.
· Many Learned Society journals are highly ranked in terms of both citation and readership numbers; many are also made available at no cost to universities in poorer countries as part of philanthropic programmes.
· Given the UK’s reputation as the world leader or world second – usually after the USA – in many disciplines on a wide range of indicators, including publishing of research, it is not surprising that the UKs Learned Societies, collectively, have ownership and responsibility for a significant number of the world-leading international peer reviewed journals in a wide range of disciplines.
· Such journals typically receive high rates of paper submissions and, all things being equal, will continue to do so as emerging nations seek to achieve the highest international recognition for their research.
· While this needs further substantiation, the cost and the annual increases in subscription rates of Learned Society journals tend to be less than the journals published purely by the commercial publishers.
· The profits from Learned Society publishing are invested directly into supporting the delivery of the activities listed in the section above.
· Learned Society publishing underpins membership and income to varying degrees.