Open Access

OA 49

Written evidence submitted by the Society of Biology

The Society of Biology is a single unified voice, representing a diverse membership of individuals, learned societies and other organisations. We are committed to ensuring that we provide Government and other policy makers - including funders of biological education and research – with a distinct point of access to authoritative, independent, and evidence-based opinion, representative of the widest range of bioscience disciplines.

The Society welcomes the interest of the Committee and is pleased to offer these comments, gathered in consultation with our members and advisors for your consideration.

Summary

· The Society of Biology welcomes policies that maximise access to research outputs; however the current policies on open access (OA) publishing have the potential for significant unintended consequences on the UK research base and economy.

· We recommend that an impact study of OA policies is carried out to highlight any counterproductive effects and to determine if and how OA creates economic growth in the UK as predicted.

· As funding has only been provided for 45% of article processing charges (APC) for RCUK funded research in 2013/14, it is difficult to see how research institutions will pick up this shortfall, particularly over the transition period.

· Researchers will experience variation across disciplines and institutions in terms allocation of funds for OA publication charges, required embargo periods, and the impact of international collaborations. CC-BY licensing should be de-coupled from the OA mandate until the economic implications for the UK are understood through a full inquiry, engaging all stakeholders.

· Thought must be given to the transition period to ensure that Learned Societies who rely on publishing income are able to continue supporting the skills pipeline and career development in their discipline, engage with the public dissemination of science and offer expert advice to policy makers.

· We are keen to enter into dialogue on the opportunities and challenges of OA with government, the higher education community, funding bodies and publishers, to determine appropriate solutions that will maximise both access to research outputs and the capacity to underpin growth and excellence in the research community.

 The Government’s acceptance of the recommendations of the Finch Group Report ‘Accessibility, sustainability, excellence: how to expand access to research publications’, including its preference for the ‘gold’ over the ‘green’ open access model.

1. Many learned societies view OA developments from a broad perspective. An OA policy can assist charitable objectives by maximis ing access to research outputs, but at the same time can mak e their capacity for future financial support of their discipline more uncertain . The potential loss of income will impact major activities within their discipline, including support for the skills pipeline and career development, engaging with the public dissemination of science, and offering expert advice to policy makers.

2. We are therefore keen to enter into dialogue on the opportunities and challenges of OA with government, the higher education community, funding bodies and publishers, to determine appropriate solutions that will maximise both access to research outputs and the capacity to underpin growth and excellence in the research community.

3. The current policies on OA publishing have the potential for significant unintended consequences on the UK research base and economy – it is vital that these are addressed. Some of these potential impacts are indicated in the Finch Report, but there has been little concerted action to address them thus far and the lapse of time is adding to concern.

4. We recommend that an impact study of OA policies is carried out to highlight any counterproductive effects and to determine if and how OA creates economic growth in the UK as predicted. This is in line with recommendations to other EU governments, such as the Groupement Français de l'Industrie de l'Information (GFII) in France, who recommend an impact study to ascertain suitable business models for Gold OA, adequate embargo periods for each discipline and the impact of OA on the publishing sector [1] .

5. We note that RCUK propose to review implementation of the policy in 2014 to make any appropriate mid-course corrections – we would urge the RCUK to widen the breadth of stakeholders that it consults, including learned societies and learned society publishers.

Rights of use and re-use in relation to open access research publications, including the implications of Creative Commons ‘CC-BY’ licences.

6. There are concerns about the Creative Commons Attribution (CC-BY) licence and the commercial use of research. Clearer guidance is needed and leadership by the Research Councils would promote progress in this area.

7. The CC-BY requirement has some potential to cause the UK economic harm, both in the research arena and capitalising on UK research. CC-BY licensing should be de-coupled from the OA mandate until the economic implications for the UK are understood through a full inquiry, engaging all stakeholders. For example, the mandated application of a CC-BY licence may breach existing arrangements, where researchers obtain funding from industry partners; this could preclude future partnerships, effectively closing doors to commercial funding of UK science.

8. In order to commercialise research output, it is usually necessary to secure a proprietary position, which is often done through patenting. Once data are in the public domain (i.e. published), they constitute ‘prior art’ and will preclude/restrict the granting of patent claims, due to lack of novelty. It is often the case that a commercial partner will prevent, or at least delay, publication of research that it has funded.

The costs of article processing charges (APCs) and the implications for research funding and for the taxpayer.

9. Research institutions need clear guidance from funders about how to allocate OA funding and charges, and University administrators need support to understand and effectively implement policy, and inform researchers of their publishing options and obligations.

10. The RCUK initial funding and the subsequent block grants to aid implementation of its policy on OA are a welcome start. The RCUK initial funds have been an important catalyst for the establishment of University OA funds and the clarification of OA publishing policies, however there is concern that the RCUK has seriously underestimated the funds needed for OA publishing. As funding has only been provided for 45% of article processing charges (APC) for RCUK funded research in 2013/14, it is difficult to see how research institutions will pick up this shortfall, particularly over the transition period. Future funding levels appear insufficient to cover APCs and sustain the level of publishing previously achieved. Some Universities are piloting internal funding mechanisms to address underfunding of (or indeed unfunded) authors, for example the University of Nottingham’s scheme [2] , but as the scale of demand is likely to increase so will the strain on these provisions.

11. A great deal of research is funded by small scale grants (e.g. PhD research grants and minor charity funding) or occurs as a ‘spin off’ from major research projects, and is not funded directly. Funds are not generally available within universities and other institutions to pay for OA publication of this type of research. Smaller organisations and specialist societies are likely to be hit especially hard, and retired scientists are unlikely to have access to these funds. It is also unclear how indirect grant moneys will be handled given the TRAC methodology for allocating overheads. As most research outputs are published after the end of the grant, they cannot be accounted during the grant funding period The TRAC methodology makes it difficult to introduce new funding strands to indirect grant funding.

12. It is still unclear how funds will be accessed by researchers and how money will be ring-fenced and managed by universities. It seems to have fallen to universities to establish an effective mechanism for OA funding, but greater guidance from funders is needed. There is uncertainty about the methods of allocation of funds, as well as concern that funding may be inequitably distributed amongst authors. Prioritising access based on seniority of the researcher or research area, and the OA funding requirements of primary and secondary authors, particularly for international research, will be problematic; this may discourage UK authors from taking primary authorship. If APCs apply across the board, it may be that some researchers will feel unable to submit their work to the most appropriate (and possibly greatest impact) journal as they are unable to access APCs.  

13. There is concern that the development of mechanisms to allocate publishing charges within universities and funded institutions will themselves absorb a significant proportion of the funds allocated for OA charges. Many systems are currently being created to align with existing accounting mechanisms and there is concern that they will lose efficiency and become less cost-effective with time.

14. The allocation of APCs is unclear for multi-authored papers that are funded by multiple grants, and similarly when a researcher moves institution mid-way through a project.

15. Funds will also be needed to sustain the costs of maintaining journal subscriptions in the transition period, as researchers require access to material in other publications and to material for which no APC has been paid.

16. Insufficient funding for APCs could lead to the loss of some reasonably-priced high-impact journals, especially those published by societies . This would also create a loss of significant export revenue for the UK.

17. It is not clear that the full implications to universities of transfer of funding from the Funding Councils [Scottish Funding Council (SFC), Higher Education Funding Councils for England (HEFCE) and Wales (HEFCW) and Department for Employment and Learning, Northern Ireland (DELNI)] to research budgets have been considered.

The level of ‘gold’ open access uptake in the rest of the world versus the UK, and the ability of UK higher education institutions to remain competitive.

18. Research publication is increasingly a global activity, and so OA policy setting raises concern about the capacity of UK publishers to remain internationally competitive. The UK is a significant but relatively small market for publishers, so a major challenge will remain until international publishers universally adopt publishing approaches that are acceptable to UK authors, funders and the Government. As many of the highest-impact bioscience society publishers are based in the USA and may not offer optional open access or appropriate embargos, this may become a closed publication avenue for UK researchers, thus damaging the UK bioscience base.

19. The APC model may also discriminate against scientists from the developing world who may not have access to funding. Currently many learned societies provide journal access to these authors at reduced rate or free of charge and there are voluntary schemes whereby publishers waive APC for disadvantaged authors.

7 February 2013

Member Organisations

Agriculture and Horticulture Development Board

Anatomical Society

Association for the Study of Animal Behaviour

Association of Applied Biologists

Biochemical Society

Biosciences KTN

Breakspear Hospital

British Andrology Society

British Association for Lung Research

British Association for Psychopharmacology

British Crop Production Council

British Ecological Society

British Lichen Society

British Microcirculation Society

British Mycological Society

British Neuroscience Association

British Pharmacological Society

British Phycological Society

British Society for Gene and Cell Therapy

British Society for Immunology

British Society for Matrix Biology

British Society for Medical Mycology

British Society for Nanomedicine

British Society for Neuroendocrinology

British Society for Parasitology

British Society of Plant Breeders

British Society for Plant Pathology

British Society for Proteome Research

British Society for Research on Ageing

British Society for Soil Science

British Society of Animal Science

British Toxicology Society

The Ethical Medicines Industry Group

Experimental Psychology Society

The Field Studies Council

Fisheries Society of the British Isles

GARNet

Gatsby Plants

Genetics Society

Heads of University Centres of Biomedical Science

Institute of Animal Technology

International Biometric Society

Laboratory Animal Science Association

Linnean Society of London

Marine Biological Association

MONOGRAM – Cereal and Grasses Research Community

Nutrition Society

The Rosaceae Network

Royal Entomological Society

Royal Microscopical Society

Science and Plants for Schools

Scottish Association for Marine Science

Society for Applied Microbiology

Society for Endocrinology

Society for Experimental Biology

Society for General Microbiology

Society for Reproduction and Fertility

Society for the Study of Human Biology

SCI Horticulture Group

The Physiological Society

Tropical Agriculture Association

UK Environmental Mutagen Society

UK-BRC – Brassica Research Community

UK-SOL – Solanacea Research Community

University Bioscience Managers' Association

VEGIN – Vegetable Genetic Improvement Network

Zoological Society of London

Supporting Members

Association of the British Pharmaceutical Industry

Association of Medical Research Charities

Astrazeneca

BASIS Registration Ltd.

Bayer

BioIndustry Association

BioScientifica Ltd

Biotechnology and Biological Sciences Research Council

BlueGnome Ltd

Forest Products Research Institute

Huntingdon Life Sciences

Institute of Physics

Ipsen

Lifescan (Johnson and Johnson) Scotland Ltd

Medical Research Council (MRC)

Oxford University Press

Pfizer UK

Royal Botanical Gardens Kew

Royal Society for Public Health

Select Biosciences

Syngenta

The British Library

UCB Celltech

Unilever UK Ltd

Wellcome Trust

Wiley Blackwell


[1] Recommendations of the European Commission on Open Access : GFII’s first comments http://www.gfii.fr/en/presse/recommandations-de-la-commission-europeenne-en-matiere-d-open-access-premieres-observations-du-gfii?symfony=bpfsnsklo2aerga0mc0jod8974

[1]

[2] http://www.nottingham.ac.uk/is/finding/openaccess.aspx

Prepared 7th March 2013