Open Access: Responses to the Committee's Fifth Report of Session 2013-14 - Business, Innovation and Skills Committee Contents

Appendix 2: Response from Research Councils UK

Research Councils UK (RCUK) is a strategic partnership of the UK's seven Research Councils which each have a Royal Charter and together annually invest around £3 billion in research. We support excellent research, as judged by peer-review, which has an impact on the growth, prosperity and wellbeing of the UK. To maintain the UK's global research position we offer a diverse range of funding opportunities, foster international collaborations and provide access to the best facilities and infrastructure around the world.

We also support the training and career development of researchers and work with them to inspire young people and engage the wider public with research. To maximise the impact of research on economic growth and societal wellbeing, we work in partnership with other research funders including the Technology Strategy Board, the UK Higher Education Funding Councils, business, Government, and charitable organisations. Further details are available at

This response is submitted by RCUK and represents its independent views. It does not include, nor necessarily reflect, the views of the Department for Business, Innovation and Skills. The response is made on behalf of all seven Councils:

  •   Arts and Humanities Research Council (AHRC)
  •   Biotechnology and Biological Sciences Research Council (BBSRC)
  •   Engineering and Physical Sciences Research Council (EPSRC)
  •   Economic and Social Research Council (ESRC)
  •   Medical Research Council (MRC)
  •   Natural Environment Research Council (NERC)
  •   Science and Technology Facilities Council (STFC)

RCUK response to the House of Commons Business, Innovation and Skills Committee Report: Open Access

The report from the Business, Innovation and Skills Committee on their enquiry into Open Access contributes to the on-going debate on how best to implement Open Access within the UK, and RCUK will give appropriate consideration to the recommendations made and issues raised in the report, as part of the planned review focusing on the implementation and impact of RCUK's Open Access policy that will take place in the final quarter of 2014.

The RCUK Policy on Open Access (published in July 2012), and its implementation plan, were developed within the context of the Finch 'process' and refined following extensive discussion with key stakeholders.

RCUK's approach to implementation of its policy is one of evolution and not revolution. The phrase we often use is that it is a journey and not an event. The aim is to move to peer-reviewed papers arising from Research Council funded research being available open access over a transition period of some five years. During the transition period it is planned that the compliance targets for the numbers of papers made available Open Access will be increased year-on-year, as will the funding we make available to support Article Processing Charges (APCs). During the transition period, we are allowing authors to use journals with embargo periods longer than the headline figure in the policy, but in line with those agreed by the Government, for publicly funded research where no funds are available to cover the payment of APCs. The compliance targets also mean that researchers in discipline areas which have yet to develop a range of compliant OA publishing routes will still be able to publish without penalty.

At the heart of the RCUK philosophy on Open Access is our desire to ensure the widest possible access to the outputs of the research that we fund, recognising that there is a wide range of potential users from private individuals to innovators and SMEs, as well as researchers. Researchers are an important part, but not the only part of this constituency. Our policy has been designed to support this wider constituency, recognising that not all users will be familiar with how the research communications system works, and may not appreciate the differences between pre and post peer-reviewed versions of papers, and author manuscript versions versus final published versions. Ensuring easy access to the final, peer-reviewed version of a paper is extremely important. In a world where anybody can publish anything on the internet, RCUK recognises that it has a duty to ensure that users have ready access to high-quality, peer-reviewed published papers arising from Research Council funded research. We are not convinced that institutional repositories are always the best way of providing this, and that solutions such as 'request a copy' button or emailing the researcher for a copy of the paper are not scalable to a wider constituency of users. In addition, the headline figure quoted in the report that 60% of journals already allow immediate un-embargoed self-archiving of the peer-reviewed version of the article does not reflect the reality for Research Council funded authors. A comparable figure for journals used by Research Council funded authors is between 17% and 20% .

RCUK defines Open Access as unrestricted, on-line access to peer-reviewed and published research papers. There are various models for achieving open access, some of which allow more immediate access. RCUK has a preference for immediate, unrestricted, on-line access to peer-reviewed and published research papers, free of any access charge and with maximum opportunities for re-use. This is commonly referred to as the 'gold' route to Open Access. RCUK prefers 'gold' Open Access as we consider it provides the best way of providing immediate access, free of charge to the final peer-reviewed versions of papers to the widest group of users. Papers are referenced by the journal in which they are published. Therefore, by going directly to the journal web site a reader can be confident that they are accessing the final peer-reviewed and formally published record of research.

Detailed responses to the report's recommendations are made below.

Strengthening deposit mandates to increase open access

RCUK should build on its original world leading policy by reinstating and strengthening the immediate deposit mandate in its original policy (in line with HEFCE's proposals) and improving the monitoring and enforcement of mandated deposit (paragraph 31).

The current RCUK Open Access policy is the first such RCUK policy. Previous policies have been implemented by individual research councils, and varied between councils. Only the MRC had a requirement (since 2006) for availability of papers via a repository (Europe PubMed Central) within a specific time period (6 months). The policies for other councils required deposit and access subject to publishers' copyright and licensing conditions. The current RCUK policy is much stronger in requiring deposit and access within clearly defined time periods. Reinstating individual council policies would be a backward step.

With some 26,000 research papers arising per year from Research Council funded research, the monitoring and enforcement of deposit is never going to be a simple task. RCUK is working with repositories, publishers and others to find ways of making this as simple, and administratively efficient as possible.

Open Access worldwide

Government and RCUK should rigorously monitor global take up of Gold and Green and international developments in open access policy worldwide. This data should be used to inform both the reconvening of representatives of the Finch working group in the Autumn of 2013, and RCUK's review of its open access policy in 2014 (paragraph 35).

RCUK keeps a watching-brief on international developments in Open Access policy, and it is intended that the position of the UK as compared to other countries will inform the RCUK review in 2014.

Pure Gold and Hybrid Gold

RCUK has undertaken to publish data on "how the open access block grants are being used, specifically the numbers of research papers which are being made open access through payment of an APC and the actual APCs being paid to publishers". We recommend that RCUK also requires data on subscription expenditure from UK HEIs to establish the impact of its policy on subscription purchasing and pricing (paragraph 41).

RCUK supports the need for much greater transparency of the costs of publishing in and subscribing to journals. This not only covers costs of APCs and subscriptions, but also the largely 'hidden' costs of page and colour charges levied by some subscription journals when publishing a paper. Access to data on subscription expenditure may be restricted by confidentiality agreements between publishers and institutions. Information on amounts spent on page and colour charges tends not to be centrally accounted for by institutions. RCUK will work with HEFCE and representatives of the research library community to find ways of gaining maximum transparency of these costs.

Embargo periods

The stated policy objective of the Government and RCUK is to increase access to publicly funded research. Long embargoes are a barrier to access. We recommend that the Government and RCUK revise their policies to place an upper limit of 6 month embargoes on STEM subject research and up to 12 month embargoes for HASS subject research, in line with RCUK's original policy published in July 2012 (paragraph 50).

The RCUK policy on embargo periods is unchanged since July 2012, and requires publishers to provide a 6 month embargo period for STEM and 12 month period for HASS subjects, where they do not provide a compliant 'gold' OA route. During the transition period we are allowing authors to use journals with embargo periods longer than the headline figure in the policy, but in line with those agreed by the Government for publicly funded research where no funds are available to cover the payment of APCs - i.e. 12 months for STEM and 24 months for HASS subjects, except for biomedical research, where a maximum embargo period of 6 months is required, in line with the MRC's 2006 policy. This flexibility is required to ensure that, during the transition, researchers that we fund are not unduly constrained in the choice of journal they have available to them to publish in.

Given the importance of ensuring that UK open access policy does not result in reduced access in the UK or worldwide, the Government and RCUK must monitor and evaluate the impact of their open access policy on embargo lengths imposed by UK publishers. The impact on different subject areas must also be carefully monitored. That information must inform future meetings of the Finch Group and RCUK's reviews of open access policy (paragraph 51).

RCUK keeps a watching-brief on changes in embargo periods, and these will form part of the evidence examined as part of the 2014 review of our policy. In this context, we welcome the recent reduction in embargo periods by Elsevier, such that the majority of its journals now offer a green option with 12/24 month embargo periods in line with those agreed by the Government for publicly funded research where no funds are available to cover the payment of APCs, as well as a hybrid-gold option.

Affordability of APCs for authors and UK research organisations

We are concerned that the expectation appears to be that universities and research organisations will fund the balance of APCs and open access costs from their own reserves. We look to the Government and RCUK to mitigate against the impact on university budgets. The Government must not underestimate the significance of this issue (paragraph 64).

Publication of research results is an integral part of the research process, and is thus a legitimate part of the cost of undertaking research. RCUK is committed to providing the necessary funding to cover the costs of publishing papers arising from the research funded by the Research Councils. The size of the RCUK publishing fund has been based on estimates of the number of papers arising from Research Council funded research and the average value of APCs, and it is distributed to institutions as block grants, in proportion to the amount of funding they receive to employ researchers (direct labour costs). So far, block grants have been awarded only for the first two years of the transition. The size of the publication fund for future years, and the algorithm for allocation of block grants to institutions will be reviewed as part of the 2014 review of the RCUK policy, and will be subject to the outcome of the next Spending Review. We will look to institutions to provide us with evidence on numbers of publications and APC costs to help inform the 2014 review.

The initial size of the publication fund and the mechanism for its distribution is of course based on estimates and assumptions. However, we had to start somewhere, and this is an initial funding line for the first two years of the transition. We are disappointed that some institutions, e.g. the Russell Group, are continuing to say that in 2013/14 RCUK is providing only enough funding to cover 10% of papers produced. Whilst this is technically correct, it refers to 10% of total papers produced by an institution, and not 10% of those funded by RCUK. We continue to believe that RCUK funding is sufficient to allow institutions to meet their overall OA compliance targets for Research Council funded publications (through both Gold and Green combined) of 45% in year-1 and 53% in year-2.

The shared ultimate goal of full Gold open access

The Government and RCUK should clarify that Gold open access is the ultimate goal of, rather than the primary route to, their open access policies. We recommend that the Government and RCUK reconsider their preference for Gold open access during the five year transition period, and give due regard to the evidence of the vital role that Green open access and repositories have to play as the UK moves towards full open access (paragraph 70).

RCUK's ultimate goal is to remove the barriers that restrict access to the outputs of the research funded by the Research Councils, in order to ensure the maximum availability to the widest possible constituency of users. There are barriers of both cost and of delay to access. RCUK supports a twin-track approach to Open Access, by both Gold and Green routes. RCUK's preference is for immediate, unrestricted on-line access, aka Gold open access, for reasons defined in section 2 of this response.

RCUK's current guidance provides that the choice of Green or Gold open access lies with the author and the author's institution, even if the Gold option is available from the publisher. This is incompatible with the Publishers Association's decision tree, and RCUK should therefore withdraw its endorsement of the decision tree as soon as possible, to avoid further confusion within the academic and publishing communities (paragraph 71).

Endorsement of the 'decision tree' was part of the outcome of developing the RCUK policy within the context of the Finch process. It represents the post-transition 'end state' when RCUK expects to be providing sufficient funding to cover the publication costs for the majority of research papers arising from Research Council funding.

The RCUK policy has been in force now for over six months. Whilst there was some confusion in the early period, the evidence we have is that institutions now understand the flexibility we are offering during the transition period, and that the 'decision tree' has to be seen within the context of this flexibility.

Achieving a functional market

If RCUK and the Government continue to maintain their preference for Gold, they should amend their policies so that APCs are only paid to publishers of pure Gold rather than hybrid journals. This would eliminate the risk of double dipping by journals, and encourage innovation in the scholarly publishing market (paragraph 77).

RCUK made an explicit decision not to restrict the RCUK block grants only to covering APC costs for pure Gold journals. To have done so would have restricted the choice of authors as to where they could publish their research by limiting them to pure Gold journals if they wanted to 'go gold', and we believe it would also have limited innovation in scholarly publishing. RCUK commitment to provide APC funding without restriction has already driven change within the publishing industry, with many major subscription journals now offering a hybrid-gold option for the journals that Research Council authors chose to publish in. It is unlikely that publishers would have made these changes if RCUK had restricted its APC funding to pure Gold journals.

RCUK considers that publishers need to ensure that subscriptions paid by institutions for hybrid journals reflect any additional revenue that the journal has received through the APCs that the institution has paid in order to publish 'gold' papers in that journal. RCUK will work with JISC Collections, representatives of the research library community and publishers to ensure that differential pricing of subscriptions is introduced at an institutional level.

Whilst RCUK does not restrict its policy to supporting only pure Gold journals, institutions are free to decide how they allocate their RCUK block grants, and this could include declining to make APC payments to specific hybrid Gold journals that institutions may consider guilty of 'double-dipping'.

Depending on the evidence for 'double-dipping' and the extent of differential pricing provided by publishers, RCUK will review its position on support for hybrid Gold as part of its 2014 review.

The evidence we saw suggested that authors have little price sensitivity when they choose a journal in which to publish. We recommend that RCUK amends its policy to allow grant funds to be used for publishing charges, which is by far the most common model internationally. This would re-introduce price pressure by prompting authors to make an informed decision on where to publish. We recommend that the Government endorse genuine price transparency from publishers so that it is clear to subscribers which services and costs are and are not included in the overall subscription price, enabling subscribers to assess the costs and benefits of purchasing (paragraph 78).

It is unfortunate that the report has conflated the issue of price sensitivity to subscription journals with the mechanism for support of APC payments. It is hoped that one of the benefits of introducing author side payments through APCs will be to introduce much greater price sensitivity in the research publications market, whilst still preserving the quality achieved by effective peer-review. How APC funding is made available to authors is a secondary issue, and RCUK is not aware of any evidence that providing block grants to institutions for payments of APCs is leading to authors making un-informed decisions as to where to publish.

The previous funding mechanism, where researchers requested APC funds as part of a grant application, did not work effectively. Funding provided within grants has to be used and accounted for within the lifetime of the grant. Papers do not arise neatly at a set point in the research process. Some arise before the research is finished, and some arise after the end of a grant, with some papers being the result of research carried out with multiple grants. Many researchers were not effectively using the grant funding route to request APC funds, whilst at the same time Research Councils were being approached by researchers who wanted to 'go gold' but who did not have access to APC funds in their grants. Restricting APC funding to those who had requested it in grants would have disenfranchised a large number of researchers funded in the past three to four years, who had not thought to request APC funds, but who now wanted the opportunity to 'go gold'.

RCUK made an explicit decision to introduce a block grant for APC payments as a way of recognising that papers arise throughout the whole research life cycle and not just within the lifetime of specific grants. The block grant is for all papers arising from Research Council funded research submitted for publication from 1 April 2013, regardless of when the research was funded.

It is the responsibility of institutions awarded the RCUK block grants to ensure that the APC funds are allocated in such a way as to enable researchers to make informed decisions as to where to publish, based in part of price sensitivity.


We recommend that the Government reports the outcomes of its further investigations into licensing to us and communicates them clearly through RCUK as soon as possible in order to assuage concerns of authors and their institutions (paragraph 85).

RCUK should monitor complaints from authors and/or their institutions about breach of licensing conditions or inappropriate re-use of content, consider these at its review of open access policy, and identify appropriate action if necessary (paragraph 86).

RCUK commits to communicating information on issues around licensing as and when the information becomes available. RCUK will also monitor any complaints relating to breach of licence conditions. Evidence of issues relating to licensing will be considered as part of the 2014 review, which will include identifying appropriate actions as necessary.

11 November 2013

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Prepared 26 November 2013