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 www.rcuk.ac.uk.
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.
Licensing
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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