4 The transition to open access: costs
and hidden costs |
Pure Gold and Hybrid Gold
36. Neither the Finch Report nor the Government
nor RCUK make any detailed distinction between hybrid journals
and fully open access or "pure" Gold journals.
Consequently, publishers operating either type of model are therefore
equally eligible to receive APCs paid by UK research funders and
We received many submissions arguing that this would have two
unintended consequences: allowing "double dipping"
by hybrid publishers, and promoting artificially high APCs.
37. Due to the Government's clear preference
for Gold funded by APCs, and the fact that RCUK has said it will
make available £100m to fund the implementation of this policy,
it seems likely that publishers will be incentivised to add a
Gold option to their subscription model, and become hybrid as
a direct result of the Government's open access policy. Evidence
from Reed Elsevier supported this assumption:
Since 1 April, when the new UK policies were implemented,
there has been a differential pattern of open-access publishing.
There are many more hybrid open-access journals, in particular,
in the landscape now. The Finch group was looking forward to that
new landscape. [...]With the Government's policy that we are all
implementing, we will see an increase in the amount of hybrid
open-access publishing done at scale.
38. It seems likely that for-profit publishers
of hybrid journals with a diversified income comprised of both
subscriptions and APCs will seek to maintain that joint revenue
stream for as long as possible, especially if in doing so they
would be actively complying with Government and funder policies.
Clearly, one of the factors that will determine the cost of any
move to open access in the UK will be the extent to which subscriptions
need to be maintained, while payments of APCs increase. This is
referred to in the Finch Report as "stickiness".
As we have seen, even if the UK reaches total open access by paying
for APCs for 100% of research produced in this country, it must
continue to pay subscription charges in order to access the vast
majority of the rest.
39. The Government and RCUK have reiterated the
Finch Report's conclusion
that HEIs and others must "negotiate hard"
with publishers to drive down subscription charges to reflect
the additional funding they are receiving through APCs. RCUK has
said it expects publishers to introduce differential pricing to
reflect its additional income.
We heard evidence from Reed Elsevier that it operates a strict
no double dipping policy, which it operates by "modify[ing]
[its] list prices two years in arrears to reflect the number of
hybrid open-access articles that are published".
The evidence we received suggested that this cannot operate as
a genuine rebate since the reduction in subscriptions is applied
to all subscribers worldwide, regardless of whether they have
paid APCs or not.
In this way, the Government's open access policy means that the
UK subsidises access to research for the rest of the world.
40. Our evidence suggested that average APCs
charged by pure Gold publishers are considerably lower than those
of publishers operating hybrid journals. The
major Gold publisher PLOS published 11% of all peer reviewed research
articles funded by the Wellcome Trust in 2012, for which the average
APC was £1060. This was around two thirds of the average
paid by the Wellcome Trust.
The published accounts
of PLOS reveal it is making a modest operating profit, and its
publicly available price list
shows that it has not raised its prices since 2009, in contrast
to subscription based publishers. Some
submissions to this inquiry argued that lower APCs led to low
quality publishing content, but this was contradicted by the evidence
from PLOS whose largest journal PLOS ONE published in 2012 more
peer-reviewed research papers funded by the Wellcome Trust, MRC,
BBSRC and Cancer Research UK than any other journal.
41. 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.
42. David Willetts, the Minister with responsibility
for Open Access policy, explained his assessment of the advantages
of Gold funded by APCs over Green as follows:
First of all, it is honest, it is explicit. There
is a cost and a value to publishing and we should recognise it
[...]It is explicitly recognised and I like that about it. I like
the fact of course that you do get the work openly accessible
straight away. The hidden cost in green is waiting six months,
12 months, 24 months, whatever it is, until the layperson outside
the academic community can access a piece of work that he or she
as a taxpayer has already paid for once. That is the second advantage.
43. Evidence to our inquiry, however, does not
back up this point of view and runs counter to the Minister's
assessment. A 2011 study showed that 60% of journals allow immediate
unembargoed self-archiving of the peer-reviewed version of the
article, that is, immediate open access.
Where publishers impose an embargo, would-be readers can send
an automatic email to the author requesting an e-copy.
44. The Finch Report observed of embargoes that
"the restrictions imposed by publishers seem to have succeeded
so far in limiting any potential impact on take-up of subscriptions
to their journals".
We heard conflicting views on whether short embargo periods pose
a risk to publishers,
but there is no available evidence base to indicate that short
or even zero embargoes cause cancellation of subscriptions. Evidence
from the field of high energy physics shows that despite nearly
100% immediate, unembargoed deposit (Green), subscriptions have
not been damaged.
The 4 million EU funded PEER (Publishing and the Ecology of European
Research) project (2012) showed that traffic to journal websites
increased when articles were made available through a publicly
possibly because interest grew as articles were disseminated more
45. Several submissions argued that short embargo
periods were more harmful to HASS (humanities, arts and social
sciences) than STEM (science, technology, engineering and medicine)
disciplines. The most frequently deployed argument in HASS subjects
is that since these articles have longer citation half-lives (i.e.
are referred to over a longer period) a longer embargo is necessary.
The Finch Report was persuaded by this distinction, recommending
embargoes for HASS subjects of 24 months and for STEM subjects
of 12 months. We did not receive any evidence to support this
recommendation, which was adopted by the Government and RCUK though
their endorsement of the Publishers Association's decision tree.
Figure 2: The Publishers Association's decision tree for policy on access to UK publicly funded research outputs
46. Some of the evidence we received predicted
that the open access policies of the Government and RCUK regarding
embargoes would incentivise publishers to introduce embargoes
or lengthen existing embargo requirements, in order to force UK
authors to pay for Gold.
Longer embargoes result in reduced access to published research
findings for the UK, and reduced access to the rest of the world.
We heard reports of a UK publisher in social sciences switching
from a zero embargo policy to require a 24 month embargo, citing
its accordance with the recent change to UK open access policy.
47. The Government's response to this was that
the publisher's interpretation of UK policy was inaccurate, since
Government and RCUK policy includes embargoes of up to 12 and
24 months respectively, as a "maximum allowance" rather
than "a requirement".
However, the Government acknowledged that the publisher "was
acting within the limits of UK policy" and acknowledged that
"any move to extend embargo periods where shorter ones are
otherwise sustainable for publishers would be counter to the overall
aims of the Government OA policy".
The Government told us that the Publishers Association would "welcome"
being informed of instances where "inappropriate" embargoes
48. Since then, the world's second largest journal
publisher, Springer, has imposed a 12 month embargo on papers
deposited in institutional repositories, where previously unembargoed
deposit was permitted.
49. We note the absence of evidence
that short embargo periods harm subscription publishers. We have
seen evidence that current UK open access policy risks incentivising
publishers to introduce or increase embargo periods. This has
serious implications for open access in the UK and the rest of
the world. We agree with the Government that lengthened embargoes
are counter to its aim to increase access.
50. 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.
51. 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.
Levels of Article Processing Charges
52. The Finch Report's economic modelling of
the costs to the UK of moving towards open access used a range
of APCs, beginning with a starting point of £1,450, a middle
ground scenario of £1,750, and a higher scenario of £2,175.
The Finch group arrived at the figure of £1,450, the lowest
figure in its modelling, because it was the average APC paid by
the Wellcome Trust at the time.
53. We received a considerable volume of evidence
to suggest that the prices of APCs used in the Finch Report's
modelling were very high. Indeed, BIS's own 'Economic Analysis
of the cost of alternative options for open access in the UK'
stated that "the Finch Group reported £12m spent nationally
in Open Access in 2010 for around 16,000 open access articles",
which works out at an average price per article of only £750.
A 2012 study found the global average APC of open access journals
to be £571.
The evidence of major open access publisher PLOS gave more detail
about Wellcome's average payments for APCs:
One of our concerns, and a concern of many pure open-access
publishers, is to ensure that we have an effective, functioning
market in article-processing charges. If we do not have a market
and we do not have some price sensitivity for authors, there is
a concern that prices can run out of control. One example of that
is again in our evidence, where the charges we made to the Wellcome
Trust in 2012 were actually around about two thirds of the average
of what the Wellcome Trust pays. Of course, the Wellcome Trust
pays those bills, so it is very easy to spend more money when
you are spending someone else's money.
54. While the Finch Report did not attempt to
set market levels for APCs, the figures it used in its modelling
undoubtedly created a risk that publishers would see these as
a benchmark. RCUK explained in its evidence to us that in calculating
the total amount of funding that it would make available to support
Gold funded by APCs, "the average cost of an APC has been
taken from the Finch Report (estimated as £1727 plus VAT)."
The Government confirmed that RCUK's expected spend of £100m
on Gold OA over the next five years was based on the same figure.
55. We have not seen any evidence to suggest
that either the Government or RCUK have attempted to establish
whether the figures used in the Finch Report's modelling accurately
represented current APC averages. The minutes of the meeting of
the Finch working group on 22 February 2012 record that two BIS
economists who "provided assistance in economic modelling
for the Group", also "worked on the advice to Ministers
once the Group's report [was] finalised".
When BIS's own economic analysis was released in March 2013, the
Rt Hon David Willetts MP wrote to the House of Lords Science and
This analysis was done in mid 2012 prior to the publication
of the recommendations of the Finch Group and prior to the announcement
of RCUK policy. It was not intended as an evaluation of the policy
that has now been adopted but it supports the Government preference
for Gold access independently of Finch and RCUK.
56. The same economist was involved with the
Government's initial pre-Finch Report analysis of open access,
the Finch Report modelling, and the Government's subsequent acceptance
of those recommendations. This draws the independence of the Finch
Report and its economic analysis into question. We are of the
view that had the Finch working group commissioned entirely independent
economic analysis this
would have been avoided.
57. We conclude that the Finch
Report, the Government and RCUK have failed to assess adequately
the existing levels of APCs that are charged by a range of open
access journals, both within the UK and worldwide, and instead
formed a plan of expenditure based on payments to publishers that,
compared to a range of benchmarks including APCs of the largest
"pure" Gold publisher, are rather less than competitive.
58. We recommend that the
Finch working group commissions an independent report on APC pricing,
which should include average APC prices of pure Gold journals
and hybrid journals, domestically and internationally.
59. We strongly support the
recommendation of the Science and Technology Committee of the
House of Lords that the Government undertake a full cost-benefit
analysis of open access policy, including the impact on different
subject areas. This analysis must include data to reflect actual
rather than projected costs during the transition period.
Affordability of APCs for authors
and UK research organisations
60. A large number of contributors to our inquiry
argued that the block grants provided by RCUK to fund APCs would
be insufficient to facilitate the transition to APC funded publishing
at scale, and would not compensate research organisations for
the increased costs of both maintaining subscription purchasing
and funding APCs. The Head of Politics at the University of Exeter
estimated that block grant funds for a department of 35 fulltime
academics and many more post-doctoral students would cover only
a single APC for the entire department.
We asked the Minister whether this raised concerns around affordability
of APCs. He responded:
The University of Exeter runs on a budget of several
hundred million pounds. Part of what Exeter does is attract academics
who wish to publish research findings. It is reasonable to say
that part of the academic and research mission of Exeter is to
ensure that good quality research is funded. This argument that
I get a bit presents a picture of the relationship between academics
and university management that I do not recognise.
61. Though not entirely clear, this would seem
to suggest that the Government's view is that institutions must
look elsewhere in their budgets to find the funds to cover the
costs of maintaining subscriptions and paying APCs, which raises
serious issues for HEIs. Several representatives of the HE community
said that in contrast to Gold, Green was achievable and sustainable
for their institutions.
This was supported by recent research which suggested that with
APCs at £1500 (i.e. at the lower end of the range used in
the Finch Report's modelling), adopting Gold would cost UK universities
12 times the cost of adopting Green, and for the more research
intensive universities, Gold could cost 25 times as much as going
Green. Many submissions
referred to the administrative and management costs for universities
of processing, distributing and monitoring the block grant for
open access. These will need to be monitored.
62. We also received differing views on the total
opportunity cost represented by the Government's open access policy.
The Government submitted that this "will only be about one
per cent of the science budget of £4.6 billion per annum".
The Russell Group described this in different terms:
The funding for open access is being taken directly
from Research Council budgets, which could otherwise be used to
support research, doctoral training and knowledge transfer activities
that have a more direct impact on economic growth, jobs and future
quality of life. RCUK has earmarked £37 million over two
years for Gold open access: £17 million in the first year
of policy implementation and £20 million in year two. This
is equivalent to the stipends and fees for 964 doctoral students
in year one, 1,135 in year two and even more in subsequent years
as open access requirements increase. In research terms this is
three times more than EPSRC is investing in the UK Catalysis Hub
at Harwell, which will have major applications in energy, manufacturing
and healthcare. Over a five year period, RCUK has estimated it
will need to put over £100 million into Gold open access,
similar to the whole of the Government's recent announcements
on capital spending for synthetic biology research.
63. At a time when the budgets
of research organisations and HEIs are under great pressure, it
is unacceptable that the Government has issued, without public
consultation, an open access policy that will require considerable
subsidy from research budgets in order to maintain journal subscriptions
and cover APCs. Significant public investment has already been
made in institutional repositories, of which there are 120 in
the UK, and they could represent a more cost-effective and sustainable
route to full open access.
64. 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.
The shared ultimate goal of full
Gold open access
65. Within the longstanding debate on open access
policy, proponents for Green and Gold are often described as being
diametrically opposed in their views. In fact, the evidence we
have seen demonstrates considerable common ground between the
two positions. Professor Stevan Harnad, an advocate of Green,
argued that a well managed transition process using strong deposit
Induce the transition to Gold open access [...] to
allow publishing to evolve toward the obvious, optimal and inevitable
outcome: Gold open access at a fair, affordable, sustainable price,
with no inflation and no double-dipping.
66. The most comprehensive economic analysis
available supports this. A 2012 report commissioned by the UK
Open Access Implementation Group assessed the costs and benefits
of Gold for UK research institutions and found that in a fully
open access world, the net benefits of Gold would be greater than
those of Green. In their article 'Planting the green seeds
for a golden harvest', Dr Alma Swan and Professor John Houghton
If open access were adopted worldwide, the net benefits
of Gold open access would exceed those of Green open access. However,
we are not in an open access world [...] At the institutional
level, during a transitional period when subscriptions are maintained,
the cost of unilaterally adopting Green open access is much lower
than the cost of Gold open accesswith Green open access
self-archiving costing average institutions sampled around one-fifth
the amount that Gold open access might cost, and as little as
one-tenth as much for the most research intensive university.
Hence, we conclude that the most affordable and cost-effective
means of moving towards open access is through Green open access,
which can be adopted unilaterally at the funder, institutional,
sectoral and national levels at relatively little cost.
67. The key to the success or failure of the
UK's open access policy therefore is the management of the transitional
stage to full open access. The almost immediate acceptance of
the Finch Report's recommendations by the Government and RCUK
in the formation of their policies, together with the radical
change in policy direction from predominantly Green policies and
mandates towards Gold funded by APCs, has resulted in insufficient
consideration being given to this transitional period. As discussed
earlier, the understanding of how that transition might be most
effectively managed for all stakeholders has also been hampered
by the Finch Report's failure to evaluate the success of existing
UK open access policies and the vital role the Green route will
make to that transition.
68. Slowly, the messages from RCUK are changing.
There have been more than half a dozen substantive revisions to
RCUK policy and guidance since its official issue in July 2012.
In January 2013, RCUK said that "at the current time the
Gold option provides the best way of delivering immediate, non-restricted
access to research papers".
By April, its position had changed to "we have a preference
[for Gold]... but it is not an absolute preference," and
"we should not place all our bets on one particular horse".
RCUK's current position is that even if APCs are available, either
the Green or Gold route is acceptable, with authors or their institutions
free to decide.
Both routes now count towards RCUK's expected rates of compliance,
which before recognised only Gold open access.
The decision tree, originally produced by the Publishers Association
and publicly endorsed by both the Government and RCUK, therefore
does not represent RCUK's position.
69. The pro-active stance the
Government has taken in the formation of open access policy is
to be welcomed. However, we are of the view that the Government
has failed to communicate effectively that Gold open access is
the ultimate goal at the end of a transition phase. Because insufficient
attention has been given to the transitional route, the Government
has neglected the opportunity to ensure that costs are constrained,
and that institutions and research authors are convinced of the
merits of open access policy.
70. 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
71. 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
51 See Glossary Back
The Finch Report, recommendation ii Back
See Glossary Back
Ev 39 Back
The Finch Report, p 38 Back
The Finch Report, p 11 Back
Ev 50 Back
Ev 75 Back
10 July 2013) Back
10 July 2013) Back
Ev 85 Back
RCUK Policy on Open Access and Guidance para 3.14 (ii) http://www.rcuk.ac.uk/documents/documents/RCUKOpenAccessPolicy.pdf
Ev 116 and http://romeo.jiscinvolve.org/wp/2011/11/24/60-of-journals-allow-immediate-archiving-of-peer-reviewed-articles-but-it-gets-much-much-better/ Back
Ev 70 Back
The Finch Report, para 5.10 Back
Reed Elsevier gave conflicting evidence on this topic, speaking
of "crystal-clear consensus" in the subscription-publishing
community that short embargoes can undermine the sustainability
of journals, whilst also acknowledging "we have not seen
clear evidence of an undermining or cancellation of subscriptions
at this point."(Q34) Two witnesses representing PLOS and
ALPSP respectively used the results of the same survey to support
their opposing arguments for and against longer embargo periods.
Ev w82 Back
Ev w118 Back
Ev w118 Back
Ev 76 Back
See Q131 and http://poynder.blogspot.fi/2013/06/open-access-emeralds-green-starts-to.html Back
Ev 132 Back
Ev 132 Back
Richard Poynder blogspot: Open access: Springer tightens rules
on self-archiving (June 2013) http://poynder.blogspot.co.uk/2013_06_01_archive.html Back
Ev 96 Back
The Finch Report, p 72 Back
Ev 54 Back
Ev 117 Back
Ev 99 Back
Ev 39 Back
Ev 132 Back
Ev 113 Back
Swan and Houghton,'Going for Gold? The costs and benefits of Gold
Open Access for UK research institutions: further economic modelling'
Report to the UK Open Access Implementation Group (http://repository.jisc.ac.uk/610/) Back
Ev 39 Back
Ev 114 Back
Ev 77 Back
Houghton, John W. & Swan, Alma (2013) Planting the green seeds
for a golden harvest: Comments and clarifications on "Going
for Gold" D-Lib Magazine 19(1/2)http://www.dlib.org/dlib/january13/houghton/01houghton.html Back
Ev 96 and para 3.1 of RCUK's evidence to the House of Lords Science
and Technology Committee's inquiry into the Implementation of
Open Access http://www.parliament.uk/documents/lords-committees/science-technology/Openaccess/OpenAccessevidence.pdf Back
RCUK guidance, para 3 p4http://www.rcuk.ac.uk/documents/documents/RCUKOpenAccessPolicy.pdf Back
RCUK re-revised its policy in April 2013 so that Green or Gold
OA now count towards its expected rates of compliance, of 45%
in 2013/14, 53% in 2014/15 and 75% in 2017/18 Back
See Figure 2 Back