Business, Innovation and Skills CommitteeWritten evidence submitted by The Academy of Social Sciences

Executive Summary

The Academy of Social Sciences counts 46 of the social science Learned Societies and more than 850 of the country’s most distinguished social scientists amongst its membership. Both groups have expressed a range of concerns over the implementation of Open Access publishing.

The Academy is in favour of the principle that the results of publicly-funded research should be more readily available to researchers outside the academic sector and to the public at large. However, we are concerned that that there has been insufficient reflection on the potential impacts on the ecosystem of academic publishing and Learned Societies’ business models and work of a move to mandated Open Access. The Academy’s main concern is that the Finch Group’s recommendation for an ordered transition may not be being implemented.

RCUK has said informally that embargoes of 24 months will be accommodated in the transition phase. We would welcome formal confirmation of this. Our view is that, in the absence of firm evidence on the impact(s) of embargoes of different lengths on sustainability and excellence in the research and publishing infrastructure, it is unwise to commit to scenarios where longer embargoes are ruled out. Until we actually know how either 1-year or 2-year embargoes work in relation to sustainability and excellence, the best course is to go into the transitional period, mindful of the potential risks of a rapid move towards 12-month embargoes, and to use the time to collect robust evidence of the consequences of embargo restrictions on consumer behaviour, stakeholder incomes and the value-adding activities of Learned Societies.

The nature of the “managed transition” to OA is crucial to its eventual success, and to support from within the HSS community. The Academy’s vision of this transition rests on the following features:

That the transition period is entered into openly, with an emphasis on robust evidence-gathering to assess properly what works to preserve the UK’s highly-rated research infrastructure and prestige publications.

That the transition period is not rushed or truncated; that sufficient resources are available for adaptation to new business models for publishing compatible with OA.

That excellence and international standing are carefully monitored in the implementation process, with the option of delaying or reframing processes should risk and/or damage to research or publishing systems be observed.

That stakeholders, researchers, funders and Government communicate effectively and respect one another’s concerns, using proper evidence to adjudicate between competing claims.

That there is no imposition of a “one-size-fits-all” solution to the issues of implementation of OA as it is already clear that different academic disciplines and different publishers and varied HEIs will each experience distinctive impacts in the move towards Open Access publishing.

Submission

1.1 The Academy of Social Sciences counts 46 of the social science Learned Societies and more than 850 of the country’s most distinguished social scientists amongst its membership. Both groups have expressed a range of concerns over the implementation of Open Access publishing.

1.2 The Academy is in favour of the principle that the results of publicly-funded research should be more readily available to researchers outside the academic sector and to the public at large. However, we are concerned that that there has been insufficient reflection on the potential impacts on the ecosystem of academic publishing and Learned Societies’ business models and work of a move to mandated Open Access. These issues were amongst those aired at a major 2-day conference which the Academy staged at the end of November 2012 (http://www.acss.org.uk/OAConfNov2012.htm). The Academy’s main concern is that the Finch Group’s recommendation for an ordered transition may not be being implemented. It will take some time to establish what works to sustain publication rates, academic excellence and scholarly activity in an Open Access world. The Academy is anxious that in the rush to full implementation, perceived risks to the research infrastructure are being downgraded without adequate evidence.

1.3 The Finch Report’s emphasis on managing change over time has at times seemed in danger of being sidelined in the discussion over attaining OA in the UK.1 The Academy’s questioning of the way in which the Report’s recommendations are being implemented, echoes issues raised by Lords in the Science and Technology Committee in Dame Janet Finch’s oral evidence session on 15^th January 2013. The Academy made a written submission to the House of Lords Science and Technology Committee inquiry into Open Access publishing in January this year.

1.4 The Academy is responding to the BIS Committee’s invitation to provide written submissions to its inquiry into the Government’s Open Access policy, using the topic headings indicated by the Committee.

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

2.1 The Academy has comments related to the management of the transition to Open Access publishing. We view a rapid transition to “Gold” Open Access as potentially hindering the sustainability of publishing in our disciplines, and that of the Learned Societies themselves. These typically use surpluses generated from publishing to support wider scholarly work. The “Green” Open Access model allows journal articles to continue to be supported by subscription, enabling income from subscription to be preserved through embargo periods.

2.2 “Gold” OA is the preferred option of RCUK’s published policy. Arguably, the immediate free access to material provided by the “Gold” model is less of a prize for HSS than STEM, as articles in our disciplines remain cited over longer periods.

2.3 The Finch Group, and subsequently BIS, have recommended a “Green” route which allows 12–24 month embargo periods, with discretion for journals to set their own limits; RCUK has recommended a maximum embargo period of 12 months for ESRC- and AHRC- funded work, with work from scientific Research Councils complying with an embargo period of 6 months. The disparity between RCUK and Finch/BIS regarding embargoes has been a cause of controversy. There has been no formal statement from RCUK indicating a willingness to accommodate embargoes of over 1 year in length. The opinion of the Academy, and reflected in cautionary comments in the Finch Report, is behind a transitional period, during which embargoes of up to 24 months to persist, in a “mixed economy” of journals featuring “Gold” and “Green” OA articles. RCUK has said informally that embargoes of 24 months will be accommodated in the transition phase. We would welcome formal confirmation of this. Within the Academy these longer embargoes have widespread support. There is some evidence that 12 month embargoes may lead to libraries cancelling journal subscriptions. Our view is that, in the absence of firm evidence on the impact(s) of embargoes of different lengths on sustainability and excellence in the research and publishing infrastructure, it is unwise to commit to scenarios where longer embargoes are ruled out. Until we actually know how either 1-year or 2-year embargoes work in relation to sustainability and excellence, the best course is to go into the transitional period, mindful of the potential risks of a rapid move towards 12-month embargoes, and to use the time to collect robust evidence of the consequences of embargo restrictions on consumer behaviour, stakeholder incomes and the value-adding activities of Learned Societies.

2.4 The suggestion that funding for APCs should come at least in part from existing research funds, spreads limited funds further, and overlooks the fact that publishing is often by individual academics, who are not covered by Research Council grants, but who are nevertheless “publicly funded” as research-active employees of HEIs in receipt of block grants. This is particularly the case in our community. The question as to how APCs work in a situation where research premises are publicly funded, but a particular study is funded through a charity or trust, remains unanswered, and may require additional guidance. How researchers working outside HEIs are to cover the costs of APCs is also unclear.

2.5 The “Green” OA route is not cost-free: although articles deposited in repositories can be published without APCs, there is a cost to maintaining repositories and getting articles into publications from them. There is also a cost to obtaining and maintaining “discoverability” through navigation, linking and interactive services provided by on-line publication. How exactly these costs are to be covered once subscription income reduces remains unclear.

2.6 There are distinctive types of publication and “grey data”, central to the practice of social science and humanities research which are apparently underprivileged by a “Gold” route to OA where funding for comes from “fresh” money via institutions. Monographs, collected essays, discussion papers, working papers and reviews of conference proceedings, are types of non-journal output which may suffer due to funding pressures under OA publishing, which is to be partially funded through existing research money.

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

3.1 RCUK has advised that all publicly-funded research should be licensed as CC-BY—which permits immediate commercial and derivative use of published papers’ content. More recently, RCUK has said that CC-BY may only apply to “Gold” route publications. The more restrictive CC-BY-NC-ND licences—which require authors’ permission for re-use of material—would apply to the “Green” route. Our membership seeks written reassurance from RCUK that this will be the case. HSS researchers prioritise protection of permission to cite, as interpretation and context of data and extracts are of central importance.

3.2 In HSS disciplines, citation from literary sources and re-publishing of copyrighted images are commonplace—there has been discussion concerning the capacity of CC-BY to accommodate permissions from third party sources. Clarification on this issue would be welcomed.

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

4.1 Several issues relating to APCs were raised at the Academy’s recent conference, including:

the fact that there is a funding gap between the cost of the number of papers currently published and the money proposed to be provided for APCs by RCUK;

concern over the OA mandate being imposed on research output for the 2020 REF;

the lack of transparency over how institutions (Universities and sometimes publishers) will allocate APCs in practice.

This last point is crucial: if Universities hold the funding for publication under OA, and that funding is less than in the current system, there will have to be an allocation process—and it is not at all clear how this will operate. Even if overall funding should remain the same, there are still concerns that allocation would be managed by higher education managers, rather than editors and peers. Who decides, using what criteria, whether academic work is worthy of publication or not? If Universities want the highest return on investment in publication, the OA system may struggle to accommodate early career output, when the attractions of citations in premier journals by established names are likely to be strong. Furthermore for REF 2020 there are worries that “Gold” and “Green” options for publication may assume a hierarchical order, with “Gold” publications potentially seen as the most prestigious, and Green options viewed as second rate. Were these fears to be confirmed, there would be implications for the overall ranking and rating of UK academic departments and HEIs. Again, evidence is required to make an assured call.

4.2 The Academy is aware of various approaches adopted by HEIs responding to the new funding structures: allocating funding on a first-come-first-serve basis and postponing the decision on what to do when the money runs out until forced to do so; transferring the responsibility wholesale to journal publishers for them to decide; acknowledging that rationing will take place, but uncertain about how exactly it will occur. None of these variants is reassuring for academic freedom to publish innovative or adventurous work, nor for overall transparency. We could see a new system being introduced without sufficient time to explore sustainable options: potentially a “real-time” experiment with maximum exposure to risk.

4.3 As already covered in paragraph 2.5 above, there is anxiety because APCs are to be funded partly from existing resources There may not be enough money to sustain current volumes of articles using APCs. Again, we refer the Committee to the unresolved issues around how APCs are to be calculated where University-employed staff publish charitably-funded research findings. As HEFCE policy on OA remains to be finalised, exactly how (and how much) research will be mandated to be OA-published through QR funding is uncertain. This affects particularly those scholars who publish without Research Council project funding.

4.4 The above concerns are brought into focus in Finch et al’s comment that:

“Current funding regimes focus on providing access to research literature through libraries, via payments for subscription-based journals. Arrangements to meet the costs of APCs for open access publishing tend to be ad hoc and unsystematic. In the period of transition there are bound to be additional costs as both systems exist side by side.” (Report of the Working Group on Expanding Access to Published Research findings—Executive Summary (2012):6)

How precisely the extra costs are to be met remains uncertain. There is even uncertainty over the eventual level at which APCs will settle: while the Finch Report’s mid-range assumptions suggested a charge of £1,750, others have gone higher, and it has been noted that HEIs have an interest in driving APC costs down, both to maximise return on investment and sustain the volume of publications. These uncertainties undermine confidence in an Open Access future.

4.5 Open Access could therefore represent an additional cost to the UK taxpayer, in order to cover APCs and “Green” routes to publication alongside. Against any such cost must be weighed the benefit of increased access to research-based publications. It is not clear that the cost-benefit analysis has been adequately carried out.

4.6 We have argued elsewhere (notably in our response to the House of Lords Science and Technology Committee inquiry last month) that a potential cost of rapid transition to “Gold” OA is the sustainability of Learned Societies. These Societies typically fund wide-ranging scholarly activity through surpluses generated by publication via subscription. The Academy contends that this wider scholarly work has a value to the taxpayer as well as to Societies’ membership. By providing grant funding for research projects that may not receive backing from Research Councils, the Societies contribute to the diversity and innovation of research; by supporting postgraduate students and early-career researchers they help ensure that there is a healthy “pipeline” of well-qualified researchers to feed into institutional vitality and publishing markets; they advocate for competitive UK research at home and internationally, forging links with researchers in other countries and markets. They are therefore at the heart of putting research into practice by building communities of knowledge and communicating their findings. The introduction of APCs and mandated “Gold” OA must therefore be part of a landscape which permits a measured pace of change, allowing the work of Learned Societies to be sustained through a managed process of adaptation.

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

5.1 Many of the prestigious social science journals are hosted outside the UK, with no compelling case to comply with UK policies. They may not wish to comply with “Green” route embargos of only one or two years; they may not alter subscription rates whilst offering “Gold” OA. The USA, as the largest research and publishing market in the world, is a key player. The Americans have not yet committed to OA, and as the dominant force in global social science publishing, and with US researchers subscribing in large numbers to UK social science journals, their decisions about OA will have decisive impact here. At the Academy’s November conference, Dr Felice Levine, who directs the American Educational Research Association, suggested that the US government “will not quite follow the Finch report”: it will support the move towards the principle of OA, but without prescribing how it should come about. In this scenario, US Learned Societies may have time to develop and test various business models on the way to full implementation, an opportunity potentially being denied their UK counterparts.

5.2 The UK produces 6% of published research worldwide. The rest of the world is at various stages on the route to adopting OA, and with some diversity of preference for “Gold” or “Green” routes. This means that there is going to be a “shake-out” period of uncertain length, during which OA practices will spread unevenly, and interim costs will vary country-by-country. It is a climate of great uncertainty as even the strongest proponents of OA acknowledge. Whilst the benefits of OA are largely undisputed, the costs are both contested and unevenly distributed within and between countries.

5.3 The UK’s early lead on OA leaves a number of questions unresolved:

If articles are co-authored by academics from different countries, not all of whom are OA-compliant, what proportion of the cost of publication is covered via APCs in the “Gold” route?

If it is cheaper to publish under existing rules than under OA, how will we guard against UK research becoming less attractive to publish than that from non-compliant countries?

If OA becomes the preferred standard for high-income countries, what happens to the market for research by authors in emerging economies?

As with the other areas of concerns outlined above, the OA model offers many opportunities for the future of UK research, but it is uncertain how the possible negative consequences can be avoided, given the rapid pace of change.

5.4 Last month the Academy recommended that the House of Lords Science and Technology Committee undertake a more detailed inquiry into OA, taking on board the widespread concerns over implementation in our constituency. We have not yet heard whether this recommendation has been taken up. Given the complex issues raised by OA, and the uncertainty over the magnitude and distribution of costs attached to implementation, we urge the Government to attend to our desire for a managed transition over time, thus ensuring that excellence and innovation are preserved in all academic disciplines, and that the current ecosystem of research and publishing is adapted to meet change, rather than damaged by it.

5.5 The nature of the “managed transition” to OA is crucial to its eventual success, and to support from within the HSS community. The Academy’s vision of this transition rests on the following features:

That the transition period is entered into openly, with an emphasis on robust evidence-gathering to assess properly what works to preserve the UK’s highly-rated research infrastructure and prestige publications.

That the transition period is not rushed or truncated; that sufficient resources are available for adaptation to new business models for publishing compatible with OA.

That excellence and international standing are carefully monitored in the implementation process, with the option of delaying or reframing processes should risk and/or damage to research or publishing systems be observed.

That stakeholders, researchers, funders and Government communicate effectively and respect one another’s concerns, using proper evidence to adjudicate between competing claims.

That there is no imposition of a “one-size-fits-all” solution to the issues of implementation of OA as it is already clear that different academic disciplines and different publishers and varied HEIs will each experience distinctive impacts in the move towards Open Access publishing.

7 February 2013