Business, Innovation and Skills CommitteeWritten evidence submitted by the British International Studies Association (BISA)
Executive Summary
The British International Studies Association (BISA) is a charitable learned society with 1000 national and international members. BISA supports the principles of open access publishing, and was encouraged by the Finch working group report. However, we are disappointed by the research council’s interpretation of the report into policy and speed of policy implementation without adequate consultation.
The model proposed by ESRC of Gold Open access, with 12-month embargo, and CC-BY creative commons licencing:
threatens the financial viability of BISA (and many other charitable learned societies);
will entail very significant costs to the taxpayer in creating new infrastructure within Higher Education Institutions to fund the costs of publishing academic research and;
fails to protect the intellectual property of UK academic research and ironically threatens the global competitiveness of the UK knowledge economy.
BISA operates on a not for profit basis reusing income arising from publishing to further our charitable objectives. We are very reliant on publishing receipts; it represents 80% of our annual revenue. We promote research excellence, and exercise a rigorous peer review process for our journal with 74% of submissions rejected.
BISA funds UK research out of our publishing incomes, supporting especially graduates and early career scholars, as well as our wider scholarly community including scholars in the developing world. A requirement of being a charity is Public benefit and through our outreach work with schools and other non-university links, we provide more accessible formats of academic research outputs via our website, newsletter and social media such as twitter, face book, LinkedIn and YouTube.
Gold Open Access for UK academics alone would not provide a sustainable income model for our journal. We would look to provide a hybrid journal and a mixed economy. Where a subscription base and traditional submission system was provided for non UK academics work and where open access is not currently a requirement. This would be managed alongside the new Open access publishing options for UK researchers. Learned Societies are going to need time to rebalance their income streams and business plans and the hybrid journal format will provide some time to plan and restructure.
Green Open Access is not without costs, peer review will still be required in many instances and repositories require administration and careful set up so work is discoverable. Embargo periods need to reflect the “slow burn” effect of social science research outputs, with 24 months being the mini period but more ideally 36 months for more theoretical or historical research outputs.
Creative commons licenses are obviously not designed with academic publishing in mind. The CC-BY is wholly unpopular across our membership, with CC-BY-NC-ND being the preferred licensing option; however some concede that they may have to accept CC-BY-NC should there be some flexibility provided. There is significant concern over the reuse of research, in particular commercial reuse and lack of control over where research is reused which seems to have been taken out of the authors hands by CC-BY. We do not see why the government should want give away UK funded IP free of charge to the world.
In regard to Article Processing Charges (APCs) universities need to be encouraged to develop equitable allocation policies across all career stages including PhD students. Only 30 universities regarded as research intensive have been provided with additional block grant funding, the remaining universities whose staff undertake research and contribute to the scholarly will have to find the funding out of other resources or only have the option to publish green open access available for their research oriented staff.
Finally, there is general concern across the UK research community that other countries especially the US and China are not going to embrace open access leaving UK Intellectual Property open to significant exploitation both in the UK and overseas. The proliferation of large “light touch” peer review e-journals like PLOS-One could significantly impact and dilute research quality and excellence, these journals offer very low APCs and do not seem to have the reputational accountability to the academic scholarly community that Learned Society publishers have.
Introduction
1. The British International Studies Association (BISA) welcomes the opportunity to respond to the Business, Innovation and Skills Select Committee’s inquiry into the UK Government’s Open Access (OA) policy and to do so, on behalf of our members. There are a number of very important issues raised and we look forward to discussing these further.
2. BISA is a UK registered charity and learned society. Our organisation has a membership of around 1000 members representing over 50 countries. Our charitable objectives are:
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3. BISA supports the principal that knowledge should be shared and our strap line is “Sharing thoughts on International Studies”. It was very encouraging to see that the working group chaired by Dame Janet Finch were able to work constructively together and to reach consensus on a way ahead. We are also pleased to see that the UK Government endorsed the findings of the Finch Working Group. We are disappointed though, with the interpretation of the Finch Working Group findings by Research Councils UK (RCUK) in particular in the formation of their Open Access policies and we await the promised HEFCE consultation with interest. The research funding body policies represents a significant shift in the current research publishing landscape. We are not sure all the matters highlighted by the Finch Group have been fully considered, especially in regard maintaining excellence and sustainability in regard to publishing for to learned societies, academics, policy makers and practitioners and publishers. The research funding policy makers appear to have focussed on Accessibility at the expense of much of the remaining recommendations of the working group.
Who are the British International Studies Association and what do we contribute to the research landscape globally and UK economy?
4. As stated in paragraph 2 above, BISA exists to promote and support international studies/relations as an academic discipline and closely related subject disciplines. We operate on a not-for-profit basis, with financial support coming through our membership fees, events, and more especially through our publishing income. Our publications, are provided free of charge for our members, and are an important member benefit and the reason many join the association especially the overseas members.
5. Learned Societies such as BISA are a key part of the scholarly landscape; they provide advice, guidance, connect academics and practitioners, provide networking opportunities, continuing professional development, conferences, dissemination of the latest scholarly research and thinking, and have a dedicated focus on their discipline. We also raise the profile of UK academia and the UK more generally, through our links and partners, collaborative working with other organisations based in the United States (International Studies Association), Japan (Japanese Association of International Relations and Europe (newly formed European International Studies Association) are current examples.
6. BISA is currently very reliant on its publishing receipts. The association publishes one Journal “Review of International Studies” which is published under contract with Cambridge University Press (a not for profit university press), the journal has a good mix of national and international manuscript submissions. This journal represents 80% of the association’s annual revenue. As an organisation, we are significantly reliant on this revenue stream for our continued sustainability, so are very concerned about the time frames proposed for Open Access introduction. The journal has a rigorous blind peer review process with 74% of submissions currently rejected, in 2011 the journal was ranked 17th out of 80 journals in the field of International Relations by Thomson Reuters. The journal is one of the top UK journals in our field and highly regarded and certainly achieving publication in it is regarded as meeting a high level of research excellence.
7. BISA is a charity but also operates like a small business contributing to the UK economy creating employment both on a permanent and temporary basis, our reserves are invested in the UK, and we use professional services such as solicitors, accountants and other professional advisors. We bring foreign exchange to the UK with our international conferences and overseas membership, for our events we hire UK hotel accommodation or university facilities contributing to the wider UK economy, we also make net VAT contributions. Any reduction in publication incomes to BISA will mean reduction in our ability to contribute to the wider UK economy as well as the scholarly research environments. This could have a significant impact on the UK economy when multiplied across the many hundreds of Learned Societies in the UK.
8. BISA also provides direct financial support to researchers such as funding through our 25 specialist study groups and workshop funding, support for PhD students at our events and in the completion of their PhDs, and travel grants and hardship funds for both national and international scholars to attend our conferences and BISA sponsored events.
9. BISA is also seen as important outside our close academic field and as part of our charitable public benefit remit. The association provides public facing easily accessible information portals through the website, newsletters and social media platforms. We also have been in more recent years reaching out to organisations such as the United Nations Association collaborating in the running of Model United Nations events for school children. BISA has been consulted by a major exam board on the updating of ‘A’ level Global Politics syllabus and in conjunction with this we are looking to provide support for teachers with teaching materials, who are mostly not specialised in the subject area. The BISA also offers free membership to ‘A’ level and undergraduate students so they have access to our academic community from early on and understand what studying our field has to offer in regard to employability and career paths.
Topic 1—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
10. “Gold” Open Access refers to the immediate, free to read (with appropriate re-use rights) publication of the Version of Record of articles. This is the final published version, following peer review, editorial administrative input, and publisher input with copyediting, typesetting, proofreading etc.
11. The BISA journal “RIS” publishes approximately 20 out of 52 manuscripts by UK academics a year, if all opted for the “Gold” route, with an APC of £2000 per manuscript, this would not quite cover the publisher costs. In addition, we also have the Editorial administrative costs to cover to ensure submissions are scrutinised properly and peer reviewed before rejection/acceptance and to ensure excellence is maintained. So if the journal had to rely on just “UK Gold” APCs alone it would be unsustainable. However, worryingly the market may demand lower APCs. As a result, BISA will have to make a choice. We can stop many, if not all, of the activities that we support in the research landscape at a significant risk of losing our member base, or the association could accept and publish many more articles, in order to maintain our journal income. The latter means that the standards of excellence and the peer review processes will have to change significantly, putting at risk the quality standard our journal has been recognised for internationally. Otherwise we can look to increasing other income streams but this is going to mean significant adjustment in our business model and take time to make those adjustments. Worryingly we may find that we just end up squeezing already tight research budgets in different ways through increased membership fees, event registration fees etc.
12. Journal Archives—There has been no mention of how learned societies cover the on-going costs of maintaining journal manuscript archives under gold or green OA, so items remain free to read and accessible for many years for historical reference, currently there is a “pay-firewall” to access articles on the JSTOR archive at what point do articles become archive and can they be charged for having been Gold OA and an APC charged? What happens to existing archive items, many universities get access to the archives as part of their subscription base so these may have to continue to be charged going forward?
13. “Green” Open Access refers to the deposit of an author’s Accepted Manuscript, the version following peer review and incorporation of the reviewers’ comments. This option does not come without costs either; the academic editorial administration of peer review has staff costs for “RIS”. The learned society employs appropriately qualified editorial administrative staff to ensure that submissions are of an appropriate subject and conform to the guidelines laid down by that journal; they also administer the peer review process. There are also the publishers costs associated with “Green OA”. Publishers have invested in supporting that process with appropriate software systems, making it as simple, streamlined and secure as possible for those reviewers. Security of such systems is critical. Reviewer details have to be kept secure and maintained, for example when a reviewer changes jobs, location or indeed their subject specialty. The embargo period will allow a “pay-firewall” for a period of time, so some of the costs of providing green open access can be recouped.
14. For Humanities and Social Science where work is slow burn, the allowable embargo periods should be extended from 12 months to 36 months ideally, but realistically 24 months as a minimum embargo period would be more acceptable. In regard to the embargo periods it seems that RCUK think “one size fits all” policy in this regard is fine and they take no account of the type of discipline and how quickly work is discovered and recognised as ground breaking or of note, and actually read. Please Note: that the concern about embargo periods is felt not solely within Learned Societies and publishers, but amongst the wider academic community as well, and it is not about maintaining surpluses it’s about covering the basic costs as a minimum. Some of the disciplines within STEM are also concerned at the proposed short embargo periods under green open access.
Topic 2—Rights of use and re-use in relation to open access research publications, including the implications of Creative Commons “CC-BY” licenses
15. Creative Commons (CC) licences were clearly not designed with academic publishing in mind. Their origins seem to be in the computer open source software design field. The majority of our Academic authors are very concerned about the liberal CC-BY licences currently supported by RCUK, and very much prefer the much less permissive CC-BY-NC-ND, or if all else fails the option of the CC-BY-NC. Many of the data sets used by humanities and social science researchers are already in the public domain so the need for a CC-BY license is less clear when this work would be less likely to be targeted for data mining. STEM subjects have the added protection of being able to Patent new medical discoveries, pharmaceuticals, engineering designs, so they still are able to protect their product. For social sciences and humanities the products are often thoughts, analysis and testing of theories, for which the only form of protection was the Copyright system.
16. Some of the positive outcomes of CC-BY are:
It allows anyone, anywhere in the world, access to the Intellectual Property (IP) created by UK researchers and funded by the UK taxpayer.
Commercial and non-commercial operations can harvest all UK generated and funded IP, repackage, rebrand and make available to others as they see fit, including developing nations.
Readers can do whatever they like with the contents of journal manuscripts, including translation, further dissemination, reanalysis, reinterpretation, republication with other articles or pieces of articles.
The author(s) only need to be acknowledged.
17. Some of the negative outcomes of CC-BY are:
UK generated and funded IP can be utilized by anyone, anywhere in the world, for their own commercial gain.
Authors lose control of who reuses their work and importantly the context in which is it reused. Author reputation and the integrity of scholarly information are at stake. The original contribution of the author could be lost in time.
Links to the original article can be lost which means that any updates, addenda, corrections are not included with the redistributed articles.
Publishers less able to defend authors rights.
Dilution of the Impact of UK research may also be a problem, if research can be reused ‘ad infinitum’ tracking reuse and the impact of the original research will be difficult if not impossible to identify/find if permissions from authors are not required.
18. It is unclear to BISA, why the UK government seeks to give away (free of charge) its intellectual property to the commercial sector and the world. Research that has been invested in by that nation’s taxpayers in this almost unilateral way. The only other current open access driver is the European Horizon 202 project, elsewhere in the world there is differing views and preferences for Open Access there appear to have been no cost benefit analysis of the affects of this. There is also a significant risk of a “brain drain” as leading UK scholars seek to move to research communities that ensure their work is valued and protected from exploitation for commercial or non-commercial purposes.
Topic 3––The costs of article processing publication charges (APCs) and the implications for research funding and for the taxpayer
19. “Gold” OA potentially provides a model that may be sustainable for Learned Societies such as BISA; the Article Processing Charges (APCs) may have to be much higher in order to cover the real costs of publication. However, more thought needs to be given by government to the funding for APCs costs at HEIs, it is not acceptable to say this should be funded out of Quality Related (QR) money while the QR pot is shrinking and research council funding is being reduced in real terms. This will be catastrophic for UK research, which is already woefully under-funded.
Universities need to be encouraged to set up clear, transparent and equitable systems for allocation of and access to APC funding—otherwise we are likely to see a move towards only funding established/proven scholars as outputs required for Research Excellence Framework 2020.
“Competition” for APC funding across disciplines and between scholars will have adverse effects on careers.
Universities need to support APC funding for all career stages, including PhD students.
The ability to pay rationing may limit access to Gold Open access.
There is also the issue of Co-authored works where the Co-author is overseas and their organisation refuses or cannot contribute to the APC costs about half of all published UK papers are with overseas co-authors.
Online journals also attract VAT which will have to be charged for APCs and is an additional hidden cost for universities.
What effect with this have on the highly successful and internationally renowned research base in the UK?
20. It is not just the costs of Article Publications Charges (APCs) that have implications for research funding and the taxpayer. Universities are spending undisclosed amounts of monies developing repositories to store their faculty’s’ publications when publishers already have well established systems in place. What happens to the content of institutional repositories when the public funding for such institutional repositories is unsustainable or the institutions merge or in this new economic realty go out of business? Is the work deposited there going to be discoverable?
21. APCs are currently subsidized by subscription income, if subscription income reduces significantly APCs would likely need to be higher, assuming additional, alternative income could not be found. In the case of Learned Societies, charging their members more for the services they provide might have to be an option that is considered. Their public facing information portals are provided free of charge and they would be very reluctant to change this.
22. It is possible that income from APCs could replace subscription income and thus Learned Societies activities could be maintained but at a slightly more limited level. BISA is working with our publisher to look at ways we can evenly and fairly transition some of our subscription income to APCs income. However, this needs to be a carefully monitored and balanced process, to avoid damage and disruption to the Learned Society research funding and scholarly publishing.
23. There seems to be no consideration of independent or researchers based in universities without central research funding and how they are to access Gold open access publishing, it seems they are going to be relegated to Green as their only option, which seems inequitable.
Topic 4––The level of “gold” open access uptake in the rest of the world versus the UK and the ability of higher education institutions to remain competitive
24. At the present time, Open Access uptake is predominantly in the UK and given the April deadline for the introduction of RCUK mandate, the UK will be isolated in providing Open Access to its tax-payer-funded Intellectual Property. In addition, most journals that also publish overseas academic research will maintain a subscription base and go “hybrid” so UK academics and universities will still have to fund subscriptions to be able to access research published in other parts of the world and it looks unlikely that the other two large producers of academic research China and the US are that willing to offer Open Access to their publicly funded IP.
25. If UK researchers publish in leading US journals or other leading overseas publications that do not offer Open Access and have very restrictive copyrights such that “green” deposit of final Version of Record may not be allowable either. There are concerns that this research will not be admissible for the Research Excellence Framework 2020 going forward as it will not be available as Open Access if that is the case, this will therefore significantly impact on excellence in certain fields where overseas journals are the top ranked.
26. It is also of concern the proliferation of Open Access journals in recent years that offer very “light touch peer review” such as PLOS One, were methodology is scrutinised but intellectual content and excellence are questionable. These journals seem to go be going the quantity route rather than quality, and their significant revenues do not appear to be going back into supporting academic research or the wider scholarly communities, as in the case of journals published by Learned Societies.
Recommendations
There needs to be flexibility by research councils and research funders for authors to choose gold or green open access routes, with limited funding flexibility needs to be provided in the systems.
Consideration needs to be made of the Learned Society contribution to the UK economy and research funding, there appears to have been no cost benefit analysis undertaken of the changes to UK academic publishing and the knock on affects on Learned Society sustainability and the UK economy of making Intellectual Property freely available by Open Access publishing, we would ask that this analysis is undertaken in detail and as soon as possible.
Embargo periods for Green open access in regard to the social sciences really needs to be a minimum for 24 months but more ideally 36 months to ensure Green OA provision costs are covered, our research is slow burn taking new work time to establish a readership.
CC-BY licenses are too permissive—there is no consideration for third party copyright restrictions, there needs to be flexibility with this and the research councils need to consider making other licensing options available ideally CC-BY-NC-ND but a minimum option of CC-BY-NC. STEM sciences have other options for protection their research outputs such as patents, social science relies on the existing copyright system for similar protection.
In regard to Article Processing Charges—there needs to be clear equitable funding allocation policies within universities across all career stages including PhDs student.
The UK government seems to be operating in isolation with their Open Access policies which are a concern in a modern globalised world. UK intellectual property, expertise and research have value and are a commodity, sold worldwide and respected. If it is now going to be available free of charge, with the research communities of the US and China reluctant to embrace Open Access at the same pace. The UK could be making an uncompetitive move driving UK academics and researchers overseas and we need the government to monitor this closely, as the ability to continue excellent research going forward could be compromised.
Flexibility needs to be exercised by research funders where to top ranked journals in certain fields are overseas and do not offer open access currently and have very restrictive copyrights if excellence is to be maintained across the UK scholarly community.
Gail Birkett
Chief Executive Officer
7 February 2013