Business, Innovation and Skills CommitteeWritten evidence submitted by HistoryUK(HE)

Executive Summary

1. HistoryUK welcomes in principle the move to Open Access to journal based research.

2. The policy direction last autumn (heavily favouring Gold OA for all disciplines) has caused major concerns.

3. Journal publications significantly enhance the quality of UK Historical Research. History articles are much greater in length, have longer “half-lives”, and do not become obsolete. They are a different endeavour intellectually and commercially from STEM subject journals. OA policy needs to recognise this.

4. Academic Freedom, Cost, and the position of Early Career Researchers all mean that the Gold route would generate serious problems for historical research.

5. The Gold route in particular also looks likely to have negative impacts on the international profile of UK Historical Research, taking it out of step with the rest of the world.

6. The difficulties associated with gold mean that green open access is likely the best model for historical research, and across much of the Humanities and Social Sciences (HSS).

7. For Green to be adopted, it must be viable. This means embargos sufficient to sustain the current rich culture of journal publication. In the case of historical publications, longer embargos are appropriate given the longer half-lives and “shelf-lives” of historical research.

8. We are unconvinced of that the benefits of CCBY outweigh the costs for HSS in terms of the loss of protection of intellectual property, the dangers associated with allowing derivative works in sensitive areas of research, and the possible increased costs or embargos publishers may feel compensate for the transfer of a commercial asset to a third party.

9. We welcome the recent clarifications of policy and the recognition of the continued role for Green OA. We urge that the government and funding councils recognise the advantages of the Green model of Open Access for humanities and social sciences, and adopt policies on embargos and CCBY accordingly for those disciplines.

Full Submission

1. HistoryUK is an organisation which collectively represents 87 subscribing Departments of History located within HEIs across the UK. It is not a learned society but rather a body which seeks to represent collectively the views of a major discipline within the humanities. As scholars our instincts are naturally to share the fruits of our labours with the largest possible audience—academic and non-academic. Given this we entirely accept the spirit of the government’s move towards Open Access.

2. Journals currently play an important and distinct role in the production of historical research (and constituted 36% of History submissions in RAE2008).1 They delineate subfields, allow new approaches to emerge, provide an important foundation for monographs and books (which remain the “flagship” of historical research and at times reach very wide audiences), and through peer-review provide valuable feedback enhancing the quality of research. Such feedback is often particularly valuable for early career researchers. Moreover, beyond peer review, the production, editing, checking, and other services associated with publishers add value to the finished article. Journals project the UK’s excellence in HSS research on a global stage. Most History journal articles have not only along “half lives”, but also a long “shelf life”. Unlike articles in STEM subjects, they remain relevant for very long periods.

3. Before addressing the subjects requested by the committee, we must highlight our concern at the pace with which the OA agenda has been taken up by the funding councils, particularly RCUK. We also note that much less is in the public domain from HEFCE, and since Quality Research funding outweighs income from the funding councils, this has also caused considerable concern amongst departments. Given the time lags involved in research, decisions about research and publication in the next REF cycle are already being taken—either in ignorance of the shifting policy agenda, or (equally, perhaps more damaging) through attempts to “second” guess the final outcome. For example, although the policy position regarding “Green” Open Access has been helpfully clarified (particularly by BIS), there remains a widespread presumption across the sector that gold alone is favoured, and decisions about research are already being formulated on that basis. There is an urgent need for clarity and for an early acknowledgement that research currently in preparation will not fall-foul of rules not yet finalised.

4. As a result, HistoryUK has a range of concerns at the speed with the Open Access Agenda has been implemented, particularly by the funding councils (RCUK and HEFCE), often on a limited evidence base. Very few studies have been undertaken of publication patterns in Humanities and Social Sciences. Thus there is a real danger that a model of Open Access appropriate for STEM subjects but inappropriate to the pattern of HSS subjects will be imposed in ways which undermine the production and curtail the impact of HSS research, and hinder the reproduction and recruitment of outstanding researchers.

Problems with Gold

5. These problems are particularly associated with the “gold” model of Open Access, which has dominated the policy agenda. We welcome the recent clarifications by RCUK and BIS before Lord Krebs’ committee recognising the validity of the green route. Nonetheless, it is necessary to re-iterate some of the problems the imposition of a purely gold route would pose for historians and others in the humanities.

6. The Costs and Practicalities of Gold: Many of these issues are generated by the “producer pays” model embodied in the gold route to publication. It is often pointed out that the likely publication costs generated by a wholesale shift to gold constitute only a small fraction of the research budget. This may be true in aggregate, but the costs of producing HSS research are far lower (since they do not require same level of capital as STEM subjects).2 The vast majority of HSS research is conducted without funding from RCUK, and relies rather on QR income often supplemented by smaller grants from funders such as the British Academy or, in Scotland, the Carnegie Fund. Some is conducted without even these supports. As a result, the new cost introduced by any expectation that gold be the sole route to publication would be disproportionately heavy for HSS research.

7. This burden will be accentuated by the fact that the longer lengths and turnaround times of HSS journals, and their lower frequency than equivalent science publications makes it likely that Article Processing Charges will be higher. Data on the average cost of APCs is hard to come by. As the Royal Historical Society pointed out in their submission to Lord Kreb’s enquiry, costs in history journals could reach far exceed the £1,750 predicted in the Finch report, reaching £3,000 or even £7,000.3 The likely costs to departments and institutions depend on the rate of publication. The cost gold would be a considerable and unnecessary burden, or alternatively (and more likely) would constrain patterns of publication.

8. There also further practical problems that arise from the gold route. Historical research tends to be “lumpy” with long lead-ins culminating in a spate of publications. Some scholars (and clusters of scholars) may also publish more heavily in journals than others due to the particular requirements of their sub-fields. In these circumstances the gold route creates potential accountancy problems (will sufficient funds be available in a given financial year). This will pose a particular challenge for small and even medium departments.

9. Institutional Constraints on Academic Freedom. Academic freedom is a principle fundamental to academic life. The independence of researchers is often integral to their role in civil society, as well to their ability to produce the best (and most beneficial) research. The constraints imposed gold model they undermine the principle of academic freedom by placing institutional publications committees between researchers and their audiences. It is too soon to see how institutions will administer such funds and what considerations they bring to bear. Again it is not obvious that institutions can judge the likely value of research and the attempt to “pick winners” may prove counter-productive. The decision to only fund 3* and 4* research has already created considerable (and unproductive) additional burdens as institutions attempt to second guess REF results, and it is quite clear to anyone with experiences of these processes that this second tier of “inexpert peer-review” is crude and imperfect compared. The problem will be compounded if such processes become a barrier to publication, rather than a barrier to submission in REF exercises. Were OA incorporated into the REF in a crude way—or with an overemphasis on gold—the logic of the system would encourage HEIs to target funds at research considered “certain” to achieve 3* or (perhaps only) 4* marks. Far from receiving access to the full range of Historical research, the effect would be that the public received only a full slice—the slice perceived most likely to impress REF sub-panels. The problem would be further compounded for collaborative research and co-authored articles which would have to clear two separate sub-committees before submission.

10. Local History. There is no reason to suppose that research that makes the highest scholarly impact is the same research that is of most value to the public (REF 2014 implicitly acknowledges this since only 3* and 4* research attract funding, but impact may arise from research which receives only 2* status). Local History Societies across the UK for example publish journals which frequently attract academic articles, and cement close collaborations with academic departments. Yet these articles may not receive funding under the systems proposed at present (and local history societies are unlikely to have the infrastructure to adopt gold OA, but may have fewer objections to green), creating a perverse incentive for historians to disengage from their localities. Such local collaborations are also vital for a range of industries, not least tourism and the heritage sector.

11. Early Career Researchers, Retired and Independent Scholars. Often debates about Open Access have not considered fully the career paths of researchers. It is clearly in the national interest to ensure that the HEI sector is able to produce successive cadres of excellent researchers, and the only criteria ought to be merit. There are important differences between Early Career Researchers in HSS subjects, including history, and those in sciences. In particular, whereas science tends to be conducted by large teams incorporating ECRs, in history (and across HSS) individual research is the norm. This accentuates the role of journal publications. These are particularly important in the careers of early researchers, helping them build their reputations globally, often with the benefit of feedback through peer-review. Hence publication, and not least journal publication, inevitably becomes a factor in discussions on recruitment. Imposing gold open access requirements, particularly in the REF, would incentivise institutions to employ those who had the means to “pay to publish”, introducing a plutocratic element into a process that ought to be purely meritocratic. Even those on temporary incorporating research contracts (common in early career) might well find themselves cut off from institutional publication funds since institutions would have few incentives to publish their work.

12. Equally, a good deal of valuable historical work is published by independent scholars or retired academics. In the case of retired academics, their publications represent the continued returns of a life time of public investment in their work. As a discipline in which expertise is cumulative, often scholars produce their best work late in life. Gold risks marginalising such scholarship, assuming publishing models based on subscriptions remain commercially viable.

13. The combination of points 7–12 will be that a move to gold will completely undermine the “complex eco-system” which sustains the production HSS research in its full range and diversity, with negative repercussions for both HEIs and societies.

International Issues and the Competitiveness of the UK Sector

14. Open Access is developing at different paces across the globe (with the US particularly looking much slower to adopt OA), and the different forms of OA are being adopted. For example, the Irish government, in contrast to the UK, has favoured a centralised version of the green route.4 The model incorporated in the EU’s Horizon 2020 programme also remains unclear.

15. Overseas publication is a major outlet for HSS research, not least history. Historical research in the UK is global in subject matter. The global scope of our research itself enhances the benefits of UK-based historical research to society, and also enhances the status of UK research, and the UK itself. This global engagement is enriched by the ability of UK historians to engage with scholars across the globe through publication. An insistence on OA where no OA option is available will necessarily diminish this international engagement and status of UK historical research. This will be compounded if UK researchers are also excluded from other OA options available globally.

16. Another element of the difficulties presented by gold, particularly a gold requirement in the REF, is the introduction of a disincentive to the recruitment of international researchers. The strength of UK history, and indeed of the sector as a whole, depends on the recruitment of the very best researchers. An OA Gold requirement in the REF would create a strong barrier to such recruitment, even from countries favouring other forms of OA. Equally, OA publication requirements that diverge from those in other jurisdictions potentially disrupts collaborative research endeavours.

17. All of this suggests that the international dimensions under consideration by the committee suggest again a need to re-think the wisdom of too great or exclusive an emphasis on gold. Furthermore, it is essential that even OA Green (particularly in REF exercises) take full account of the real benefits to the UK of a high international profile. A failure to do so risks perversely punishing scholars and disciplines which are truely “world-class” and likely to maintain high rates of international publication.

The Merits of Green

18. Most of these problems can be overcome if a viable version of Green is recognised as a legitimate channel for the publication of research, particularly HSS research. The Finch Report, and certainly Janet Finch herself in subsequent comments, has argued that Green should remain an element in any OA policy. We welcome the recent acknowledgement of this by BIS (not least in the Minister’s evidence to Lord Krebs).

19. The Finch Report preferred gold for a number of reasons, but a major consideration was the speed with which research became available to wider academic and non-academic audiences. This is clearly a major consideration in fast moving STEM subjects where papers have short “shelf-lives”, and are rapidly superseded. However this is one area in which HSS research is fundamentally different. HSS journals tend to have much longer “half-lives” (in other words take longer to reach their audiences). More importantly HSS research is not superseded in the same way as in STEM subjects. Old articles remain relevant long after their publication—often indefinitely. The embargos necessary to the Green Route to Open Access are not, therefore, beset by the same problems in HSS subject that inform the desire for gold in STEM subjects.

20. In this context, incorporating a viable version of Green into the policy mix (and particularly for REF exercises) presents a range of advantages given the real problems presented by Gold for History, and HSS more generally.

(a)Cost: Although Green is not cost free (institutional repositories after all require funding) these costs are far lower than the cost of APCs, and funding is largely in place already. Funding for gold can then be targeted at research where instant availability is likely to generate the greatest benefits.

(b)Academic Freedom. Green preserves a far greater measure of (but not complete) academic freedom since it allows researchers greater scope to publish in the most appropriate outlets for their research (so long as those outlets allow a compliant form of green) without the intervention of their institutions.

(c)The “Complex Eco-System”. Green involves far less of an upheaval in the current system of publication, and thus retains the benefits of full and thorough peer review (uncomplicated by incentives to publish).

(d)Reproducing Researchers. Peer review and the promotion provided by journal publication, it has already been pointed out, is of particular benefit to early career researchers, building reputations and projecting their research on a global stage (in a way which would not happen if ECRs could only publish in institutional repositories- as would likely happen under Gold). It would ensure that access to research careers was based purely on merit, rather than on the ability to pay APCs.

(e)Internationalisation: While not entirely alleviating the problems of UK researchers publishing overseas or of recruiting the best researchers globally, the Green route would at least alleviate these problems by ensuring the UK does not become out of step with the rest of the world. Even so, barriers to international publication would remain—particularly in the United States (which houses many of the most prestigious journal). Even under Green the continued risks of isolating UK research would have to be taken into account in framing policy—particularly at the level of the funding councils.

(f)Sustainability: Finally, at present it is unclear that commercially viable versions of gold are available for HSS subjects that preserve the real benefits provided by journal publication. While not wishing to deter innovation, a continued role for Green over the medium to long term (possibly indefinitely) is vital to the sustainability of History as a discipline.

21. For these reasons we entirely endorse the judgement of the Royal Historical Society in its submission to Lord Krebb’s enquiry that Green is the only viable route for History and many other HSS subjects.5

Embargos:

22. If Green is to be given a chance, then it is necessary for embargo periods to be set which recognise the long half-lives and shelf-lives of history journals. As an organisation recognising departments, we do not have the evidence to hand to judge the exact embargo, but for Green to be given a serious chance, embargos must be realistic, and the transition gradual.

23. While to date the uptake of Green has been slow, this is because the pressures for adoption have, until recently, been weak. The strong policy direction now given to Open Access, if allowance is made for Green as a viable route, would doubtless transform the situation. Failure to give Green a chance risks jeopardising the production of research.

24. With this in mind we welcome Prof. Rick Rylance of RCUK’s clarification of its position to Lord Kreb’s committee: that the policy of 12 month embargos for HSS subjects was an aspiration after five years, and would necessarily be subject to review. Even so, we still note that this is a seemingly more stringent requirement than the 24 months endorsed by BIS in response to the Finch Report and in the decision tree produced by the Publisher’s Association. Even so, a statement in December by editors of history journals declared 36 months to be “the shortest possible period that would still protect our viability”.6 Given this, if Green is to be made to work, the policy must be implemented with sufficient latitude to maintain the “complex eco-system” described in the Finch report.

25. For research which has a very long shelf life, it surely serves the public interest to wait 24 (or longer) to secure permanent access to that research thereafter where the alternative is to risk undermining the production of that research in the first place, or that the research produced is of a lesser quality.

CCBY Licences

26. We have no objection to the use of the full range of Creative Commons Licenses to endure that research made available on an Open Access basis remains available, and to provide some defences for publishers and researchers.

27. However, given that (as is now increasingly acknowledged), we are entering a transition phase, there are good grounds for a less prescriptive approach in the precise kinds of licenses adopted. In particular, we would argue that there are good reasons to think that CCBY NC ND Licences are often more appropriate in HSS subjects like History. While in STEM subjects the patent system provides additional defences of intellectual property, in HSS this is not the case. Greater protection is therefore often in both the researchers’ preference and in the public interest.

28. The preference for CCBY originates in part from the supposed potential for the commercial exploitation of research data through data mining and other practices. The extent of these opportunities has yet to be demonstrated beyond a narrow range of fields. The potential to produce derivative works through CCBY Licences also creates concerns for a subject like history which often tackles highly politicised or otherwise sensitive topics. There may be good reasons to defend research tackling historical topics from misrepresentation through the additional protections of CCBY NC ND.

29. There are also good reasons to balance the as yet unsubstantiated economic advantages of CCBY licences against the possible additional barriers to Open Access they create. Many publishers may view these potential commercial advantages as an asset (which CCBY transfers to third parties) and take them into account either in setting APCs, or in deciding on the embargos for Green. A restrictive policy on CCBY may effectively create additional barriers to the implementation of OA.

Recommendations for Action

30. We re-iterate our desire to see Historical research reach the widest possible audience. Our concerns centre on the need to ensure that a model of OA is not implemented which impedes the production of HSS research, and in our judgement Green is the best and most viable means to achieve this in our discipline. A viable version of Green would also ameliorate (but not eliminate) the international problems created by OA.

31. Until recently, the OA agenda has been driven too heavily by the concerns of the STEM subjects. If it is to be made to work, it must be implemented with sensitivity to the specific patterns of journal publication typifying different disciplines and clusters of disciplines. This is entirely in line with existing policy and structures, whether REF sub-panels and the funding councils.

32. The incorporation of OA into any REF exercise possesses particular problems. The issues are different from those surrounding on RCUK grants since the REF seeks to reach a summative assessment of the quality of all research and the research environment retrospectively. Hence we ask that HEFCE hold a full and open-minded consultation.

33. On this basis we recommend that, in acknowledgement of the profound difficulties attending the gold route to open access for HSS subjects, a viable Green open access capable of sustaining the “complex ecosystem” constituted by journals in our field should be incorporated government policy and HEFCE and RCUK should conduct full and open minded consultations on this basis with due acknowledgement of disciplinary differences, the need to maintain academic freedom, and the international repercussions of any policy.

7 February 2013