Business, Innovation and Skills CommitteeWritten evidence submitted by the Royal Society of Chemistry

The Royal Society of Chemistry (RSC) welcomes the opportunity to respond to the House of Commons Business, Innovation and Skills Committee inquiry into the Government’s Open Access policy.

The RSC is the largest organisation in Europe for advancing the chemical sciences. Supported by a network of 47,000 members worldwide and an internationally acclaimed publishing business, its activities span education and training, conferences and science policy, and the promotion of the chemical sciences to the public. This document represents the views of the RSC. The RSC has a duty under its Royal Charter “to serve the public interest” by acting in an independent advisory capacity, and it is in this spirit that this submission is made.

Summary of Recommendations

1. The RSC supports the development of any fully sustainable publishing environment for researchers, which maximises dissemination of knowledge.

2. Noting the caveat above on sustainability, the RSC is fully supportive of open access publishing. On this, we are actively engaged with the community, as exemplified by our “Gold for Gold” initiative which offered over £1m of open access credit to UK research institutes in 2012, with a further £1m of credit offered in 2013.

3. Government policy should be based on the evidence, data and considered recommendations from the Working Group on Expanding Access to Published Research Findings chaired by Dame Janet Finch.

4. We acknowledge the positive actions by RCUK in setting up block grants for UK institutes, and supporting Gold open access as the long term and favoured model for sustainability.

5. The RSC acknowledges that during a transition period, there will be a mixed Gold/Green open access environment.

6. We are however concerned that the findings of the Finch Group Report, as endorsed by Government, have not been implemented by RCUK in full. Specifically, there has been considerable confusion around how UK researchers should publish their work when no funding for Gold open access fees is available. The Finch Group recommendation suggests Green open access, with embargo periods (of 12/24 months) whereas RCUK communications are unclear and suggest shorter 6/12 month embargos. Recent developments suggest some movement on RCUK position; clarity is essential in this matter.

7. We encourage recognition that each subject discipline is individual. Green embargos should not be reduced arbitrarily until the system breaks and the subscriptions upon which green open access fully relies are cancelled. Experimenting in this way has the potential to be highly detrimental to sustaining high quality publishing for the advancement of science.

8. Consideration should be given to the global impact of any policy or proposal. Science knows no boundaries, and science publishing is also a global venture. Open access for UK content will certainly showcase UK research output, however one must acknowledge that open access provides equal reader benefits for all nations, and all researchers worldwide.

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;

9. RSC welcomed the evidence, data and considered recommendations from the Working Group on Expanding Access to Published Research Findings chaired by Dame Janet Finch1 which provided a thorough evaluation of enhancing access to research content. We acknowledge the depth of research involved, with all relevant stakeholders reaching agreement. We were delighted to see that the UK Government were fully supportive of the findings of the report (the sole exception being the recommendation on VAT).

10. The RSC fully supports objectives to ensure that the outputs from research activity are made as widely available as possible. This is fully aligned to our Royal Charter objective to advance the chemical sciences through the dissemination of chemical knowledge2

11. The RSC supports any and all sustainable models of access. We have, for some years, embedded flexibility in our publishing model to meet the needs of the scientific community, funders and those interested in accessing our journal content.

12. The highest standards of publishing must be adhered to with regard to publishing content under an open access environment. This can only be achieved through the professional management of the publishing process, from submission through peer review to archiving. RSC content satisfies the fundamental pillars of scholarly publishing, namely:

Certification (validation of quality and integrity)

Registration (recognition of achievement)

Accessibility (unparalleled online access, worldwide)

Archiving (reliable perpetual accessibility)

Discoverability (industry leading services to identify content)

13. It is important that consumers of research content are confident that the article they read is the final “version of record”. This typically resides on the publisher’s content delivery platform and is widely accessible. Note: post-publication changes, such as addendum or corrigendum, are not always tagged to versions held elsewhere, eg at institutional or subject repositories.

14. In terms of open access, the RSC supports “gold” open access, and encourages funding to be made available to support authors during the transition from reader to author-side payments.

15. The RSC has offered a hybrid “gold” open access option for all our journals since 2006. This enables the final “article of record” to be made available to all, immediately, via our website and without any barriers to access. Authors who do not wish to take the gold option can elect to deposit their accepted manuscript in a non-commercial repository after an embargo period of 12 months (the “green” open access option).

16. Gold open access is defined as follows:

“Publication costs are covered by an “Article Publication Fee” (APC) being paid by authors upon acceptance. The final “article of record” is made available to all, immediately, without any barriers to access”

17. Gold open access is widely accepted as the only long term sustainable open access model. It has the advantage of aligning payments to support manuscript handing, peer review, copy editing, typesetting and dissemination of content, with the objective of free access to users. Supporting Gold or hybrid Gold open access may be a cost effective solution to enhance public access to research content. This is also the quickest route to providing public access to research articles derived from publicly funded research.

18. Green open access is defined as follows:

“Research papers are made available via a subject or institutional repository. An embargo period is often involved, typically 6–24 months (12 months for articles published in journals published by RSC Publishing). No payment is made—publishers seek to recoup their investment through traditional sales during the embargo period”

19. Green open access is only sustainable if the embargo period is sufficiently long to avoid erosion of the very subscriptions the model relies upon to exist. Green open access in itself does not make any financial contribution towards publishing activities. As such, it may only be relevant as a transitional option.

20. The Publisher’s Association prepared the following flow chart to provide clarity on the Finch Group Report recommendations. However, real confusion exists in relation to RCUK’s interpretation of “box A”. Specifically, for the physical sciences, is the embargo period 12 months as recommended by the Finch Group?

Figure 1

FLOWCHART OF FINCH GROUP DECISION TREE

21. The RSC acknowledges that during a transition period, there will be a mixed gold/green open access environment.

22. Setting appropriate (green) embargo periods are critical to ensuring a sustainable publishing environment. Evidence exists of journals which have lost significant subscriptions [revenue] from adopting too short embargos; for example, the journal Annals of Mathematics reverted to a subscription model after experiencing significant loss in subscriptions following an open access experiment whereby content was made available freely.

23. Green Open Access absolutely relies upon institutes retaining their journal subscriptions, to support the editorial activities that the research community values.

24. It is generally acknowledged that embargo periods should reflect the variation of “usage half life” of different journals and disciplines. One size does not “fit all”, even within the physical sciences.

25. To date, a minority of articles is available via open access (and those that are, are often difficult to find and access). Regardless of embargo periods, this means libraries currently retain all their subscriptions in order to access the significant majority of content. Until the ratio of open access/non-open access content shifts, no-one can accurately predict library subscription behaviour.

26. There is however an acknowledged and understandable expectation that “over-short” embargo periods will encourage institutes to cancel subscriptions. A brief study3 jointly commissioned by the Publisher’s Association and ALPSP (Association of Learned and Professional Society Publishers) suggests that almost half of librarians (44%) would cancel subscriptions to journals where most of the content is available freely after 6 months.

27. In deciding whether to cancel a subscription, librarians can facilitate cost effective access to embargoed papers via pay per view, inter-library loans, or low cost article rental. Embargoed papers are thus still accessible to the community.

28. Experimenting with short embargo periods for journals until subscriptions are cancelled, cannot be undone. Experience shows that libraries, with very restricted budgets, do not (or simply cannot) (re)introduce subscriptions after cancellation.

29. Pressure to apply a 6 month embargo on chemistry journals is experimenting with the future of the community’s journals. We recommend RCUK and other funding agencies adopt the Finch Group findings, as endorsed by Government, and apply a minimum 12 month embargo on all (chemistry) journals. Even this would be an experiment, but one we feel is less likely to yield catastrophic consequences.

Topic 2—Rights of use and re-use in relation to open access research publications, including the implications of Creative Commons “CC-BY” licenses

30. The CC-BY attribution licence allows anyone access to the published content. The attribution licence allows full rework, reuse and distribution which have implications for ownership and the commercial use of research funded by the UK Government and funding agencies. The RSC supports these attributes, though we have heard concerns from researchers regarding the commercialisation of their own work, without due recompense.

31. Derivative articles are not necessarily tied to the original work, and only the original author(s) need be acknowledged. This has implications for [lack of] recognition of the original journal brand and authority, which provides an indication of quality and quality assurance.

32. Authors will also lose any control of who uses their work, and in what way it is used. This has potential implications for author reputation if work is republished out of context. This has additional consequences when an author’s work is used in this way for [other’s] commercial gain.

33. There is potential loss of income for both the author and publisher with the loss of secondary and derivative income streams. For the RSC, this is not considered significant. However, we wish to highlight this issue as it is seen as significant for many other society publishers.

Topic 3—The costs of article processing charges (APCs) and the implications for research funding and for the taxpayer;

34. Article Processing Fees (APC’s) vary by publisher, journal and article type. The RSC currently charges £1,000 for a communication style paper, £1,600 for a research paper, and £2,500 for a review (the vast majority of papers fall into the first two categories). Discounts (of 15%) are available to RSC members, and subscribers to RSC Gold. With almost all UK institutes subscribing to RSC Gold, UK authors will generally benefit from the discounted rate, such that a communication paper would cost £850.

35. Supporting Gold open access may be a cost effective solution to enhance public access to research content providing that sufficient funds are made available by funding agencies to support authors during the transition from reader to author-side payments.

36. RSC does not wish authors to be discriminated against, if they are unable to pay author-side fees. Authors unable to pay an APC will be entitled to publish without charge under the traditional subscription model, with the additional option of posting their accepted manuscript on a Green open access repository after 12 months.

37. Should the number of “reader-side payment” articles reduce, as a result of Open Access uptake, journal subscription rates will be adjusted downwards. The RSC is committed not to “double dip”, ie we will not include papers which carry APCs in our subscription calculations, and thus receiving both author-side and reader-side payments. To date, uptake of Open Access is so insignificant (<0.2% of papers, against a trend of +20% content growth) that no subscription adjustments have been justified to date.

38. While an estimated 20% of revenue entering publishing is derived from corporate organisations, their publishing output is many factors lower than this. If funding is to move towards author-side payment, academia will in effect be paying more, to subsidise free access at corporate organisations.

39. Like many society publishers, the RSC invests any surplus from publishing activities back into the science. If the sustainability of publishing is adversely affected, this would further impact science as a whole, with a particular impact on UK science.

40. The current subscription model incentivises publishers to focus on quality over quantity (low quality journals are less likely to be subscribed to). In contrast, an author-side open access model, incentivises quantity over quality. This has led to “predatory” publishers4 who seek to publish all submissions to benefit from receiving the author fee (note: these publishers are in the extreme minority, with most publishers understanding the need to retain quality standards for long term success).

41. Clarity is needed about how funding and payment of article processing charges (APCs) will be managed in practice. This is of particular interest for multi-author/international papers, and the complexities this may introduce.

42. The consequences of making content freely available, particularly with respect to potential piracy and unauthorised onward distribution should be considered carefully. The long-term sustainability of the open access-system must be preserved.

43. Licensing options should be clearly defined, to differentiate what content may be openly (publicly) shared, and what may not.

44. Policies should acknowledge the inherent costs involved in refereeing, copy-editing, typesetting, hosting, maintaining, preserving and making available scholarly journal content. Those who invest in these processes should be entitled to recover their costs to ensure sustainability of the systems for future generations.

45. We wish to highlight our “Gold for Gold” initiative, in which we distributed over £1m of credit to UK universities (in 2012 and repeated again in 2013) to publish gold open access articles in RSC journals. This was warmly received by the community, and allowed researchers and administrators to evaluate how to implement open access publishing.

Topic 4—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.

46. The scale of OA publishing is difficult to estimate accurately. There are an estimated 8,600 open access Journals listed in the Directory of open access Journals5. An estimated 7.7% of scientific, technical and medical articles are published via an open access model6.

47. Publishers who operate a hybrid (optional) model typically cite less than 1% uptake, though this is seen to be increasing slowly year on year.

48. Researchers in the chemical sciences are currently amongst the lowest adopters (proponents) of open access. By contrast, researchers in the life sciences are much more supportive of open access7.

49. Consideration should be given to the international nature of science publishing. Providing public access in one country will also provide unfettered access to researchers and other users throughout the world. Economic benefits are therefore unilateral, and will therefore be no different for the UK, North America, China or any other nation.

50. As a UK based publisher 94% of current subscriptions-based revenue is currently derived from overseas. Our authors are also principally international, with approximately 90% based overseas. During 2010 and 2011, only 0.2% of RSC authors opted to make their papers open access.

51. China as a nation publishes the largest number of papers within the chemical sciences community, and those from India are expected to grow significantly over the next decade. Sustainable business models will need to recognise the shift of research output to developing countries.

14 February 2013