Business, Innovation and Skills CommitteeZoological Society of London (ZSL)
The Zoological Society of London ZSL welcomes the opportunity to respond to the Business, Innovation and Skills Select Committee’s inquiry into the UK Government’s Open Access (OA) policy. In order to improve public access to research the Government intends to make all academic articles by UK-funded researchers open access (OA). As a publisher of STEM journals we in principle support this approach. However, for the future of Learned Societies, such as ours, it is critical that a balance is struck between widening access and maintaining sustainable publishing businesses.
1. Contribution of Learned Societies to UK Research
As a Learned Society publisher we promote and support academic research within the fields of conservation science and zoology. Our contributions to these disciplines extend beyond publishing, and include conferences, workshops, science and conservation awards, and free, public lectures. These activities, funded by publications income, allow us to connect researchers and disseminate science to academics and the public. Learned Societies represent the “hallmark of excellence” within their discipline, and their important contribution is recognised both in the UK and internationally. OA will result in reduced income to Learned Societies, and there is no other UK funding source to replace the services that Learned Societies provide.
2. Embargo Periods and Green OA
A viable Green OA option should available where there are insufficient funds to cover APCs. Given the long life of papers published in our journals, a 12 month embargo on the accepted version is the minimum acceptable period if we are to avoid undue risk. The RCUK’s policy on Green OA based on a short embargo (6 months) would threaten the viability of our journals and the wider activities funded by our publishing income, all of which contribute significantly to academic life in the UK.
3. Rights of Use and Re-use in Relation to Open Access Research Publications, including the Implications of Creative Commons “CC-BY” Licences
A review of Creative Commons-based licensing policy is urgently required to ensure that licences provide flexibility for authors. Work that is available under a CC-BY copyright license can be remixed, re-purposed and re-used by anybody, including for commercial purposes, so long as it is attributed. CC-BY license effectively removes the key rights of authors to control the use of their intellectual property. Allowing for commercial use without author consent is has the potential to undermine investment in research projects, particularly where there is a business development interest, and this is obstructive to commercial funding of UK science. CC-BY-NA (non-commercial) or CC-BY-NC-ND (non-commercial, no derivatives) should be considered and authors need to consulted in order that the appropriate licensing arrangements are available.
4. The Costs of Article Processing Charges (APCs) and the Implications for Research Funding and for the Taxpayer
APC may need to be much higher than anticipated if the aim is to cover the real costs of publication. Competition may demand lower APCs, which would result in Learned Societies forfeiting their broader non-publishing activities or being pressured to publish many more papers in order to increase income, which could compromise integrity of peer-review and the journal quality.
The introduction of mandatory APCs systems has the potential to threaten academic freedom and researchers’ careers. With limited APC funds, institutions will need to manage competition for funding and will be pressured to judge work by standards other than peer review. Institutional Publication Committees will ration funds in line with pressures for Research Excellence Framework (REF) and impact, which means that a great deal of potentially valuable work will be unfunded.
The requirement for APCs increases inequality both across and within institutions, by linking prestige in research and publishing to the capacity to pay APCs, rather than academic quality. UK journals will also be under pressure to select research according to whether APCs can be paid, instead of simply taking the best quality research. More resources need to be committed to cover not just the cost of APCs but also to develop systems to for payment of APCs.
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
Giving away the UK’s tax-payer funded intellectual property will mean that other countries benefit at the UK’s expense. Until OA is mandated in other countries, UK researchers will want to access to research published in other parts of the world, and they will still have to purchase this content, so the cost to UK research persists.
I hope that the Committee will engage with all stakeholders with regard to these important issues.
Linda DaVolls
Head of Scientific Publishing
7 February 2013