Business, Innovation and Skills CommitteeSupplementary written evidence submitted by PLOS

At the invitation of the BIS Committee, I would like to provide additional clarification and evidence about two issues raised at the oral enquiry on Tuesday 16 April.

A. Disagreements in interpretation of the impact of Open Access on the scholarly communications industry (including publishers and scholarly societies) and the availability of high quality data.

1. The committee noted that there are differing interpretations of the available evidence from different stakeholders about the transition to Open Access, including (a) the impact of embargoes on subscription revenues, (b) the appropriate pricing of APCs and additional costs to publishers and societies during any transition, (c) the cost of archiving and ability to achieve OA via repositories and (d) potential differences between STEM and AHSS. This is due to a number of factors but a primary one is the quality, clarity and completeness of the available evidence in this space. Many arguments put forward in the written and oral evidence to the committee depend are based on supposition or on qualitative survey evidence, which is often based on marketing methodology rather than high quality scientific design that provides more rigorous and comparable quantitative evidence.

2. There is a need for high quality monitoring of the transition and the development of reliable and trusted sources of data for all players to rely on. The efforts of Research Councils UK and the Open Access Implementation Group to define and develop monitoring systems that will allow us to manage the transition require support and a commitment to providing high quality data (including financial) from all stakeholders.

B. Licensing and the use of the Creative Commons Attribution license (CC BY)

3. It was noted in evidence that many submissions argue against the CC BY license. We would note that those submissions that advocated the use of CC BY uniformly came from organizations that have deep experience of its implementation and have fully embraced it. Those positions that were opposed came from organizations with limited experience of Creative Commons licensing or which are seeking to protect real or imagined revenue streams based on closed content.

4. Particularly noteworthy is the submission from the Association for Learning Technology (ALT). Its journal, Research in Learning and Teaching, moved to an Open Access basis with a CC BY license in 2012 and in ALT’s evidence it describes the concerns about CC BY as “very much overplayed”. I was involved in advising ALT on the transition in 2009–10. At that time I was arguing that CC BY was the right license but ALT had concerns, similar to those expressed today by many scholarly societies in their submissions, about loss of revenue and, in particular risks to the integrity of work. That ALT is very happy with the decision to adopt CC BY and their experience of its use in practice after nearly 18 months should be both instructive and encouraging for those that have concerns.

5. Nonetheless, we accept that researchers have significant concerns around commercial re-use and the integrity of their work. We further accept that we have yet not convinced all our research and society colleagues that CC BY is the most effective license for maximizing the impact of publicly funded research. We agree that it is critical that authors retain the rights to their work (eg copyright) and have the ability to make informed choices about how they wish their work to be used. As long as those rights are retained by the research community those of us who argue for CC BY can then work to provide further evidence of its utility, confident that our colleagues will be able to make the choice to release work under freer terms when and if they are convinced.

6. To achieve this we must separate the desire of some incumbent publishers to retain exclusive commercial or distribution rights from the rights of authors to choose how their work is used. Some publishers are claiming they support authors’ rights to choose while at the same time acting to retain exclusive commercial rights over published work. To support future innovation we must ensure that authors retain the right to authorize any commercial or derivative re-uses when they choose to do so. We must not cede exclusive and non-recoverable rights to commercial organizations whose interests are not necessarily aligned with those of researchers, funders, or the users of research. PLOS, along with other pure Open Access publishers uses a “license to publish” approach where authors retain copyright and grant the publisher only non-exclusive rights to publish with no exclusive rights.

Cameron Neylon
Advocacy Director, PLOS

23 April 2013

Prepared 9th September 2013