Business, Innovation and Skills CommitteeWritten evidence submitted by The Russell Group
Summary
The Russell Group is committed to open access, but the sector, and in particular research-intensive universities, face a number of challenges in the implementation of open access policy.
In addition, we remain concerned about the overall business case for the Government’s open access (OA) policy that is predominantly focused on a relatively rapid move to Gold OA.
Where funding is required to deliver the Government’s OA policies this must be additional money, not re-purposed research funds.
The Green route is a simple, genuine and cost effective way of delivering OA. Embargo periods still need to be agreed and could be phased with the intention to deliver shorter periods over time.
Greater freedom could be given on CC-BY licensing requirements to help keep costs down and ensure researchers aren’t overly restricted in where they can publish.
OA policy is effectively being extended far beyond research funded by the Research Councils, without any additional support being made available to cover these costs. We estimate RCUK funding will only cover Gold OA costs for around 10% of total Russell Group publications.
It is not clear how moving rapidly to Gold OA will improve our international standing which has been built up over many decades; indeed, implementation of OA policy could be detrimental to our standing and restrict academic freedoms.
1. Introduction
1.1 We welcome the opportunity to contribute to this inquiry into the Government’s open access policy. As well as submitting this short note, we would be happy to contribute oral evidence if required. We would also like to draw the Committee’s attention to written evidence the Russell Group submitted to the recent House of Lords inquiry into open access publishing, which covers some related issues.
1.2 The purpose of the Russell Group is to provide thought leadership and strategic direction for the 24 major research-intensive universities of the UK; we aim to ensure that policy development in a wide range of issues relating to higher education is underpinned by a robust evidence base and a commitment to civic responsibility, improving life chances, raising aspirations and contributing to economic prosperity and innovation.
2. Russell Group Position on Open Access
2.1 Many Russell Group universities are themselves lead players in moves towards open access, in particular through the development of repositories and other initiatives to ensure the widest possible dissemination and discussion of research.
2.2 The Russell Group remains committed to open access, but we still have concerns over the robustness of the overall business case for the Government policy. In addition, there are significant challenges and risks that need to be addressed, as well as opportunities to be realised in implementing this policy. The academic and publishing sectors are going through a period of substantial change even without Government intervention on open access. It is important that policy and its implementation do not damage the UK’s standing for world-class research and do not disadvantage or otherwise burden universities with unreasonable costs or other requirements.
2.3 Gold OA—where authors pay an Article Processing Charge (APC) up front to support immediate open access of publications—is not the only way to facilitate open access. The Green model—where materials are available in repositories—is perfectly valid, simple and cost-effective.
2.4 We are monitoring the implementation of Government policy carefully and have had a number of meetings with RCUK and BIS to discuss challenges with them. We will also be taking an active interest in OA developments for future rounds of REF with HEFCE.
2.5 We are grateful for the clarification RCUK has been able to provide on its publication targets, OA compliance and other matters, and its willingness to review policy implementation in 2014. We welcome that RCUK describes the implementation of its OA policy as a journey over at least five years rather than being a “day 1” requirement. This will allow much needed breathing space for universities to make further steps towards open access. Ultimately, moves in the direction of OA will probably take longer than five years.
2.6 We now look forward to confirmation of the position RCUK will take as it finalises its guidance notes on implementing OA policy. We hope that the final guidelines will reflect our concerns and give universities significant flexibility in how they use their block grant to achieve open access.
3. The Economic Case for Open Access Publishing
3.1 We are concerned about the overall business case for the Government’s OA policy that is focused predominantly on Gold OA.
3.2 First, the funding for OA is being taken directly from Research Council budgets, which could otherwise be used to support research, doctoral training and knowledge transfer activities that have a more direct impact on economic growth, jobs and future quality of life. RCUK has earmarked £37 million over two years for Gold OA: £17 million in the first year of policy implementation and £20 million in year two. This is equivalent to the stipends and fees for 964 doctoral students in year one, 1,135 in year two and even more in subsequent years as OA requirements increase. In research terms this is three times more than EPSRC is investing in the UK Catalysis Hub at Harwell, which will have major applications in energy, manufacturing and healthcare. Over a five year period, RCUK has estimated it will need to put over £100 million into Gold OA, similar to the whole of the Government’s recent announcements on capital spending for synthetic biology research.
3.3 Where funding is required to deliver the Government’s OA policies this must be additional, “new” money, not re-purposed research funds. If this is not possible, other alternative solutions may be required, for example allowing universities more freedom on how the block grant can be used and/or altering OA target levels to create a phased approach to OA over a longer time period.
3.4 Second, the market for Gold OA is still very much in its infancy and we are concerned the UK will end up paying twice for research papers: via both APCs and subscriptions. Even if the UK moves strongly in favour of Gold OA, we will still continue paying subscription charges to access the journals our researchers need. The UK produces approximately 6% of the world’s published research articles and so our expectation is that this is the level of reduction in overall subscription costs the UK might be able to achieve. Research Libraries UK (RLUK) has estimated UK universities currently pay around £150 million in subscription charges so a 6% reduction amounts, at best, to a saving of £9 million a year. At the same time our international competitors will be able to access our best research papers for free.
3.5 Third, it is not clear why moving swiftly towards Gold OA will necessarily benefit the UK economy through the increased exploitation of research outputs. Businesses are already able to access UK research via libraries, their own journal subscriptions and, increasingly, though direct engagement with university research groups and individual academics. For commercial exploitation purposes it is usually important for businesses to have access to research well before it is published so that appropriate intellectual property protection can be put in place prior to commercialisation. This means it is the on-going relationships between business and universities that need to be fostered, alongside universities’ own commercialisation activities, as the priority for delivering economic returns.
3.6 It should also be noted that Gold OA will give free access to the UK’s academic research output to businesses competing with the UK from overseas. A more focused solution, providing UK businesses with a degree of competitive advantage, would be to deliver a national licence arrangement for organisations based in the UK.
4. Green Open Access
4.1 Green OA was recognised as being important in the Finch Review, and is also accepted as part of the OA landscape by BIS and RCUK—although they all favour Gold. A quarter of Research Council funded papers are expected to be made open access through Green routes in five years time in the RCUK model and three quarters through Gold.
4.2 Green OA can include self-archiving in institutional or discipline-based repositories and/or archiving in repositories operated by publishers. Publishers may then allow free access to deposited material after an embargo period. Institutional repositories are already searchable by current web engines in an effective way.
4.3 The Green route is a simple, genuine and cost effective way of delivering OA, but there is no additional RCUK support for Green OA even though it is a part of their overall OA model. We recognise that the Government and RCUK have a stated preference for Gold OA, but we would like to see a wider acceptance and financial support for Green OA routes as a valid option. The Finch Review recommended an additional £10 million should be made available for repository enhancements.
4.4 In some disciplines, including physics and economics, it is already fairly standard practice for working versions of papers to be circulated on the web or shared through open repositories for comment and further input. It is possible these activities could be put at risk by some approaches to OA publication.
4.5 Green OA with reasonable embargo periods is an important element in the mix of options for all researchers and in particular for some disciplines in arts, humanities and social sciences. We have discussed possibilities of a phased approach to embargo periods with RCUK and hope that this will be considered as they develop their new guidance material. We support the Finch Group recommendations that would allow 12–24 month embargoes in certain circumstances. We recognise that six months has already become the standard practice in medical sciences, and we should not pull back from that, but nor should Government seek to impose a six to 12 month model on disciplines that could be damaged by such a move. Embargoes longer than 24 months may also be needed in some cases.
4.6 Green OA will remain an important option for publications with small numbers of research papers. Moving to Gold OA could mean disproportionately high APCs for researchers and thus additional burden on universities. Mandatory Gold, or even Green with very short embargo periods, could also seriously undermine the viability of monograph and book publishing as well as some distinguished UK journals.
5. CC-BY licences
5.1 OA costs are likely to be higher than modelled for the Finch Review because of the requirement for Gold OA to be accompanied by a CC-BY (creative commons by attribution) licence allowing commercial and all other forms of re-use and modification. Some journals have already increased their APCs where this licence is available, others are unlikely to offer the highest level CC-BY licence as an option and this will restrict journal choice for researchers.
5.2 We recognise that a CC-BY licence removes doubt about how research papers and their content may be reused, but we wish to see the licensing requirement widened to include other CC-BY non-commercial and share-alike licences. This will help to keep OA costs down and will ensure researchers are not unduly restricted in where they can publish. A CC-BY-NC option also clearly allows the original creator of the IP to retain control during any subsequent commercial use. Again, there could be a phased approach over a number of years to encourage CC-BY in the long-term.
6. Cost of Delivering Gold Open Access
6.1 RCUK will be providing a block grant to universities to accelerate Gold OA publishing in the UK from 1 April 2013. In Year 1, RCUK has estimated that its funding will cover Gold OA costs for around 7,500 research papers produced by Russell Group universities. We estimate that this is around 10% of all publications produced each year by the Russell Group—funded from all sources, not just those deriving from research funded by the Research Councils.
6.2 Just looking at Research Council funded research, our universities have started to estimate whether the allocations indicated for them will be sufficient to meet RCUK’s targets. So far, the allocations appear to be an under-estimate, with universities reporting potential funding gaps of between £0.4 million and >£1.4 million in Year 1. At least in part this is because these universities publish more papers than estimated by the Research Councils.
6.3 The calculations are complicated by unknowns such as future APCs that may be higher with CC-BY licences and because our world-class universities typically aim to publish in the most highly regarded journals, which are likely to charge higher APCs. Much world-leading research is also done in collaboration with other researchers in other institutions—often overseas—and/or is funded from multiple sources including business, charities and other parts of Government. It is almost impossible to disaggregate research outputs to determine if papers include an element of Research Council funded activity or not—and especially if the original research was done many years ago or elsewhere.
6.4 We have discussed this with RCUK and have made it clear the draft guideline for their OA policy to apply to all research funded “wholly or in part” by the Research Councils is impractical.
6.5 A wider concern is that OA policy is effectively being extended far beyond research funded by the Research Councils, without any additional support being made available to cover these costs. This is likely to be a particular challenge in some arts, humanities and social science subjects where the Research Councils provide only a small proportion of research funding. As new research project proposals are drawn up with other funders it may be possible to include additional lines to cover their proportion of Gold OA costs, but it is not possible to do this retrospectively. It means that universities could find themselves burdened with funding the balance of OA costs from their own reserves for many years to come while the outputs from existing research projects and programmes are published.
6.6 In addition to the direct APC element, there will also be significant administrative and management costs for universities of establishing and operating a new OA model. The costs are recurring and will need to be covered for the full period of policy implementation. We have recommended to RCUK that universities should be free to use the block grant to cover reasonable costs associated with OA, rather than being overly prescriptive. This additional freedom would allow universities to be flexible in how they administer the block grant, deliver culture change for the future (eg with training), provide oversight of publishing strategies and explore other options that can lead to more open access in the future.
6.7 The additional requirements of meeting the Governments OA policy come at a time when universities are making major strides to improve operating efficiency as a result of the Wakeham Review. In delivering OA, universities must not now be penalised in the Wakeham efficiency calculations that the Research Councils are using to encourage the reduction of indirect costs.
7. Competitiveness
7.1 The UK’s leading universities are already highly competitive and rank among the best in the world on most indicators. The UK is in a unique position for a medium-sized economy having such a high proportion of world-class universities and researchers and regularly punching well above our weight in terms of research publications rated as excellent internationally.
7.2 It is not clear how moving rapidly to Gold OA will improve this international standing that has been built up over many decades. Indeed, open access policy implementation may create unintended behavioural consequences—for example in publishing strategies among academics or in the perceived attractiveness of the UK to overseas researchers—which could start to undermine our reputation.
7.3 There may, for example, be an impact on the international standing of UK universities if there is an overall reduction in the number of research papers submitted to the most highly-rated journals because of cost or licence restrictions or if the proportion of international researchers in UK institutions is affected.
7.4 Limited funding and strict requirements for Gold OA are likely to mean that cost rather than academic relevance will often have to become the deciding factor on where to publish, and with a block grant there may also be a timing effect on publications—a peak being created artificially as annual grants are released to institutions. These changes will put the UK at a disadvantage internationally and may make the UK less attractive as a location for the best international researchers as most will not face such restrictions from research funders in their home countries.
7.5 In short, there is a real concern that funding limitations will restrict academic freedom and that OA policy will be seen as another layer of Government regulation on the sector.
7.6 Our universities will not flourish if they are over-regulated. Academic freedom and university autonomy are essential components of our universities’ success.
7 February 2013