My RCUK submission
March 30, 2012
Tonight, I sent my submission to Research Councils UK in response to their call for comments on the recently issued docment RCUK Proposed Policy on Access to Research Outputs. I am now posting my comments publicly. I urge you all once more, please send your own comments to email@example.com with the subject “Open Access Feedback”. They do not need to be as long and detailed as mine: I am sure they would welcome short-and-sweet comments!
I enthusiastically welcome the proposed changes in the the RCUK Policy on Access to Research Outputs, recognising that this policy’s more timely availability of access to research and the more liberal licensing terms will be good for research, for industry and for society in general. Some minor harm to the businesses of subscription-based publishers is a regrettable possible side-effect, but that harm — if it is real, which has not been demonstrated — is greatly outweighed by the benefits that will arise from the adoption of the new access policy.
I will comment on each of the changes individually.
(2) What do the Research Councils mean by Open Access?
“The existing policy will be clarified by specifically stating that Open Access includes unrestricted use of manual and automated text and data mining tools. Also, that it allows unrestricted re-use of content with proper attribution – as defined by the Creative Commons CC-BY licence.”
It is very heartening to see this clarification, especially as certain publishers seem to be using the phrase “open access” extremely loosely to refer to any articles to which any kind of access is provided. The definition used in the RCUK policy is compatible with that of the Budapest Initiative which first defined the term in 2002.
Particularly welcome is the clarification that “open access” may not exclude commercial use — a clause that is sometimes adopted by authors or journals that hope to gain financially by forcing commercial organisations into a royalty agreement, but which almost invariably simply prevents the research from being used.
(3) How is a Scholarly Research Paper made Open Access?
One of the two methods by which a paper can be made Open Access is given as follows:
“The version of the published paper as accepted for publication … is archived and made accessible in an online repository … access may be restricted to comply with an embargo period imposed by the publisher.”
This wording could be improved by clarifying that the deposit itself is to be made as soon as the paper is accepted, but with an embargo period before the deposited manuscript is made open access. Most modern repositories support such “dark deposits”, with the open-access date specified at deposit time so that no further human intervention is required six months later when the embargo expires.
This approach would have several advantages: first, deposits would be made when the project is fresh in the author’s mind. Second, article metadata (though not full text) would be available from acceptance time, speeding recognition of the paper and application of the research. Third, potential readers who discover metadata in advance of embargo expiry will be able to obtain copies direct from authors.
(4) What do journals need to do to be compliant with Research Council policy on Open Access?
“The existing RCUK policy on access to research outputs does not state specific criteria to be satisfied for a journal to be recognised by the Research Councils as ‘Open Access Policy Compliant’. The revised policy therefore introduces such criteria.”
This is an important and very necessary change, in light of the variety of ways the term “open access” has been abused.
Although the Directory of Open Access Journals (http://www.doaj.org/) lists over 7000 “open access” journals, specific licensing terms are specified only for a very small proportion of these, so that users cannot easily tell what rights they have regarding articles from most listed journals. A more explicit list of True Open Access journals will be helpful, especially to text/data mining projects. I hope that RCUK will either establish such a list, or (better still) work with DOAJ to add an RCUK-compliance field to its database.
(5) What Research Outputs will be covered by Research Council Policy on Access to Research Outputs and where should they be published?
No comments other than agreement.
(6) When should a paper become Open Access?
“In future, Research Councils will no longer be willing to support publisher embargoes of longer than six [...] months from the date of publication, depending on the Research Council.” [for councils other than AHRC and ESRC]
This is definitely an important step in the right direction.
However, I question whether any embargo period at all is acceptable for research funded by the public. I understand that the six-month period is a compromise in hope of appeasing publishers, but the core point here is that the Research Councils are not beholden to publishers but to the British public. Their goal is to obtain the best value in return for taxpayer investment in research, not to perpetuate the business model of old-school publishers.
I would therefore support a no-embargo rule, whereby final manuscripts could be posted to repositories as soon as they are accepted (i.e. even before publication). Publishers that are unhappy with this arrangement would be free not to accept manuscripts submitted under these terms, and to seek submissions from elsewhere.
(7) How is Open Access paid for?
“Research Council grant funding may be used to support payment of Article Processing Charges to publishers.”
This principle is a good one. However, there are practical difficulties in estimating at the beginning of a project how much money to request for publication fees when it is not known how many papers will proceed from a project, what journals they will be submitted to, or whether they will be published during or after the lifetime of the project.
For this reason, rather than including publication fees in grants, I would favour the establishment of a separate pot of funds dedicated to supporting publication of RCUK-funded research whether during or after any given project.
(8) Acknowledgement of funding sources and access to the underlying research materials
“Research papers [must include] a statement on how the underlying research materials — such as data, samples or models — can be accessed.”
Requiring this to be explicitly stated is a valuable addition which is cheap to comply with.
But I am disappointed to find so large a loophole as “The underlying research materials do not necessarily have to be made Open Access”. While understanding the need for some datasets to remain private (e.g. patient records and other personal medical data), I would prefer to see such exceptions listed, with a clear expectation that datasets not in one of the exception categories should be made open access. The motivation for this change is the same as that for the whole policy: that free availability of data, like research, accelerates both further research and commercial applications, to the benefit of the public.
(9) Implementation and compliance
No comments other than agreement.