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 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!

(1) Summary

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 ( 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.

Dr. Michael P. Taylor
Research Associate
Department of Earth Sciences
University of Bristol
Bristol BS8 1RJ

14 Responses to “My RCUK submission”

  1. Donato Pezzutto Says:

    Dear Mike Taylor,
    I stumbled upon your site in a most unlikely and roundabout manner. I am a doctor, practicing family medicine, who made an observation on the Mona Lisa painting, which lead to me writing an article, “Leonardo’s Val di Chiana Map in the Mona Lisa”, which was eventually published in the peer-reviewed journal, Cartographica, 46:3, 2011. I also have two follow-up articles awaiting the submission process. This is the extent of my publishing experience. It has been long and frustrating. In my case, after the tedium of formatting each submission to the guidelines of a publisher, either print or electronic, there is the protracted wait for the editor and referee process. With each rejection the process is repeated with the next potential publisher. This represents an enormous waste of time and effort for the author, editors and referees. In my case, after numerous rejections by art history journals, this finally ended for one article getting published in a geography journal. I am grateful that it received validation by experts who were best qualified to judge the merits of my hypothesis, but it remained in limited access for six months before it entered open access. My other two articles are in the limbo of the submission process.
    All this waiting has left me to wonder why a better way has not yet emerged. All significant scholarly writing should be made available in a timely and efficient manner to all interested readers with a minimum of barriers. The open access model has been addressing this problem and has been adopted by new and old journals. This proliferation has aggravated the problem that a new article could potentially be subject to an ever greater cycle of submission, review and rejection before being published.
    A centralized site of submission, editorial clearance, refereeing, revision and publishing, in an open access model, is a concept that is overdue. Such a site could also function as an archiving, indexing, searching and discussion forum. Any university (or association of universities or research centers) has the core human resources that would volunteer to provide content, editing, refereeing and organizing of a centralized site –many already host such sites but each limited to journals of a narrow scope. This model would be potentially revolutionary –think Wikipedia meets Facebook for scholarly articles.
    I have other ideas for this concept which I call OPUS e-journal or Open-access Peer-reviewed Universal Scholarly e-journal. What do you think?
    Sincerely, Don Pezzutto MD.

  2. Mike Taylor Says:

    Hi, Don, thanks for chipping in. Yes, the process of going through consecutive (and often contradictory) reviews before finally finding a home for an article truly is an infuriating one; and, more importantly, a stupid one. We have to find a better way.

    I doubt a single centralised site is going to be it, though. Who is going to build, maintain, staff and fund something with the capacity to handle 1.5 million articles a year? (Four thousand a day, one every 21 seconds.)

    I suspect we’re headed for a fundamental change in academic culture. Unfortunately, like most revolutions, it’s likely to be messy. PLoS is probably one part of the puzzle, arXiv is another, F1000 Research may be a third, perhaps FigShare is a fourth. I can’t see yet how it’s all going to fit together, which of those approaches will survive, and what others might arise down the line.

  3. Don Pezzutto Says:

    I agree that the status quo cannot stand and that academic culture is now going through a revolution and most revolutions are messy and unpredictable. But I am hopeful that a group of highly rational people who have a common goal will succeed. That goal is that all worthwhile scholarly contributions be made widely and free available while maintaining quality and reducing barriers.

    I am exploring the possibility of an alternative to the dominance of the commercial model and the redundancy of the submission-editor-review-resubmission cycle, by starting a centralized site. It would be beyond my wildest dreams that such a site would suddenly be handling four thousand articles a day. My site would possibly start with one or a handful of universities or institutions. If successful it would gradually include other institutions and the centralized nature would be in name and approach. Like Wikipedia, there would be one website that would represent editors, reviewers and archives spread potentially world-wide. To simplify the submission handling process, there would be a suggested style-guide, which would likely become dominant, but any commonly recognized style of presentation and citation would be accepted. To facilitate the sorting of each submission to particular editors and reviewers, submissions would be labelled by subject. Once accepted the article would be directly posted in the archive for anyone to read. The submission-to-publication would only have one cycle not counting any suggested revisions.

    Costs of a centralized site, which would operate as a non-profit umbrella entity, would be kept low. Funding would start by grants and budgets of participating institutions. These same institutions would eventually see a savings. If this scheme started to handle great numbers of submissions, these institutions would start to cut their subscriptions to certain periodical. The commercial publishers would be forced to adapt. I suppose a few prestigious ones would be left unchanged while others would fold. Some might change to fill a potential market. No one can keep up with the avalanche of papers available even in their own field of study. Periodicals that featured key articles or reviews of identified articles would be a service worth subscribing to. Electronic versions could simply post links to the archived articles. Print versions of periodicals that included full article reprints of select archive material might be commercially successful. Subscribers paying for this review, would sustain the print periodical, which in turn, would pay the centralized site a copyright fee. The whole academic publishing world could be turned on its head.

    Sincerely, D Pezzutto.

  4. Mike Taylor Says:

    Don, this sounds like a plan to me. I know that there are several broadly similar initiatives under way or planned in the sciences (e.g. arXiv, F1000 Research, the lamented Nature Precedings) but I don’t know of one in the arts or humanities, and someone’s going to built one that catches fire eventually. There’s no reason it shouldn’t be yours.

  5. […] not Research Councils UK, who recently stated “Ideally, a paper should become Open Access as soon as it is published. […]

  6. […] The Finch report and the RCUK report recently came out. These reports have taken stances concerning green and gold open access in the […]

  7. […] and makes Elsevier’s “open access” journals unacceptable venues for work funded by RCUK and other […]

  8. […] On top of that, RCUK have been criticised for “lack of clarity”: quite unfair since their policy is pretty explicit and in any case has twice been clarified on their blog. This is not a hard resource to find: anyone honestly concerned about a perceived lack of clarity could find it in ten seconds of googling. RCUK also caught criticism for lack of consultation — also unfairly, as they made a call for comments which I also responded to. […]

  9. […] 2012: draft policy released for comment. As I noted in my submission, it was excellent. It did not accept non-commercial clauses (on either Gold or Green OA), and […]

  10. […] part of the progressive erosion of RCUK’s initially excellent open-access policy, barrier-based publishers somehow got them to accept their “open-access […]

  11. […] scandal here is that when RCUK first published their draft open-access policy in March 2012, it was exemplary. Its front page summarised its key points as […]

  12. […] Green-OA embargoes are iniquitous). Not only that, but 12 months exceeds the 6 months suggested by the better, earlier version of the RCUK policy and some […]

  13. […] have wanted all embargo periods to be eliminated, or at the very least capped at six months as in the old, pre-watering-down, RCUK policy. But that was too much to hope for in the political environment that publishers have somehow […]

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