Re: RCUK policy on open access

From: Stevan Harnad <>
Date: Tue, 28 Jun 2005 16:59:58 +0100

These are some comments on the summary of the RCUK Proposed Policy.

        RCUK Announces Proposed Position on Access to Research Outputs

The proposal is *excellent* overall, correcting all three of the
flaws of the NIH Policy:

     (1) requiring instead of requesting self-archiving,
     (2) immediate self-archiving instead of delayed self-archiving,
     (3) favouring institutional self-archiving instead of insisting only
         on central self-archiving

There are just a few suggestions for optimising the RCUK policy, below.

The most important one concerns correcting a potential opt-out loophole
that the current wording inadvertently encourages (based on an incorrect
assumption about the modest cost of creating and maintaining an
institutional repository).

There are also a few little mix-ups about copyright, preservation, and
OA journal publishing costs.

But overall, the proposed RCUK policy is splendid!

Comments on:

> Research Councils will require for all grants awarded from 1 October
> 2005 that, subject to copyright and licensing arrangements, a copy
> of any resultant published journal articles or conference proceedings
> should be deposited in an appropriate e-print repository (either
> institutional or subject-based) wherever such a repository is
> available to the award-holder.

An excellent, very welcome policy, but it would be helpful if the
copyright remark were coupled with an explicit link to the Directory of
Journal Policies on self-archiving:

This would make it clear that for the 92% of journals that have already
given their green light to author self-archiving there is no copyright
issue any more. At most, there is a possible copyright issue only for
8% of journals today.

> Deposit should take place at the earliest opportunity, wherever
> possible at or around the time of publication.

This is an excellent antidote to the NIH/Wellcome 6-12-month embargo.
It would be good to explicitly encourage the self-archiving of
pre-refereeing preprints too (prominently tagged as such), wherever
the author judges it suitable. (It is mentioned as a possibility, but
it should really be encouraged too.)

> There will be no obligation to set up a repository where none exists
> at present.

This is the one serious problem with the present draft. I would
strongly urge omitting this stipulation. Otherwise it will construed
as a general opt-out clause for the RCUK requirement; indeed it will
implicitly encourage institutions to opt out. Saying nothing at all,
one way or the other, about any obligation to set up a repository,
would be far better than saying this.

> Although RCUK sees advantages in the deposit of material in
> institutional repositories, Research Councils will leave to authors
> the choice of which is the most appropriate repository for their
> publications.

It is very helpful that (like the UK Select Committee), the RCUK
sees the advantages of institutional over central self-archiving.
It would also be a good idea to cite explicitly the JISC Technical Report
which provides all the evidence in support of that expressed preference:

        Swan, A., Needham, P., Probets, S., Muir, A., Oppenheim,
        C., OBrien, A., Hardy, R. and Rowland, F. (2005) Delivery,
        Management and Access Model for E-prints and Open Access
        Journals within Further and Higher Education. Technical
        Report, JISC, HEFCE.

        Swan, A., Needham, P., Probets, S., Muir, A., Oppenheim,
        C., OBrien, A., Hardy, R., Rowland, F. and Brown, S. (2005)
        Developing a model for e-prints and open access journal
        content in UK further and higher education. Learned Publishing
        18(1):pp. 25-40.

> Full implementation of the above requirements depends upon copyright
> and licensing practice, and RCUK will engage the publishing industry
> and other partners to develop effective policy and practice in this
> area.

Again it would be better to cite the Directory of Journal Policies
on self-archiving explicitly here: here

(rather than to make needlessly dark allusions to putative copyright
problems that are in fact far fewer and far smaller than most people
assume). It is commendable to engage the publishing industry, but
the fact is that -- if this is needed at all -- it is only for the 8%
minority of journals that are not yet green on self-archiving!

> E-print repositories that carry published material must make a clear
> distinction between articles that have been peer-reviewed and those
> that have not -- and also between different pre-print versions. RCUK
> will work with the managers of e-print repositories to develop a
> standard for making clear to all users the distinction between
> pre-prints and post-prints.

Again commendable to inform about and stress this distinction (but please
note that it is already fully taken into account, for example, in the
GNU Eprints software, which prominently tags both the refereed/unrefereed
distinction and the various versions of preprints and postprints).

> Councils recognise that, although e-print repositories provide clear
> benefits, they also impose costs on institutions and on the bodies
> that provide the necessary co-ordination and support for networking,
> interoperability and preservation.

There are some costs to creating and maintaining institutional
archives, but they are surprisingly small. So again, it is a strategic
error (and might encourage institutional opt-out) if RCUK implicitly
implies, darkly, that institutional archiving costs are substantial.
They are not. They are a simple extension of existing infrastructure:

It would be very useful if RCUK did some objective quantitative
investigation of the actual cost of creating and maintaining an
institutional repository, and specified the likely cost (if/when it
is referred to).

> Adoption of an "author-pays" publication model is also likely to
> lead to some shift in costs, small initially, but probably larger
> in the longer-term. Councils will ensure that applicants for grants
> are allowed, subject to justification of cost-effectiveness, to
> include in the costing of their projects the predicted costs of any
> publication in author-pays journals. Such charges will be one of
> the elements of Full Economic Costs.

This too is commendable. But it is ever so important not to mix up
in any way the cost per article of publishing in an author-pays
(OA) journal -- which can range from $500 to $2500 per article --
with the cost per-article of OA self-archiving, which is only a few
dollars per article, even with the (low) institutional repository
infrastructure costs factored in.

If these two costs are conflated, not only are the two means of
providing OA mixed up -- one of them being the one being *required* by
RCUK [OA self-archiving, the cheap option] and one of them merely
being *recommended* if/when possible [OA publishing, the costlier
option] as ways of providing OA -- but the higher costs of the one
(OA publishing) are being mixed up with the far lower costs of the
other (OA self-archiving), at the latter's expense!

Please do not hamstring the RCUK obligate requirement (OA self-archiving)
with either (1) the costs of the RCUK optional recommendation (OA
publishing) or (2) the implied high cost of institutional archiving
(which is in reality low).

By the same token, there should be no hamstringing of the RCUK
self-archiving requirement with (3) a putative need to renegotiate
copyright (which no longer applies to 92% of journals!) nor with (4)
the costs of digital preservation:

> Long-term preservation
> RCUK draws a distinction between two
> overlapping purposes: (a) making published material quickly and
> easily available, free of charge to users at the point of use, and
> (b) long-term preservation and curation.

This too is needlessly conflating two very different, independent
matters, one of them not really RCUK's responsibility at all, as

To self-archive a copy of one's postprint in one's institutional
repository is to provide a *supplement* to the publishers official
version of the article, for all those would-be users worldwide whose
institutions cannot afford to buy the publishers official version.

The self-archived supplement is not a *substitute* for the official
published version. And it is the official published version that
has the preservation problem -- a problem that has nothing to do with
either open access or self-archiving! Please do not conflate the two,
adding a spurious preservation cost to the provision of the
self-archived OA supplement, as if the self-archived supplement
were the official version, the only version, and the one with the
essential need for long-term preservation.

The self-archived supplements can and will be preserved for long-term
access, but theirs is not the general problem of digital preservation
of journal articles! Nor is the latter the problem that the RCUK
is or should be trying to solve. RCUK is concerned with providing
access to UK research results for those who cannot afford access
to the official journal version.

> Learned Societies:
> RCUK views the Learned Societies as key members
> of the research community whose work the Research Councils support.
> RCUK will discuss with the Learned Societies ways in which they can
> adapt to and exploit new models of publication.

Again, if RCUK wishes to discuss OA publishing with Learned Societies
(or with commercial publishers, for that matter), that is fine, but please
do not conflate that with the OA author/institution self-archiving
that RCUK is proposing to require here! The author/institution
self-archiving that is to be required just provides a supplement to
traditional journal publishing (whether learned-society or commercial),
not a substitute for it; and 92% of journals (whether learned-society
or commercial) already endorse author/institution self-archiving.

Publishing in an OA journal (and support for its costs) are not being
(and cannot and should not be) required by RCUK, but merely encouraged,
if/whenever possible. RCUK can also encourage publishers to become
OA publishers, if/whenever possible. That's fine and welcome too. But
please do not mix up any negotiations about converting publishers to
the OA publishing model, and covering their OA publishing costs, with
author/institution self-archiving (and its negligible costs).

The only publishers (if any) that require any discussion at all
about self-archiving are the few (8%) that have not yet given
self-archiving their blessing. For this, there is a new Swan & Brown
JISC report, which (along with many other new findings) reports the
attitude to author/institution self-archiving of the two prominent
(Learned-Society) publishers with the longest and fullest experience
with self-archiving. Swan & Brown

        "asked the American Physical Society (APS) and the Institute
        of Physics Publishing Ltd (IOPP) what their experiences
        have been over the 14 years that arXiv has been in existence.
        How many subscriptions have been lost as a result of arXiv?
        Both societies said they could not identify any losses of
        subscriptions for this reason and that they do not view
        arXiv as a threat to their business (rather the opposite
        -- in fact the APS helped establish an arXiv mirror
        site at the Brookhaven National Laboratory)."

Note that this is about the economic effects of self-archiving, not
the economic effects of adopting the OA publishing model! Please
keep the two distinct. The former is what is being required of
authors, the latter is merely being recommended where/when possible.

Stevan Harnad

A complete Hypermail archive of the ongoing discussion of providing
open access to the peer-reviewed research literature online (1998-2005)
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UNIVERSITIES: If you have adopted or plan to adopt an institutional
policy of providing Open Access to your own research article output,
please describe your policy at:

    BOAI-1 ("green"): Publish your article in a suitable toll-access journal
    BOAI-2 ("gold"): Publish your article in a open-access journal if/when
            a suitable one exists.
    in BOTH cases self-archive a supplementary version of your article
            in your institutional repository.

Received on Tue Jun 28 2005 - 16:59:58 BST

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