Response to the UKRI Open Access consultation

Posted by rsl11 at May 29, 2020 03:05 PM |
The English Association and University English response to the UK Research and Innovation (UKRI) Open Access consultation

The English Association and University English have submitted a joint response to the consultation on UKRI's proposed Open Access policy.

Open access (OA) refers to the removal of price and permission barriers to peer-reviewed research. It refers to peer-reviewed research disseminated online in a digital format without a paywall and published under some form of open license. OA is meant to prevent the inequality of access to research outputs that exists under a subscription ecosystem as anyone can read for free. However, its implementation is difficult and comes with challenges, particularly in the humanities disciplines. (1)


While the EA and UE broadly agree in the principle of democratising access to research,  there are some challenges we wish to highlight:

  • The English subject community faces specific and unique threats. 1) Both small publishers and learned societies with journals fear significant financial loss as a consequence of a shift towards zero-embargo publication, and although there are some good examples of publishers moving towards  this, there is no research yet on the risks posed by the sector moving en masse to zero-embargo publication. 2) Moreover, the freedom of choice of UKRI-funded researchers with regards to publishing their articles will be severely limited. Many UK researchers currently publish on the international stage, and journals outside the UK have no incentive to comply. There is significant concern in our community that strict compliance will limit international collaborations in the Humanities: scholars are committed to publishing on the international stage, and not only in OA UK journals.
  • A CC-BY licence with the non-derivatives clause offers protection against uses of our work that are regarded by many in our community as unethical (plagiarism). We strongly disagree that where compliance with UKRI’s OA policy is achieved via a repository, a CC BY licence (or OGL where needed) should be required for the deposited copy. Most humanities journals ask authors to sign the CC-BY licenses with the non-derivatives clause, and this is accepted. To replace this with the most permissive license that allows for re-use and adaptation of any kind, provided the original author is acknowledged, is not acceptable to the majority of Humanities scholars, where the line between raw data and its argued presentation is much harder to draw.
  • As the publishing industry works to adapt to the new challenges of covid, all efforts should be made to avoid adding to the workload of academic publishers. We strongly disagree that at UKRI’s OA policy should have a case-by-case exception allowing CC BY-ND for the version of record. Academic publishers argue that the administrative burden of case-by-case exceptions will be worse for smaller publishers and contribute to reduction in publication choice (or possibly further consolidation in journal publishing).
  • It is imperative that REF policy should be kept separate from UKRI policy. Our researchers are not for the main part key beneficiaries of UKRI funding, and sweeping decisions would impact on their research capability unless funding were increased significantly through QR. A clearer statement on this would generate more support for UKRI’s aspirations - and additional funding - for its funded researchers.
  • We are concerned that the proposals will lead to a loss of income for associations and societies that use funding available from journal income to support the sector (e.g. ECA bursaries and fellowships, as well as the salaries and pensions of any professional services colleagues). There will be costs associated with the administration of OA (data capture, repository management), and the maintenance of repositories. The English Association (co-signatory of this response) fear financial loss as a result of a sudden, reduced (modest) profit share from publications; this would impact on the salaries and pensions of the professional services team who support English Studies, students and teachers, from primary to higher education. We would like to see more research on the impact of transformative agreements, and financial support from UKRI to explore new business models.
  • Understanding the costs of publication needs to be part of a review of UKRI funding.We agree there should be more transparency in terms of publication charges (APCs and BPCs), and we agree that this should inform future funding levels. We also recognise that publishing carries a cost that needs to be met. Copy-editing, quality of production, advertising, peer review of books and special journal issues are obvious costs that are part of a publisher’s overheads.
  • We strongly argue that hybrid journals are an important part of a diverse publishing ecosystem, delivering progress towards Open Access: articles published under the green route are publicly available. Most humanities journals are hybrid journals, and this will remain the case for some years, even with transformative deals, because the route to OA journal status is less clear for smaller publishers. UKRI funding should not be used to benefit one part of the sector - the larger well-established businesses for example - at the expense of smaller publishers. The point of this UKRI consultation is to ensure that UKRI research is published open access, and it is and can be in hybrid journals, alongside high-quality ‘green’ outputs funded through QR or self-funded (independent scholars).
  • We would welcome further advice and research on the impact on learned societies, and financial support to help us explore new business models.There are several different business models being considered across the Humanities: e.g.  APC, open and subscribe. The English Association charges a membership fee to fund its many different activities, and we would be reluctant to increase this at this time of economic uncertainty, especially since so few of our members, school teachers, general public, researchers are UKRI-funded; this UKRI requirement should be funded by UKRI.
  • 12 months is far too short an embargo period given the life of a monograph and its impact. The UUK OA And Monograph Evidence Review reported that “70% of publisher sales take place in the first two years after publication, with 80% of sales taking place in the first three years”. In the humanities, reviews do not usually appear until 18-24 months post-publication and this has an impact on sales, and therefore the sustainability of publishers’ lists. We are reluctant to make the case for different embargo periods for different disciplines because we feel this would be confusing, and would like to see a stronger explanation of why the 12-month embargo period has been chosen. A longer embargo period should be allowed until we have a better understanding of the impact of these decisions on a fragile industry (book publishing). This is especially important as we move into a deep recession. Longer embargo periods offer greater protection for smaller publishers, who may publish a small number of significant monographs in niche areas. We do not understand the aim of UKRI policy to be the concentration of power in the hands of larger publishers and warn against unintended consequences.
  • EDI concerns require clarification of deposit requirements for early career and non-affiliated researchers, to minimise barriers to compliant publication for researchers without a current institutional affiliation, and hence without access to BPCs (from HEI or funding body) or easy access to institutional repositories.

Download the full response

1 Eve, M., 'A Beginner’s Guide to Open Access and Plan S', Newsletter 223 (2020), 11 - 13.

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