Our response to the UKRI OA Review
1 June, 2020 | Liz Allen |
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In February, UK Research and Innovation (UKRI) launched a consultation on its Open Access Review.
F1000 Research Ltd and Taylor & Francis have submitted responses to the consultation. These illustrate how we are working on complementary paths to transform scholarly communication in order to accelerate research impact across the whole ecosystem.
We support an Open future.
You can view the F1000 Research Ltd response below:
We welcome the opportunity to respond to the UKRI open access review.
Section A: Research Articles
Q1. To what extent do you agree or disagree that it is clear what research articles are in-scope of UKRI’s proposed OA policy (see paragraph 46 of the consultation document)?
Agree (mostly) – see below
Two issues that require clarification.
- Research article type – scholarly publishing outlets today (journals, OA platforms) increasingly support author choice by offering a widening range of research article types, including but not limited to: Research Protocols and Methods pieces, Case Reports/Case Studies, Software and Data focused articles and more traditional Research Articles, Reviews and Opinion Pieces. While there can be some tailoring of the instructions to reviewers in their task of providing a review across the diversity of article types, peer review remains a core service used to support enhancement, validation and trust in content.
To add precision to the requirements of the UKRI’s OA policy, it would be helpful for the UKRI to make clear that all types of research-based articles that are submitted for peer review at publication outlets that meet the UKRI’s qualifying standards/criteria (and for which some sort of payment is required to secure OA – predominantly though an ‘Article Processing Charge’ (APC)) are covered by the policy.
- Multi-funded work – could the UKRI clarify that its OA policy applies to work with at least some UKRI HE funding acknowledged in the work being published.
Q2. Are there any additional considerations that the UK HE funding bodies should take into account when defining research articles that will be in scope of the OA policy for the REF-after-REF 2021? (200 words)
Yes
As above, given that multi-funded research is commonplace, could the UKRI clarify how its policy applies in the situation where research is supported by the contributions of many research funding agencies (and what happens if other organisations do not share the UKRI’s OA mandate). Authors – and publishing venues – need clarity on the policy and associated rules that apply to ensure the necessary OA compliance actions.
Occasionally, when a submitting author is not funded by an agency with an OA policy mandate, but there are collaborative authors on the article who are supported by a funding agency with an OA mandate, there can be some confusion about whether OA is required – and therefore a delay in action.
The UKRI also needs to be clear about when it will ‘pay’ to enable OA. For example:
- would the policy apply if ‘at least one author’ has UKRI HE funding?
- if there are multi-funded authors listed on an article, and one or more of the authors have access to funds to support OA, what is the role of each funder? (i.e. do they split the costs? Is there a lead? Etc)
Q3. In setting its policy, should UKRI consider any other venues for peer-reviewed research articles which are not stated in paragraph 47 of the consultation document? (100 words)
No
The key thing is to clarify that peer-review is required for an outlet to be an approved venue of publication. Publication outlets need to demonstrate – ideally according to some objective (and UKRI approved) criteria – that peer-review is conducted.
Q4. Are there any specific challenges for you, your community or your organisation in terms of complying with the requirement in UKRI’s proposed policy for immediate OA of in-scope research articles?
No
Q5. Should UKRI’s OA policy require a version of all in-scope research articles to be deposited in a repository, irrespective of whether the version of record is made OA via a journal or publishing platform?
No/Don’t know
Please explain your answer (700 characters maximum, approximately 100 words). Please note that some Research Councils already require articles to be deposited in specific repositories, as detailed in the terms and conditions of funding. UKRI does not expect this to change.
UKRI should consider how – through simple requirements around meta-data and identifiers (e.g. ORCID ids; IDs for UKRI grants; Crossref Funding Registry[1]) and institutional IDs (ROR[2]) – it can support auto-population and meta-data deposition across publishing outlets, institutional repositories, and other research output related sites (e.g. researchfish/interfolio) – so that content is syndicated across systems but the curation (and duplication) across many multiple sources is avoided.
Investment will be needed, but will enable research outputs to be widely discoverable across multiple sites and accessed where needed, using interoperable functionality (ref: OpenAIRE’s support of EC funding programmes and repositories[3])
Q6. For research articles, are there any additional considerations relating to OA routes, publication venues and embargo periods that the UK HE funding bodies should take into account when developing the OA policy for the REF-after-REF 2021?
No
Q7. To what extent do you agree or disagree that where compliance with UKRI’s OA policy is achieved via a repository, a CC BY licence (or Open Government Licence where needed) should be required for the deposited copy?
Strongly agree (though see Q8 below re: exception)
Q8. To what extent do you agree or disagree that UKRI’s OA policy should have a case-by-case exception allowing CC BY-ND for the version of record and/or author’s accepted manuscript
Strongly agree
Please explain your answer. UKRI particularly welcomes evidence supporting: specific cases where ND is considered necessary; an ND exception not being necessary; any implications an ND exception could have for access and reuse (2,000 characters maximum, approximately 300 words).
For a simple, clear, implementable (and enforceable) OA policy, for authors, for publishers, for funders, for institutions, we suggest that the licence required to enable OA should be a default CC BY licence. This is well used and well understood across most communities as the bed-rock for open access.
We do think that there may need to be some deviation in exceptional circumstances but this – as suggested by Q8 – should be on a case by case basis and NOT a choice for all. We believe that if authors are presented with a choice of CC BY or CC BY-ND then this will add to workflow burdens to implement the policy (e.g. by publishers), cause confusion among authors (e.g. if multi-funded and where different OA requirements may apply), and may slow down compliance and undermine the OA policy. We believe that if there needs to be an exception, then that should be considered (and managed) by the UKRI/OA policy team.
Q9. Would the proposed licensing requirements for UKRI’s OA policy, which exclude third-party content (see paragraph 55 of the consultation document), affect your or your organisation’s ability to publish in-scope research articles containing third-party content?
No
Q10. Are there other considerations UKRI should take into account regarding licensing requirements for research articles in-scope of its proposed OA policy?
Yes
As noted in our response to Qs 1 and 2, we would like to flag that multi-funded/sponsored work could impose different requirements (e.g. around licensing) upon their respective authors.
In its policy therefore, the UKRI will need to make it clear what happens if/when there may be different licensing requirements for multi-funded/authored work. Would potentially conflicting license requirements be problematic for UKRI? The UKRI needs to be clear about when its requirements/policy applies, for example, if ‘at least one author’ has UKRI HE funding.
Would divergent licensing requirements potentially deter collaboration between partners? Perhaps internationally and/or with a commercial partner? Clarity around such scenarios could be clarified in the original grant funding terms and conditions.
Q11. For research articles, are there any additional considerations relating to licensing that the UK HE funding bodies should take into account when developing the OA policy for the REF-after-REF 2021?
Yes
If yes, please expand (2,000 characters maximum, approximately 300 words). Please see paragraphs 29-31 of the consultation document before answering this question.
Related to Q10, where work is potentially multi-funded/sponsored and any collaborating authors have different perhaps non-OA, licence requirements, the UKRI should clarify its requirements for submissions.
Would the output from UKRI-funded research working with a researcher requiring licensing that may be less permissive than the UKRI-researcher/s be eligible for submission? Would this potentially deter certain types of research collaborations? How would this affect the potential for certain types of academic-commercial partnerships for example? As noted in Q10, clarity around such a scenario (and the implications for REF submissions) should be made clear early in the research process/in the original grant funding process.
Q12. Which statement best reflects your views on whether UKRI’s OA policy should require copyright and/or rights retention for in-scope research articles?
c. UKRI should require an author or their institution to retain copyright AND specific reuse rights, including rights to deposit the author’s accepted manuscript in a repository in line with the deposit and licensing requirements of UKRI’s OA policy.
Please explain your answer. UKRI particularly welcomes views as to whether it is necessary to require copyright and/or rights retention if its policy were to require a CC BY licence, which enables reuse. If you selected answer b or c, please state what reuse rights you think UKRI’s OA policy should require to be retained (2,000 characters maximum, approximately 300 words).
We believe the default licence should be CC BY to enable maximum reuse which is the ultimate aim of open access. The main aim is to deter any ownership of the content by the publisher, the aim should be to enable use and reuse (with appropriate attribution) into the future, without barriers.
Is there a case where the funder may exert some ownership around content? Is there a scenario where ownership of specific outputs – for example a data set created during a medical charity research funded project (and involving patient data) – be more appropriately ‘owned’ by the funder? This scenario is not covered in the response option but as research and types of collaboration evolve, there may need to be more consideration around the scenarios needed to protect and assure access to research outputs (beyond articles) into the future.
Q13. Regarding research articles in-scope of UKRI’s OA policy, to what extent do you agree or disagree with each of the seven proposed technical standard requirements for journals and OA publishing platforms?
For each of the seven standards (see paragraphs 67a-67g of the consultation document):
Strongly agree
For each of the seven standards (see paragraphs 67a-67g of the consultation document), please explain your answer (700 characters maximum, approximately 100 words, per standard).
a. Persistent digital object identifiers (PIDs) for research outputs must be implemented according to international standards such as DOI, URN or Handle
Strongly agree
UKRI should specify the PIDs that it requires to be linked to UKRI output to help publishers/platforms to implement the policy correctly and enable the inter-operability that PIDs permit – to be effective, standards rely on clarity of definition and consistency of use.
As other funding agencies are doing (e.g. Wellcome) it would be an opportune time for UKRI to issue PIDs (and ORCID IDs) for its grants/funding to enable the linkage between funding and output AND, importantly, to support OA compliance monitoring across funding areas.
b. Article-level metadata must be used according to a defined application profile that supports UKRI’s proposed OA policy and is available via a CC0 public domain dedication; the metadata standard must adhere to international best practice such as the Crossref schema and OpenAIRE guidelines
Strongly agree
Open article meta-data is essential – again to enable the benefits of the OA policy (ie discoverability, use and reuse of research) – and we support the proposal that the meta-data standards should meet defined schemas (e.g. Crossref). We would also recommend that the UKRI includes in its policy precise guidance around the meta-data schema that it requires for compliance.
c. Machine-readable information on the OA status and the licence must be embedded in the article in a standard non-proprietary format.
Strongly agree
Having machine readable content and licences is key to discoverability and use of research and should be a core element of the UKRI policy.
Particularly for some of the more technical aspects of the UKRI policy, there may need to be training/webinars available to support absolute clarity around what is required of publishers wishing to enable compliance with the UKRI’s policy.
d. Long-term preservation must be supported via a robust preservation programme such as CLOCKSS, Portico or an equivalent.
Strongly agree
As part of this, it would be good for the UKRI to issue guidance around which preservation services exactly meet UKRI’s requirements (e.g. an approved list that meet the UKRI’s standards). Could there be a way to add the preservation outlet to the meta-data?
e. Openly accessible data on citations must be made available according to the standards set out by the Initiative for Open Citations (I4OC).
Strongly agree
Citation information are a core part of any scholarly record – and should be made openly accessible and stored/available in UKRI designated outlets (e.g. I4OC).
f. Self-archiving policies must be registered in the SHERPA RoMEO database that underpins SHERPA/FACT
Strongly agree
It is important to describe where/how work is being stored for long term access and use.
g. Unique PIDs for research management information must be used and must include the use of ORCID to identify all authors and contributors
Strongly agree
F1000Research already capture ORCID IDs for our corresponding/submitting author as standard – and across all our publishing outlets. It is more challenging to capture the ORCID id for ‘other’ authors (due to publisher workflow and MSS system adjustments that are required – though it is possible); in the first instance we would recommend that the UKRI policy requires ORCID IDs for the corresponding/submitting author AND others where this is possible within existing workflows (and secure PID for grants, as recommended above).
We also suggest that the UKRI recommends the use of the CRediT (now a NISO standard[4]) taxonomy among publishers.
Q14. Regarding research articles in-scope of UKRI’s OA policy, to what extent do you agree or disagree with each of the five proposed technical standard requirements for institutional and subject repositories?
a. PIDs for research outputs must be implemented according to international standards such as DOI, URN or Handle
Strongly Agree
As with journals and OA platforms, using UKRI specified persistent identifiers will be key to maximising the discoverability of UKRI-related research and enabling inter-operability across systems.
A more integrated system, linking output to institutions and subject repositories could also support future research evaluation, strategy and reporting (e.g. REF submissions) providing automated solutions and reducing the burden of compiling specific information).
Q15. To support the adoption of technical standards for OA, are there other standards, actions and/or issues UKRI should consider? Yes / No / Don’t know / No opinion.
Please explain your answer (400 words)
As part of the policy it will be important for the UKRI to issue very exact guidance around which standards/persistent identifiers etc it requires for compliance with its policy – so that publishers/repositories can implement any changes precisely (and therefore support authors to be compliant).
We encourage the UKRI to consider where it can harmonise its requirement with other like-minded research funders (and other stakeholders) to minimise the potential for divergent policies that require publishers (and other service providers) to develop different workflows to accommodate different policy requirements.
We recommend that the UKRI also mandates the use of an ORCID id for all its PIs (and those employed on grants where practicable). This could form part of a national ORCID ID policy and lay the foundations for the UK to be at the fore of supporting inter-operability across a currently fragmented research ecosystem (potentially connecting researchers, institutions, funders and publishers).
Q16. To support the implementation of UKRI’s proposed OA policy requirement for research articles to include an access statement for underlying research materials (see paragraph 69 of the consultation document), are there any technical standards or best practices that UKRI should consider requiring?
Yes
Providing access to any underlying data/materials/resources we believe should be integral to an OA policy today as these are often the key to making the work useable and reusable – and therefore maximising the potential for impact (and for funding Return on Investment (ROI)). We do recognise that not all scholarly work is underpinned by concrete data/resources so there would need to be some flexibility around such a requirement.
We recommend that the UKRI aligns its requirement in this area with other funders to support momentum and uptake of this, keeping things simple for researchers (as authors) and for publishers working to implement a system to support this. As a minimum we would advocate that the UKRI consider standards for underlying data/materials/resources:
- that
align with FAIR standards
- are included (directly accessed) in data availability statements and not via ‘Supplementary files’
- have a digital footprint (DOI) and are citable to support those responsible for the work involved in curating and managing important underpinning resources to get credit and visibility for their (historically hidden) work.
Q17. UKRI’s OA policy is proposed to apply to in -scope research articles accepted for publication on or after 1 January 2022. Which statement best reflects your views on this?
a. The policy should apply from 1 January 2022
We support the policy coming into effect as soon as possible as we believe this will make a substantive positive difference to the access to research, and competitiveness of the UK.
We appreciate that there may need to be some lead time for publishing outlets/platforms/repositories to adjust their workflows and systems to enable full implementation of the policy before its launch – especially if the UKRI is, as we hope, prescriptive about its exact requirements (e.g. around meta-data and PIDs).
Q18. For research articles, are there any considerations that UKRI and UK HE funding bodies need to take into account regarding the interplay between the implementation dates for UKRI’s OA policy and the OA policy for the REF-after-REF 2021? Yes / No / Don’t know / No opinion.
No opinion
Q19. Do you think the proposals outlined in Section A will have any financial cost implications for you or your organisation?
Yes
For a simple OA mandate, there would be no cost to us as a publisher.
Should the UKRI be more prescriptive around the meta-data standards it prescribes – which we support – there may be some associated costs to us (particularly to our manuscript submission system (MSS) and internal workflows) to ensure that we capture information that we may not already (for example, should the UKRI require the collection of an ORCID ID for all authors (as opposed to the corresponding/submitting author)). But as our response sets out, we are indeed supportive of the UKRI being prescriptive about how its policy should be implemented.
Q20. Do you think the proposals outlined in Section A of the consultation document will result in financial benefits for you or your organisation?
No
Q21. Can you provide any evidence of a changing balance of costs across research organisations arising from an emphasis on publishing costs rather than read costs?
Yes
There are an increasing number of studies that show the benefits (and opportunity cost) of OA publishing, both in terms of the academic profile of scholars and within academia, but also outside of academia[5],[6],[7]. And we believe there is much further to go in reaping these benefits, with investment in the embedding of unique identifiers and PIDS in the scholarly research system – maximising the ability for discoverability, use and reuse of research across the UK and globe. There is robust international evidence that demonstrates the economic benefits of research[8],[9],[10],[11] and the additionality that making those findings and outputs (including data) openly accessible contributes to economic impact[12],[13],[14],[15] while also enabling public access and contributing to societal impact.
Q22. Can you provide any evidence on cost increases and/or price rises (including in relation to OA article processing charges (APCs)s and subscriptions) and reasons for these?
Q23. Do you think there are steps publishers and/or other stakeholders could take to improve the transparency of publication charges?
Yes
We believe that price transparency is key – as publishers have their own overheads, systems, business models, set up etc, that can all effect their underlying costs. We believe that price – and for the service received – is something that remains key in ensure the scholarly communication system is sustainable and offers value to researchers.
F1000 Research is actively involved in the Plan S Price and Transparency Framework pilot with Annual Reviews, Brill, The Company of Biologists, EMBO Press, European Respiratory Society, Hindawi, IOP Publishing, PLoS and Springer Nature (https://www.coalition-s.org/coalition-s-announces-price-transparency-requirements/). F1000 Research is working hard to provide price transparency for all the services it provides during 2020.
As the UKRI knows, over the last 3 years, F1000 Research has been providing tailored research publishing services directly to funding agencies and institutions (“Platforms”). While each Platform is tailored to support individual funder requirements, all share the common goals: to drive full OA compliance, at a reasonable cost and at minimal burden to researchers (as authors), thus supporting the potential for use and reuse of the research they have supported.
Q24. Regarding UKRI’s consideration about restricting the use of its OA funds for publication in hybrid journals (see paragraph 80 of the consultation document), please select the statement that best reflects your views:
a. UKRI OA funds should not be permitted to support OA publication in hybrid journals
Q25. To what extent do you agree or disagree that UKRI OA funds should be permitted to support OA costs that support institutional repositories?
Q26. To help accelerate policy adoption, should UKRI introduce any other restrictions on how UKRI OA funds can be used?
Q27. There are many business models that can support OA. A common model for journals is based on APCs, but there are also other models (such as membership models and subscribe to open). Are there changes or alternatives to the present UKRI funding mechanisms that might help support a diversity of OA models?
Yes
We would like to see a diversity of OA business models emerge – and to support different disciplines. While OA is the goal, we believe there may be a number of routes that scholarly publishers – in all their guises – could provide to enable this – and that can help to eliminate the potential for inequality across disciplines and cadres of researchers across the world.
While we believe that the dominance of the APC (author (or funder) pays) model has been significant in building momentum towards OA, one size is unlikely to fit all. The key thing is that providers of OA publishing services need to comply with the UKRI’s requirements (which need to be clearly defined) around, for example:
– meta-data standards
– PIDs
– Price and service transparency
– Discoverability and indexing and preservation standards.
Q28. As discussed in paragraph 74 of the consultation document, transformative agreements are one way of moving to OA in a more cost-effective way. Are there approaches to managing transformative agreements or other mechanisms and developments that UKRI should consider to help manage the transition to OA in a way that is cost -effective and offers public value to the UK?
Yes
While there are some benefits around transformative agreements – not least in terms of the simplicity of achieving OA for authors! – we do worry that such ‘big deals’ can effectively reduce author choice around publishing venue, effectively lock out OA-born and smaller publishers and have the potential to create and exacerbate inequalities in access to research across the globe; this does not therefore represent good value to the public (nor does it guarantee any kind of a sustainable model of publishing).
We would advise UKRI to consider how and where transformative deals can have unintended consequences in terms of lock-ins (and potential cost tie-ins) with specific publishers (often those operating at scale) while effectively making OA-born publishers work harder to engage and access researchers.
Q29. Are there any existing or new infrastructure services that you think UKRI should fund the maintenance and/or development of, to support the implementation of its OA policy for research articles?
Yes
There remains considerable fragmentation in the ways in which research outputs are shared and discovered. Many of the changes now required in the scholarly publishing system are the result of needing to unpick legacy systems that were designed for a bygone age; it seems strange that we are still developing policies to try to bring about 100% OA compliance in a publishing system more than 20 years since it was first mooted to be desirable. And in the time it has taken to develop more stringent policies to deliver OA once and for all, could we now be more ambitious and rethink how the scholarly publishing system could work to best effect as an integrated piece of the research ecosystem?
We would like to see the UKRI and other funders work more closely as part of a connected research ecosystem, to co-design ways to ensure the sharing and ‘publishing’ of research outputs is integral to the research process and not an adjunct. We believe that it is an opportune time to consider what, why, when and how we want research findings to be shared; how does scholarly publishing support the research process and how can we design a system that can optimise all the investment and opportunity cost involved in funding and doing research.
Q30. To what extent do you agree or disagree that UKRI should provide or support a national shared repository?
Neither agree nor disagree
Please explain and, where possible, evidence your answer (200 words)
While investment in the underpinning research infrastructure is essential and overdue (e.g. connected systems to enable the discoverability of all research; setting up agreed research meta-data standards – e.g. institution, funder, output typology etc; investment in system- wide adoption of PIDs for many of the touch points in research), we believe that inter-operability is key going forward – and if done properly, will negate the long-term need for additional (and often duplicative) repositories /data storage per se – beyond including an inventory of meta-data.
Q31. Should UKRI require preprints to be made OA where there is a significant benefit with regard to public emergencies?
Yes and No
If yes, is there a recognised definition of ‘public emergency’ and/or protocols that UKRI should consider if this policy is implemented (200 words)
As the current Coronavirus pandemic makes very clear, there can be no social, moral or economic value in delaying the publication of research – and there is increasing evidence that getting work out quickly is helping to very significantly accelerate the global, and collaborative response to COVID-19. Now that this has demonstrated that it is indeed possible to work together to accelerate research progress, there is no reason why other research situations and fields should not also benefit from the same levels of acceleration of progress.
We do not think that building a policy around ‘public health emergencies’ alone will be helpful or workable. For example: as implied, the definition alone will be near impossible to pin-down; where in the world should that ‘emergency’ exist for the policy to apply? How long should the emergency exist for it be subject to the policy? And many other questions.
We believe that an OA policy defined only around a specific topic (however defined) will dilute the larger ambition that the UKRI has for its OA policy and will effectively slow down any actions to move the needle to OA as the default.
Q32. Are there any supporting actions that UKRI could take alongside its OA policy to support the use of preprints in all disciplines?
Section C: Monitoring Compliance
Q57. Could the manual reporting process currently used for UKRI OA block grants be improved? Yes / No / Don’t know / No opinion.
No opinion
If yes, please explain how (300 words)
Q58. Except for those relating to OA block grant funding assurance, UKRI has in practice not yet applied sanctions for non-compliance with the RCUK Policy on Open Access. Should UKRI apply further sanctions and/or other measures to address non-compliance with its proposed OA policy?
Yes
Please explain your answer (300 words)
If a policy is indeed a requirement or mandate – which we believe at this time is the intention of the UKRI with its revised OA policy – then this should indeed be accompanied by some type of sanction for non-compliance. We do not prescribe what an appropriate sanction might be but if the requirement around OA is fully integrated into the funding process – and is, for example, part of any grant terms and conditions, then non-compliance would constitute a breach of the grant conditions.
Q59. To what extent do you agree or disagree with the example proposed measures to address non-compliance with the proposed UKRI OA policy (see paragraph 119 of the consultation document)?
Agree
Please explain your answer (300 words)
As noted in Q58, if a policy is indeed a requirement or mandate, then this should indeed be accompanied by some type of sanction for non-compliance. We do not prescribe what an appropriate sanction might be but if the requirement around OA is fully integrated into the funding process – and is, for example, part of any grant terms and conditions – then non-compliance would constitute a breach of the grant conditions.
This is why we believe that the UKRI must be very precise with its requirements when issuing its policy – and make sure that its implementation can be achieved, that compliance can be accurately reported, and that the burden to researchers in all of this is minimised, especially if any sanction for non-compliance may ultimately reflect on the researchers/grant holder there can be no room for ambiguity (and this could be better managed through additional automatic checks if the use of PIDs are required for researchers (as authors) and grants).
Section D: Policy Implications and Supporting Actions
Q60. Do you foresee any benefits for you, your organisation or your community arising from UKRI’s proposed OA policy?
Yes
Please expand (400 words)
A tightly defined UKRI policy for OA would have benefits for F1000 Research and all publishers, including those well-established open access publishers and those working to expand their OA offering. For researchers – who are essentially our primary/first line customers – we want to provide a high-quality service that meets their needs (and those of their funder). Through the actions of funders like the UKRI and initiatives like Plan S, the expansion of services and a wider choice of OA outlets that comply with their funder mandates simply and effectively can only be a good thing for our customers (and the UKRI through its ability to achieve full compliance).
As noted in previous questions, the more alignment and harmonisation there can be around the UKRI’s policy for OA and those issued by other research funders (and other stakeholders) the easier it will be for publishers/platforms/repositories to develop policy compliant workflows, and therefore for researchers (as authors) to publish their work according to the requirements of their funder.
Q61. Do you foresee UKRI’s proposed OA policy causing and/or contributing to any disadvantages or inequalities?
Yes
If yes, please expand, referencing specific policy elements and including any comments on how UKRI could address any issues identified (400 words)
Any challenges/issues created by a drive to OA are not something that is specific to the UKRI’s OA policy – and we would not advocate that the UKRI deter from its paths in pursuit of compliance among its grant holders.
However, as is increasingly documented, there is a need for a more fundamental rethink about how the requirement to share and communicate research findings is best organised and its place in the research ecosystem. We currently have a fragmented research system: where research is funded, where it is undertaken, where researchers are employed, and where research is published is currently across a myriad of largely unconnected entities. The sharing and publication of research is something that predominantly comes towards the end of a research project cycle and is enabled through a scholarly publishing system, the costs for which have historically been included in the research budget.
Increasingly in a ‘pay to publish’ world (which to-date is the predominant model used by publishers to deliver OA), where a researcher has access to funds to support the costs of publishing (whether the charges to publish are seen as good value or not!), the researcher gets to publish; but many researchers simply do not have access to funds to support their desire to publish their work. With more push towards funder/author pays models, this creates the potential for inequalities (e.g. where researchers working in certain disciplinary areas typically have less access to the types of funding support which can include provisions for publishing costs – such as in HSS) and the potential to exacerbate those that already exist (e.g. for researchers working in resource-poor environments).
This does not mean that the UKRI and other funders should abandon their own drive towards OA compliance – the aims of OA are still entirely valid and necessary; rather that, alongside its own requirements for OA, the UKRI and other stakeholders in the research ecosystem (and across the world) should work together to consider how to yield the benefits that rapid and open access to research can bring to all, in a sustainable and equitable way.
Q62. Do you foresee any positive and/or negative implications of UKRI’s proposed OA policy for the research and innovation and scholarly communication sectors in low-and-middle-income countries?
Yes
If yes, please expand, referencing specific policy elements and including any comments on how UKRI could address any issues identified (400 words)
OA to UK-funded research will provide huge benefits to researchers across the world – and especially in due course if this policy also extends to support open data/material and underpinning resources; this will be key to reducing research waste, duplication and enabling use and reuse of research and for others to build upon existing findings.
As is the case now, and as we described in Q61, the predominant business model used to deliver OA publishing via an APC (‘funder/author pays’) does present barriers to researchers who are unable to secure funding to support the publication of their research. And while publisher waiver policies do offer some options to researchers working in resource-poor environment and LMICs, the system really does not put all researchers on an equal or equitable footing. We would like to see the UKRI and other stakeholders in the research ecosystem (and across the world) work together to explore alternative systems and business models that bring the benefits of OA to all and in a sustainable and equitable way
We do not think that the need to minimise any global inequity should detract the UKRI from its own path to OA compliance, rather in parallel, there is an urgency to address the wider issue around the need for more sustainable and equitable systems of publishing and sharing research.
Q63. Do you anticipate any barriers or challenges (not identified in previous answers) to you, your organisation or your community practising and/or supporting OA in line with UKRI’s proposed policy?
Q64. Are there any other supporting actions (not identified in previous answers) that you think UKRI could undertake to incentivise OA? Yes / No / Don’t know / No opinion.
If yes, please expand (300 words)
Q65. Do you foresee any other implications (not
identified in previous answers) for you, your organisation or your community
arising from UKRI’s proposed OA policy?
Section E: Further Comments
Q66. Do you have any further comments relating to UKRI’s proposed OA policy? Yes / No.
If yes, please expand (400 words)
Yes
If yes, please expand (200 words)
Even if UKRI intends to consider its policy requirements around open data/resources/materials at a later point – a strong indication in this OA policy that this is indeed the direction of travel will help publishers, in particular to start to consider how they can implement this in their own polices and workflows.
We would encourage UKRI – alongside other funders and those issuing OA (and other) policies and mandates around their research – to continue to work closely with those who will be essential for the successful implementation of any policies (e.g. publishers, OA platforms and repositories) – to ensure all stakeholders fully understand the scope, precise requirements and timeframes of policies. Most importantly for its success, the policy needs to be implemented in the same way (where needed) to reduce the burden and confusion that divergence around policies across a multi-funded, international and ever more connected research ecosystem, creates for those doing the research!
Q67. Do you have any further comments relating to commonality between UKRI’s proposed OA policy for outputs acknowledging UKRI funding and the OA policy for the REF-after-REF 2021?
Q68. Do you have any further thoughts and/or case studies
on costs and/or benefits of OA?
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