Response to House of Lords Science and Technology Committee Call for Evidence on Open Access

In the UK the parliamentary House of Lords Select Committee on Science and Technology is conducting an enquiry into the implementation of the government’s policy on open access. Last Tuesday they took oral evidence from Dame Janet Finch (which you can watch here) and on 29th January they will be talking to more stakeholders including the minister for universities and science, David Willetts and, I believe, representatives from funders and publishers.

As part of the process the committee also issued a call for evidence from other interested parties. I have seen submissions from Mike TaylorRoss Mounce and Heather Morrison and am sure there may be others. Before contributing I waited to hear what line of questioning the committee would take with Dame Janet; to avoid likely repetition, I tried to use my remarks to pick up on points that had emerged during that first session.

The complete submission prepared for the committee is laid out below (slightly reformatted to make it more blog-friendly).



Response to the 
Call for evidence on Open Access

18 January 2013


I.  Who am I and why am I responding to this call?

  1. My name is Dr Stephen Curry and I am a Professor of Structural Biology at Imperial College London (though I am writing today in a personal capacity). I have been an active research scientist for around 25 years and published over 80 peer-reviewed articles.
  2. To fulfil a sense of duty as a publicly-funded researcher, I also write regular science blogs at Occam’s Typewriter and for the Guardian Science blogs. Over the past twelve months have written extensively on the issue of open access (OA) from the perspective of a working academic.
  3. Through this I have developed a useful dialogue with many interested parties, including academic colleagues, publishers and funders and a reasonably good understanding of many of the issues that are intertwined with open access. Last September, for example, I summarised the key outstanding questions for UK policy on open access in the light of the Finch Report and the new RCUK policy. I have also written about the severe problem of the over-reliance of journal impact factors as a measure of prestige, which is retarding the uptake of open access scholarly publishing. The committee has my gratitude and sympathy for taking up this important but complex topic.
  4. I know that other academics have responded to this call so I don’t wish to repeat points that are likely already to have been made but I watched the committee take oral evidence from Dame Janet Finch on 15th January and was struck by some of the lines of questioning that were taken up. I wanted particularly to respond to these. My comments address the four issues to be considered by the committee’s inquiry but do not map neatly onto them because they are interlinked.

II.  Dame Janet’s introduction – the question of sustainability and support for OA through article processing charges (APCs)

  1. In her opening remarks Dame Janet described one of the criteria for success in meeting the brief of the working group would be to come up with recommendations that would be financially sustainable for publishers and universities.
  2. This statement does not quite make explicit — as Dame Janet did when speaking to Research Libraries UK in November 2012 — that part of the brief given to her working group by the Minister, David Willetts, was not to damage the publishing industry. The question is what is meant by ‘damage’ in this context and how far did consideration of this constraint affect the resulting recommendations (particularly in view of the fact that publishers were represented on the committee).
  3. It is in most stakeholders’ interests to ensure that the processes of scholarly publication can continue without significant disruption during the transition from subscription-based access to open access. Publishers and universities therefore have some common interests, but it should not be forgotten that ‘financial sustainability’ will mean different things for the different stakeholders. While publishers quite understandably look to maximise profits, universities (and research funders) should be seeking to get the best value for money from the taxpayer-funded research budget. The large profit margins of some publishers (of the order of 40%) suggest that there is room to extract better value from the current spend on scientific publishing.
  4. Research funders should seek to extract this value and savings on total publishing costs should be seen as an important driver for the move to OA. Although there are cost implications in the transition, in the long run, economic forecasts suggest that gold open access will be cheaper. I would argue that some loss of publishers’ profitability due to the emergence of a more active and transparent market with the rise of OA publishing is not a type of damage that should concern us. Rather it is something that should be allowed to occur as the consequence of technological and cultural changes.
  5. Nevertheless, there are concerns that the emphasis of Finch and the RCUK policy on adopting a preference for gold OA will make the transition period unnecessarily expensive. The committee will no doubt have received a spectrum of views on that point — much debated among OA advocates in the last few months. It is problematic but one thing that should not be overlooked is that RCUK has made it clear that researchers can use green OA repositories to meet the terms of its new policy. These are free to authors but typically involve embargo periods of 6-12 months before the published research is freely accessible, and rely on the continuation of journal subscriptions.
  6. My view is that the more costly route of preferring gold OA is a worthwhile investment because it offers spending power that can be used as leverage to allow publishers (and learned societies) to wean themselves off subscriptions. It also provides funds to encourage the development of new, more innovative OA journals that will create a more vibrant market, a move that is necessary to help drive down the costs of the article processing charges often required to publish via gold OA.
  7. There is a risk that by providing funds for gold OA, the UK is locking in advantages for existing publishers and locking in current, relatively expensive APC pricing structures. However the rise in recent years of new OA publishers and journals, such as the Public Library of Science (PLOS), eLife and PeerJ, suggests to me that there could well be strong competition in the OA market. However, that strong competition will only happen if researchers are directly exposed to the cost implications of gold OA. This needs to be a feature of the implementation of the new RCUK policy at university level.
  8. A related question that came up in the evidence session with Dame Janet. Lord Rees expressed concern about the administrative burden on universities of managing the funds allocated to them by RCUK to pay APCs. To an extent, this administrative burden already exists since several universities (including Imperial College) already have OA funds set up and have established simple procedures whereby staff can apply for monies to cover APCs. These will have to expand as the RCUK policy is rolled out but I don’t see the administrative problems as insurmountable. Indeed the expansion of these procedures is an opportunity to ensure that researchers are involved in spending decisions. Discussions and debates about the levels of APCs at the researcher level will help to create a transparent market that could exert downward pressure on prices. (One problem with the present situation is that researchers are generally ignorant of subscription costs, and this has in part contributed to them spiraling to unsustainable levels).

III.  Will a move to open access affect the prestige of UK research?

  1. A more difficult question relates to the role of publishing in establishing and maintaining the prestige of researchers and UK institutions. This is an issue that was raised by more than one member of the Science and Technology committee on 15th January in questions about the impact of the UK policy on OA of our institutions’ international rankings. In particular there was concern that limits on university funds to cover APCs would prevent researchers publishing in ‘top journals’.
  2. These concerns are overstated and misguided. They are overstated firstly since, at least at present, many ‘top journals’ (Nature, for example) enable authors to publish via green OA at no additional cost. Secondly, the entry of leaner, more innovative OA journals at the top end of the market (such as eLife) will reduce costs.
  3. The concerns are misguided because the academic community has come to use journal impact factors as an easy proxy for the quality of a particular piece of research (or a particular researcher) when it is no such thing (4). Studies have repeatedly shown that the distribution of citations attracted by different papers in any given journal is extremely skewed. On average only about 15% of papers in the journal get large numbers of citations, while most are cited only rarely if at all. This pattern is maintained whatever the ranking of the journal. What this tells us, and it has been widely known for many years, is that impact factors are a poor indicator of the quality of an individual research paper.
  4. Unfortunately, the widespread reliance on impact factors as measures of the quality of a paper, a researcher, or even a university has created an unhealthy situation that puts excessive power in the publishers of established titles. Until the research community can break its reliance on the impact factor proxy, and focus instead on evaluating and giving credit for the published work itself, the ‘top-ranked’ journals will be allowed to charge excessively high APCs.
  5. This is a deep-seated cultural problem within the research community. It is being eroded but only slowly. However, the drive for open access will enable the adoption of article-level measures of quality because, by making the research literature more widely available, more people will be able to access and evaluate it.
  6. Pre-publication peer-review should be maintained in an OA world in my view, as a check on the technical quality of the work that is being reported. But as the skewed citation distributions for the papers within any journal has shown repeatedly, pre-publication review by just two or three reviewers is unreliable as a determinant of the ultimate impact or significance of a given piece or work. For that evaluation to take place the research must be disseminated widely (and hopefully rapidly) and the response of the research community to it captured and reported.
  7. It also needs to be borne in mind that the primary function of publishing is to share knowledge with the research community, businesses and the public; contributions to this function should be incorporated into measures of prestige rather than simply looking at the name of the journal.

IV.  How should the Government address the concerns raised by the scientific and publishing communities about the policy?

  1. There is already some provision for this. The Finch group has been charged with conducting a review of the situation within the year (though I’m not sure a definitive timetable has been published), while RCUK has committed itself to reviewing its new open access policy within two years. It is to be hoped that these reviews will offer scope for input from the research community and other stakeholders.
  2. However, there is one particular concern that I would like to raise. A key question for the UK (and one that I would like to see the committee put to Mr Willetts) is what impact its choice of a policy that relies heavily on gold OA will affect international cooperation on open access? This is a concern since most other research-active nations, including the US and the EU, appear to have a preference for green OA routes. It seems to me that this policy divergence risks greatly prolonging the process of transition to a system of scholarly publishing that is free from subscriptions and entirely supported by APCs. Mr Willetts has stated publicly that he would be discussing open access policy with ‘colleagues’ within and beyond the EU. It would be helpful to know what progress has been made in these discussions.


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