A consultation period was open until 8th February 2019, allowing individuals and organisations to respond to the plans, which are set to come into force on the 1st January 2020. LSHTM fully supports the overall aim of Plan-S to deliver full and immediate open access to publications that result from publicly funded research. However, there are aspects of the guidance that require further clarification. Our response to the two questions posed in the consultation was as follows.
Is there anything unclear or are there any issues that have not been addressed by the guidance document?
The most concerning aspect of Plan-S is the lack of clarity about financial support for the policy, especially given that Plan-S is set to come into force in less than 11 months. One of the 10 Principles of Plan-S is that “Open Access publication fees are covered by the funders or universities, not by individual researchers”. This is not clarified further in the associated guidance document. To what extent are universities expected to make institutional funds available to help pay for open access? Is it expected that funders will cover most of the costs of open access publishing?
Issues have already arisen at many UK HE institutions, where only a limited amount of funding has been provided in the form of ‘block grants’ for open access and at best can cover only a small proportion of the publications output by researchers (particularly UKRI researchers). Green open access, with 0-month embargo, remains an unrealistic (non-compliant) option with very few journals having responded to the proposed Plan-S by delivering this change. Indeed, this repeats the observation that very few journals developed more liberal green open access policies in response to MRC’s and Wellcome Trust’s older open access policies requiring research articles to be made available open access under the CC BY license or via green open access with a maximum 6-month embargo. Instead journals have preferred to promote their paid-for routes to compliant open access status. Plan-S makes this issue even more acute; it seems unlikely that hybrid journals will deliver compliant green open access options by 1st Jan 2020. Moreover, most higher education institutes will be in no position to provide institutional funding to cover the funding shortfall and will be left in a situation where researchers have no choice but to publish in non-compliant publishing venues. There are a few potential solutions to this issue, including but certainly not limited to: ensuring that funders provide significant and sufficient funds for Plan-S; permitting longer embargo periods where funding is not available to pay for gold open access; and, providing further support for non-APC routes to open access.
A related issue is how much do funders expect to reduce their open access costs through Plan-S? This is not a stated aim of Plan-S, but can be assumed to be part of the problem with the current open access landscape. A concern is that publishers may try to maximise their income through fully open access journals with higher APCs, so that the costs of open access actually may rise. For instance, an existing hybrid journal may offer a green open access policy that is currently compliant with various funders’ policies, and researchers may publish at no cost to the funder. However that policy would be non-compliant with Plan-S (which demands a 0-month embargo) and the researcher may then publish with a compliant fully open access journal (likely a commercial OA journal, at a cost to the funder). Moreover, it is not clear what is considered “reasonable costs” and how this will be enforced in practice. Given that a handful of journals have responded to Plan-S through flipping to a fully OA model (but as far as we know none have recently delivered a new 0-month green open access policy), it seems reasonable to suggest that publishers expect to meet the Plan-S challenge through an APC-based business model. Publishers have resisted dropping their embargo periods, despite some publishers (CUP, Sage, Emerald) continuing to profit with shorter embargo periods (though we note many of these journals still impose longer embargoes on PubMed Central deposit, despite 0 month embargoes permitted for institutional repository deposits).
DORA and Research Evaluation
Another major concern is the effect Plan-S will have on Early Career Researchers, UK-based researchers not in direct receipt of funding from one of the Plan-S signatories, and international researchers with no recourse to open access funding. Although DORA is supported in principle by many funders and institutions, it is arguable that its effects are yet to be really seen. In practice, most ECRs and later-career researchers continue to target “high impact” journals because of the worry that DORA is not taken seriously. There have been anecdotal reports that even in organisations that have signed up to DORA, DORA-informed procedures are not followed, instead falling back on the impact factor and therefore using where the article was published as a proxy for quality. How are the Plan-S signatories going to ensure that ECRs and others are not going to be disadvantaged by no longer being able to publish in a wide range of hybrid journals? How will DORA or similar initiatives be enforced in practice?
Researchers without Funding for Gold Open Access
If the expectation is that journals will flip to open access models, how will this impact researchers in the UK with no funds for open access (who are unlikely to qualify for waivers or discounts) and researchers based internationally (who may or may not quality for waiver schemes)? It is important that researchers are not priced out of open access journals. We support the Plan-S criteria that the journal must provide APC waivers for authors in low-income countries. However, it is unlikely that even with discounts those in middle- or higher-income countries would be able to pay for gold open access. Therefore, we would encourage further support for non-APC based open access publishing, as well as support for publishers wishing to develop compliant green open access policies but which may be unable to deliver this by 2020 (particularly smaller independent and society publishers). In this regard, we welcome the initiative announced by the Wellcome Trust, UKRI and ALPSP to explore models to help learned societies transition to open access. Working with smaller open access publishers and platforms to ensure they meet the technical requirements for Plan-S should also be highlighted as a priority.
Post 2021 REF Open Access Policy
It will also be useful for UKRI to clarify whether Plan-S apply to the next REF period (i.e. post 2021). The UK REF is administered through UKRI: will Plan-S policies apply to all academic researchers employed in UK HEIs in receipt of any QR funding via UKRI?
Are there other mechanisms or requirements funders should consider to foster full and immediate Open Access of research outputs?
The guidance document specifically states that “cOAlition S does not favour any specific business model for Open Access publishing or advocate any particular route to Open Access given that there should be room for new innovative publishing models”, however non-APC routes to open access seem to be given a back-seat in announcements by the various funders.
Plan-S includes provision for a transitional period which will allow hybrid journals to remain compliant through models like the Springer Compact agreement. However, not all university libraries subscribe to such transitional models (since they cannot or do not need to subscribe to such package deals). Researchers whose libraries subscribe to such models therefore have a significant advantage over those whose don’t, since they will be permitted to publish in a much wider range of journals for another couple of years. Those universities will also be able to deliver more open access articles than institutions only in receipt of a block grant for open access would be able to. We therefore ask for this transitional period to be revisited to ensure it is equitable for all institutions in receipt of funding from Plan-S funders. This may be in the form of providing some institutions with additional funds where they do not subscribe to these transitional agreements, or permitting a degree of non-compliance where funds for APCs have been depleted.
Much discussion and commentary about the Plan-S guidelines has been around flipping journals from a hybrid to fully OA model. Wellcome Trust has indicated that they would permit some funds to be used to support models such as the Open Journal of Humanities platform where authors from a particular institution publish a reasonable amount with them, but have at the same time ruled out using funds to help launch institutional presses. More clarification and justification about what non-APC open access platforms and models would be supported, and what financial support from Plan-S funders are available would be useful. A growing open access publishing infrastructure should involve commercial, society, academic-led, as well as university-led publishing. It is not clear why transitional (i.e. hybrid) models are supported but more sustainable (and probably less expensive) or non-profit approaches are not explicitly supported. We encourage Plan-S funders to allow block grants to be used to help launch more sustainable publishing platforms and university presses, or to make other funds available for such initiatives.
A final concern is the demand put on open access repositories to provide full-text in XML (JATS) format. Realistically, most HEIs are not set up to provide this kind of support in relation to their open access repositories, and repositories such as Europe PMC that do provide this service spend significant amounts in delivering it. These costs cannot be absorbed at an institutional level. Providing full-text in XML format should be a recommended standard but not mandatory.