Today is the last day of a consultation by Research Councils UK (RCUK) on its draft policy on Access to Research Outputs [PDF]. The proposals are a clear and strong statement that RCUK-funded research should be made available via open access (OA). It goes far beyond the current OA offerings from some publishers and represents a welcome statement of support for the OA movement. Where the policy is less strident is on open access to research data and related materials.

I copy my email to RCUK below.

Dear Sir or Madam,

I am writing in regard to the consultation on the draft proposals for a new RCUK policy on Access to Research Outputs.

I welcome the RCUK’s lead on the issue of open access to RCUK-funded research outputs and am pleased that a strengthening of the current policy is proposed.

In particular the requirement for Open Access (OA) to mean CC-BY is a significant improvement over the current policy; it is abundantly clear what RCUK means by OA and leaves no scope for ambiguity. Some journal publishers, most notably Elsevier, have been obfuscating the term “Open Access” with their own decidedly non-OA offering. If these publishers wish to publish papers on RCUK-funded research they will have to adopt the industry standard for Open Access that is inscribed in the Budapest Open Access Initiative.

The lack of a non-commercial clause in the draft policy is important. Without a specific RCUK definition of “commercial”, a non-commercial clause would lead to a degree of ambiguity on what was and was not allowed and would allow publishers to define their own terms for commercial use. If there is one group that should not be determining the scope of commercial exploitation of research papers it is academic publishers, who have provided naught but the final typeset manuscript. It behoves RCUK and UK scientists to allow the widest possible use of their research outputs. The tax-payers that fund this work should expect that the maximal benefit be derived from the research and that is not achievable if access to the published record is restricted to non-commercial activities. In short, a non-commercial clause would be a barrier to the widest possible dissemination of RCUK-funded research outputs.

The mix of Gold and Green OA allows a staged progression towards Gold OA which should be considered the ideal method of making scholarly research OA. Until a sustainable funding model is in place that does not in itself restrict dissemination due to an insufficiency of funds Green OA represents a workable compromise. However, the individual research councils should specifically mandate suitable repositories. Green OA works need to be discoverable and easily searched, linked to etc. For Gold OA publisher’s websites provide easy access to papers that are discoverable via web searches and tools such as Web of Knowledge and Scopus. Green OA is a different case and without a strong lead from RCUK we risk fragmentation of the OA versions of research outputs that will limit the scope of access. A repository (or repositories) similar to UKPMC is required for the remaining research councils and RCUK should look to invest in such a service for the entire UK academic community.

The statements in the policy setting out the requirements journals need to meet to be compliant with the draft policy are a welcome addition. There has been little or no regulation of the OA publishing industry and as such there is a wide variation in what is meant by OA and how it is provided by the journals. The compliance statements should help introduce an accepted standard for OA to the STEM publishing environment.

Whilst, in an ideal world, there should be no need for embargo periods I accept that for a period of transition an embargo of no more than 6 months be the policy or one that is worked towards. The policy should indicate that this is an interim measure and that the RCUK will strive towards removing the acceptance of an embargo from future versions of the policy.

The policy on “How Open Access [is] paid for” represents a clear statement that the required costs to the scientists and institutions of implementing the policy can be met directly from grant funds or from overheads. RCUK will need to work with institutions to ensure that appropriate increases in Indirect Costs are allowed on grant applications in order that sufficient an institutional fund be available so as to not restrict dissemination of research findings for lack of funds.

Section 8 on access to research materials is the one weak area of the proposed policy. The draft fails to appreciate that it is not access to the underlying data that is of sole importance; the ability to discover those data and make links between disparate data sets are equally important. Hence the establishment of data/research material repositories such as /inter alia/ Dryad and Figshare. The rest of the policy acknowledges that tax payer-funded research outputs should be freely available and does so in a clear and strong manner. The policy on data is particularly weak but open data of is fundamentally the same nature as OA publication. Appropriate meta data allow links between data to be made that might not otherwise be identified or appreciated. The RCUK should mandate that data collected as part of council-funded projects be deposited in one of a series of approved repositories.

Yours sincerely

Dr Gavin Simpson Department of Geography UCL


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