My draft response to the UKRI OA consultation

Some of my draft responses to the UKRI OA consultation.

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)?

Agree

If anything is unclear, please explain why (1,350 characters maximum, approximately 200 words).

This could be made clearer by specifying that the technical standards requirements must be met by any “OA platform”.

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?

No opinion.

Q3. In setting its policy, should UKRI consider any other venues for peer-reviewed research articles which are not stated in paragraph 47?

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?

Yes

Please explain and, where possible, evidence your answer.

I write in several capacities. As a CEO of the Open Library of Humanities, we have no problem complying with the terms as all of our articles are gold OA and openly licensed, although we do at present allow licenses that are not permitted under the policy, mostly to accommodate third-party rights inclusion. As a researcher, I would need to see movement towards a zero-embargo green policy at many of the venues in which I have published over the past few years to see compliance.

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?

Yes

Please explain your answer

Doing so has multiple advantages. First, it ensures the widest dissemination and discoverability of the material via interoperative metadata standards. Secondly, despite the labour overhead of deposit, it helps institutions to help researchers comply with the policy. It is very difficult to monitor adherence in an open, distributed environment. Thirdly, it enhances the digital preservation of these artefacts by redundant, multiple backups.

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?

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 OGL where needed) should be required for the deposited copy?

Disagree

Please explain your answer (1,350 characters maximum, approximately 200 words).

I believe that an open license of some kind should apply to work deposited in a repository, if at most to allow open copying of content. However, as in my other responses, I believe that UKRI should adhere to the Plan S principles that it has signed and permit the CC BY-SA license. The Plan S document states that ‘cOAlition S will, as secondary alternatives, accept the use of the CC BY-SA 4.0 license, and use of the public domain dedication, CC0’. Either of these licenses should be acceptable and would allay many of the fears of publishers.

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.

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).

I believe ND to be among the most harmful of the CC licenses, disallowing most of the beneficial implications of open licensing (translation, format shift, mining etc.). It is not strictly necessary for third-party material to be included, which can be excluded from the license. (Although there is a broader problem of third-party material encapsulated within any document [such as a PDF] that purports to be openly licensed, since one cannot disseminate the PDF without violating the copyright of the non-licensed material within.)

Q9. Would the proposed licensing requirements for UKRI’s OA policy, which exclude third-party content (see paragraph 55), affect your or your organisation’s ability to publish in-scope research articles containing third-party content?

Yes

If yes, please explain how (1,350 characters maximum, approximately 200 words).

We at OLH continue to experience misunderstanding from museums about the licensing of third-party material even in the digital, let alone open, world. They consistently ask us for a “print run” and cannot understand that we want to disseminate the material openly, forever, infinitely, online. A concerted effort is needed to change the licensing models of museums, galleries, archives, and libraries to accommodate digital publishing. When they do have knowledge, they generally ask us for even more restrictive licensing and the entire process becomes somewhat protracted.

Q10. Are there other considerations UKRI should take into account regarding licensing requirements for research articles in-scope of its proposed OA policy?

Yes

If yes, please expand (1,350 characters maximum, approximately 200 words).

As above, I believe that UKRI should, as a Plan S signatory, offer CC BY-SA as an alternative, as specified in the cOAlition S document.

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?

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?

a. UKRI should require an author or their institution to retain copyright and not exclusively transfer this to a publisher

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).

It is important that institutions or authors retain copyright rather than transferring it or exclusively signing away all rights. Such a policy ensures that institutions will always be able to meet the other terms but also could allow for future re-use of material without the formal need for attribution by the author him/her/them -self.

However, the wording on “retain copyright and not exclusively transfer this to a publisher” needs to be much tighter. At present, it is not always a copyright transfer, but an exclusive license of all rights, which is not the same as a transfer.

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):

a. Strongly agree

b. Agree

c. Agree

d. Strongly Agree

e. Disagree

f. Agree

g. Agree

For each of the seven standards (see paragraphs 67a-67g), please explain your answer (700 characters maximum, approximately 100 words, per standard).

a. PIDs are important for the unique identification of content and the extraction of its metadata. b. It would be helpful to have more information about what these openly licensed profiles will be. Crossref schema metadata is usually deposited at Crossref, not made openly available on the publisher platform. c. Again, this is easy in JATS XML and in Crossref deposits via the AL tag, but it is not clear how this should be embedded in PDF and HTML files. More clarity on how precisely this machine readable information should be encoded is needed. d. Preservation is important. How equivalence to Portcio or CLOCKSS is determined should be specified. e. I disagree with this. It adds substantial publisher overhead (and costs) and is not well used except in data analytics projects that often misuse citation data for crude ends. Some types of reference – such as archival finds – are incredibly difficult accurately to encode as element-citations in JATS, rather than mixed-citations, which miss all the benefits. f. This is a good idea. g. ORCID is useful for contributor identification and should be included.

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? For each of the five standards (see paragraphs 68a-68e):

a. Disagree b. Agree c. Agree d. Agree e. Agree

For each of the five standards (see paragraphs 68a-68e), please explain your answer (700 characters maximum, approximately 100 words, per standard)

The only comment I have is on a. There is a risk here of duplicating identifiers for the same content, thereby diluting usage metrics and canonical endpoints. Further, the assignation of Crossref DOIs requires a membership (at cost) as well as membership to a digital preservation service (the PILA agreement requires this). It is not viable for most organizations running an institutional repository to also deposit metadata with Crossref to assign DOIs. (Though it may be possible with another registrant.)

Q15. To support the adoption of technical standards for OA, are there other standards, actions and/or issues UKRI should consider?

Yes

Please explain your answer (2,650 characters maximum, approximately 400 words).

UKRI should insist on funder metadata deposit with Crossref DOIs (“fundref”).

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), are there any technical standards or best practices that UKRI should consider requiring?

No opinion.

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

Please explain your answer. UKRI particularly welcomes detailed evidence as to the practical implications of the choice of date. If you selected b or c, please also state what you consider to be a feasible implementation date (2,000 characters maximum, approximately 300 words).

There are many publishers who already have zero-embargo green OA, even if only in some disciplines (Cambridge UP, SAGE, and Emerald all have such policies), so there is no reason why the policy cannot apply from the selected date and other publishers will just have to adapt.

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-afterREF 2021?

Don’t know

Q19. Do you think the proposals outlined in Section A will have any financial cost implications for you or your organisation?

Yes

Please expand, providing evidence to support your view, where possible (2,000 characters maximum, approximately 300 words).

Potentially, the following at my university: membership of Crossref, membership of a digital preservation organization.

At the publisher that I run, OLH, potential development time to comply with all technical reqirements.

Q20. Do you think the proposals outlined in Section A will result in financial benefits for you or your organisation?

Yes

Please expand, providing evidence to support your view, where possible (2,000 characters maximum, approximately 300 words).

The potential to access resources openly helps us to ameliorate our subscription library budget at our university.

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?

Q22. Can you provide any evidence on cost increases and/or price rises (including in relation to OA APCs 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

Please expand. Views are also welcome on how greater transparency might inform future funding levels (2,000 characters maximum, approximately 300 words).

There are things that can be done to improve transparency, such as giving levels of profit/surplus for organizations. However, I would strongly advise against always making this into a per-article breakdown. There is no uniform cost per article and atomising breakdown in this way creates substantial difficulties in terms of reporting overhead while fostering unrealistic expectations.

Q24. Regarding UKRI’s consideration about restricting the use of its OA funds for publication in hybrid journals (see paragraph 80), please select the statement that best reflects your views:

a. UKRI OA funds should not be permitted to support OA publication in hybrid journals

Please explain and, where possible, evidence your answer (2,650 characters maximum, approximately 400 words).

All recent reports on OA expenditure have shown hybrid to be universally more expensive. For instance, The Wellcome Trust’s recent report ‘The Reckoning: An Analysis of Wellcome Trust Open Access Spend 2013 – 14’ said that ‘The average APC levied by hybrid journals is 64% higher than the average APC charged by a fully OA title’. It is not a cost-effective use of UKRI resources to support publication in venues that will cost more to the public purse. A good summary of evidence of hybrid’s cost can be found at https://unlockingresearch-blog.lib.cam.ac.uk/?p=969

Finally, UKRI would be acting against its signature to the Plan S declaration if it decided to allow publication in hybrid venues.

Q25. To what extent do you agree or disagree that UKRI OA funds should be permitted to support OA costs that support institutional repositories?

Strongly Agree

Please explain and, where possible, evidence your view (2,650 characters maximum, approximately 400 words)

It is not free of cost to run institutional repositories and, given that these form a primary delivery route for the policy, their costs should be able to be charged against UKRI OA funds.

Q26. To help accelerate policy adoption, should UKRI introduce any other restrictions on how UKRI OA funds can be used?

No opinion.

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

Please expand (2,650 characters maximum, approximately 400 words).

It should be acceptable for institutions to spend their UKRI budget on subscribe-to-open and membership models, provided they then make a good effort to promote these to their researchers. These models are hugely cost effective and distribute funding in a way that promotes broader open-access uptake. However, these models cannot simply be supported retrospectively once a researcher has published in them (this would neutralise their difference and transform them to mere APC setups); they rely on broad support and that not every institution may “use” its membership to publish in a given year. Therefore, institutions should be allowed to use UKRI funds for such memberships, on the understanding that researchers who ask about publication will be directed to such venues.

Q28. As discussed in paragraph 74, 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?

No opinion.

Please expand (2,650 characters maximum, approximately 400 words)

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

If yes, please state what these are and explain and, where possible, evidence why UKRI should provide support (2,650 characters maximum, approximately 400 words).

UKRI should support the SHERPA infrastructures.

Q30. To what extent do you agree or disagree that UKRI should provide or support a national shared repository?

Strongly agree

Please explain and, where possible, evidence your answer (1,350 characters maximum, approximately 200 words).

This is a brilliant idea that would provide another OA outlet for material, thereby increasing discoverability, dissemination, and preservation of outputs. It would also ensure that no researcher fell through the cracks of not having a repository in which to deposit the work.

Q31. Should UKRI require preprints to be made OA where there is a significant benefit with regard to public emergencies?

Yes

If yes, is there a recognised definition of ‘public emergency’ and/or protocols that UKRI should consider if this policy is implemented? (1,350 characters maximum, approximately 200 words.)

The threshold here is virtually impossible to define. An instance of serious illness is always an emergency/important for the individual suffering from it, but quantifying this suffering for preprint purposes is callously quantifying. If there is value in preprints, they should be required for everything.

Q32. Are there any supporting actions that UKRI could take alongside its OA policy to support the use of preprints in all disciplines?

Yes

If yes, please expand (1,350 characters maximum, approximately 200 words).

A shared national repository that supports preprints could help here.

Q33. To what extent do you agree or disagree that the types of monograph, book chapter and edited collection defined as in-scope and out-of-scope of UKRI’s proposed OA policy (see paragraphs 96-98) are clear?

Disagree

If you disagree, please explain your view (2,000 characters maximum, approximately 300 words).

The specific criteria for trade books should be more clearly defined. What are the expected print runs? What marketing activities are to be expected? Where should the volume appear? (i.e. in bookshops?) What are the associated media profiles of such works? Without these it will be too easy for claims to be made that books are ‘trade’.

Q34. Should the following outputs be in-scope of UKRI’s OA policy when based on UKRI-funded doctoral research?

a. Academic monographs Agree b. Book chapters Agree c. Edited collections Agree

Please explain your view (1,350 characters maximum, approximately 200 words).

It would be excellent for these items to be openly available. However, there are some challenges. Foremost among these is that the production of a first academic monograph – or even the other output types – takes place while the author will no longer have access to any UKRI funding and perhaps not to an institutional repository. There must be provisions made for how such individuals can access UKRI OA funding and/or repository systems. Further, care needs to be taken to specify what the link is between the output and the thesis? How is ‘based on’ to be decided if, say, a total rewrite is undertaken?

Q35. To what extent do you agree or disagree that UKRI’s OA policy should include an exception for in-scope monographs, book chapters and edited collections where the only suitable publisher in the field does not have an OA programme?

Disagree

Please explain and, where possible, evidence your view (1,350 characters maximum, approximately 200 words).

I am sceptical that a definition of “only suitable publisher” can be found that doesn’t just allow too wide an exception. Is this the only publisher that exists in the field (and how is “the field” defined?) and what about broad remit publishers such as Palgrave Macmillan or Open Book Publishers? What if the “only” OA publisher in “the field” declines a contract to the author? Does this constitute a lack of suitability?

Q36. Are there any other considerations that the UK HE funding bodies should take into account when defining academic monographs, book chapters and edited collections in-scope of the OA policy for the REF-after-REF 2021?

Q37. Regarding monographs in-scope of UKRI’s proposed OA policy, which statement best reflects your view on the maximum embargo requirement of 12 months?

a. 12 months is appropriate

Please explain and, where possible, evidence your answer. If you answered b, c or d please also state what you consider to be (an) appropriate embargo period(s) (1,350 characters maximum, approximately 200 words).

Most sales of academic books take place within the first 18 months (with inverse proportionality to rank in the frequency table – see the recent Fullstopp report, https://www.universitiesuk.ac.uk/policy-and-analysis/reports/Documents/2019/Fullstopp-Final-October-2019.pdf p. 52), so one could extend the limit upwards to this bound. However, the majority are within the 12 month period.

The embargo should also be determined not by the citation or usage half-life, but by the sales curve.

Q38. Regarding book chapters in-scope of UKRI’s proposed OA policy, which statement best reflects your view on the maximum embargo requirement of 12 months?

a. 12 months is appropriate

Q39. Regarding edited collections in-scope of UKRI’s proposed OA policy, which statement best reflects your view on the maximum embargo requirement of 12 months?

a. 12 months is appropriate

There is no evidence of these volumes having a different sales curve, so the embargo should be the same.

Q40. Do you have any specific views and/or evidence regarding different funding implications of publishing monographs, book chapters or edited collections with no embargo, a 12-month embargo or any longer embargo period?

Yes

If yes, please expand (2,000 characters maximum, approximately 300 words).

Several studies have tried to gauge the impact of OA books upon revenue models for publishers, but with only limited success (the OAPEN-UK project, for example). It is also the case that, if it is expected that books will become OA, libraries may opt not to purchase. However, on the other side, there is still a strong preference for print books, which may indicate that OA can serve as a discovery mechanism and bolster print sales.

Q41. To what extent do you agree that self-archiving the post-peer-review author’s accepted manuscript should meet the policy requirement?

Strongly agree

Please explain and your view (1,350 characters maximum, approximately 200 words).

This is a sensible view as many of the existing models for OA book publication – such as the Book Publication Charge – remains impossible for most researchers.

Q42. Regarding monographs, book chapters and edited collections, are there any additional considerations relating to OA routes, deposit requirements and delayed OA that the UK HE funding bodies should take into account when developing the OA policy for the REF-after-REF 2021?

No opinion.

If yes, please expand (2,650 characters maximum, approximately 400 words).

Q43. To what extent do you agree or disagree with CC BY-ND being the minimum licencing requirement for monographs, book chapters and edited collections in-scope of UKRI’s proposed OA policy?

Disagree

Please explain and, where possible, evidence your view (1,350 characters maximum, approximately 200 words).

The BY-SA license should also be allowed. The Plan S document states that ‘cOAlition S will, as secondary alternatives, accept the use of the CC BY-SA 4.0 license, and use of the public domain dedication, CC0’. This license would allay many of the fears of publishers and I have had open-access books published by Stanford University Press and Cambridge University Press under these licenses. They simply ensure that re-use of the content remains open for others to re-use and would stop the “pirate” practices that many other publishers fear (i.e. being undercut by printing houses simply taking their work and printing it).

Q44. To what extent do you agree or disagree that UKRI’s OA policy should include an exception for in-scope monographs, book chapters and edited collections requiring significant reuse of third-party materials?

Agree

Please explain your view (1,350 characters maximum, approximately 200 words). Questions 45-46 concern how ‘significant reuse’ may be defined.

We have experienced significant licensing hurdles around the inclusion of third-party material. There is, in fact, a broader problem of third-party material encapsulated within any document [such as a PDF] that purports to be openly licensed, since one cannot disseminate the PDF without violating the copyright of the non-licensed material within. Having liberal exemptions here will make this much easier, though I still believe that the original text, without third-party material, could usefully be made open access.

Q45. To what extent do you agree or disagree that if an image (or other material) were not available for reuse and no other image were suitable, it would be appropriate to redact the image (or material), with a short description and a link to the original?

Agree

Please explain your view (1,350 characters maximum, approximately 200 words).

This is much better than nothing. Although art historians have noted that it will greatly impoverish the work, one could think of the same thing in the context of literary criticism, replacing quotations with “see p. 26, line 15 in novel X” and it would still be helpful to have the surrounding critical argumentation.

Q46. Do you have a view on how UKRI should define ‘significant use of third-party materials’ if it includes a relevant exception in its policy?

If yes, please expand (2,000 characters maximum, approximately 300 words).

Q47. Do you have any other comments relating to licensing requirements and/or the use of third-party materials, in relation to UKRI’s proposed OA policy for academic monographs, book chapters and edited collections?

Yes

If yes, please expand (1,350 characters maximum, approximately 200 words).

Please revisit CC BY-SA, as above, and as per the Plan S declaration.

Q48. Regarding monographs, book chapters and edited collections, are there any additional considerations relating to licensing requirements and/or thirdparty materials that you think that the UK HE funding bodies should take into account when developing the OA policy for the REF-after-REF 2021?

Q49. Which statement best reflects your views on whether UKRI’s OA policy should require copyright and/or rights retention for in-scope monographs, book chapters and edited collections?

a. UKRI should require an author or their institution to retain copyright and not exclusively transfer this to a publisher

Please explain and, where possible, evidence your answer. 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). It is not necessary to repeat here, in full, information provided in response to question 12.

Please see my response to section 12 over the care needed in the wording around “transfer”.

Q50. Regarding the timing of implementation of UKRI’s OA policy for monographs, book chapters and edited collections, which statement best reflects your view?

a. The policy should apply from 1 January 2024

Please explain and, where possible, evidence your answer. If you selected b or c, please also state what you consider to be a feasible implementation date (2,000 characters maximum, approximately 300 words).

This proposed date is over a decade since the Crossick report, which called for extensive experimentation and preparation. This should have proved ample time for the publishing industry to have adapted, although it likely has not.

Q51. In order to support authors and institutions with policy implementation UKRI will consider whether advice and guidance can be provided. Do you have any suggestions regarding the type of advice and guidance that that might be helpful?

No.

Q52. Regarding monographs, book chapters and edited collections, are there any other considerations that UKRI and the UK HE funding bodies need to take into account when considering the interplay between the implementation dates for the UKRI OA policy and the OA policy for the REF-after-REF 2021 OA?

Yes

If yes, please expand (2,650 characters maximum, approximately 400 words).

The long pre-contract lead time must be factored in, with a high number of initial exemptions to be expected.

Q53. Do you have any views regarding funding levels, mechanisms and eligible costs to inform UKRI’s considerations about the provision of funding for OA monographs, book chapters and edited collections in-scope of its proposed policy?

Yes

If yes, please expand (2,650 characters maximum, approximately 400 words)

Please see our article on the funding costs of OA monographs: Eve, Martin Paul, Kitty Inglis, David Prosser, Lara Speicher, and Graham Stone, ‘Cost Estimates of an Open Access Mandate for Monographs in the UK’s Third Research Excellence Framework’, Insights: The UKSG Journal, 30.3 (2017) https://doi.org/10.1629/uksg.392

Q54. To support the implementation of UKRI’s OA policy, are there any actions (including funding) that you think UKRI and/or other stakeholders should take to maintain and/or develop existing or new infrastructure services for OA monographs, book chapters and edited collections?

Yes

If yes, please state what these are and, where relevant, explain why UKRI should provide support (2,650 characters maximum, approximately 400 words).

Supporting the Directory of Open Access Books and requiring deposit would be a good step.

Q55. Are there any technical standards that UKRI should consider requiring and/or encouraging in its OA policy to facilitate access, discoverability and reuse of OA monographs, book chapters and edited collections?

Don’t know

Q56. Do you have any other suggestions regarding UKRI’s proposed OA policy and/or supporting actions to facilitate access, discoverability and reuse of OA monographs, book chapters and edited collections?

Q57. Could the manual reporting process currently used for UKRI OA block grants be improved?

Don’t know

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 (2,000 characters maximum, approximately 300 words).

A threat that will not be carried through is hardly a threat and sanctions should be applied.

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)?

No opinion.

Q60. Do you foresee any benefits for you, your organisation or your community arising from UKRI’s proposed OA policy?

Yes

Please expand (2,650 characters maximum, approximately 400 words).

I am extremely enthusiastic about the prospect of more and more high-quality funded research being available to read without barriers. I waste substantial portions of my academic working life trying to gain access to material. This OA policy will contribute towards fixing that.

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 (2,650 characters maximum, approximately 400 words).

Although I have replied, “yes”, I actually believe “no” and have done so in order to posit counter-arguments to aspects here that others have raised to me.

“Early-career researchers will be disadvantaged”. This is often posited as a reason, claiming that it will be harder for ECRs to get academic jobs if OA monographs (in particular) are mandated. This is disingenuous. The very same senior scholars who advance this argument control the career paths and evaluation that they posit as though it were some objective force of nature.
Arguments for disadvantage here neglect the disadvantages conferred on those with, say, disability and illness who cannot currently travel to a library when OA copies are not available. In this respect, the policy HELPS with inequality and disadvantage.
The proposed green routes eliminate any inequality of access to funding for gold OA.

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 LMICs?

Yes

If yes, please expand, referencing specific policy elements and including any comments on how UKRI could address any issues identified (2,650 characters maximum, approximately 400 words).

This OA policy contributes positively to knowledge exchange and intercultural educational approaches with LMICs. There is also much that we can learn from the existing open ecosystems of scholarly communication in LMICs and this exchange must be bidirectional.

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?

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?

Martin Paul Eve

My draft response to the UKRI OA consultation

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