However, if you were hoping for a revision that delivered simplicity, clarity, and practicality, I would urge you to look elsewhere. These changes compound the problems within the initial policy, add some new problems, and have all the markings of an enforcement and bureaucratic debacle.
With this revision, the RCUK is outlining a policy for universities and publishers that seems sure to trap UK scientists and universities in their own bedclothes for years to come.
The flowchart offered in the RCUK’s revised policy attempts to outline the new policy’s implications and process graphically. It was produced by the Publishers Association, and endorsed by the RCUK. This decision tree elides some important elements — notably, who is implementing and enforcing each step and at what cost — while also sowing confusion:
In this flowchart, if I’m a scientist funded by RCUK money, I have to choose a Gold OA publisher or put my paper in a repository within six months of publication. Already, we have an enforcement step — someone has to check up on these matters. We’ve seen that compliance with such deposit requirements is low if not enforced, and the RCUK policy is silent on how it may be enforced and how they’ll fund enforcement.
But let’s assume I want to follow the Gold OA route. The next question is, Are there APC funds available? The plan is that these will be distributed by block grants, so the real question is, Does my institution have any money left from its RCUK block grants? If so, I can apply for these funds, which will be managed by a university body yet to be invented (and an administrator I do not envy). If no funds remain, I can publish somewhere that allows Green OA after 12-24 months.
Can I hear UK academics praying for the APC funding to be exhausted? After all, then they can publish almost anywhere without having to face a panel of faculty members and administrators to fend for APC funding.
I’ll return to the issue of academic freedom, because it’s critical. Let’s look at a few major levers in the policy, one by one, to try to see what the RCUK is trying to say, and potentially what could really happen.
Block grants — The revised policy states that universities will receive block grants based on an estimate the RCUK makes through a process they have yet to explain. The primary purpose of these grants is to fund Gold OA, but the RCUK concedes in this revision that the grants can be used for secondary purposes, as well. (In addition, block grants are being distributed now, but enforcement is five years hence, leaving me to wonder exactly why universities struggling with funding won’t use the block grant funds for other things before enforcement arrives.) The most likely of these secondary purposes once enforcement begins will be to cover the overheads involved with accepting, managing, and disbursing the funds. Overheads usually run about 30%, so I think we’ll likely see that level of diversion from the block grants’ primary purpose. After all, disbursing these funds will not be an easy chore, and will likely involve faculty and staff from multiple areas, meeting frequently enough to not slow down article submissions, especially in competitive areas. There will need to be administrative support, record-keeping, and so forth. Block grants will be administered differently at various universities, so there won’t be economies of scale; they will become a bone of contention feeding academic politics and in-fighting; and policies around disbursement (and remediation, in cases in which a paper is rejected) will require a lot of attention.
Embargoes — Taking the flowchart at face value, the question of embargoes has an interesting answer in this scenario. That is, when the publisher doesn’t want to offer Gold OA or scientists don’t want to publish in a journal offering Gold OA, the embargo is short (six months, except for art, humanities, and social science papers). However, if the universities have expended their APC block grants, the embargo goes to 12-24 months — but only for publishers offering Gold OA who can’t have it paid. But what would PLoS Medicine do in such a situation? They are currently only set up to accept APCs. If the RCUK grant at University H has run out, yet Researcher H has decided that PLoS Medicine is the best venue, what is the university, researcher, or PLoS Medicine to do? Do OA journals need to start up a subscription option much as many subscription journals have set up an OA option? Does PLoS Medicine grant a waiver? Or is this decision tree missing a few branches?
Funding — Research applications to RCUK will no longer be permitted to include OA or other publication charges, as of April. This puts the entire onus for OA funding on the block grants. How this affects authors in multi-national groups is unclear; after all, if an author funded in Australia works with an author funded by the RCUK, which policy is the group publishing under? Can they choose? How the funding is escrowed during peer review and rejection cycles is also unclear. There is also the question of how publishers are paid. Do they invoice the university once they accept a paper? What if the block grant has run dry during the “net 30” or “net 60” interval? In a Times Higher Education story covering the revision, an RCUK spokesperson noted that if a university “eked out” its block grant over the course of a year, it could insist on the shorter embargo. There is no incentive for funding to be stretched, however; researchers and universities have no reason to view the market solely through small block grants, and their choices of publishing venues actually expands once block grants are exhausted. If those block grants actually exist, that is — there is an interesting aside in the revision document:
We are aware that a number of research organisations that receive Research Council funding are not in receipt of an RCUK OA Block Grant. If evidence can be provided of this causing significant problems, we will consider this as part of the 2014 review.
In other words, the complaints have started, and the bureaucracy is responding with bureaucracy.
Individual journals are unlikely to be heavily motivated by whatever the RCUK implements, except in some edge cases where RCUK-funded papers provide a large proportion of a journal’s content. Otherwise, no single journal is likely to get a high concentration of RCUK-funded research — there are too many journals, and more every month. If a journal misses out on one paper from an RCUK-funded group, tears will not be shed. The RCUK is likely overestimating its potential to affect the market in any appreciable way.
The dilemma at the heart of this is that the policy pits academic freedom against fiscal policy. To address this, the revised policy states that the RCUK plans to increase funding for APCs over the next five years so that all papers derived from RCUK funding are OA. There are no concrete plans for this, nor can there be, as the document also states later that the RCUK does not specify an upper or lower limit on the level of APCs paid out of block grants. How can you budget for something if you don’t know the price or the volume?
The conflict with academic freedom becomes clear in a section where the RCUK urges institutions to “work with” authors so that price is a factor taken into account for publication decisions, and point to a list “which puts no weight on the impact value of journals in which papers are published.” In other words, putting your work in the right venue and getting the highest impact setting possible isn’t as important as the financial aspect — we want your institution to “work with you” (euphemism noted) on establishing a market, but please refer to a list that puts no weight on impact metrics.
This dilemma was identified a few years ago in a post on the Kitchen by Phil Davis. There is an interesting footnote to the piece:
The pay-to-read (aka subscription) model avoids conflicts with academic freedom. Authors are not limited by their institution as to where they publish their work, only that there is no guarantee that their institution will provide access to that work. Librarians make choices over which titles provide good value for their institution, and through their collective choices, have moderating effects on market prices. I see no way in a author publication fund model to exert market forces and still allow authors the freedom to decide where they publish their work.
There is no doubt the RCUK’s efforts are a sincere attempt to implement a nationwide system of OA publication. However, their approach has already raised hackles, and incremental changes are making the approach seem more obtuse and unmanageable. If the RCUK thought it would blaze a trail the rest of the world would eagerly follow, they were mistaken, as the recent OSTP policy memo and the Australian policies show. And if the RCUK believes these revisions increase the odds of success, I believe the emerging picture of bureaucratic layers, promise of fights over scarce funding, implications for academic freedom, and relatively small size of the UK research community all indicate very rough waters ahead.