Over the past several weeks, many in the scholarly publishing world have been reacting to the open access (OA) 10 principles outlined by cOAlition S — a plan now referred to as “Plan S”. The principles laid out were interesting but lacked significant detail leading to loads of conversations trying to imagine what an implementation might look like.

Last week the “implementation plan” for Plan S compliance was posted. The biggest questions going in were whether they would really disallow hybrid models and what the proposed the APC cap would look like.

While at first, the introduction to the implementation plan sounded like a compromise (hybrid okay for now, no cap yet on Article Processing Charges), the devil is in the details. The technical details make clear that the only acceptable solution is author-pays, APC Gold or Platinum OA. This has been mandated by making all other options nearly impossible. Let me explain.

Gold ornaments with strings attached
Strings attached.

Publishing Compliance

The implementation plan describes what kind of OA journal and/or platform would be considered compliant to host papers based on Plan S-funded research. For starters, the journal/platform must be included in DOAJ or be in the process of evaluation and there must be a peer review process that roughly follows COPE guidelines.

Compliant journals must “enable authors to publish under a CC BY 4.0 license (alternatively CC BY-SA 4.0 or CC0).” The word enable seems important. It would appear that an OA journal that gives authors a choice of licenses will still be considered compliant, but that cOAlition S-funded authors will be required to select the abovementioned licenses.

The implementation plan seems to throw a nod in the direction of those who fairly believe that the APC model of OA disadvantages researchers who are underfunded:

“The journal/platform must provide automatic APC waivers for authors from low-income countries and discounts for authors in middle-income countries.”

How this is to be determined is not at all explained. Currently, some journals use the World Bank designations, others use HINARI which is based on World Bank data, and still others make up their own maps. Waivers for APCs is a controversial topic with many complaining that they are unevenly applied. The lack of detail here does not adequately address concerns nor explain exactly what is required.

Presumably, requiring those same “automatic” APC waivers will extend to the hybrid journals ruled to be compliant because they are under what are called, “transformative agreements” (more on this below). While free or heavily discounted access is often provided to the subscription part of the journal, waivers for APCs in hybrid journals are less common given that OA publication in those journals, and hence the charge, is entirely optional.

Reporting Compliance

In order to be a compliant journal/platform, “transparent costing and pricing” is required. Specifically,

“information on the publishing costs and on any other factors impacting the publication fees (for example cross-subsidising) must be openly available on the journal website/publishing platform. This must include details on direct costs, indirect costs, and potential surplus.”

So let’s start with the fact that pricing from vendors is proprietary and often not legally disclosable. Next, we can consider that APCs are not, in fact, what it costs to publish a paper. APCs also cover the costs for:

  1. Rejected articles (those cost money too)
  2. Published papers with waivers (see above regarding mandatory waiver requirements)
  3. Subsidizing other journals

Hold on, why should Author A pay extra so Author B can publish in a different journal? Well, some communities are small. A journal has an expense even before it has papers and some cost more than others. Look at PLOS as an example. Their APC-funded OA, high-end journals that cover specific fields are not financially sustainable on their own. They continue to exist because they are supported largely by surplus generated from APCs paid by authors publishing in PLOS ONE. This is often the truth for any publisher with a suite of journals — some make money, and some don’t even cover their expenses. Those that don’t cover their expenses are still important to the community they serve.

The Plan S implementation document makes mention of commissioning a study to look at costs before it decides on an appropriate cap. Seeing as publishers of different sizes, with different levels of scale, offering different services, in different parts of the world, serving different audiences all have different costs, this should be interesting.

In addition to costs, “potential surpluses” must also be disclosed. That is privileged business information and I question the usefulness of this requirement. Is there an acceptable level of surplus, and if so, who makes that determination? Are the activities of one organization seen as more valiant than the others, allowing for more surplus to be acceptable from publisher A but not from publisher B?

Technical Compliance

Technical requirements on content output are likely to cause problems for some OA journals. Compliant journals are required to have full-text XML of article content set in the JATS DTD. It is important to state that creating properly tagged XML to the JATS DTD is not a simple conversion. Doing this competently can be one of the largest expenses incurred by a publisher. Many newer platforms built for OA journals are not set in JATS.

Citations must be parsed and tagged in the metadata and made available for free in a “standard operable format” (not defined). This would be achieved by signing on to the Initiative for Open Citations and depositing the tagged citations with Crossref to make them available. Reference editing and tagging is often the most grueling part of the composition process. In order to have full reference sections that meet the stated requirements, investment needs to be made for editing, clean-up software, tagging, author querying, and quality control. This is a big ask for smaller operations, particularly those running lean operations in order to keep APC levels down.

Additionally, all funder information must be included in the metadata. Again, some publishers have done this via the Crossref Funder Registry, but many others, including smaller OA journals, have not incurred this expense. Installing this functionality into one’s article submission system can be an expensive and time-consuming task.

A significant number of OA journals do not have archiving set up via partners such as CLOCKSS or Portico. This too is a requirement of compliant journals. Journal must also provide “linking to underlying data, code, and so on available in external repositories.” In order for a journal article to have linking to this information, the author must provide it. It appears that compliant journals must REQUIRE that authors make the “data, code, and so on” available and cite it in the paper. This means additional editorial overhead as each article must be checked for inclusion of this type of content, authors must be chased to provide those links, and those links must be checked to ensure their validity. Again, article submission systems will need to be customized to include these sorts of questions for authors.

All in all, the requirements for Plan S-compliant OA are easily performed by journals owned by commercial publishers and large OA-only publishers. This is not a friendly policy for lower-cost or “community-founded” initiatives or for societies that self-publish and are interested in starting OA journals.

Hybrid Compliance

The Principles released last month included a prohibition on publishing in hybrid journals. This requirement is where a lot of concern about Plan S originated. Hybrid OA allows researchers mandated to publish OA, or those preferring to publish OA, to publish in their journal of choice. Plan S makes this choice more complicated.

Plan S allows for publication in a hybrid journal as long as that journal has a transformative agreement to flip to full OA within three years of the agreement. These agreements need to be signed no later than December 31, 2021. These transformative agreements are essentially the “Read and Publish” agreements with guarantees about flipping to OA in a certain time period.

The implementation plan is, once again, light on details. Read and Publish deals are usually made with a library or a library consortia. These are not the same entities as the funding bodies behind Plan S. If a journal has one such deal with one library, is that sufficient for compliance? How many such deals would be needed? Does the journal need to seek approval from cOAlition S (or from every separate member of cOAlition S) for every deal that is undertaken to determine compliance? Having to run all such deals past multiple bureaucracies would essentially make them impossible to accomplish.

It would be very difficult for a hybrid journal that today only has <10% of its articles OA to make a promise to flip at some specific time in the future. The requirements for APC waivers and discounts may also skew the data. Having a consistent and significant amount of OA articles is only going to precipitate a flip to OA if those papers are collecting the full APC.

Even if a journal has a Plan S-compliant transformative agreement, the funders participating in Plan S can still choose to not pay the APC. This would be similar to the Wellcome Trust model where grantees aren’t prohibited from publishing in hybrid journals, but Wellcome won’t foot the bill.

The implementation plan takes exception to the Mirror Journal concept. The guidelines state that mirror/sister journals (OA version of subscription journals with overlapping editorial boards) will be considered the same as hybrid and therefore, not be compliant. How this is to be determined and monitored (what level of overlap is acceptable?) has not been disclosed.

There is a lifeline thrown to hybrid journals later in the post.

Green OA Compliance

At this point, you may be thinking that Plan S-funded authors should just archive accepted papers in an OA repository and be done with it. Not so fast…this is also about to get a lot harder for Plan S-funded authors.

The implementation plan does allow for authors to post papers on an OA Repository. However, there are lots of strings attached.

First, there can be no embargo and the posted content (either the publisher created version of record of the author accepted manuscript) must by under a CC BY license. For the most part, this can only happen if an author has paid an APC. Journals will not typically facilitate peer review and produce a paper without being able to cover those expenses either through an APC or by selling the content.

To be considered compliant, repositories must meet some difficult technical requirements, including automated manuscript ingest. This requirement moves away from systems where authors have to upload files one at a time. But where might they be ingesting these manuscripts from? The publishers, of course. cOAlition S is requesting that publishers facilitate deposit while declining to pay for it. And looking at the requirements, this may be the only way. Full-text XML in the JATS DTD, tagged metadata “of the same quality criteria of open access journals,” an API, and a “QA process to integrate full-text with core abstract and indexing services.” Finally, it must cost the author nothing to deposit in such a repository.

A question was asked on Twitter…are there any institutional repositories that meet this requirement. The answer, so far, has been no. However, EuropePMC meets the technical requirements, but only for a subset of content.

figshare eagerly jumped in to the conversation to say that they were putting full text XML conversion on their roadmap and bioRxiv is having all their papers converted to XML thanks to funding from CZI.

bioRxiv has a different problem though, it currently only allows an actual preprint—unpublished manuscript, not peer reviewed by a journal — which disqualifies them as a compliant Plan S repository. In fact, while the implementation plan encourages authors to post preprints, what they want to make free is the peer-reviewed version.

And that is where we have a problem. The members of cOAlition S don’t want to facilitate the peer review process for their funded authors. They don’t want to start their own journals like the Gates Foundation or Wellcome Trust have tried. Their stated goal is to eliminate subscription journals and by making the lower-cost OA options onerous to implement, they have devised a plan that calls for author-pays APC-supported Gold OA.

The Loop-hole: Hybrid + Self-Archiving

A cOAlition S-funded author could publish in a hybrid or mirror journal where the publisher offers CC BY as the licensing option. The author can then archive the paper in a compliant repository and meet all of their funder requirements. The only problem is that the funder will not be paying the APC. For wealthier authors with diverse funding sources, those from well-funded institutions, or those with collaborators with access to APC money, this would not be a problem.

Ongoing Expenses

What I find particularly difficult about Plan S is that it does not embrace an OA mechanism that currently exists. It bolts on new requirements to current OA processes, which could be problematic, at least until everyone gets up to speed. The new requirements come at significant expense and it’s not a one-time expense, it’s an ongoing expense. That said, reducing the cost of publishing is not a stated goal of the plan.

What cOAlition S does state is that they want to work toward, “new models of academic publishing,” and mentions that incentives and support will be made by the cOAlition S participants to “open access infrastructure, where necessary.”

While I hope that support will including funding for whatever is envisioned, I can’t help but wonder why a system was not put in place to make the plan successful from the start. The implementation plan, with its expensive and not-really-there-yet requirements, seems to assume that others — publishers, institutions, third parties — will start building this infrastructure at their own expense. Larger publishers are likely to get out of the gate first for compliance, and smaller, independent, and society publishers may never be able to catch up.

Discussion

16 Thoughts on "Plan S: A Mandate for Gold OA with Lots of Strings Attached"

You hit it in the closing: these specifications for and by the majors – Frontiers, Hindawi, PLoS, the BMC/Scientific Reports, etc. portion of Nature/Springer’s portfolio, and such will cruise. Others, not so much. Seems to me, if major private research funding trusts such as Wellcome, Hughes, Gates want to make these sorts of specifications, that’s fine. It’s their money, they can make the rules. For public agencies to bully in and effectively say they favor certain companies over others or non-profits, that seems a problem.

There are two problems with: “The journal/platform must provide automatic APC waivers for authors from low-income countries and discounts for authors in middle-income countries.” Firstly, this would be a very blunt weapon to address a very nuanced need. There are well-funded institutions in low-income countries and poorly-funded institutions in high-income countries.
Secondly, today, there are programmes like Research4Life that provide low-priced subscription access in low-income countries. This is affordable for providers because providing additional access to a digital platform costs almost nothing, a big change from analogue days when it was uneconomical for publishers to discount print for the same cause. However, the same is not true for digital publishing costs – every additional article published increases costs (in the same way as selling another printed book increased costs). So, just as it was uneconomical for publishers to discount books at scale for low-income customers, so it will be uneconomical for publishers to waive/discount APCs at scale for low-income/mid-income authors. Unless of course, they increase APC prices for ‘wealthy’ authors and cross-subsidize.

David Sweeney, the Executive Chair of Research England, has said that wealthier nations should be willing to increase their publication spend in order to pay for less-wealthy nations:
https://www.timeshighereducation.com/news/rich-should-pay-help-poorer-nations-make-open-access-switch

“Where there are costs, let those of us in the wealthier nations take the responsibility for those who cannot afford it,” he said. “I want a culture of openness where it is a truly global scholarly enterprise that everyone can participate in.”

Speaking to Times Higher Education, Mr Sweeney said that wealthy funders “should take some responsibility to make sure that these countries are not excluded as a result” of the shift to open access.

“How we do that is definitely an issue that needs some discussing, but…contributing towards article processing charges is one example,” he said.

I look forward to seeing how much the UK increases its publication budget to pay higher APCs in order to help less fortunate nations, and how it intends to effectively manage that increased spend to achieve this.

On top of that, how do you deal with articles that have a mix of authors from low-, middle-, and high-income countries? What fee would apply to a single author that did the research in a high-income country and has since moved to a low-income one, or vice versa? Any formula that adjusts APC by the makeup of of the author list seems likely to set off an avalanche of unintended consequences.

Spot on, Toby. Also, how does a researcher from a low-income country find out about what waivers are available? The default reaction is “I can’t afford to be published because I can’t pay an APC” because of all the differing policies and lack of clarity. So we’re just replacing one obstacle with another for researchers in the Global South. Never mind making it even harder for those scientists and their institutions to launch their own journals so that they can play an equal role in the scholarly communications ecosystem!

Ah, what we are learning is that the devil is in the details. And, the details are being given by those who don’t know what they are doing! If I were a betting man, I would say that Plan S will be about as successful as the Soviet Five Year plans.

Intrigued by the comment that vendor (publisher) costs “are not legally disclosable”. I am not aware of any law in any country that prevents companies from declaring their costs. So I presume what is really meant is “vendors (publishers) often choose not to declare their costs” – something which is quite different, and which makes it clear that publishers could choose to disclose their costs if they wanted to.

One potential example would be a publisher that has a contract with a vendor that includes a non-disclosure clause for the rates being paid. In order to be compliant with Plan S, the publisher would need to re-negotiate all such contracts which 1) may take a very long time, 2) may incur significant legal support costs, 3) may result in less favorable terms to the publisher given the time pressures involved and the vendor having them over a barrel and 4) may require the publisher to move to a different solution if the vendor chooses not to be compliant, resulting in switching costs.

All of which means higher APC levels for researchers to cover those costs.

All this to amend a non disclosure clause? Sorry, I worked in publisher/vendor contracts for 12 years, and know your statement is nonsense. It could be done quickly and economically if the will is there, with no requirement to increase APCs.

“If the will is there” is perhaps a bigger issue than it appears. Why do some companies want non-disclosure of the rates they’re charging customers? If that vendor feels that everyone knowing what everyone else is charging will significantly harm its revenues, there may be some resistance.

It’s also not clear what reporting is required. Perhaps one could lump all such activities under a vague “Direct Costs” and “Indirect Costs” lines in a report and not expose the specific costs paid to specific vendors. Not sure this would be considered compliant, but at this point, who knows.

Regardless, a review of all agreements would seem necessary, and it’s but one of many time consuming and potentially expensive roadblocks to compliance, even if it is eventually a resolvable one. It is also another advantage for larger publishers who handle most things in-house rather than outsourcing them to a contracted vendor, so score another point for the big commercial houses.

Hi – just setting the record straight – “However, EuropePMC meets the technical requirements, but only for a subset of content.” Actually all incoming full text content is in XML – only a fraction of older content is not (12+ years).

EuroPMC describes itself as “a full text literature database for the life sciences.” Not all research being done is in the life sciences, hence their remit covers only a subset of the content being created.

As I understand the requirements, it is only repositories that have to store full text in JATS. Journals must ensure “Availability of the full text (including supplementary text and data when applicable and feasible) in machine readable format (for example XML), allowing for seamless Text and Data Mining (TDM).”

Martin, you are correct. Though that seems very odd to me. Why would a repository collected author accepted manuscripts be held to a higher technical standard than journals?

Yesterday COAR published a statement on the implementation guidelines of Plan S, might be interesting for readers of this blog who want to know what the repositories themselves think:

https://www.coar-repositories.org/activities/advocacy-leadership/open-science-and-sustainable-development/

Excerpt from their statement: The Confederation of Open Access Repositories (COAR) reiterates our support for the goal of Plan S to achieve “immediate Open Access to all scholarly publications from research” and we appreciate the opportunity to provide feedback on the guidance on the implementation of the Plan. We recognize and agree with the aim of transforming the publishing industry, however to truly improve and transform the system there needs to be a multipronged approach, with a number of actions undertaken concurrently. We would like to stress the importance of repositories as complementary mechanisms for advancing innovation in research communications, as outlined in the COAR Next Generation Repositories report and ensure that their role is adequately reflected in Plan S. In general, COAR supports the implementation guidelines outlined in Plan S and therefore we will focus our comments on the requirements for repositories. COAR and others in the repository community have significant concerns related to several of the requirements for repositories, a number of which we argue are not necessary and will create artificial barriers to the participation of universities and other research organizations in the scholarly communication system. While some of these recommendations may be ‘nice to have’, they are not prerequisites for robust and interoperable repository services. Instead they could result in driving repository functionality in the wrong direction, create too high of a bar for less resourced institutions, and further centralize research infrastructures and services because they cannot be adopted, leading to a replication of the existing inequalities in the scholarly communication system. [see https://www.coar-repositories.org/files/COAR-response-to-implementation-of-Plan-S-1.pdf for full statement]

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