Many thanks to Brian Lynch and Les Carr for providing quote/commentable versions of
Lord Rees's letter to the Fellows who signed the
Open Letter to the Royal Society dissenting from the Royal Society's
Position Statement on Open Access which had been aimed at delaying implementation of the Research Councils UK's proposed
policy on access to research outputs.
Royal Society's Position on Open Access
To: Fellows signing the open letter
From the President Lord Rees of Ludow 7 December 2005
Lord Rees:
Dear Fellow,
I am responding to your letter on access to published research, to clarify the Society's position. Your draft letter was brought to the Society's attention last week by a number of Fellows and this response was endorsed by the Royal Society's Council when it met last week.
We certainly do not, as your letter implies, take a 'negative stance' to open access. We are simply concerned that open access is achieved without the risk of unintended damage to peer review, quality control and long term accessibility of the scientific literature.
The
Fellows' letter stated quite explicitly in what respect the Royal Society position statement on open access was negative:
"The society's statement, which takes a largely negative stance on open access, appears to be aimed at delaying implementation of the Research Councils UK's proposed policy on access to research outputs."
It is the RS's stance on the RCUK open-access policy that is at issue here, and the RS's stance in its position paper on open access was that the RCUK policy should not be implemented but deferred, pending more "experimental evidence" (without specifying: evidence of what? how gathered? and why?).
Moreover, there is a consistent dissociation between what the RCUK is actually proposing, and what the RS is arguing against. The RCUK is proposing to require that the author's final, peer-reviewed draft of all published, peer-reviewed articles resulting from RCUK-funded research should be self-archived in the author's
institutional repository (or a
central repository) in order to make it accessible to those would-be users who cannot afford access to the published version.
Peer review is not at issue.
Quality control is not at issue.
Long-term accessibility is not at issue. The proposal is to provide supplementary accessibility over and above what exists already, for those would-be users who cannot afford access now.
The RS's allusions to peer review, quality-control and long-term accessibility are hence non-sequiturs. One can guess, however, what motivated them: There is the implicit assumption that self-archiving may (1) cause journal subscription declines or even (2) catastrophic cancellations, which would make journals unable to cover costs, and thereby make it impossible to provide peer-review/quality-control. The worry about long-term accessibility is even more convoluted, being based on the assumption that when journals collapse for inability to cover costs, not only will there be no more journals, but the access to what there had been would be lost as well.
This
doomsday scenario is cited as grounds for opposing the immediate implementation of the RCUK policy, despite the fact that the scenario is not only based on pure speculation, but there already exists substantial empirical evidence against it: In physics (for example) self-archiving has now been going on for over 14 years; in some areas of physics, it reached 100% years ago. Yet both the UK and US Learned Societies in Physics (IOP and APS) have
reported that there has been no detectable decline in subscriptions associated with self-archiving, that they do not see self-archiving as a threat, and that they indeed host mirror-sites of the main central self-archiving site in physics, Arxiv.
Hence peer review, quality control, and long-term accessibility are alive and well in the field that has been experimenting the longest with self-archiving and open access. And the resulting OA has since also been shown to deliver substantial benefits to research and researchers, in terms of usage and citation impact that is enhanced 25%-250%+. Nor are these benefits peculiar to
physics. They are
present in every other discipline in which the comparison has been made.
Lord Rees: The Royal Society is committed to the widest possible dissemination of research outputs. [emphasis added]
We must pause to reflect upon this abstract statement, because, on the face of it, it is in such blatant contradiction with what the RS is concretely trying to do with its position statement. RCUK can rightly say that it "is committed to
the widest possible dissemination of [RCUK]
research outputs" for their widest possible dissemination is precisely what RCUK is proposing to mandate. The RS, in contrast, is opposing this long-overdue RCUK OA mandate, and trying to see it delayed still longer.
On the face of it, then, the RS position certainly does not sound like a commitment "to
the widest possible dissemination of research outputs."
And what are the grounds for this opposition by RS to what the RS itself professes to be committed to? The doomsday scenario -- for which there is no supporting evidence, with all the evidence to date instead contradicting it.
And what does the RS propose instead? Seeking more evidence.
More evidence of what? How? If 14 years of evidence of
peaceful co-existence between self-archiving and journal publishing is not evidence enough, what is?
And why is the RCUK proposal itself not supported as
the experimental means of gathering more evidence? RCUK only funds a small portion of the contents of any given international journal. If we are testing the road to 100% OA, then 100% OA for RCUK-funded research, indeed for all UK research, is still just a small percentage of total worldwide OA, hence of total worldwide journal content. So the RCUK policy will not even go as far as self-archiving has already gone in physics.
Not that it would be a bad thing at all if RCUK-mandated self-archiving did go all the way to 100% worldwide OA -- but the fact is that it does not. So if one has a hypothesis that self-archiving might lead to subscription decline after all, despite all the negative evidence from physics, is the RCUK policy not the way to
test that very hypothesis, if one is truly seeking objective evidence rather than simply seeking to draw pre-emptive conclusions from dire conjectures?
Lord Rees: The Society is itself a delayed open access publisher (already providing free access after 12 months)
Please let us lay this to rest at once: There is no "delayed open access publishing." Open access means free, immediate online access. Delayed access is not open access, it is
embargoed access. And research progress is not well-served by access embargoes. Access embargoes are not "
the widest possible dissemination of research outputs." Why should would-be users of a piece of new research who cannot afford access to the journal that it happens to be published in have to wait a year before they can access, use, apply, and build upon that research? Whose interests does that serve?
More important: RCUK is not asking (nor can or could it require) journals to become open-access journals, nor their publishers to become open-access publishers: It is commendable if publishers do; it is commendable if they make their journals' contents accessible to nonsubscribers after a one-year embargo. But neither of these has anything to do with the RCUK policy, which is that RCUK
fundees must make a supplementary copy of their final, peer-reviewed drafts OA immediately upon acceptance for publication, by self-archiving them -- for the sake of maximising the uptake and impact of RCUK-funded research.
Lord Rees: and [RS] provides immediate access to researchers in developing countries
All acts of charity and largesse by the RS are welcome. But it is neither the RCUK's policy to require such acts of charity and largesse from publishers, nor is the RCUK's policy to leave would-be users worldwide dependent on such acts of charity and largesse from publishers. RCUK is proposing to mandate that its own fundees self-archive immediately, and not out of charity, but in the interests of research progress and impact, including their own citation impact (which also brings authors career and funding benefits, not to mention prestige, prizes, and RS Fellowships).
Lord Rees: and also to scientific papers that are of major public interest (for example the results of the farm scale evaluation of genetically modified crops).
These are further instances of admirable magnanimity, but not something on which the world's would-be research usership can afford to rely for research progress on
all findings.
Lord Rees: However, the Society is not in favour of policies that might imperil scholarly communication by undermining the established subscription model of publishing before the alternatives (such as author-pays journals) have been fully explored and have been shown to be viable in the long term.
Not only do the undemonstrated perils of "undermining the established subscription model of publishing" through OA self-archiving go counter to all existing evidence, and not only do they fail to take into account the demonstrated benefits of OA self-archiving, but demanding a prior demonstration of the viability of the author-pays model as a precondition for RCUK's applying the demonstrated experimental results to date is rather like demanding a prior demonstration of the viability of the US economy under Kyoto restrictions as a precondition for signing the Kyoto accord!
Lord Rees: I hope that you will agree that any decisions that impact on something as important as the future of scholarly communication should be based on sound evidence.
Does stanching a cumulative annual scholarly impact loss of 25%-250% not impact on the future of scholarly communication? Is scholarly communication primarily about protecting scholarly publishers from any imaginable risk at all costs, irrespective of objective evidence for or against?
Lord Rees: Our various statements on this subject, which have been discussed extensively by the Council of the Royal Society, outline a number of questions that have been raised with us as part of this debate. They include the following:
+ Are the various alternative models appropriate to all disciplines? Many of you work in the biosciences and may not realise that concerns about RC UK'S proposals have been raised with us by the mathematics, chemistry and physics communities.
Are there any disciplines that do not benefit from increased access, usage and impact? Are there any that do not lose from loss of access, usage and impact?
And mathematics is catching up on physics in the practice of self-archiving. I doubt that it is the self-archiving mathematicians and physicists who are raising the concerns; and we already know it is not their Learned Societies, APS and IOP.
Or is this a reference to the IOP's data on reduced downloads at the IOP's sites for self-archived articles? But what difference does that make if it is having no effect on subscriptions? Would IOP be hosting a mirror Arxiv site if it felt self-archiving was a threat to its subscription revenues? Isn't
pooling download counts the obvious, natural solution? Or is it again expressed concerns about possible perils that are being counted now as if they were objective evidence of something other than what they are (expressed concerns about possible perils, contradicted by all evidence to date)?
Lord Rees: + Would researchers without a grant or research position or from the developing world be able to afford to publish under an author-pays mode!? Would those journals that hope to subsidise such researchers be able to afford to do so in a sustainable manner?
(1) Why is this question being asked at all, in connection with the RCUK policy, which is not mandating author-pays publishing but OA self-archiving? Lord Rees: + Do the alternative models of publication provide the same level of quality assurance and peer review as the established model? For example, under an author pays model will there be a pressure to publish articles by authors who can pay rather than to publish the very best work?
(2) Why is this question being asked at all, in connection with the RCUK policy, which is not mandating author-pays publishing but OA self-archiving? Lord Rees: Where repositories contain both pre- and post- print articles is there an effective method for distinguishing between multiple versions of the same paper?
The answer is
Yes: It is called the
metadata tag "published in JOURNAL NAME" just as it always was.
Or are we to go on renouncing 25%-250% of annual research access and impact on the off-chance that some of the versions used by would-be users -- who would otherwise have had no access at all -- might have uncorrected errors, or might be mis-tagged by their authors or institutions? Should we eschew books because of possible misprints, or library indices because of possible cataloguing errors? (These trivial points have all the familiar features of special pleading and filibusters. We have heard them many times before,
verbatim. It would be so much more helpful to hear Lord Rees's own thoughts, in his own words.)
Lord Rees: + Is there sufficient funding to ensure the survival of institutional repositories in the long term?
The answer is again
Yes (because the
set-up and maintenance costs for an OA IR are risibly low).
Nor is it at all clear,
prima facie, why this question should be the RS's concern at all; but let us suppose for the sake of argument that there are
not sufficient funds, and that after a year or two in which they increase research impact by 25%-250%, all IRs go bottom-up: Is
that, then, a reason for renouncing that year or two of maximised research impact? Is it a reason for delaying the RCUK mandate? (Why are these irrelevant concerns about IR support being asked at all?)
(As it happens, the IR movement is growing quite robustly, for
digital-curation reasons of its own, independent of OA concerns, and with
preservation/survival its main raison d'etre: Should RCUK delay its mandate till the digital survivalists can ensure their own survival?)
Lord Rees: + Under a self-archiving model, how will peer review be organised if, as some fear, journals go out of business? Is the brand of a journal important, and if so what will replace it?
Is "
what some fear" to be taken as empirical grounds for delaying or deferring the adoption of a practice (self-archiving) that has already empirically demonstrated its benefits, with no resulting empirical evidence to support the fears?
If any subscription journals go out of business, their titles ("brands") can always
migrate to OA publishers.
Lord Rees: + Is there an inherent problem with the current model and do the proposed alternatives address it?
(3) Why is this question being asked at all, in connection with the RCUK policy, which is not mandating author-pays publishing but OA self-archiving?Lord Rees: These are just some of questions that we believe should be addressed.
In view of the importance of this issue, and the very significant long-term consequences that changes in policy could have, we believe that more evidence needs to be collected.
More evidence on what?
And is all the accumulated evidence on the benefits of OA self-archiving to research and researchers -- and the absence of any negative effects on subscriptions or publishers -- to be ignored? Will anything other than evidence of subscription-decline be accepted as actually being evidence? And how long do we have to keep gathering evidence before we can act on it?
And how (now we are on the subject) are we to test whether the hypothesis that self-archiving will cause subscription decline is valid? Is the RCUK policy itself not the direct test of the so-far-unsupported hypothesis that self-archiving will cause subscription decline?
Why must we wait and first test alternative economic models (which are
not what RCUK is proposing to mandate) before we can test self-archiving itself (which is what RCUK
is proposing to mandate)? Are we simply to accept without supporting evidence that self-archiving will lead to subscription decline and to the need to adopt other economic models?
Lord Rees: As contribution to this evidence base, we believe that a study should be commissioned to assess the relative merits of the various models that have been proposed under the rather broad banner of 'open access',
How does testing the relative merits of models test whether or not the hypothesis that self-archiving imperils journals is valid?
Lord Rees: including that outlined by RC UK in its consultation document.
What model was outlined by RCUK in its
consultation document? The only
two concrete measures RCUK proposed were (1) to require self-archiving and (2) to help fund author-pays costs.
Lord Rees: Such a study should assess what potential benefits and drawbacks could result from changing current practices in the dissemination of research findings to each of the proposed new models.
Assess it how? By asking people's opinions about perils? Is it not the RCUK policy itself that tests whether self-archiving generates subscription loss? Has not all evidence to date attested to self-archiving's benefits, and no evidence to date given any hint of drawbacks?
Lord Rees: It would need to examine how these benefits and drawbacks may vary from discipline to discipline and the impacts on researchers who may not be funded through traditional routes.
The RCUK policy, being pan-disciplinary, will test just that: Does any discipline fail to enhance research impact by self-archiving? Do some disciplines have subscription declines and others not?
But what has funding to with it, since OA publishing is not what is being mandated?
Lord Rees: Reliable evidence would allow the research community as a whole, including RC UK, to make better informed decisions about whether changes in current practice are desirable. We have indicated to RC UK that we would be happy to discuss with them how such a study might be taken forward.
It seems clear that the only thing the RS is interested in testing is the viability of different economic models for publishing. Fine. Let the RS go ahead and test publishing models.
But meanwhile, the RCUK is committed to applying (and thereby also further testing) ways to generate "
the widest possible dissemination of [RCUK]
research outputs", and OA self-archiving is one of the ways that has already garnered a lot of supporting evidence.
Let the RCUK, without further delay, test whether the already-demonstrated positive effects generalise to all disciplines, whether all enjoy the impact benefits, whether any signs emerge of subscription decline. Let the outcome and the policy be evaluated in 2008, as proposed, or even annually. But let there be no further delay in getting the RCUK experiment underway.
Lord Rees: Our overriding concern is the future of scholarly communication. It is important to remember that more than 40% of journals are published by not-for-profit organisations many of whom use their publishing surpluses to fund activities such as academic conferences and public lectures, which are also crucial to the exchange of knowledge. A loss of income by not-for-profit publishers (particularly some of the smaller Learned Societies) would lead to a reduction in, or cessation of, these activities.
First, to repeat, there is no evidence to date of any loss of subscription income as a result of author self-archiving.
Second, if there ever were some detectable loss of publisher revenue as a result of self-archiving, would the optimal response be to curtail the self-archiving and its benefits? to renounce "
the widest possible dissemination of research outputs"? Are "activities such as academic conferences and public lectures" to continue at all costs to be subsidised by researchers' lost research impact? Or might there be some
other way to fund such worthy activities than by curtailing "
the widest possible dissemination of research outputs"?
But in any case, should we not decide what to do about
that bridge if and when there is some evidence that it exists and we are coming to it, rather than now, when all we have is the evidence of benefits with no drawbacks (or drawbridges) at all?
Lord Rees: The Society wishes to enable maximum access to the outputs of research while safeguarding the future of scholarly communication. I hope that the Society can count on your support in encouraging a study that explores the many issues around the future direction of scientific publishing.
OA self-archiving maximises research access and impact and has shown no signs of imperilling subscription revenue. It is time to apply this long-standing and well-supported empirical finding, and extend it further. RCUK funds only a small portion of any individual journal's contents. In a few years it will be possible to re-assess whether or not mandated self-archiving has had any detectable effect on subscription revenue (and whether that warrants any change of RCUK policy, or merely
adaptation by publishers). Meanwhile let RCUK, with no further delay, widen the dissemination of its research outputs, to the benefit of UK's research and the
UK tax-payers' investment in it.
Stevan Harnad