Wellcome Trust and the 6-month embargo

The Wellcome Trust will have the eternal historical distinction of having been the first research funder to actually mandate Open Access (OA) self-archiving (May 2005):

"Comparing the Wellcome OA Policy and the RCUK (draft) Policy"

This represented a very important forward step for the planet's progress toward the optimal and inevitable target: 100% OA. The earlier well-intentioned but much-flawed -- and since failed -- NIH Public Access Policy alas did not help advance OA, but rather missed an opportunity and inadvertently held things back for at least 2 years. But the hope now is that -- inspired in part by the far better model provided by the Wellcome Trust policy -- the NIH policy will be revised, becoming a self-archiving requirement instead of just a self-archiving request, no longer allowing a delay of up to 12 (or even 6) months.

It does not follow, however, that the current Wellcome Trust policy is unflawed, or that it provides the optimal model for others to follow. It was a great help at its historic time, as a counterweight to the far more flawed NIH policy, but at this historic point, the Wellcome Trust policy too risks becoming a retardant instead of a facilitator of OA, if it is imitated by others in its flaws instead of its strengths.

The strength of the Wellcome Policy is that (1) it is an exception-free requirement, not an optional request, and that (2) it does not allow a delay of longer than 6 months.

Its flaw is that (a) it allows any delay at all and that (b) it requires self-archiving in a central, 3rd-party repository (PubMed Central; PMC) instead of the author's own institutional OA Institutional Repository (IR) (from which PMC could then harvest if/when it wishes).

The two flaws are linked. For the simple and natural way to rule out delays is to require immediate deposit of the accepted, final draft in the author's own institutional OA IR (immediately upon acceptance for publication), but merely request/encourage that access to the deposited draft should be immediately set to "Open Access." That leaves the author the option to provisionally set access instead as "Restricted Access" if need be (for up to 6 months).

How is this linked to the requirement to deposit in PMC instead of at home? Because PMC is neither the author nor the author's institution. It is not even the Wellcome Trust. It is a generic, 3rd-party repository, which publishers can (perhaps rightly) construe as a rival 3rd-party publisher. Publishers are certainly within their rights to block or embargo rival 3rd-party publishing. (Whether it makes any sense to try to treat a 3rd-party OA repository as a rival publisher in the OAI-interoperable age is another matter!)

But the author and the author's own institution certainly cannot be construed as a rival 3rd-party publisher: They are the party of the first part, the content-provider, and the publisher is only the party of the second part: the value-adder and vendor.

And that is why far more journals have given their green light to author self-archiving in their own respective institutional OA IRs, than to self-archiving in a central 3rd-party repository like PMC. And that is also why PMC-archiving is more vulnerable to a publisher embargo.

But there is an ultra-simple way to require immediate deposit while accommodating any publisher embargo at the same time: Require immediate deposit in the author's own OA IR -- immediately upon acceptance for publication -- and harvest the full-text into PMC after 6 months!

That way the deposit is, without exception, immediate, and for about 93% of articles, access too will be immediately OA. (Those articles, too, can be immediately harvested into PMC.) For the c. 7% of articles set to Restricted Access, the metadata will be immediately visible anyway, and emailed eprint-requests (facilitated and automatized with the help of the IR software) can fulfil the access-needs of would-be users who cannot afford access to the proprietary journal version during the embargo period.

Why not implement the deposit/access-setting distinction, but in PMC rather than in the author's own IR? Because it fails to generalise to all the rest of OA research output (in all fields of research, not just biomedical). The Wellcome Trust funds some of the world's biomedical research; NIH funds more; but there are vasts amounts of further research -- in biology, medicine, physical sciences, engineering, social sciences and even the humanities -- that would all fail to benefit from a parochial PMC mandate for biomedical research. If, instead, funders like Wellcome and NIH mandated that their fundees self-archive in their own institutional OA IRs, that would effectively "tile" all of OA space, effectively and completely, as universities cover all fields of research output. (Central OA repositories like PMC and others would still be available for any orphan works from unaffiliated researchers.)

In other words, funders are not helping world OA if they keep thinking of it as a go-it-alone operation. Funders only fund bits; central OA repositories don't exist for all disciplines and fields; and even if they did, they -- unlike the researchers' institutions -- do not have the clout to reinforce scattered funder mandates with institutional self-archiving mandates, to ensure that all their institutional research output is indeed self-archived.

So the simple and sensible way to update and optimise the pioneering Wellcome Trust self-archiving mandate would be to (1) require the self-archiving to be done in the fundee's own institutional OA IR (as the UK Select Committee proposed), (2) require it to be done immediately upon acceptance for publication, (3) encourage immediate access-setting to OA, (4) require access-setting at OA by 6 months at the latest, and (5) harvest the metadata into PMC immediately upon deposit -- and the full-text into PMC (if need be -- there's a case to be made for just linking to the IR version) within 6 months at the latest.

Why is Wellcome Trust not making this simple and obvious update without even any need for prompting? I think it is because there are again green and gold wires crossed: Over and above its mission to ensure that all Wellcome-funded research (and, hopeably, all research) is made OA, the Wellcome Trust has the further worthy goal of encouraging a transition to the OA (gold) publishing model. This is all fine, but not if the slow, uncertain transition to gold OA is supported at the expense of a speedy, certain transition to 100% OA itself (green).

And that is what I think is happening: Wellcome is not doing everything it could to hasten OA itself, because it is not committed only to OA, but to publishing reform too.

My own view is that publishing reform will take care of itself, and that the urgent task is to get to 100% OA as soon as possible. (Indeed, that itself will probably prove the most important stimulant to publishing reform.) But to slow the immediately feasible and certain transition to OA in the service of far slower and less certain -- and more hypothetical -- measures to induce publishing reform, is not, I think, to help OA along the road to the optimal and inevitable (and already overdue) outcome.

Some comments:

On Mon, 13 Mar 2006, Robert Kiley (Wellcome Trust) [RK] wrote in the American Scientist Open Access Forum:

RK: "Please note the Wellcome Trust currently does NOT have any plans to reduce the 6 month time limit on its grant condition. The grant condition requires published research (original research papers in peer reviewed journals) arising in part or whole from Trust funding to be placed in Pubmed Central (or UK PMC when it exists) no later than 6 months after the date of publication."

No need to reduce the 6 months if Wellcome does not wish to. Just mandate immediate deposit (in the fundee's own OA IR) and let delayed access-setting bear the burden of the delay. Meanwhile, everyone gets into the habit of self-archiving at home, and emailing eprints can bridge the gap, universally and uniformly.

RK: "It is obvious that a potential delay of up to 6 months is not ideal in terms of the timing of access, but it is a realistic response to the very real concerns of publishers, large and small, that self archiving is a threat to their business model. Whether this is eventually shown to be the case is immaterial as it is this perception that we need to deal with."

Fine. As noted: Mandate immediate deposit and allow the option of delayed access-setting.

RK: " As the only funding organisation with a mandate in its grant condition to support open access through open access publishing and archiving in PMC we are very well aware how many journals are currently at odds with this policy."

Note the conflation of open access provision (through self-archiving, green) with open access publishing (gold)...

RK: "That is why, in conjunction with JISC, we are funding an extension of the Sherpa/Romeo project to identify, at the journal level, which journals will allow a copy of the published paper to be deposited into PMC/UKPMC so it is available no later than 6 months after the original publication date."

It is always good to extend Sherpa/Romeo's coverage, but Romeo already lists embargoes, if any. So surely what Romeo needs is more coverage of journal self-archiving policies, not a focus on 6-month embargoes!

RK: "In order to encourage experiments in alternative business models to the subscription model the Trust also explicitly supports open access publishing as part of the research funding process."

So far, so good. Funding authors' OA (gold) publishing charges is very constructive and helpful. But now this:

RK: " That is why we provided some assistance to OUP, Blackwell's and Springer in drafting the author licence for their various open access offerings so that they were explicitly compliant with publishing and depositing in an archive such as PMC."

This sort of thing simply encourages the locking in of a 6-month embargo instead of helping to phase it out!

If the Wellcome Trust instead simply mandated immediate deposit and let access-setting bear the weight of any embargoes, it would not need to get into the business of entrenching and canonizing embargoes instead of letting them die a quiet death of natural causes!

RK: " We see open access repositories and open access publishing as complimentary exercises and to us, and the publishers we talk to, there is a direct link between the impact of self archiving and the publishing process so it is a pragmatic response to deal with both issues in parallel."

What is complementary today is: (1) non-OA publishing, (2) OA publishing, and (3) OA repositories for the author self-archiving of both (1) and (2).

Self-archiving is not a form of OA publishing, and the immediate and reachable goal -- the one that justifies OA in the first place, namely, access to 100% of published research articles -- is a transition to 100% OA, not necessarily a transition to OA publishing.

RK: " In time the most likely scenario, and one the Trust is supporting, is that open access publishing, or another model yet to be invented, will become the norm and publishers will be able to operate without a reliance on subscriptions. As such the 6 month embargo period will be kept under review but at the moment the Trust has no plans to change it."

That's fine. Let the allowable 6-month delay stand, but let it be a delay in access-setting, not deposit. And let the immediate deposit be in the fundee's own institutional IR, with PMC harvesting it after the allowable delay -- rather than delaying the deposit itself, and insisting it be in PMC!

Stevan Harnad