Re: Open Letter about OA to the Royal Society by Fellows of the Royal Society

From: Stevan Harnad <>
Date: Tue, 13 Dec 2005 00:59:41 +0000

    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

Here are my comments:

> To: Fellows signing the open letter at
> From the President Lord Rees of Ludow
> 7 December 2005

> Dear Fellow,
> Royal Society's Position on Open Access
> 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 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.

> The Royal Society is committed to the widest possible dissemination
> of research outputs.

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 research
outputs" for their widest possible dissemination is precisely what RCUK
are proposing to mandate. The RS, in contrast, is opposing the long-overdue
RCUK OA mandate, and trying to see it delayed still longer.

On the face of it, that does not sound like a commitment "to the
widest possible dissemination of research outputs."

And what are the grounds for the RS's opposition 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 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 OA, hence of total 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?

> 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
impact of RCUK-funded research.

> 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 to allow would-be users to be dependent on them. 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).

> and also to scientific papers that are of major public interest
> (for example the results of the farm scale evaluation of genetically
> modified crops).

Further instances of admirable magnanimity, but not something on which the
world's would-be research usership can rely for research progress on *all*

> 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!

> 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 publishing from any
imaginable risk at all costs, irrespective of objective evidence for
or against?

> 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 perils that are being counted now as if they were objective
evidence of something other than what they are (expressed concerns about
perils, contradicted by all evidence to date)?

> + 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

> + 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

> 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.)

> + 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).

It is not at all clear 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 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 survivalists can ensure their survival?)

> + 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 grounds for delaying or deferring the
adoption of a practice (self-archiving) that has already demonstrated
its benefits, with no resulting evidence to support the fears?

If subscription journals go out of business, their titles ("brands")
can always migrate to OA publishers.

> + 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

> 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 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 to 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 evidence that self-archiving will lead to subscription decline
and the need to adopt other economic models?

> 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?

> including that outlined by RC UK in its consultation document.

What model was outlined by RCUK in its consultation model? The only two
concrete things RCUK proposed were to require self-archiving and to
help fund author-pays costs.

> 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 its benefits and no evidence to
date given any hint of drawbacks?

> 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 being

> 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 interested in applying (and thereby also further
testing) ways to maximise research impact, 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 positive effects
generalise to all disciplines, whether all enjoy the impact benefits,
whether any show signs 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.

> 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 ever some loss of publishing revenue as a
result of self-archiving, would the optimal response be to curtail
the self-archiving and its benefits? Are "activities such as academic
conferences and public lectures" to continue at all costs to be subsidised
be researchers' lost research impact? Or might there be some other way
to fund such activities?

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.

> 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 access and impact and has shown no signs
of imperilling subscription revenue. It is time to apply this 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 any detectable
effect on subscription revenue (and whether that warrants any change of
the policy, or merely adaptation by the publishers).


Stevan Harnad
Moderator, American Scientist Open Access Forum

Chaire de recherche du Canada
Centre de neuroscience de la cognition (CNC)
Université du Québec à Montréal
Montréal, Québec, Canada H3C 3P8

Professor of Cognitive Science
Department of Electronics and Computer Science
University of Southampton
Highfield, Southampton
Received on Tue Dec 13 2005 - 01:05:38 GMT

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