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6 February 2019

ALPSP has submitted a formal response to the Call for Feedback on Guidance on the Implementation of Plan S.  ALPSP encourages ALPSP Member organizations also to make their own individual responses before the deadline of 8 February (17:00 CET).  

The ALPSP position statement is as follows:

The Association of Learned and Professional Society Publishers (ALPSP) is the international trade body for not-for-profit organizations and institutions that publish scholarly and professional content. Founded in 1972, ALPSP represents over 300 member organisations in 30 countries, making it the largest trade association helping scholarly and professional publishers around the world.

Publishing is a fundamental part of the research process. Representing learned societies and not-for-profit publishers with communities across all disciplines, including science, medicine, humanities and social sciences, ALPSP is committed to facilitating researchers sharing their work to allow the advancement of knowledge for the benefit of society. Moving towards open access is aligned with this commitment.  We recognise Plan S aims to escalate the movement of journals to a fully open access business model and are supportive of the central principles of Plan S. However, we believe the scale and complexity of the proposed transition, together with the short timescale involved, could introduce unintended consequences which we would like cOAlition S to take into consideration.

1. ALPSP has concerns regarding the pace of change advocated by Plan S

We are concerned that the short time frame set out by Plan S will not enable many of our members to transition their business models or for researchers to fully engage with any consultation process. For example, by January 2020 the results from the UKRI review will only just be available, the outcomes of which will be unclear for UK researchers until that point. Furthermore, this rapid transition will disproportionately impact smaller publishers, with limited funding and less flexibility in terms of approaches.

2. We request more clarity regarding the requirements for transformative agreements with opportunity for further review

The Plan currently proposes transformative agreements as a mechanism to smooth the transition process. We can see that these agreements are helpful, particularly to authors who do not receive funding for research. We request more clarity around the requirements for compliance for these agreements.

Plan S requests that all journals within an agreement must flip to open access on expiry of a deal.  As publishers cannot commit to this on behalf of all journals in a collection, we cannot see how any of the current transformative agreements between publishers and customers are compliant and yet Coalition S has openly supported them.  An opportunity for review of the extent of migration to open access when 2- or 3-year agreements expire rather than a commitment to flip all journals to open access in this short time frame would encourage more agreements of this kind to progress.

Coalition S should be aware that transformative agreements are unavailable to all but the largest players due to the scale and complexity of such negotiations, disadvantaging smaller publishers.

3. We advocate the retention of different licence options

We support the concept that authors retain copyright of their work.  We would, however, advocate the retention of different licence options, the NC/ND options in addition to CC-BY.  There are many fields, specifically within the humanities and social sciences, where the mode of expression of arguments is integral to the scholarly work, an aspect which should be considered when determining mandates for publication licenses.

4. Funding is not universally available to those publishing research

cOAlition S has chosen not to support publication in hybrid journals for research funded from January 2020. We are concerned that Plan S will place considerable restrictions on many researchers, who may be unable to select the most appropriate outlet for their publications. Learned societies were established to foster and advance their disciplines on a global scale and there is a concern raised by many of our members that any rapid transition to full open access will introduce barriers that prevent many researchers – those without funding or unable to pay APCs – from publishing at all. The consequences are likely to be detrimental to global collaboration in research and will force our members to make tough choices about which author bases to support.            

5. The global publishing landscape is complex

Our membership base is extremely varied, covering a range of different regions, business models, publisher sizes and disciplines, and this is reflective of the global publishing landscape. Therefore, any “one-size fits all” approach to open access is unlikely to accelerate the transition on a global scale. Many of our members are concerned about the suggestions of capped article processing charges (APCs) because the running costs associated with each of their journals are equally varied. We therefore welcome the joint project between ALPSP, Wellcome Trust and UKRI to explore how society journals can be sustainable under Plan S.  However, the results of this initiative won’t be available until August 2019, just four months before the proposed introduction of Plan S.

We welcome the opportunity for stakeholders to give feedback on Plan S and we encourage the supporting funders to further engage with all publishers and learned societies, given the critical importance of publishing programmes to the vitality of their disciplines and communities. The ability of learned societies to facilitate the development of national and international networks, provide education and training, enable public engagement with their subjects, fund research, and advise government on all aspects of their discipline, must be considered in future funding models. We believe that constructive engagement with all stakeholders in the academic publishing landscape is the best route to transition to a more open future, while continuing to support a vibrant research community both within Europe and beyond. ALPSP is keen to continue to engage with funders after this consultation period to represent our members and to facilitate our members engaging directly.

Categories: open access, research