The ALPSP Copyright Committee has made formal response to the new Model Grant Agreement (MGA). It expresses caution and highlights that some of the provisions could undermine the excellence of European research and the sustainability of a diverse research ecosystem. 

Background: The EU is currently considering the wording of the template for the successor to Horizon 2020, Horizon Europe, which will relate to funding available from 2021.  Further details can be found here. 

29th May 2020

Ms Mariya GABRIEL
EU Commissioner Innovation, Research, Culture, Education and Youth
European Commission 
Rue de la Loi 200
B-1049 BRUSSELS

CC: Jean-Eric Paquet, Director General DG Research and Innovation;  Anna Panagopoulou, Director RTD.G, Research & Innovation Outreach, DG Research and Innovation; Konstantinos Glinos, Head of Unit G4, Open Science, DG Research and Innovation

Recommendations for the Horizon Europe Model Grant Agreement relating to Open Access

Dear Ms Commissioner Gabriel,

Please allow us to thank you for your dedication and support to the research and innovation community during these difficult times.

The Copyright Committee of ALPSP writes to caution the European Commission about the envisaged revisions to the new Model Grant Agreement (MGA) for the upcoming European Framework Programme Horizon Europe.  We wish to highlight some of the provisions included that could undermine the excellence of European research and the sustainability of a diverse research ecosystem.

Given that ALPSP is based in the United Kingdom (UK), we strongly hope to remain part of the European research community and that the UK’s membership of Horizon Europe is maintained as part of the future relationship with the European Union.

ALPSP is an international membership trade body, based in the UK, that supports and represents not-for-profit organisations and institutions that publish scholarly and professional content.  With nearly 300 members in 30 countries, membership also includes those that work with these publishers and societies.  Its mission is to connect, inform, develop and represent the international scholarly and professional publishing community.  ALPSP has publisher members across the world, including a number in the European Union, and many of its members publish the outputs of research projects funded by the EU.

Members of ALPSP strive to support the progress of science by producing, validating, broadly disseminating and curating the highest quality peer-reviewed research outputs in their content. These outputs often result from research grants, yet they require significant investment to turn ‘raw’ research findings into the final validated output.  Publishers and learned societies have a history of working together to strengthen scholarly communication and promote open science and open access.

However, it is critical that these efforts take place within a framework that respects publishers’ ability to invest in high-quality publications that demonstrate the expected rigour, and that does not hinder researchers from communicating their discoveries.

ALPSP welcomes the clear goal of the European Commission in the current mandate to consider carefully the impact of policy changes, as well as the commitment that initiatives taken by the European Commission be consulted upon widely.  Keeping this process in mind, we see potential risks to quality and sustainability if grant recipients were to be:

a)       provided with insufficient funding, or no funding at all, for the costs of high-quality open access publication;

b)      no longer permitted to publish in their choice of open access publication, whether it operates a fully open access model or a hybrid open access model in transition towards full open access;

c)       permitted, as an alternative to open access journal publishing, to comply with policy requirements by posting the peer-reviewed, ‘accepted’ version of their article on an open repository immediately and under a liberal Creative Commons licence, thereby jeopardising the publisher’s means of recovering its costs; and/or

d)      continued to be denied funding for articles published after projects have ended.

If adopted, these revisions would present a number of consequences which will hinder our members’ shared aims of advancing open access and working collaboratively to solve society’s biggest challenges.

At the same time, the ecosystem that supports researchers – in which European industry is a market leader – must be sustainable to safeguard the future of research.  Publishers and learned societies play an important part in the research workflow and support the infrastructure of scholarly communication; this includes, but is not limited to, management of the peer review process, typesetting, tagging for discovery and distribution, and ensuring the content is preserved for generations to come.  Once the article is published, ALPSP members ensure that the most reliable Version of Record (VOR) will continue to be made available, with the relevant amendments, and – where necessary – retractions.  All these elements form part of the scholarly communication process, which is maintained at cost by learned and professional publishers.  A zero month embargo will need to be accompanied by an increase in funding for open access publication costs in order to support publishers’ ability to continue to do this.  If deposited under a liberal Creative Commons licence that does not restrict commercial use, this would allow third parties to harvest and exploit that material for their own commercial purposes, which would severely hinder the ability of publishers and learned societies to recoup the associated publication costs and disincentivise them from investing in new technologies and standards.

To introduce a zero month embargo without increased funding for open access would threaten the incentive to develop such innovations and would risk the quality and quantity of publications.  Should some publications cease to exist, this would also profoundly impact author choice.  This would additionally have the unintended consequence of limiting venue of publication choice for researchers who have no funding at all.

Therefore, we recommend:

a)         safeguarding researchers’ freedom of choice by trusting them to know the best ‘home’ for their research;

b)        retaining the current embargo periods (6 months for STM, 12 months for SSH) which recognise the fundamental differences which exist across disciplines and ensure the long-term sustainability of preferred publications;

c)         ensuring that grant funding for publication is available after projects have ended;

d)        focusing on incentives and rewards for researchers rather than increasing the administrative burden of grant applications; and

e)        ensuring that sufficient funding is available for researchers to publish their research on a gold open access basis in their journal of choice

Please be assured that our destination is the same as yours – a fully open access and open science world and ALPSP members are always willing to experiment on and develop new methods of scholarly communication which are of benefit to researchers.  Those are priorities that need to be combined with the needs of researchers and of the entire community and that should be reflected in any updates to the MGA.  As an example, learning from the current need for rapid dissemination of research, we welcome discussions on how to best encourage the use of preprints as a means to achieve faster dissemination of research.

We request that you consider an open and collaborative discussion with all interested parties.  This would allow for a transparent and constructive conversation, which we express our commitment to, in order to explore what routes we could embark on together.

Wayne Sime
Chief Executive
The Association of Learned & Professional Society Publishers
Egale 1, 80 St Albans Road, Watford, Hertfordshire WD17 1DL

Categories: open access, research