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80 St Albans Road
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www.alpsp.org

14 June 2024

By email: info@ref.ac.uk

Dear UKRI,

We are writing this letter on behalf of the Association of Learned and Professional Society Publishers (ALPSP) and in response to the UK’s Research Excellence Framework 2029 OA Consultation. ALPSP is an international trade association which supports and represents not-for-profit organizations that publish scholarly and professional content, and those that work with them. Our members represent a diverse range of publishing models whose authors often face unique challenges in making their research more open and equitable. We thank you for taking the time to conduct this consultation and welcome any future opportunities to discuss the issues touched on below in more detail.

In 2022, the UK published 56% of articles, reviews and conference papers gold open access (Gold OA). This is a great achievement considering just 9% of outputs were published Gold OA in 2012. Furthermore, the number of UK Gold OA articles (all articles with any author affiliated with a UK organisation) was 4% higher when compared with the number of global Gold OA articles (UK: 50%; global 46%) Many of our members are proud to have played a part in making the UK a leader in this publishing route. Gold OA fully supports immediate (and irrevocable) availability upon publication of the Version of Record (VoR). We agree that the REF 2021 OA Policy was a success, with only 25% of in-scope outputs not meeting OA objectives, and most often then for sound policy reasons, and we agree that a certain threshold of tolerance may often be necessary. We remain positive in our aligned goals of ensuring trusted, reliable, and verified content is made widely available and accessible and Gold OA remains the most viable and appropriate route to achieve these goals.

Gold OA is the best route to increasing usage and availability of content immediately upon publication, allowing for broad, global distribution. Researchers, authors, publishers, universities and institutions all agree that Gold OA confers many advantages and have therefore partnered to create solutions that allow for Gold OA in most scenarios, such as Transformative Agreements (TAs). These tools help reduce administrative burdens, mitigate the financial impacts of full and immediate Gold OA, and encourage greater opportunities for collaboration. However, in certain situations alternative Creative Commons or subscription licences may be better suited to govern the publication & address author concerns over how their publication is used (particularly commercially). We remain open to understanding these author concerns.

Publishers invest heavily in stewardship over their published content and in ensuring the VoR is maintained throughout time and in conformance to strict research integrity principles. Gold OA facilitates this stewardship by ensuring it is the final, published VoR that is distributed, shared, indexed, registered in discovery services etc. Many publishers also participate in community led initiatives, such as the OA Switchboard, which aims to simplify the sharing of metadata and make reporting easier and the JISC Router that helps participating institutions monitor OA publications. These are great examples of the collaboration that already exists, and we want to build on this. Gold OA also helps to ensure the author's copyright is respected in mandating attribution and, where applicable, by allowing the author to retain the copyright in the work. These are just a few of the benefits Gold OA confers and we always welcome further opportunities to discuss and explain the real-world impact of the Gold OA licensing model compared to others.

Publishing methods that allow for different versions of an article to be disseminated with different licences challenge publishers’ stewardship efforts. Such models may pose a risk to the sustainability of OA publishing and research integrity efforts, as well as how best to plan investments to keep up with technological advances such as AI. Research integrity, or how we ensure we are sharing trusted, verified, and reliable content, is of paramount concern to all publishers. Applying Creative Commons licences to different versions of an article stymies vital research integrity efforts and makes it more complicated for any reader to understand what research may be relied upon. Conflicting licences raise questions as to whether this could lead to lower quality, less discoverable UK research, ultimately undermining our collective goals.

The number of UK authored articles being published Gold OA is growing quickly. However, the difference in growth rates for OA between disciplines highlights researchers’ concerns. TAs are helping to reduce these disparities due to their wide-spread acceptance, potentially allowing all authors access to funding. In turn, this allows disciplines with historically lower levels of funding to be granted better opportunities for Gold OA. However, clearer funding policies are still needed to allow equitable access to OA publishing routes.

Enabling UK researchers to publish the VoR under an appropriate OA licence maximises its global impact and hence the return on investment of funded research. Gold OA achieves this at only a fraction of the overall research budget. Looking only at direct cost savings in relation to publishing models neglects what those costs achieve, and providing rich output across the diverse landscape of UK research under Gold OA terms is an achievement.

We agree with the four UK higher education funding bodies that Gold OA licensing should be encouraged but that in certain scenarios there would be ‘clear rationale for applying more restrictive measures’. However, it is not clear why Creative Commons licences should apply to articles that are not published on a Gold OA basis, since this will (a) undermine the copyright protection in the article and (b) conflict with the licensing terms agreed between publishers and academic institutions under subscription agreements. Authors who do not publish Gold OA would presumably not want to see their content still being made freely available under the wide CC-BY terms. We would therefore support reconsidering the exclusion of the CC-BY NC ND licence to manuscripts to ensure more authors opt for OA.

Different publishing models allow for maintenance of more healthy and sustainable financial models. There remain a minority of UK-based researchers who publish via the subscription route, for instance because their institution has opted not to establish a TA. For smaller UK publishers and ALPSP members, allowing for author choice in terms of what journal is most appropriate, providing publishing opportunities to independent researchers for those who may otherwise be excluded from institutional funding options, and maintaining the UK’s reputation as a leader in research integrity requires an amount of flexibility. It is vital the rich tapestry of UK publishers remains viable as they are a fundamental part of the research community.

It is uncertain what future investments will be required to maintain this status of research publication excellence. Technological challenges are likely to continue to escalate, and publishers of all sizes are strategizing how to cope. Many of our members have raised concerns over potential commercial reuses of their content and the lack of any safeguards for such reuses in the CC-BY licence. Researchers, such as those in HSS subjects, are concerned with the research integrity implications of unrestricted commercial reuse and have urged publishers to take steps to ensure proper stewardship and management of their work.

Many of these problems are further emphasised for long form manuscripts. Research norms, discipline, subject, or other factors may often limit the options for selection of the most appropriate publisher for a longform output, and such output’s international dimension plays a factor. Additionally, infrastructure supporting Gold OA publications are in place for many journal outputs, however, long form content needs investment to build suitable frameworks that allow for OA compliance. We think it appropriate that measures are allowed to cover such scenarios and welcome all opportunities to detail more fully the scenarios that may ‘fall between the cracks’.

We are all mindful of mitigating unforeseen adverse consequences that might arise from unilaterally applying a one size fits all approach. In certain circumstances, we also understand embargo periods may be necessary. Many publishers do not believe that the reduced embargo period is sufficient to ensure the longer-term viability and sustainability of high-quality publishing services unless there is guaranteed funding to support immediate Gold OA publication for all UK researchers (where there is no need for any embargo).

Researchers are not in control of the timing of when an article is accepted. It may take 2-3 months for a submitted article to go through peer review before it is accepted, and in some disciplines, it can take much longer. Additionally, research collaborators will often discuss and agree jointly on the journal they wish to submit to many months prior to submission. We wish to express our concerns on the impact of any policy announcement that does not consider publishing decisions already in place or that provide authors with little notice on their compliance requirements. We would recommend applying the policy to articles submitted from a date that falls at least 6 months after the date on which the final policy is announced.

We do not consider that additional exceptions are required. The exceptions, and the process researchers or institutions should follow, should be stated clearly and prominently in the final policy guidance and proactively communicated to research communities. In the previous REF period, we heard from several researchers who were not aware of the existence of exceptions, or how they could adopt them for their research article. We encourage all stakeholders to work on best methods to communicate this policy openly.

Researchers, institutions, publishers, and publishing service companies as well as a host of attenuated communities, are facing new challenges providing trusted, verified content not only at the moment of publication but for the lifetime of the work. High quality publishing must not become compromised by misinformation, technology misuse or abuse and bad actors such as paper mills. This requires continued investment in rigorous processes that focus on quality assurance and preserve research integrity. Such investment necessitates reliable funding models that support the diverse range of UK society, learned, and professional publishers. The economic costs of any policy changes must be fully assessed, understood and accounted for in the funding plans for the REF29 policy. Continued funding is required, not only to maintain high-quality publishing for UK researchers, but also to allow for investment in enhanced research integrity, infrastructure, and data sharing support.

These are initial responses, and we would be happy to provide additional detail or evidence where possible on any of the topics outlined in this letter. We look forward to further opportunities to collaborate as you continue to develop the REF29 OA policy.

ALPSP (www.alpsp.org) is the international trade association which supports and represents not-for-profit organizations that publish scholarly and professional content, and those that work with them. It offers education and training and provides a vibrant forum in which to share and promote best practice and help individuals and organizations thrive. ALPSP is proud to have over 320 member organizations across 35 countries. 

Yours sincerely,

Wayne Sime
CEO, ALPSP

Read Endorsement of the submissions by the UK Publishers Association and the Association of Learned Professional and Society Publishers to the REF Open Access consultation.