And Fred Friend has kindly allowed me to reproduce his critique
A PERSONAL CRITIQUE OF THE GOVERNMENT RESPONSE TO THE SCIENTIFIC PUBLICATIONS REPORT (HC 1200)
Frederick J. Friend, Honorary Director Scholarly Communication, University College London, [email protected] .
“We are disappointed that the Government has missed the opportunity to take more decisive action in response to our Report”. (HC 1200, page 6.)
These words from Members of Parliament on the House of Commons Science and Technology Committee will be echoed by many in academia who were hoping that potential improvements in internet access to the publications and data resulting from academic research would be recognised and supported by the UK Government. The Government Response continues to support publication models from the print era and fails to grasp the opportunities presented by changes in scientific communication. The following quotations from the Government Response illustrate weaknesses in the Government position.
“Consequently, the Government’s approach is to facilitate a level playing field so the market can develop without any institutional barriers being put in the way of any particular publishing model. This option is the most appropriate to encourage competition and innovation in publishing, to promote greater accessibility, to maintain quality and to retain freedom of choice for authors.” (HC 1200, page 10.)
If the Government are serious in their wish to “facilitate a level playing field”, there is no indication in their Response of action to make their wish a reality. The way in which the subscription publishing model is operated places barriers in the way of the development of alternative publishing models. The Government’s wish “to encourage competition and innovation in publishing” is very laudable, but no action is proposed to realise this wish. The subscription model provides no competition in the supply of published work (the publisher’s copy being the only copy accessible) and only provides competition for authors through quality and not through price, i.e. authors choose publication outlets on the basis of impact factors without any regard for cost. Copyright arrangements place a barrier in the way of competition and the development of alternative publication outlets. The current structure is protectionist in design and operation. Positive action is required to create the level playing field the Government rightly desires.
“An author-pays model would lead to industry (which is a significant user) paying less and therefore, unless the author-pays model was cheaper to run, the Government would find itself forced to pay more.” (HC 1200, page 10.)
This is one of a number of opinions in the Government Response derived from speculation about the effect of a particular business model. The assumption is that revenue to support publications without subscriptions would come entirely from authors or Government-supported funding agencies. Existing journals have a mix of revenue streams and open access publishers can be imaginative in developing new revenue structures. The opinion expressed also ignores the issue of value for money. The benefits to education at all levels from open access to information will provide Government with better value for money than the current toll-based publications structure.
“The Government is not aware that there are problems in accessing scientific information, or that there is a large unsatisfied demand for this…….. The Government is not aware of any evidence of a significant problem in meeting the public’s needs in respect of access to journals through public libraries.” (HC 1200, page 15.)
Librarians are much more closely in touch with reader needs than the Government and the view from libraries is that access to scientific information for students and for members of the public is poor. Even the largest libraries have had to cancel journal subscriptions and even the largest libraries can only afford to purchase a small proportion of the scientific literature. The British Library document delivery service is greatly valued but it can only supply a small proportion of existing demand, let alone the potential demand for access over the internet from individuals working at home. Access to scientific publications largely depends at present upon travel to a library building, often at a considerable distance, and the current subscription system does not meet the demand for unlimited electronic access.
“Some universities argue that their libraries are already so heavily used by staff and students, to whom they have to give priority, that the capacity is not there to let the general public in too. There are also a number of specific issues such as collections that could attract high demand, that need to be addressed.” (HC 1200, page 16.)
These statements illustrate the Government’s lack of understanding of the differences between access to print publications and electronic publications. Electronic access to scientific journals from the reader’s home does not place a burden upon a library’s physical capacity. Issues such as seating capacity or access to high-demand collections are only important in considering access to printed content. It is the publishers’ insistence on allowing only “walk-in” access to electronic content and refusal to allow remote access for members of the public that is more likely to put pressure upon library capacity than remote electronic access.
“The cost of supplying free or low-cost access to institutions in developing countries is only possible because there is no commercial market for the publications in the countries concerned (hence the exclusion of China and India).” (HC 1200, page 17.)
This statement illustrates the weakness in current schemes to provide the results of scientific and medical research to developing countries, viz. that the publishers are unwilling to allow access when an existing or potential market is threatened. The recipients of free access are determined not by their need but by their lack of potential as subscribers. Many countries (for example South Africa) are in desperate need of access to UK research but the subscriptions of a few wealthy institutions rule them out of free access under the current arrangements. The deposit of UK research results in repositories or open access journals would make this content available to all who need it.
“The Government is not convinced that there is an impending crisis in journal provision within the HE sector. Some in the sector have queried whether the general increase in journal prices over recent years is justifiable and sustainable; but the sector’s aggregate spending on journal subscriptions continues to be only a small proportion of their total research costs and the total spend on journals only equates to 1% of HEFCE funding. The government has not seen evidence to suggest that access for researchers to journals and other research information is becoming more difficult. If anything, the reverse seems to be the case as increasing amounts of material become accessible from the researcher’s desktop. According to figures produced by the Publishers Association, there is an increasing number of downloads from UK based publishers. These downloads are estimated to be 250-300million in 2002, 500-600million in 2003 with a projected volume for 2004 of 1 billion.” (HC 1200, page 19.)
The Government has accepted publishers’ arguments about the lack of problem without applying the same critical analysis that the Science and Technology Committee did when presented with similar arguments. The effect of rising journal prices upon library provision is well-documented in the Evidence to Enquiry by the Science and Technology Committee. The “increasing amounts of material” available to researchers are coming from only a handful of publishers, while many journals from small publishers are being cancelled to pay for the bundled deals. The number of downloads given in the Government Response is presented without any indication of content to which they refer, nor whether they only refer to UK use or to world-wide use.
“It is not possible, under long-standing agreements with our European partners to exempt or zero-rate supplies of digital publications to libraries. Libraries are liable to pay VAT on many goods and services that they purchase in the same way as any other purchaser. The normal VAT rules do, however, allow institutions that are undertaking taxable business activities to recover the VAT they incur. In addition, local authorities are refunded the VAT incurred on goods and services (including digital publications) purchased in connection with their statutory public duties, including the provision of public library services. This refund scheme is achieved by section 33 of the VAT Act 1994, and is designed to ensure that VAT does not become a cost borne by local taxation.” (HC 1200, page 24.)
The Government has not provided a satisfactory answer to the issue of VAT charged to libraries. If VAT can be refunded to public libraries, why cannot it be refunded to academic libraries? If universities can claim exemption for medical equipment, why cannot they claim exemption for medical journals? This is the kind of flexibility in the VAT arrangements which the Government has the power to implement without the agreement of other European states.
“Institutional and thematic repositories can play a significant role in the dissemination of research outputs. However the Government has no present intention to mandate Research Council funded researchers to deposit a copy of their published material in institutional repositories.” (HC 1200, page 28.)
“We note that the value of institutional repositories will depend critically upon the comprehensiveness of their collections, including both published and unpublished material from research, whatever the source of funding.” (HC 1200, page 29.)
There is an inconsistency between these statements. The Government recognises the value of repositories, believes that their value lies in their comprehensiveness, and yet is not willing to mandate the deposit of the results of research it funds.
“In the Government’s view, flexible copyright arrangements are part of the competitiveness basis on which publishers market their journals. Publishers, both commercial and not for profit, use flexible copyright arrangements to compete for the services of authors.” (HC 1200, page 30.)
Flexible copyright arrangements are certainly important but the Government fails to recognise that present copyright arrangements are not flexible. An author is rarely given any choice in the wording of copyright agreements. A publisher will refuse to publish unless the publisher’s copyright agreement is signed. Publishers do not use their copyright policies to compete for authors; they use the impact factor of the journal.
“It is also the case that most current Open Access initiatives are subsidised by charitable institutions.” (HC 1200, page 31.)
This statement is totally false. Most open access journals are published by commercial publishers, by not-for-profit publishers or by academic institutions. The Public Library of Science is the single high-profile open access publisher working under a substantial charitable grant and it has a business plan which leads to viability without charitable subsidy. All journals - whether open access or subscription - are “subsidised” in their start-up period whether from profits on previous publications or from an external grant.
“This is because the key area of uncertainty is the extent to which the true costs of STM publications are reflected in current models.” (HC 1200, page 32.)
“Ultimately, it will be the research communities themselves who will determine any future impact of author-pays publishing and the Government should not adopt a stance which either strongly encourages or discourages author choice.” (HC 1200, page 32.)
These are two examples of statements in the Government Response which do not make sense in relation to other parts of the Response. In what way are publishing costs not reflected in current models? Surely other parts of the Response argue that it is open access publications which do not reflect true costs, while subscription journals do? And elsewhere in the Response the Government argues for author choice, but in the sentence quoted above does not wish to encourage author choice!
“The Government would be willing to consider applying this approach [MRC recognition of author charges as indirect costs] more widely to health research in concert with other research funders.” (HC 1200, page 33.)
This is the only encouragement for open access publication payments to appear in the Government Response and is very welcome. But why only health research?
“It is not currently evident that author-pays publishing is a growing phenomenon. According to figures reported to us from Ulrich’s Periodicals Directory, of 89 new journals launched so far in 2004, only 11 of these are Open Access journals.25 This compares to 30 Open Access Journals that were launched during the whole of 2003. Ulrich’s also shows that the percentage of Open Access journals launched, compared to all journals launched has actually decreased since 2001. In 2001, there were 63 new Open Access journals launched out of 308 journals (20.5%), 2002, 47 out of 255 journals (18.4%) and 2003, 30 out of 198 (15.2%). The current percentage for 2004 is 12.4%.” (HC 1200, page 35.)
In fact the percentages for new open access journals as a proportion of all new journals are very encouraging for such a new business model. The figures from the Lund University Directory of Open Access Journals www.doaj.org are even more encouraging and demonstrate that - contrary to the Government view - “author-pays” publishing is a growing movement.
“The majority of revenue from STM publishing, comes from exports rather than UK sales, resulting in global subscription revenue of £750 million. For example, The Royal Society of Chemistry receives approximately 90% of its revenue from exports, which is then funnelled back into the UK through its work training teachers, making the RSC the 2nd largest provider of training for teachers in the UK (after the Government). The Government would want to avoid placing the UK at a disadvantage in a global market, or damaging what is a thriving, innovative market in STM publishing.” (HC 1200, page 35.)
“The Government is concerned that learned societies could lose a substantial amount of income in a move to author-pays publishing It is inherent in the author-pays publishing model that these societies, who have large amounts of export sales, will suffer.” (HC 1200, page 36.)
The view that income for the UK economy or for UK publishers will be damaged through conversion to an open access business model is a myth. If UK publishers produce high-quality journals they will replace their current income from subscriptions with income from publication-charges paid by authors or funding agencies. And for learned societies that new source of income can be used to continue their support for educational activities. The greater threat to the UK balance of payments and UK publishers comes from failing to seize the current opportunities for change, putting the UK at a disadvantage in relation to other countries ready to adopt change.
