RHS Response to Plan S Transformative Journals consultation

19 December 2019

The RHS has responded to the cOAlition S consultation on their draft framework for transformative journals criteria in Plan S. We were grateful to have the opportunity to contribute to the development of the framework through this process, full details of which are available here. The survey closes at 09.00 CET on Monday 6th January 2020.

The consultation offered three opportunities for comment on elements of the framework. The RHS responses to these are reproduced below in full.

Colleagues and stakeholders may also be interested in the following:

 

RHS Response to Plan S Transformative Journals consultation

Q.1 The draft framework specifies that a Transformative Journal must demonstrate an annual increase in the OA penetration rate of at least eight percentage points year-on-year, measured on a three year rolling period. If you disagree that this is fair and reasonable, then please specify what target you would support, and why. [2000 character limit]

The RHS does not support imposing arbitrary, unachievable targets for yearly increases in OA, and we see little or no prospect of History journals “flipping” to full OA. For the vast majority of History (and wider Humanities) journals submission numbers are not at a scale to make such calculations possible. Nor does this proposal offer Humanities journals a financially viable pathway to sustainable publication. For evidence and figures for history publishing, see our Feb 2019 response (Part 4) to the Plan S consultation: https://royalhistsoc.org/plan-s-consultation-feb-2019/)

Requiring journals to increase OA content by a fixed % p.a. will subvert the vital role of rigorous independent peer review by forcing editors to make decisions about publication based on authors’ ability to pay for OA, rather than the work’s quality. We note SpringerNature’s response to this consultation also makes this point.

If subject to inflexible targets, authors in receipt of Plan S funds may be sorely disadvantaged if the most appropriate journals for them to publish in are made “non-compliant” by stringent universal criteria.  Existing Plan S requirements for OA journals already mean the great majority of History journals in DOAJ are not Plan S compliant. More fundamentally, by mandating author compliance regimes without first developing viable, long-term financial models for the ‘transformative’ Humanities journals in which they are expected to publish, this proposal undercuts Humanities researchers’ ability to publish in peer-reviewed outlets.

The RHS keenly supports fair, equitable open access in principle and practice, and welcomes transparency in any transition. But reducing OA goals to percentage “penetrations” (itself an inept choice of phrasing) risks further distancing Plan S from the ethical and moral impetus of the OA movement more broadly, and from engagement with the richness and diversity of potential approaches that characterise global OA initiatives.

 

Q.2 In addition to the 8% increase on OA penetration, year-on-year, the publishers of Transformative Journals must agree to either flip them to OA either when 50% of the content is OA, or by 31st December 2024. To what extent do you agree that these are fair and achievable? If you disagree with this, please specify what target (percentage of OA, or date) you would support, and why. [2000 character limit]

The calculations presented here are both inappropriate and very difficult to apply in an Arts&Hums context where journal submissions are comparatively few & fewer than 20% of authors can access APC funds.

Research carried out by the RHS indicates that Plan S signatories fund a maximum of 17% of articles in UK History (& wider humanities) journals, making any target unrealistic. (see RHS February 2019 Response, p.43 at https://royalhistsoc.org/plan-s-consultation-feb-2019/) From a base of 15% OA it would take 16 years at 8% increase to reach the 50% threshold that the coalition deem a realistic point to “flip”. History journals would need to grow OA at a rate of 36% p.a. to meet the 50% threshold by December 2024. Even at 8% growth, less than a quarter of articles are likely to enjoy access to the funds required for open access by Dec 2024.

There is little evidence currently available that more funding – particularly for arts and humanities subjects – is going to become available and cOAlition S Funder “support” is unspecified in the Plan S Principles and Implementation guidelines. There is a dearth of examples of H&SS journals operating at scale, over the long-term, without a subscription base or paywall AND without significant and ongoing institutional support from research organisations or external grant funding.

The best journals attract global authors from a wide and international range of institutions and institution-types. They do not function in closed national, regional or local systems. By rejecting hybrid as a viable, sustainable (and popular) medium to long-term means of fostering OA and setting the bar so high, this plan is likely to stifle innovation by alienating publishers (with the effect that Plan S funded researchers may be locked out of the best journals) and paradoxically drive researchers back toward subscription journals that allow submission of AAM.

 

If you have any further comments on the proposed framework for Transformative Journals, please add them here. [2000 character limit]

We thank cOAlition S for the chance to respond to this framework, but remain unconvinced of the evidence-base, or rationale behind these targets. The Sept 2019 Information Power report valuably seeks to establish evidence-based arguments, but its “transformative agreement toolkit” takes a very small sample across all research areas (from H&SS to STEMM), contains internally inconsistent arguments and dodges key issues around funding for sustainable H&SS OA journals. Of the 7 models in the IP report, only 3 seem designed to produce full, permanent OA journals, and 4 do not appear to be ‘transformative’ as defined by cOAlition S. Effectively, in this scenario the APC model remains the only viable means of funding transformative journals, yet in Humanities less than 20% of researchers have access to cOAlition S funding for APC payment.  This deficit is especially acute for ECRs.

This proposal again shows no evidence of considering potential implications for Equality, Diversity & Inclusion (EDI), or researchers (e.g. ECRs) who don’t meet waiver criteria. UK-based cOAlition S Funders have specific duties of care and legal obligations with respect to researchers’ rights to equal opportunities. The absence of any reference to EDI as defined by European legislation or UK Equality Act 2010 is a striking feature of the Plan S Principles, broader cOAlition S policy statements, and this plan.

In OA policy discussions, the term ‘transformative agreements’ describes 2 distinct types of OA contracts, which may or may not comply with Plan S. The first are contracts designed to reduce specified research organisations’ annual journal subscription costs while enhancing OA. The second are agreements by journals for a permanent transition to fully and immediately open-access peer-reviewed articles. We urge clarity and consistency from cOAlition S about their definitions, and to consider possible consequences for researchers, disciplines and wider academic publishing ecosystem.