Like many others, I found myself reading response after response after response to cOAlition S’ call for feedback on the Guidance on the Implementation of Plan S last week. The volume of response is staggering. Statements have poured in from individual and groups — publishers, scholarly societies, disciplinary repositories, scholarly communications platforms, funding agencies, publishing professionals, libraries, library associations, and researchers themselves. As the deadline drew near on Friday, I could hardly “right click/open link in new tab” fast enough as my Twitter feed scrolled by. The input from Norway alone has reached 885 pages. The Open Access Tracking Project currently has almost 400 documents tagged oa.plan_s. reddit Open Science and Scholia/wikidata have also been tracking replies. One imagines that there is feedback that has not been shared publicly as well.

cOALition S members have a large task ahead of themselves to review and engage with the commentary they have received. On the feedback form, the cOAlition stated that “in the spirit of Open Access, all responses received as a part of the feedback on the Guidance on the Implementation of Plan S will be shared in the public domain.” I hope that we will also see some sort of summary report eventually in addition to the full text of the replies.

In the meantime, I thought it might be useful to share some of the themes that I have observed emerging across the feedback documents. These are impressionistic and not a systematic analysis. I look forward to seeing comments about the themes that others have observed.

Theme 1: Clear support for the transition to open access and the goals of Plan S.

Almost universally, the responses affirm the desirability of open access publishing and continuing the progress towards full open access for scholarship. This quickly became so obvious that I started paying more attention to how the rhetorical move was made in each document, transitioning from a statement of the support for the goal of open access to the critique that was about to be made of the mechanisms detailed in implementation guidance. The nature of that rhetorical move often set up the overall tone of the particular response as more positive or more negative.

Theme 2: Concern that the implementation guidance reflects models that work for STEM but will negatively impact HSS scholars.

The Guidance from cOAlition S goes into much greater detail about article processing charge (APC) funding than any other business model for open access publishing. Research funding structures in the sciences already provide a mechanism for paying these APCs, evidenced by the millions already being spent on APCs annually. APCs are not dominant currently in the humanities and social sciences (HSS) and few social scientists and almost no humanists are confident of having sufficient financial support to pay APCs if subscription journals convert to APC-based open journals. The impact of the specified CC BY licenses also received a great deal of comment, particularly with respect to work in the humanities. Respondents are generally pushing to move away from one-size-fits-all models and asking for specific financial support for and detailed attention to non-APC-based business models as well as allowance for the full range of Creative Commons licenses.

Theme 3: The technical requirements for publication, repository, and other platforms are poorly thought out.

First, there is a great deal of confusion about what the requirements actually are, particularly with regard to transitional agreements and the requirements for hosting author manuscripts. There are also comments that some or all of the requirements are unnecessary for open access or untenable for all but the largest players. Finally, there are concerns that some technical requirements seem strangely or narrowly specified; specifically, that they are stated in ways that unnecessarily tie the Guidance to current technology tools and standards and could thereby prevent innovation going forward.

Theme 4: The predicted effects on small, independent, and society publishers raise concerns for the viability of these publishers.

Plan S favors large scale publishers, particularly those with capital reserves to invest in technology, workflows, etc., and to protect against any dips in revenue during transitions. Small, independent, and society publishers are already under pressure from both the Big Deal model for subscriptions and the current transition to open access. Many already have contracted with or sold to larger publishers, leading to a consolidation in the industry. For those publishers with greater than average volume from cOAlition S-funded researchers, the almost immediate prohibition on researchers publishing in hybrid journals could lead not only to greater consolidation but — for societies — elimination of other services or even insolvency of the societies themselves. The difference between the currently slower transition to open access and the faster transition under Plan S could mean the difference between survival and extinction.

Theme 5: Setting a fair and reasonable APC sounds fair and reasonable but it is also likely impossible.

Beyond the logistics of documenting all costs, direct and indirect, as well as surpluses, and the complexity of establishing consensus around acceptable savings, overhead, etc., commercial companies are prohibited from sharing at least some of what would be relevant information publicly by various laws and regulations.

Theme 6: Scholars and organizations in the Global South object to being told what they want.

As well-intentioned as it may be to be concerned about readers in low- and middle-income countries having access to publications to read, that does not obviate the problem that will be created for researchers in the Global South by imposing a system that demands payment for publication. Full and partial APC waivers attempt to address this issue of payment for publication but waivers are an imposed solution to a problem that is created by imposing a system.

Theme 7: The timelines are not feasible.

This is also nearly universal in the feedback. Even the most positive of feedback often questions the feasibility of the timelines in the Guidance.

Final Thoughts

In no way do these themes encapsulate every comment that I’ve seen; that would be impossible. There are definitely some unique and outlier responses. But, taken as a whole, the feedback documents I have read left me with the view that the Guidance on the Implementation of Plan S has been taken very seriously by the global scholarly communication and publishing communities.

There is enthusiasm and support for the overall goals of Plan S; however, there is also a great deal of concern about the implementation guidance and the very real possibility of negative unintended effects. As the Guidance is finalized, and as each funder begins to specify its choices about imposing the requirements, my hope is that we will see attention to mitigating the kinds of destructive effects that have been raised as concerns and to encouraging continued innovation in advancing quality scholarship.