The Royal Historical Society has published an interim/draft report feeding back on Plan S. Although not a historian but as someone with a keen interest in open access in the humanities disciplines – and in the spirit of open exchange, since this document has understandably caused some alarm among humanities scholars – I wanted to write up my criticisms (and one ringing endorsement where I agree with them) in public.

This report starts out well but also contains a substantial number of inaccuracies, contestable aspects, or selective interpretations of the information available about Plan S. Here are the parts where I disagreed or had comment:

On page 2, it is noted that funding for history research is awarded to universities via the Research Excellence Framework (REF). The document also correctly notes that UK Research and Innovation (UKRI) is a signatory to Plan S. What is missing from the report in toto as far as I could see is the fact that Research England (RE) – which partially runs the REF – is part of UKRI. UKRI is not a straightforward replacement of the Research Councils but also involves the QR stream. This is complicated, though, by the fact that the devolved administrations also have a say in the running of REF. What we do not know, therefore, is whether REF outputs after 2020 will be included in Plan S criteria. This could substantially alter the business model/motivations for societies to change their publication mode in the report, but is not, so far as I can tell, here considered.

On page 2, it is said that “Plan S implementation will potentially entail substantial new publication costs for authors”. Throughout the report there are two conflations made that are very problematic. The first is that gold open access is an author-pays model of Article and Book Processing Charges (APCs/BPCs). This is not even the definition of gold open access, which merely stipulates that the publisher make it openly available. Other models are available that do not require authors to pay but that still return revenue to a publisher. These are not explored anywhere in this document.

The second problem throughout is that while early on in the report, zero-embargo green open-access is mentioned in a footnote, this actually then disappears from the rest of the report. The architect of Plan S, Robert Jan-Smits, has repeatedly stressed that green OA, without an embargo, will be allowed. Alright, so, you might think, that must be very uncommon and result in utter business-model devastation for a publisher? Not so. Did you know that Cambridge University Press already allows zero-embargo green OA of journal articles in the HSS disciplines? CUP is, of course, one of the example publishers named later in the document. I believe Emerald also have a similar policy. This has not resulted in the collapse of their journals but has allowed more people to read the underlying work.

It is interesting and, of course, important and crucial that organisations like the RHS pay attention to equality, diversity, and career status/precarity of their communities. Universities are pretty terrible at this in general. However, in this document, open access to published research is presented as a problem for systemically disadvantaged groups, rather than as something that might help them. This begins on page two and runs throughout. I would note that one of the problems faced by precarious ECRs, as an example group, is that they can’t get easy access to research material and so find it harder to build a career. “Why don’t they go to the library?” is a common response to this. Well, I’m sure they would, if they weren’t trying to hold down a day job and fitting their research around that. Making physical access to a deposit library a prerequisite for ECRs to conduct research seems to me to be a pretty high barrier amid the other challenges they may be facing.

Further, the fact that OA is seen as a barrier for ECRs is, again, premised on APCs and BPCs. Once more, there are models for OA that do not have these charges but that do not rely on volunteerism. As far as I know, neither the RHS nor any other historical learned society has attempted to implement these.

On page 2, it is said that “Plan S is largely a UK and EU initiative”. Well, and China, one of the largest (and growing) producers of research in the world. However, see my later comments on this and censorship, on which the RHS is correct.

On page 4, the note for the need to engage with Learned Societies should note the recent UKRI and Wellcome Trust funded opportunity entitled helping learned societies transition to Plan S. I hope the RHS will engage with whomsoever is appointed to take on this work.

On page 6, it is said that “Plan S requires the replacement of the ‘hybrid’ Gold and Green OA system […] with Gold OA alone”. There are, again, two problems here. First, the syntax here is misleading, as “hybrid” looks as though it refers to “Gold and Green” as being a hybrid system. This is not what is meant by hybrid OA publication, though. Hybrid OA refers to conditions where an article is made openly available within an otherwise subscription-based journal. This is also, second, though, a misrepresentation of Plan S, which, as above, allows green OA with zero embargo.

Page 6 also contains another inaccuracy. Green OA is implicitly here defined as necessarily allowing an embargo. But zero-embargo green OA is still green OA. And Plan S allows zero-embargo green OA. The erroneous claim that “hybrid” refers to “Green and Gold” is also repeated here: “For a transition period of 3 years, journals that have committed to embrace Gold OA under Plan S terms can maintain their ‘hybrid’ status, publishing both Green and Gold articles.” (This is incorrect and is not what the Plan S transition agreement refers to, where hybrid, as above, means gold open articles in subscription journals.)

On page 8, it is said that only a modest number of authors come from Plan S funders, but, again, this ignores (I think) the ambiguous status of Research England and the REF.

On page 8, it is stated that “Gold OA mandates which shift the cost of OA from the reader to the author pose significant challenges”. I agree with this, but this is not what Plan S does. Again, there is no single mandated business model. I run a publisher that has no author or reader facing charges and that publishes 27 journals. It can be done. Also, with apologies for sounding like stuck record, zero-embargo green is just fine.

I disagree with the characterisation on page 11 of CC BY licenses encouraging plagiarism or twisting of words. We have strong academic norms to prevent plagiarism and these are not altered by a different legal status on the copyright of the work itself. The most common hyperbolic version of this argument can be seen if one uses Godwin’s Law. “Imagine that we make our work openly available under CC BY licenses and neo-Nazis take the work and pervert our views because they can”. The retort is obvious: do you really think that neo-Nazis are such respecters of copyright that they would be stopped from doing this by the fact that the law says they may not? (Also, the CC BY license does not allow a re-user to attribute changes in your words in a way that implies that you approve of their modifications.) What we actually need here is an academic code of re-use that can be enforced in the academy and para-bodies to make clear the terms of attribution. We sort of already have these in our norms but perhaps formalisation would lay such fears to rest.

The note on page 24 that production of JATS XML is prohibitive is not true. Most external typesetters can do this for a very reasonable fee. We do this at OLH and our typesetting costs are approximately £110 per article.

On page 25, there is an alarming table that shows CUP, OUP, T&F, and Wiley’s Article Processing Charges. They are, indeed, steep. What is left out from this picture is the profit or surplus margins of these organisations. A quick Google tells me that CUP had an operating profit of £16.3 million in 2016-2017; T&F (part of Informa) had a 38.1% Adjusted Profit Margin on a revenue of £530m in 2017; and Wiley reports a revenue of $1,719 million and notes that “The year-over-year increase is attributed to significant improvement in Contribution to Profit for Publishing (+117%)” – that is, their publishing business improved its contribution to profit by 117%. (As I’m writing this in a hurry, the source for the T&F figure here is Wikipedia, so don’t shoot me if it’s not 100% reliable, but it sounds in line with previous official figures when I’ve looked them up. The other figures come from Wiley and CUP). I haven’t looked up OUP’s most recent stats, but they also bring in the ££s.

So here’s a question: if the RHS hates the fees that publishers charge so much and wants people to be shocked, why doesn’t it go with or recommend publishers who don’t make millions of pounds of profits off libraries? You could then reduce those fees by a substantial amount. Those profits already exclude revenue returned to societies, after all. The cost of an APC at these publishers may well exceed the QR allocation, but historical societies seem to do little to support cost pressure, even where the entities with whom they have publishing arrangements are making millions upon millions of pounds of profit. Why, again, do those APCs need to be so high? It’s to support those profit or surplus margins, not just the cost of the actual work of publishing or a safety net.

On page 33, the potential impacts of Plan S are listed. One of these is a question: “Is there a significant likelihood, given History career structure, for ECRs to be disadvantaged by this system?” Perhaps there is. But perhaps this is a problem with the History career structure, and not with Plan S.

On page 33, it is asked whether book chapters are in or out of Plan S. I would assume they are “out for now” as they count as books, but this could be explicitly clarified.

And finally, though, to end on a positive note: the RHS is right on page 34 to query censorship and the complicity of academic publishers with censorious regimes. The Chinese government has signed Plan S. We should raise the challenges this faces in terms of ensuring that academics have the right to speak and to be read.