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Tony Ross-Hellauer, 22nd December 2018

Context: Having been asked to give feedback on the recent Plan S Implementation Guidelines for a working group, I thought I’d share my thoughts here. I’ve not really been keeping on top of the Plan S discussions, and given how late I am to the party, likely much of this has been said better elsewhere already. But anyway:

In general, Plan S is to be warmly welcomed as a bold move to conclude the transition of Open Access as the default mode of scholarly publishing in a timely manner. The devil is invariably to be found in the details, however. So, as these details become clearer, it is encouraging to see that the latest implementation guidelines make a concerted effort to address justified concerns voiced since the initial Plan S announcement. Some concerns persist however. In future development of these guidelines, it would hence be advisable to provide clarity on the following issues:

Hybrid transition agreements: The implementation guidelines state, “in a transition period, publishing Open Access in subscription journals (‘hybrid Open Access’) under transformative agreements as means to achieve compliance with Plan S.” Where it is indicated that a journal that is covered by a transformative agreement must have a clear and time-specified commitment to a full Open Access transition, it must be clear that this transition will definitely occur. Publishers have long said publicly that hybrid was a transitional measure, while doing little behind the scenes to implement that transition. The question thus arises, how strictly this condition will be enforced. Will there, for example, be penalties for journals/publishers that then renege on such agreements once the time-period elapses? If so, of what kind and how will they be enforced?

The implementation guidelines state, “in a transition period, publishing Open Access in subscription journals (‘hybrid Open Access’) under transformative agreements as means to achieve compliance with Plan S.” Where it is indicated that a journal that is covered by a transformative agreement must have a clear and time-specified commitment to a full Open Access transition, it must be clear that this transition will definitely occur. Publishers have long said publicly that hybrid was a transitional measure, while doing little behind the scenes to implement that transition. The question thus arises, how strictly this condition will be enforced. Will there, for example, be penalties for journals/publishers that then renege on such agreements once the time-period elapses? If so, of what kind and how will they be enforced? Costs: The implementation guidelines state, “Transparency on Open Access publication costs and fees is included as one of the criteria that define Plan S compliance of journals and platforms.” Given that costs of publishing seem to vary so much from publisher to publisher, this condition is an essential part of ensuring that the capping of APC costs is tied to the actual costs involved. However, whether such a condition functions effectively will rely on the way in which such transparency is implemented and monitored. At present there are no effective, widely-agreed workflows for such transparency. The creation of such will be essential in ensuring costs can be compared on a like-for-like basis. There will obviously be costs involved in implementing such systems on the publisher side, but for transparency to be effective, there will also be monitoring costs on the side of the funders. For the avoidance of inefficiencies, this would likely be best implemented by a third-party funded collaboratively by cOAlition S who can then share data will all cOAlition S members. However, this would require further formalisation of collaborative-funding and governance within cOAlition S.

The implementation guidelines state, “Transparency on Open Access publication costs and fees is included as one of the criteria that define Plan S compliance of journals and platforms.” Given that costs of publishing seem to vary so much from publisher to publisher, this condition is an essential part of ensuring that the capping of APC costs is tied to the actual costs involved. However, whether such a condition functions effectively will rely on the way in which such transparency is implemented and monitored. At present there are no effective, widely-agreed workflows for such transparency. The creation of such will be essential in ensuring costs can be compared on a like-for-like basis. There will obviously be costs involved in implementing such systems on the publisher side, but for transparency to be effective, there will also be monitoring costs on the side of the funders. For the avoidance of inefficiencies, this would likely be best implemented by a third-party funded collaboratively by cOAlition S who can then share data will all cOAlition S members. However, this would require further formalisation of collaborative-funding and governance within cOAlition S. Repository requirements: The implementation guidelines stipulate a range of technical requirements for repositories to be in compliance with Plan S. Some, however, are unnecessarily restrictive given current requirements and the technical state-of-play of most repositories. If requirements are too stringent, many institutions will be unable or unwilling to comply, and this will drive further focus on Gold OA as the primary mode of Plan S compliance. Hence, I strongly agree with the recommendation of the Confederation of Open Access Repositories (COAR) “to remove or reword some of the requirements, and move others into a “Recommended additional criteria”.[1] Such requirements include automated manuscript ingest facility, XML/JATS full-text, and helpdesk availability.

The implementation guidelines stipulate a range of technical requirements for repositories to be in compliance with Plan S. Some, however, are unnecessarily restrictive given current requirements and the technical state-of-play of most repositories. If requirements are too stringent, many institutions will be unable or unwilling to comply, and this will drive further focus on Gold OA as the primary mode of Plan S compliance. Hence, I strongly agree with the recommendation of the Confederation of Open Access Repositories (COAR) “to remove or reword some of the requirements, and move others into a “Recommended additional criteria”.[1] Such requirements include automated manuscript ingest facility, XML/JATS full-text, and helpdesk availability. Bibliodiversity and APC waiver requirements: The implementation guidelines state: “Where article processing charges (APCs) apply, cOAlition S will contribute to establishing a fair and reasonable APC level, including equitable waiver policies”. A major concern regarding the policy actions of rich Global North nations which aim to provoke global change, is that those actions have negative consequences upon other world-regions. Here, the potential for a big-flip to APC-based OA publishing has long been seen to reify author-charges as the default mode of scholarly publishing, potentially excluding less well-resourced researchers. Such effects may already be occurring.[2] Merely moving a paywall from one end of the publishing workflow to the other will merely shift the focus of existing inequities – but less well-resourced researchers will remain those who lose out. In response to this concern, the implementation guidelines make encouraging statements regarding the need to foster what has elsewhere been termed ‘bibliodiversity’[3] and that sufficient waiver systems should be in place as a condition of publisher compliance. At present, however, waiver systems lack formalisation and are too often seen as a form of “charity”. Hence, to ensure the equitable implementation of these requirements, cOAlition S could make the formalisation of waiver systems a compliance requirement, including efficient workflows, equitable and standardised criteria, as well as transparency on processes and decision-making (this could be part of the transparency of costs requirement). In addition, it must never be the case that waivers are seen as charity – as this may further reduce willingness to take these options up on the side of Global South researchers. Hence, cOALition S should consider endorsing the fourth FAIR OA principle that “Submission and publication is not conditional in any way on the payment of a fee from the author”, and that APCs are always “opt-in” on the side of the researcher.[4] Despite this, the mere mechanics of waiver-systems may drive further stratification. For example, many waiver schemes currently stipulate that all authors must be from eligible countries for the waiver to apply. But this may discourage researchers from Global North countries from collaborating with those researchers for concerns that this will mean they (or their funding grants) will then bear any APC costs. The unintended consequences of these policies should therefore be part of any scoping research and post-hoc review procedures.

The implementation guidelines state: “Where article processing charges (APCs) apply, cOAlition S will contribute to establishing a fair and reasonable APC level, including equitable waiver policies”. A major concern regarding the policy actions of rich Global North nations which aim to provoke global change, is that those actions have negative consequences upon other world-regions. Here, the potential for a big-flip to APC-based OA publishing has long been seen to reify author-charges as the default mode of scholarly publishing, potentially excluding less well-resourced researchers. Such effects may already be occurring.[2] Merely moving a paywall from one end of the publishing workflow to the other will merely shift the focus of existing inequities – but less well-resourced researchers will remain those who lose out. In response to this concern, the implementation guidelines make encouraging statements regarding the need to foster what has elsewhere been termed ‘bibliodiversity’[3] and that sufficient waiver systems should be in place as a condition of publisher compliance. At present, however, waiver systems lack formalisation and are too often seen as a form of “charity”. Hence, to ensure the equitable implementation of these requirements, cOAlition S could make the formalisation of waiver systems a compliance requirement, including efficient workflows, equitable and standardised criteria, as well as transparency on processes and decision-making (this could be part of the transparency of costs requirement). In addition, it must never be the case that waivers are seen as charity – as this may further reduce willingness to take these options up on the side of Global South researchers. Hence, cOALition S should consider endorsing the fourth FAIR OA principle that “Submission and publication is not conditional in any way on the payment of a fee from the author”, and that APCs are always “opt-in” on the side of the researcher.[4] Despite this, the mere mechanics of waiver-systems may drive further stratification. For example, many waiver schemes currently stipulate that all authors must be from eligible countries for the waiver to apply. But this may discourage researchers from Global North countries from collaborating with those researchers for concerns that this will mean they (or their funding grants) will then bear any APC costs. The unintended consequences of these policies should therefore be part of any scoping research and post-hoc review procedures. Timeline: The implementation guidelines state, “cOAlition S appreciates that the timeline for implementation of Plan S will vary among member organisations. Implementation of Plan S will take place from 1 January 2020, having impact on either 1) existing grants, 2) new projects/grants or, at the latest, 3) new calls. cOAlition S members should, at the very least, implement the new requirements in all calls issued after 1 January 2020“. For the smooth implementation of Plan S and the avoidance of confusion amongst researchers (especially given the strong statements on the intention to enforce compliance), at least the second of these options, and perhaps preferably the third, should be taken.

The implementation guidelines state, “cOAlition S appreciates that the timeline for implementation of Plan S will vary among member organisations. Implementation of Plan S will take place from 1 January 2020, having impact on either 1) existing grants, 2) new projects/grants or, at the latest, 3) new calls. cOAlition S members should, at the very least, implement the new requirements in all calls issued after 1 January 2020“. For the smooth implementation of Plan S and the avoidance of confusion amongst researchers (especially given the strong statements on the intention to enforce compliance), at least the second of these options, and perhaps preferably the third, should be taken. Compliance and Sanctioning: The implementation guidelines state, “ The individual members of cOAlition S will align their grant agreements and/or contracts with Plan S and monitor compliance and sanction non-compliance through enforcing contractual requirements.” Enforcing compliance has, heretofore, been a dog that has barked but never bitten. This is understandable as funders do not want to be seen to penalise their own researchers. But if everyone understands a threat to be empty, it is no longer a threat. Hence for OA policies to become truly effective, enforcement must be taken seriously and backed-up by clear and present consequences. Robert Jan Smits has made strong statements in this regard, viz: “it is important to do effective monitoring, but also not being afraid of applying sanctions”[5]. If this strong stance is still the case, more detail should be given how will Plan S funders effectively monitor non-compliance, as well as which penalties will be imposed under which conditions.

The implementation guidelines state, The individual members of cOAlition S will align their grant agreements and/or contracts with Plan S and monitor compliance and sanction non-compliance through enforcing contractual requirements.” Enforcing compliance has, heretofore, been a dog that has barked but never bitten. This is understandable as funders do not want to be seen to penalise their own researchers. But if everyone understands a threat to be empty, it is no longer a threat. Hence for OA policies to become truly effective, enforcement must be taken seriously and backed-up by clear and present consequences. Robert Jan Smits has made strong statements in this regard, viz: “it is important to do effective monitoring, but also not being afraid of applying sanctions”[5]. If this strong stance is still the case, more detail should be given how will Plan S funders effectively monitor non-compliance, as well as which penalties will be imposed under which conditions. Review: The implementation guidelines state, “In 2023, cOAlition S will initiate a formal review process that examines the effects of Plan S.” The main focus of the review will be to examine the effect of transformative agreements as well as the option of providing immediate Open Access to subscription content via open repositories, on achieving a transition to full and immediate Open Access.” This will be an essential factor in the eventual success of Plan S. Clarity should be offered in advance on the exact terms of this review. How will success, or otherwise, be defined? How will it be measured? What aspects will be considered within this review? I would suggest it should be as widely-scoped as possible, ensuring that mere metrics of OA share are not presented as the primary consideration. Review must hence include for example, the wider socioeconomic consequences of Plan-S, including stratification of publishing and effects on bibliodiversity.

Creative Commons — CC0 1.0 Universal

[1] https://www.coar-repositories.org/files/COAR-response-to-implementation-of-Plan-S-1.pdf

[2] Siler K, Haustein S, Smith E, Larivière V, Alperin JP. 2018. Authorial and institutional stratification in open access publishing: the case of global health research. PeerJ6:e4269 https://doi.org/10.7717/peerj.4269

[3] https://jussieucall.org/jussieu-call/

[4] https://www.fairopenaccess.org/

[5] https://horizon-magazine.eu/article/open-access-scientific-publications-must-become-reality-2020-robert-jan-smits.html

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