PLOS Provides Feedback on the Implementation of Plan S
We welcome Plan S as a ‘decisive step towards the realisation of full open access’1, in particular the push it provides towards realization of a research process based on the principles of open science. This is fully aligned with our mission to bring scientists together to share work as rapidly and widely as possible, to advance science faster and to benefit society as a whole. Our publications have operated in line with the core principles outlined in Plan S since the launch of our first journal, PLOS Biology, in 2003. We recognize that wide adoption of support for Plan S may bring additional competition within the open access publishing space. We welcome this evolution as a positive change in research culture, resulting in greater availability of information, growing inclusion in the scientific process and increasing the speed of discovery and innovation. Below is our response to the call for public feedback.
- Is there anything unclear or are there any issues that have not been addressed by the guidance document?
While welcoming Plan S, its principles and stated intentions, there are some points where we believe additional clarification would be beneficial.
A. Changing research assessment
We are glad to see emphasis on changing research assessment and commitment to the principles of DORA as part of Plan S. We believe this is critical to enabling change in publication behaviours, allowing the value of research outputs to be assessed on their merits rather than through an aggregated metric based on publication venue. However, we note that although the original publication of Plan S states that members of cOalition S ‘commit to fundamentally revise the incentive and reward system of science, using the San Francisco Declaration on Research Assessment (DORA) as a starting point’1, the implementation guidance states only that ‘cOAlition S members intend to sign DORA and implement those requirements in their policies.’ We ask cOalition S to provide clarity regarding the steps that will be taken to drive the ‘fundamental change’ indicated in the original publication.
B. Transformative agreements
While recognizing the need for a route for subscription journals to transition away from publication behind paywalls, we believe that without stringent guidelines and compliance checks, ‘transformative deals’ may have significant unintended consequences, reducing choice and narrowing the market. As identified by Adam Tickell in his 2015 review2 the need for ‘OA policy to offer greater choice to research producers’ remains, and we believe this should be a primary consideration for cOalition S in considering the future shape of the research and innovation market, particularly as it relates to the assessment and communication of research findings.
‘Transformative agreements’ offer advantage to the largest players and to publishers with substantial subscriptions business, as smaller publishers have to ‘wait in line’ to enter negotiations while those, including but not limited to PLOS, without legacy subscription businesses cannot participate. We acknowledge that the intention of cOalition S members is that ‘transformative agreements’ should not decrease the amount of money available in the system to fund publishing in other compliant venues, however, we believe this is the likely outcome as limited institutional and library publication budgets become tied into large ‘read and publish’/’publish and read’ (RAP/PAR) deals. This perpetuates the dominance of the ‘big deal’ in the market, which in its rebranded ‘publish and read’ form, has the potential to become the status quo rather than a step towards transformation, much as hybrid journals have become the status quo in relation to open access. Moreover, the transition of subscription ‘big deals’ into ‘RAP/PAR’ deals risks locking the high cost of subscriptions into an open access future, if deals so far are anything to judge by. We would like to see a ‘clear and time-specified commitment to a full Open Access transition’ as outlined in the implementation guidelines, be a central requirement for all journals covered by a ‘transformative agreement’ in order to be considered compliant with Plan S. We also ask for greater clarity on the allowed start and end dates for these agreements.
C. Deposition in open repositories
While we understand that this is a recommendation rather than a mandatory criterion for compliance with Plan S, we believe that the proposal that there be ‘direct deposition of publications by the publisher into Plan S compliant author designated or centralised Open Access repositories’ has the potential to add cost and complexity to compliance.
Currently, we and many other publishers syndicate our published articles to PMC/Europe PMC. The process of direct deposition to each repository is not without cost, requiring both staff and technical resources to set up and to run. These costs will increase should it become necessary to deposit to a range of ‘author designated’ repositories. This is especially the case given the importance of equitable treatment of publications from researchers in different disciplines and/or geographical regions, particularly as cOalition S grows.
We encourage cOalition S to reconsider this recommendation and propose deposition in a small number of recognized repositories or dispatch services, to facilitate compliance.
D. Publication costs and APC caps
In the published guidance, cOalition S calls for ‘full transparency and monitoring of Open Access publication costs and fees’ and indicates the potential for ‘standardisation of fees and/or APC caps’. We understand that the cOalition has revised this position and intends to call for transparency but not to introduce set caps. We welcome this change of approach which we would like to see reflected in the next iteration of the written guidance. We believe that requiring transparency will allow funders, or others paying the costs of publication, to assess the value of their payments while minimizing the opportunity to give rise to unintended consequences.
In considering potential unintended consequences, there is a useful parallel with the introduction of tuition fees at universities in England. Since tuition fees were introduced in 1998, they have been capped by the UK government. According to a House of Commons Library briefing paper3, each time that the cap has been raised, almost all English HEIs have increased their fees to the maximum allowed level. When it was announced that the cap would increase to £9,000 from 2012, Lord Willetts, then Minister for Universities and Science, said that the maximum fee would be charged only in ‘exceptional circumstances’4 and it was anticipated that this would ‘create a market in fees’5. This market did not emerge and in fact, nearly all HEIs set their fees at the maximum allowed rate. We believe that there is significant potential for an analogous situation to emerge in relation to APCs. Rather than creating a market where publishers set APCs at the lowest level that covers their costs sustainably, it is more likely that caps would encourage APCs to be set at the maximum allowed level even if this is substantially higher than the publisher’s costs.
Additionally, the cost associated with the publication of an individual article is highly variable dependent on publication venue. The level of editorial activity, including building relationships with, and providing support to, authors, referees and academic editors is a significant contributor to cost but generates substantial value for the research community. The level of selectivity of the journal or platform is also an influencing factor, as more selective publications incur additional costs through assessing articles that do not go on to be published in that venue. While we recognize and support the need to change the measure of selectivity from one focused on journal impact factors, we believe that the ability to differentiate levels of selectivity based on appropriate and meaningful criteria should continue, where selective journals and platforms can demonstrate their value through community engagement and cost transparency. We believe that this will support a thriving research and innovation ecosystem more effectively than moving to a ‘one size fits all’ approach.
- Published simultaneously as follows: a) M. Schiltz, available from https://www.scienceeurope.org/wp-content/uploads/2018/09/cOAlitionS.pdf; b) Schiltz M (2018) Science without publication paywalls: cOAlition S for the realisation of full and immediate Open Access. PLoS Biol. 16(9): e3000031. https://doi.org/10.1371/journal.pbio.3000031; c) Schiltz M (2018) Science Without Publication Paywalls: cOAlition S for the Realisation of Full and Immediate Open Access. PLoS Med 15(9): e1002663. https://doi.org/10.1371/journal.pmed.1002663; d) Schiltz M (2018) Science Without Publication Paywalls: cOAlition S for the Realisation of Full and Immediate Open Access. Front. Neurosci. 12:656. doi: 10.3389/fnins.2018.00656
- Open access to research publications Independent Advice, Professor Adam Tickell Provost and Vice-Principal, University of Birmingham Chair of the Universities UK Open Access Coordination Group, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/499455/ind-16-3-open-access-report.pdf
- House of Commons Library, Briefing Paper, Number 8151, 19 February 2018 Higher education tuition fees in England, https://dera.ioe.ac.uk/31330/1/CBP-8151%20_Redacted.pdf
- As above p.6
- As above p.10, Section 3.2
- Are there other mechanisms or requirements funders should consider to foster full and immediate Open Access of research outputs?
We believe that diversity and equality of opportunity, including for new entrants to the market, should be retained and encouraged to ensure to a thriving and diverse research and innovation ecosystem. Referring to part (B) of our answer to Question 1, we encourage cOalition S to consider this opportunity to move from ‘big deal’-style arrangements as rapidly as possible to avoid further consolidation around the largest players in the market.
Focusing on regulation of existing business models, both transformative agreements and APCs, may have the unintended consequence of creating barriers to the diversification in the market. We applaud the the support indicated in the implementation guidance for ‘a diversity of models and non-APC based outlets’ and encourage cOalition S to ensure equal emphasis on the development of new business models, alongside consideration of established approaches. We believe this is vital in order to maintain choice for researchers.
So-called “transformative agreements” (which seems to be central to Plan S) are done with the best intentions to increase the number of OA journals, but pose a mortal threat to existing smaller/medium and society open access journals, directing manuscripts to the large publishers who have a prepaid APC deal with libraries or consortia under such transformative agreements, away from existing OA journals. In essence, public funds are used to help large commercial companies to switch to a business model they have long resisted, instead of positively directing funds to existing OA publishers who did not have the luxury to make millions with frankly questionable business model of reselling academic content.
What librarians do here is to cement the existing monopolies/oligarchies in publishing, stifling innovation, and reduce diversity in the publishing market. In my 20 years of publishing fully open access journals, we have not once received a dime of funding from libraries (Plos has more muscle and imay have institutional agreements, but we do not have the market size to negotiate with hundreds of universities/libraries) – it is all authors paying from their research grants.
If the general model changes from author-paid APCs towards libraries picking up these costs, libraries must ensure an “open-access first” policy where native open-access publishers are equally paid (or even paid first, i.e. transformative agreements should only be made for journals where no OA journal are in existence and where there is significant demand to publish in a former subscription/hybrid journal) and ensure that manuscripts are equally directed towards native OA publishers first.
The current model of transformative agreements rewards publishers with legacy subscription content who can then say “we won’t give you access to this legacy content with a reasonable price unless you direct further manuscripts of future authors to us and not the OA competition”.
This is not only unfair but also illegal under the anti-trust, competition and procurement laws (directing public funds to large commercial publishers without proper bidding process that includes smaller publishers), and hopefully the courts and competition agencies will wake up soon and realize that Plan S and many “read and publish” deals such as Project Deal are illegal and are a threat to fair and open competition. These concerns (including the concerns raised above by Plos) are well known and have been raised repeatedly (e.g. by OASPA), but those responsible for these policies just shrug their shoulders and seem to accept that their policies are destroying an emerging ecosystem of OA publishers that are outside of the “big 5” commercial publishing corporations.
OA publishers should step up their game and start sueing libraries and consortia that throw money at legacy publishers without matching their contributions to preserve existing OA publishers and not responding to emails by OA publishers begging for similar deals.
Existing OA publishers such as Plos or JMIR Publications have in some areas superior journals (for lack of a better metric, e.g. higher impact factor), lower costs (APC), and superior turnaround times and author services, and innovative products (e.g. in our case overlay journals for preprints). It is a scandal to throw public money at legacy publishers only because of their size and ability to hold the scientific community hostage with their legacy content. How can librarians ensure that OA publishers are included in these deals and are not going to be the pioneers who die with the arrows in their back? How can native OA publishers get together and put pressure – legal pressure if needed – on libraries to not selectively encourage publication with legacy publishers but to match their contributions for existing full OA journals?