[Duraspace] Fwd: [GOAL] Publishers Association Proposal to HEFCE
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---------- Forwarded message ----------
From: Stevan Harnad <amsciforum at gmail.com>
Date: 11 October 2014 15:41
Subject: [GOAL] Publishers Association Proposal to HEFCE
To: "Global Open Access List (Successor of AmSci)" <goal at eprints.org>
I just noticed the September 12 proposal to HEFCE by the Publishers
The proposal -- which is as predictable as the succession of night upon day
-- is the following:
*1. Don't require deposit upon the date of acceptance, because publisher
embargoes are timed to begin on the date of publication, not the date of
*2. Don't require deposit of the author's final draft; wait for the
publisher's version of record.*
*3. Don't require deposit at all: let us take care of it
after our embargo has elapsed: then you don't have to worry about figuring
out the date of publication.*
*4. Please send us a justification for wanting to do otherwise.*
Now I find these four points so outrageous and presumptuous -- and so
transparently self-interested, running roughshod over the interests of
research, researchers, their institutions, their funders, and the
tax-paying public -- that they don't need to be answered at all (and of
course they need not and should not be heeded in any way).
But past experience has shown that the research community (like
Brown and the annual football
Lucy always manages to pull out from under him) somehow always manages to
fall for publisher FUD. The FUD is invariably formulated to appear as if
the publishers are just trying to help, and make things simpler and easier
for the research community. But what keeps being missed by the naive
research community is that the complications and difficulties that the
publishers' proposals to "help" with are invariably complications and
difficulties that are being imposed by the publishers themselves, in the
form of embargoes and restrictions!
In this case it's all about ensuring the one thing that is important to
publishers about open access and open-access mandates: that publishers'
embargoes on Green OA are faithfully obeyed (unless, even better, the
author pays for immediate Gold OA). Nothing to do with ensuring OA, and as
soon as possible.
The short answer to these four pieces of publisher FUD are:
1. *No thank you*. We want deposit to be done as soon as the paper is
refereed and accepted, because that is when the paper is ready to be used
by researchers. And even if an author complies with a publisher OA embargo,
they can provide individual copies to individual users with the
repository's request-copy-Button <http://j.mp/CopyReqButton> immediately
upon deposit during the embargo.
2. *No thank you*. The acceptance date is clear and certain for all papers,
and it is the earliest access point; the date of publication is later,
sometimes much, much later, and its timing is variable and indeterminate
(cover date often does not correspond to date the issue appears). And
besides coming too late, the publisher's version of record has more
(publisher) restrictions on it.
3. *No thank you*. We would rather retain control of providing
Button-access, and then OA, to our own final drafts; and we can track the
embargo for ourselves, thank you very much.
4. Please send us your justification for asking research institutions and
funders to justify to publishers when they require their researchers to
deposit their final drafts: *We are not talking about OA or embargoes here
but about deposit.*
That said, here is some tit-for-tat for the Publishers Association's letter
Following the publication of HEFCE’s statement of policy in March 2014 The
> Publishers Association and its members have been consulting with other
> stakeholders as to how best we in the publishing community can assist
> researchers and institutions to comply with the policy, particularly with
> regards to the deposit requirements.
With regards (and all due respect), the deposit requirements have nothing
to do with publishers (or with publisher embargoes on OA).
In the course of these conversations it has become clear that this aspect
> of the policy is a source of widespread concern. Therefore I am writing to
> ask if HEFCE would give serious consideration to reviewing and revising
> certain elements of it.
No doubt there is publisher concern about the deposit requirement: That
concern is precisely because deposits (unlike OA embargoes) cannot be
> For us, the problematic section is Section 18 which states that “the
> output must have been deposited as soon after the point of acceptance as
> possible and no later than three months after this date (as given in the
> acceptance letter or email from the publications to the author)”.
> Section 19 then goes on to require that the output must have been
> deposited as the author’s accepted and final peer-reviewed text, which may
> later be updated by the version of record.
Never mind the version of record. It's another matter. We're talking here
about the author's final draft, and the time it is to be deposited.
For the avoidance of doubt, The PA and members are of course in no way
> opposed to the principle of deposit per se; rather we are concerned with
> the timing and form of the mandatory deposit.
Well, it's good to know that the PA are in no way opposed to something that
is none of their business, and over which they have no control. But then
why mention it at all?
In paragraph 29 of the Consultation Document on the Policy (July 2013)
> HEFCE stated that:
> “We also wish to make the process of compliance as simple as possible for
> authors and HEIs and have received advice that the point of acceptance
> would be more suitable.” The PA’s response to the Consultation (October
> 2013) spoke to this point by saying “it is unclear where this advice has
> come from and what the justification for it is. To ensure compliance with
> embargo periods, which commence from the date of publication, it is logical
> to coincide the deposit or linking of papers with the publication date.”
Is the PA to be given a justification for a deposit policy that is none of
their business and out of their control?
And why are publisher embargoes being mentioned in this context? Yes,
publisher OA embargoes are timed from date of publication (which varies
wildly from paper to paper). But the issue here is *deposit* -- not
publisher OA embargoes or their timing.
There is no link (logical or otherwise) between the deposit date,
publication date, and embargo end-date.
Our subsequent discussions have confirmed us in our view that it would be
> far preferable for HEIs, researchers and publishers that the timing of the
> deposit of papers be coincident with the date of the publication of the
> version of record. This is for two principal reasons:
It would allow for the clearer management of embargo periods. Since these
> begin at the point of publication, deposit in institutional repository at
> this point removes the potential for any confusion arising between the
> availability of the accepted author manuscript and the version of record.
> Repositories will need to know the date of publication in order to respect
> the embargo period but they cannot know this from the date of acceptance.
As stated, OA embargo periods are reckoned from the (variable) publication
date, not from deposit date. They have nothing to do with deposit date.
And OA is OA whether to the author's final draft or the publisher's version
of record (which has extra usage restrictions).
The HEFCE/REF mandate is to deposit the final draft upon acceptance and to
provide OA after the allowable embargo at the latest. No version is
And the only version that is available until publication (and can hence be
made OA or can be provided via the Button during an OA embargo) is the
It would reduce the level of costs to HEIs, many of which have expressed
> concerns about the financial and administrative burden of ingesting author
> manuscripts in their repositories. We understand that for many institutions
> this will require a number of operations (for example, subsequent up-dating
> of data) to be performed manually which could be fulfilled automatically if
> deposit of the author manuscript is made upon publication. Not all HEIs
> have repositories capable of dealing with this requirement at present.
It is terribly good of publishers to worry about institutions' operating
expenses! There is a very useful way in which publishers could help lower
these expenses: charge less for journals, or drop OA embargoes.
But no help is needed with deposit, thank you very much. Authors are quite
capable of depositing for themselves, as well as reckoning OA embargo
Some stakeholders have made proposals for mitigating what we would see as
> the adverse effects of the proposed policy: for example encouraging
> publishers to provide author manuscripts and metadata in a standardised
> format through the Jisc “Publishers Router”.
> However, this would not address the central issue of the clear potential
> for confusion around the start date of the embargo period, which often will
> not be known at the point of acceptance. For many publishers, this proposed
> mitigation would imply an additional cost, which seems somewhat
> unreasonable to ask publishers to bear when we believe that deposit at the
> point of publication would eliminate these costs and concerns without
> compromising the policy’s goals to advance open access.
To repeat: determining the date of publication and the date of the end of
the embargo has nothing whatsoever to do with date of deposit.
It is clear that from the publishers' point of view, the ideal outcome (if
there is to be Green OA at all) is that it should be *the publisher* (who
knows the date of publication, who owns the version of record, and who
imposes the OA embargo) who controls the deposit, its timing, and the
timing of the embargo.
No, thank you. This is not about depositing as late as possible, and
providing OA as late as possible, but about exactly the reverse.
Ultimately we believe that any of these mitigating or alternative solutions
> are poor substitutes for amending the underlying policy requirement.
> It would greatly help our understanding of the HEFCE stance if you were
> able to share with us the justification for the policy – as referred to in
> last year’s consultation – and your perspective on the costs.
Publishers have no right to ask institutions and funders for
"justification" of deposit policies if the deposits are not OA.
But if you want a general idea: it is to provide Button access and Open
Access to refereed research as soon as possible.
We would be grateful if you would give consideration to amending this
> aspect of open access policy. We believe it will act as a hindrance to the
> widespread take up of open access in the UK research community, whereas a
> requirement to deposit in an institutional repository on publication would
> be a policy which would command support from a much wider range of sector
Good of publishers to be so concerned about compliance with the HEFCE
deposit mandate, but, no, ceding control to publishers over deposit timing
not the way to ensure compliance. Making compliance a prerequisite for REF
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