Independent Review of the Implementation of RCUK Policy on Open Access

Independent Review of the Implementation of RCUK Policy on Open Access Identification of Respondent 1. This is an institutional response from Anglia Ruskin University. As such, it represents and synthesizes views gathered from across our institution. 2. Should the Review Panel have any follow-up queries, Professor Richard Andrews (Deputy VC for Research & Innovation) can be contacted via his PA, Ellie Silverman, as follows: - Email: ellie.silverman@anglia.ac.uk - Telephone: 0845 196 2269 Declaration of Interests 3. Anglia Ruskin University is a post-92 Higher Education Institution, formerly known as Anglia Polytechnic University. Anglia Ruskin is research-active across a growing breadth of STEM and non-stem disciplines, ranging from medical and medicalrelated sciences to computing and engineering, and from business and management studies to social work to music. 4. Historically, Anglia Ruskin has not been in receipt of significant quantities of RCUK funding for research. As such, we do not qualify to receive payments under the RCUK block grant mechanism to support Open Access. Our intention is to grow our grant bidding activity and in due course to qualify for RCUK Open Access funds. 5. Other than in the nature of our institution and its ambitions, we do not believe we have any conflict of interests to declare to the Review Panel. Preamble: Anglia Ruskin and Open Access 6. Anglia Ruskin University is fully supportive of open access publication, the importance of effectively disseminating and sharing research findings, and the current initiatives to promote open access further. 7. We set up an Open Access Repository, ARRO (Anglia Ruskin Research Online) in 2010, which provides a green route to open access. We remain committed to the maintenance and development of ARRO in line with the original intentions set out for it at its launch: to showcase and preserve the research outputs of members of our University community. 8. As noted above we do not qualify to receive payments under the RCUK block grant mechanism to support Open Access. Similarly, we do not presently receive funds from other key funders who support Open Access, such as the Wellcome Trust. 1

9. Nonetheless, in recognition of the increasing importance of the gold route to open access publication, in March 2014 we used institutional funds to set up an Open Access Support Fund to cover costs arising such as article processing charges (APCs). This received a small amount of usage before the end of the 2013-14 academic year. The sum of 50k has again been allocated for the 2014-15 academic year, and, subject to satisfactory review and the ongoing availability of funding, it is our intention that this will be continued in the future. 10. Anglia Ruskin has not established an institutional preference towards green or gold routes to open access. Rather, we believe that research outputs should be placed in the most appropriate outlet in respect of their academic discipline to maximise their visibility and dissemination, and therefore that the choice of publication outlet, and along with it whether the OA publication entailed is green or gold, is an academic decision. 11. We provide the above explanation by way of background to our responses, following below, to the Review Panel. The effectiveness and impact of RCUK policy on the transition of RCUK-funded outputs to open access 12. As explained above, Anglia Ruskin has historically only been awarded very few RCUK grants; of the seven RCUK grants we have received over the past five years, three are very new and have not yet had the opportunity to generate outputs; the remainder were either networking grants for which publication was not an expected outcome, or predate the current RCUK OA policy. Therefore, in regard specifically to the effectiveness and impact of RCUK policy on the transition of Anglia Ruskinproduced RCUK-funded outputs to open access, the policy has really had no effect or impact since it came into force in April 2013, as until very recently we have had no grants that fall under it. For the immediate future, the new HEFCE policy on open access in the next REF will have much more significant effects. 13. More generally, in line with our institutional views on the value of open access publishing, we welcome any moves within the wider research environment to drive the transition forward. In this regard we are supportive of the intention of the RCUK policy to ensure that funded findings are made freely available. However, we do have concerns about the mechanisms by which this intention is supported. 14. Although RCUK policy does allow for green open access publication via an institutional repository, the policy s clearly-stated preference towards immediate OA publication, i.e. via the gold route, gives the appearance that green is very much an inferior, second-rate option. We have concerns that in future, two very real possibilities are that a logical progression of the RCUK policy would be to mandate gold, as was the Finch Report s clear preference; and/or that this might help push publishers to increasingly adopt gold model publication as the best means of protecting their revenue streams. Our comments following below about the blockgrant mechanism are predicated on this assessment. As it stands, we acknowledge that the possibility of green publication does address some of the concerns we address below. 15. While we recognise the reasons for doing so, the block grant mechanism used by RCUK for allocating OA funds is potentially damaging on a number of levels. In 2

recent years, across the research funding environment, a number of policy changes have had the effect intended or otherwise to increase the concentration of research funding in fewer and fewer institutions. As the results of RAE 2008 demonstrated, and as we expect the REF 2014 results will confirm in a few months time, there are pockets of research excellence spread across the sector, and no evidence to suggest that concentration leads to the best outputs. 16. The RCUK OA block grant mechanism, being calculated as it is on the basis of historical total direct staff costs in grants awarded, and with a minimum value of at least 10k in the fifth year of the scheme s operation, is another manifestation of this policy of concentration. In practice, most RCUK OA funds presently flow to institutions in receipt of the largest quantities of RCUK funding; conversely, however, it is these institutions which are probably the most able to find funds internally to cover the costs of OA publication, while those institutions which receive little or no RCUK OA funding, will have the greatest difficulty. Yet, in order to meet RCUK requirements and to continue to be able to receive RCUK research grants in future, this is what they must do. This may prove challenging to maintain in the longer term. Given that the current block grant is based on research income received between April 2009 and March 2012, and if it continues to be based on historical income, it will be some considerable time before institutions not presently in receipt of RCUK OA funds can expect to do so. 17. Within institutions, such pressures on whatever funding is available to support open access may also be damaging to individual researchers where that funding is limited. Institutions will naturally wish to ensure that the money they use to support OA is as effectively spent as possible, and this could well mean supporting experienced researchers, seen to be most capable of earning RCUK funds and needing to remain eligible by complying with RCUK policy, and most likely to produce highly-cited, excellent quality research, at the expense of others who may not have had the opportunity to prove themselves, but whose research may in practice be the more innovative and the more valuable. We are especially concerned that Early Career Researchers may be adversely affected. A similar issue may exist around doctoral students supported through RCUK funds. In order to establish their careers, they will need to publish, and should do so via open-access, but will be dependent on their employing institution which may also not be where they undertook their studies for the necessary funding. This could be particularly disadvantageous to this group. 18. We believe that it would be preferable either to provide a contribution to every RCUK grant awarded to support OA costs, perhaps continuing to do so on the basis of direct staff costs to provide some measure of scaling; or, if it were practicable though we recognise it probably is not to allow institutions to claim back actual OA publication costs incurred arising from RCUK-funded research. 19. Linking OA support to actual grants would also deal with a further issue. Where a RCUK-funded researcher transfers with their grant to an institution, that new institution becomes responsible for ensuring that publications are made in line with the RCUK OA policy. If the new institution is not in receipt of RCUK OA funds, this could place an additional burden on them, and thus be particularly challenging for institutions seeking to improve their research portfolio, in which recruitment of proven researchers may be a key strategy. 20. We would suggest amending the RCUK OA policy to better demonstrate green OA as an equally valid route to compliance, if this is indeed RCUK s intention. 3

21. We also note that there appears to be no exception clause in the RCUK OA policy it applies to all, or nothing. In preparing this response we came across an example of a RCUK-funded research project involving a third sector partner who acted as a gatekeeper to interview subjects. The findings generated put that external partner in a poor light, such that they demanded the findings be anonymised. This was just acceptable to them for publication in academic circles, but professional practitioners in the sector who are of course one of the intended beneficiaries of open access publication would have been able to work out which organisation was involved. Publishing via Open Access in such circumstances would have caused the researcher significant problems with the industrial partner and indeed would have worked against, if not prevented, the fruitful further collaboration the researcher has engaged in. Compliance with green Open Access embargo periods mandated by the policy 22. Given our position, as explained, we have not yet found ourselves in the position of needing to ensure our compliance with embargo periods. We do not believe there will be any particular difficulty around embargos, as the periods required seem to be sufficiently generous to be acceptable to most publishers. We do, however, note that there are sometimes exceptional circumstances where the most appropriate publication outlet, particularly to reach other researchers, may require an embargo outwith that mandated by the policy. In such circumstances, some form of exception clause, as already raised above, would be useful. The impact on particular discipline areas of the RCUK requirement for Creative Commons licensing, in particular CC-BY licences for gold OA 23. Similarly, licensing has not yet been an issue for us; we are aware, of course, of the different licence options. We do wonder why CC-BY is mandated for gold, whereas (although in this regard no specific licence type is required) what is allowed by more restrictive licences (such as CC-BY-NC) meets RCUK policy for green. This seems to us to be inconsistent, and adds a layer of confusion for staff as different options are available, including publisher licences. We would like the reasoning to be explained, and ideally a specific licence mandated for specific circumstances. How effectively the policy has been communicated, including evidence or views to suggest any further engagement needed 24. The existence of the RCUK policy on open access is discussed on our intranet, and was coincidentally circulated recently on our research blog, as part of provision of advice about research grant bidding. It is also referenced in respect of support and guidance made available in respect of open access publication. On the few occasions where our staff have been successful in bidding for RCUK funds, we send them a copy of the policy, so they are fully aware of their responsibilities. 25. Largely prompted by the recent introduction by HEFCE of their open access policy in relation to the next REF, we will be undertaking extra work during 2014-15 to promote open access and to ensure we are compliant with the HEFCE policy by April 2016. We will be using the opportunity to further raise awareness of RCUK OA requirements, and those of other research funders. 4

Statistics and data on compliance with the policy 26. Given that we have not, to date, been in receipt of RCUK funding leading to outputs which would have required compliance with the policy, we have not routinely collected statistics or other data which would demonstrate our compliance. As noted, however, we have recently been awarded a small number of grants whose outputs will in due course need to comply with the policy. We will be putting in processes to enable us to meet compliance monitoring requests in future. 27. The table below shows the subject area, author s REF 2014 UoA if submitted, journal title and APC levied on applications for support to our internal Open Access Fund since its launch. APC charges are in sterling and include VAT. We do not have other relevant statistics to hand. Table 1: APC charges by journal and subject area Author s Subject area REF 2014 Journal Title APC UoA Business & Management 19 J. Business & Industrial Management 1,194 Life Sciences 17 PLoS Biology US$2,900 Life Sciences 17 PLoS One US$1,350 Life Sciences 17 Ecology & Evolution 1,554 Life Sciences 17 J. of Forensic Research US$1,519 Medical Engineering 15 Computer Methods in Biomedical Science 2,146 Medical Engineering 15 J. Computer Science & Systems US$1,519 / Biology US$1,039 Primary & Public Health -- BMC Public Health 1,590 Primary & Public Health -- Social Inclusion 350 Psychology 4 PLoS One US$1,350 Vision Sciences 3 Investigative Ophthalmology and Visual Science US$1,240 Any difficulties in understanding which journals offer publication options compliant with the policy 28. In our experience thus far, we have found the Sherpa Romeo service a very useful aggregated source of information of which journals offer publication options compliant with the RCUK policy. However, we have in the process of preparing this response, become aware of anecdotal evidence where Sherpa Romeo s apparently authoritative information is in fact incorrect. 29. We have also heard anecdotal evidence to suggest that publisher websites are usually very clear in what their journals will and will not allow. 30. We welcome the efforts being spearheaded, for example by Jisc, to develop automated tools and services that can be used by institutions to help check the compliance of individual outputs. 5

Any difficulties in reaching agreement regarding multi-funded and/or multi-authored manuscripts 31. Multi-funded manuscripts have not, to date, been a problem. In respect of multiauthored work, we have chosen to take the simplest route in allocating our institutional OA funds.we expect that if we pay an OA charge arising from a joint research project, then it will be for another collaborating institution to cover the costs of the next, and so forth. Trying to split charges between collaborating institutions seems to us to be prohibitively complicated. We envisage a similar, simplistic system in respect of multi-funded manuscripts, if such a situation were to arise in future. Any difficulties in ensuring that RCUK funding for open access is used for its intended purpose 32. As noted above, given that we have not been in receipt of RCUK funding specifically for open access, we have not been in the position to encounter such difficulties. When we are eventually in receipt of RCUK OA funding, we would expect to retain our current system of application and approval for support, meaning that allocation of APCs to the RCUK-funded element of the OA fund should be centralised and straight-forward. Any difficulties in the processes and workflows relating to APC payments to publishers 33. Arising from the very limited interactions we have had with publishers to date to deal with APC charges, we have generally had no difficulties. An inefficiency in the system is that publishers tend to deal with a single contact who is usually the corresponding author of the submitted work. We are then dependent on that corresponding author forwarding invoices in a timely fashion, for example, so that we can make payment, usually by credit card. On most occasions this has worked smoothly, but we have had one example of an OA publication being agreed to on the basis of an early bird APC. Because the individual did not forward the invoice to us swiftly enough we had to pay the full rate. It would be very useful if publishers could be persuaded to run a parallel system allowing the author contact to nominate an administrator contact to deal with APC payments, leaving the author contact to deal with the content of the proposed publication. Any difficulties in obtaining the data required to demonstrate compliance 34. Again, given our position we have not needed to obtain data to demonstrate our compliance, and we will put in processes to ensure we are able to do this for future compliance monitoring exercises. 6