SUMMARY: The actual impact of Open
Access (OA) self-archiving on research,
researchers, their institutions, their funders, and the tax-paying
public (which has all already been shown to be highly positive) must be
clearly separated from any hypothetical impact it might have on
publishers (whether commercial or scholarly-society
publishers). Researchers do not conduct research -- nor does the
tax-paying public fund research -- for the benefit of publishers. The
sole point at issue concerning the FRPAA
is whether or not self-archiving should be mandated. The two concrete
questions that researchers, their institutions and funders need to put
to themselves regarding any "special relationship" with scholarly
society publishers are therefore:
(a) Would (or should)
researchers, their institutions and their funders knowingly choose to
subsidise their scholarly societies with their own actual lost research
impact in order to immunise those scholarly societies from any
hypothetical risk of lost subscription revenue?
(b) If, contrary to all
evidence to date, self-archiving were indeed destined one day to cause
publisher revenue losses -- or even to force a shift to the open-access
publishing cost-recovery model (with author-institutions paying the
publication costs for their own institution's research output out of
their own windfall savings from the cancellation of their former costs
as user-institutions, buying in the published output of other
institutions) -- is the prevention of that hypothetical outcome
something that researchers, their institutions and their funders would
(or should) knowingly choose to subsidise with their own actual lost
research impact?
A dissenting minority
of 10
US provosts opposes the FRPAA
Self-Archiving Mandate (vs. 125
in favor) on the grounds of risk to scholarly society subscription
revenue. There is obviously a biomedical publisher lobby behind some or
all of the 10 dissenting voices; the arguments are old ones, already rebutted
many times:
(1) The hypothesis that
mandated self-archiving will force a shift to the OA publishing
cost-recovery model is pure speculation at this time, with no evidence
in its support, and evidence from both the American Physical Society
and IOPP contradicting it.
(2) But even if the
hypothesis were ever to come to pass, it would not mean "diminishing
funds available for research to benefit the public good".
(3) To force a shift to
the OA publishing cost-recovery model, there would first have to be substantial
revenue losses for publishers, from institutional subscription
cancellations.
(4) But for every
penny of revenue lost by publishers in the form of institutional
subscription cancellations, there has to be a penny saved by
institutions, in the form of windfall savings.
(5) Hence if publisher
revenue losses were ever to force a shift to the OA cost-recovery
model, the institutions would have a large annual pot of windfall
savings on which to draw to pay for their own outgoing publication
costs.
(6) Hence there would
be nothing at all "requiring authors to pay for their publications
through their Federal grants, diminishing funds available for research
to benefit the public good."
(7) It is only now
-- when there are neither any institutional subscription cancellation
pressures, nor any institutional subscription windfall savings -- that
it looks as if paying OA publishing costs would require diverting money
from research.
(8) Hence it is both
self-serving and self-contradictory to invoke both the "damage"
hypothesis and the "research fund diversion" hypothesis against
the FRPAA in the same breath: If the hypothetical "damage" is the
hypothetical subscription revenue loss, then that is also the
diversion: no need to poach hypothetical research funds.
(9) The rationale for
the FRPAA self-archiving mandate, however, has nothing to do with speculative
hypothesizing about journal economics but with demonstrable
facts about maximizing research usage and impact.
Peter Suber has already provided an
excellent
critique
of the letter from a dissenting minority of
10
US provosts who oppose the proposed
FRPAA
Self-Archiving Mandate (versus the other
125
provosts who support it):
But one can never say enough in support of a good thing (and against a
bad one!), so what follows below is a detailed, systematic,
point-by-point critique of the dissenting provosts' position and the
arguments adduced in its support.
It is fairly obvious that there is a biomedical publisher lobby behind
some or all of these dissenting voices, since the statements of these
10 dissenting provosts (several of them members of executive committees
of the
American Physiological Society!)
are almost a verbatim echo of the very same points that the publishing
lobby has been making over and over, in trying to oppose self-archiving
mandates worldwide [
1,
2,
3,
4,
5],
hence the accompanying press release from the American Physiological
Society ["
APhS"](not to be confused with the
American Physical Society!) from which
more will be heard below too [
6,
7,
8].
(The attempted opposition to self-archiving mandates has already proven
unsuccessful in the UK, where four of eight
RCUK research
funding councils have already mandated self-archiving, beginning
October 1 2006.)
But never mind, we will take the points made in both the American
Physiological Society press release and the letter from the ten
provosts at face value:
On Fri, 22 Sep 2006, Martin Frank (American
Physiological Society ["APhS"]) wrote:
SENIOR ACADEMIC OFFICERS EXPRESS THEIR CONCERN ABOUT S.2695, THE "FEDERAL
RESEARCH PUBLIC ACCESS ACT OF 2006"
(APhS): (Bethesda, MD) - September 22, 2006 -
Senior academic officers from 10 institutions issued a letter to
Senators John Cornyn (TX) and Joseph Lieberman (CT) expressing their
concerns about the provisions of S.2695, the "Federal Research Public
Access Act of 2006." These institutions, which collectively make nearly
$3 billion in annual research investments, expressed their concerns
that mandating a six-month public release of journal articles would
negatively impact the academic community and the publishers that
disseminate their work.
(If the $3 billion dollar figure is pertinent at all, then the first
thing to call to mind is the more than $30 billion dollars in annual
research investments of the
125
institutions that had expressed exactly the opposite concern...)
But let us look at this more closely, for on the face of it, the effect
of making research Open Access has already been
demonstrated
to have a highly
positive impact on its impact (sic) -- i.e.,
the degree to which it is accessed, used, and cited.
So now let us hear more about the alleged downside of this -- but let
us be very careful to separate its actual impact on the
academic
community (which we already know to be positive) from its
hypothetical impact on (some)
publishers.
For, lest we forget it: researchers do not conduct research -- nor does
the tax-paying public fund research -- for the benefit of publishers [
9,
10,
11,
12].
(APhS): In signing the letter in
opposition to S.2695, Dr. Robert Rich, Senior Vice President and Dean,
University of Alabama at Birmingham School of Medicine, expressed his
concern that "the legislation would damage the special relationship
between scholarly societies and academic communities who work in
partnership to ensure that these communities are sustained and
extended, science is advanced, research meets the highest standards,
and patient care is enhanced with accurate and timely information."
The sole point at issue with the FRPAA is whether or not self-archiving
should be mandated. All
evidence so
far shows that self-archiving enhances research impact. No evidence so
far shows that self-archiving reduces scholarly society publisher
revenues, and this has been explicitly confirmed by the two scholarly
society publishers whose published contents have been self-archived the
longest and the most, the
American
Physical Society and the
Institute
of Physics Publishing: They both
report that they have
detected no subscription losses as a consequence of self-archiving.
Nevertheless, some scholarly society publishers fear, despite the
absence of any actual evidence, that self-archiving will cause "damage"
if mandated by the FRPAA (and by
other research
funders and institutions worldwide). No one knows whether or when these
fears of damage will actually come true, but let us agree that there is
a non-zero risk for publisher subscription revenues here, and that it
is definitely not outside the bounds of either logic or likelihood that
universal availability of authors' final drafts could eventually
generate cancellation pressure on subscriptions. Yet what needs to be
done by the academic community is to weigh this hypothetical risk to
publishers' subscription revenues against the demonstrated benefits to
the research impact of researchers, their institutions, their funders,
and the tax-paying public that funds them.
Hence there are two very concrete questions that researchers and their
institutions and funders need to put to themselves regarding this
"special relationship" with scholarly society publishers:
(i)Would (or should) researchers, their institutions and their funders
knowingly choose to subsidise their scholarly societies with their own
actual lost research impact in order to immunise those scholarly
societies from any hypothetical risk of lost subscription revenue?
(ii) If, contrary to all evidence to date, self-archiving were indeed
destined one day to cause publisher revenue losses -- or even to force
a shift to the open-access publishing cost-recovery model (with
author-institutions paying the publication costs for their own
institution's research output out of their own windfall savings from
the cancellation of their former costs as user-institutions, buying in
the published output of other institutions) -- is the prevention of
that
hypothetical outcome something that researchers, their institutions and
their funders would (or should) knowingly choose to subsidise with
their own actual lost research impact?
(APhS): Rich also expressed concern
that "S.2695 would divert scarce Federal dollars away from research in
order to provide a service already provided to the public by society
publishers."
It is already a speculative hypothesis that self-archiving would damage
subscription revenue; but it is
wildly counterfactual to say
that FRPAA is about diverting funds away from research in order to pay
publishers!
FRPAA is not a mandate to convert to OA publishing: it is a mandate to
convert to author self-archiving. FRPAA says nothing about diverting
funding from research to publication.
The hypothetical long-term sequel of mandated self-archiving -- a
conversion from institutional subscription-charges to institutional
publication charges -- is merely speculation, in the absence of any
objective supporting evidence (and in the face of counter-evidence).
But even if the hypothesis were ever to prove true, it would not mean
diverting a penny of research money from research funding to
publication costs! It would mean redirecting the very same money that
institutions currently spend on subscription charges toward paying
instead for publication charges.
(APhS): The nonprofit publishers
comprising the DC Principles
Coalition are among those who are able to provide public access to
literature either immediately or within months of publication without
government mandate through corporate and academic subscriptions.
This is playing loose with the words "public access." The purpose of an
Open Access self-archiving mandate is to provide access to all those
would-be users who do
not have subscription access, today.
Voluntary provision of OA by publishers is of course very welcome, but
it is far too few and far between. And the research impact loss problem
is
now, and urgent.
It would be absurd for the research community to continue sustaining
needless annual impact losses in order to wait passively for publisher
voluntarism to decide whether and when to remedy them. If publisher
voluntarism were indeed inclined to put an end to those impact losses,
surely publishers would not be lobbying
against the FRPAA
self-archiving mandate: they would be supporting it: The distributed
author mandate would be saving them the trouble of having to provide OA
themselves, from their own resources!
But it is clearly for access-denial, not access-provision, that (some)
publishers are lobbying here. Let there be no doubt about that, and
that the voluntarism of the
DC
Principles Coalition is far too little, too late.
(APhS): According to Martin
Frank, Ph.D., Executive Director of the American Physiological Society
(APS) and a member of the Coalition, "a six-month release mandate may
force some journals to shift to a publication model requiring authors
to pay for their publications through their Federal grants, diminishing
funds available for research to benefit the public good."
Martin Frank,
Ph.D.
Executive Director, American Physiological Society
http://www.the-aps.org
(1) As noted, this hypothesis -- that mandated self-archiving will
cause a conversion to the OA publishing cost-recovery model -- is pure
speculation at this time, with no evidence in its support, and the
prominent evidence from both the American Physical Society and IOPP
contradicting it.
(2) But let us suppose, for the sake of argument, that the hypothesis
should one day come to pass: does this mean "diminishing funds
available for research to benefit the public good"?
(3) What Martin Frank seems to be forgetting in his calculations is
that in order to force a shift to the OA publishing cost-recovery
model, there first have to be
substantial revenue losses for
publishers, from institutional subscription cancellations.
(4) But for every single penny of revenue lost by publishers in the
form of institutional subscription cancellations, there has to be a
penny saved by institutions, in the form of windfall savings.
(5) Hence if publisher revenue losses were ever indeed to force a shift
to the OA cost-recovery model, the institutions would have a large
annual pot of windfall savings from incoming subscription cancellations
upon which to draw, in order to begin paying instead for their own
outgoing publication costs.
(6) Hence there would be nothing at all "requiring authors to pay for
their publications through their Federal grants, diminishing funds
available for research to benefit the public good."
(7) The only thing that would have happened would be the augmentation
of the public good derived from research, by maximising its access,
usage and impact -- whether or not the hypothetical shift in publish
models came to pass.
(8) It is only
now -- when there are neither any institutional
subscription cancellation pressures, nor any institutional subscription
windfall savings -- that it looks as if paying OA publishing costs
would require diverting money form research.
(9) Hence it is both self-serving and self-contradictory to float both
the "damage" hypothesis
and the "research fund diversion"
hypothesis in the same breath: If the "damage" is subscription revenue
loss, then that is also the diversion: no need to poach research funds!
Issued on September 22, 2006, the letter reads:
Dear Senators Cornyn and Lieberman:
The undersigned senior academic officers write to express our concerns
about S.2695, the "Federal Research Public Access Act of 2006."
We agree that the broadest dissemination of scientific literature is
good for research.
If this were indeed clearly thought-through and sincerely meant, we
could stop right here. Because "the broadest dissemination of
scientific literature" is Open Access, and the FRPAA self-archiving
mandate will provide Open Access.
Letter: However, mandating a six-month
public release of journal articles would have negative unintended
consequences for the academic community.
Are these hypothetical negative unintended consequences negative for
the academic community (i.e., researchers and their institutions and
users), or for the publishing community? (The two are completely
conflated in what follows below.)
Letter: The free posting of unedited
author manuscripts by government agencies [1] threatens the integrity
of the scientific record, [2] potentially undermines the publisher peer
review process, and [3] is not a smart use of funds that could be
better used for research.
(0) The posting is by authors, not by government agencies: the FRPAA
proposal is for the government agencies to mandate that the authors
post the manuscripts.
(1) How does posting a free final, peer-reviewed, accepted draft of the
author's paper for those would-be users webwide who cannot afford
access to the publisher's version of record "threaten the integrity of
the scientific record"?
(2) What the FRPAA proposes to require to post is the author's final,
peer-reviewed draft, accepted for publication; the only thing it might
be missing is some copy-editing: How does that "undermine the publisher
peer review process"?
(3) And is it, then, smarter use of funds to subsidise copy-editing
with lost research impact?
If copy-editing is such an important added-value, what are publishers
worried about? The subscription smart-money will then just keep on
paying for it, since that added-value is missing from the author's
peer-reviewed final draft, which is merely a supplement for those who
cannot afford the publisher's official copy-edited version of record,
online or on paper.
(But please let's leave the "peer review process" out of this, because
it is not even at issue. The peers review for free, as a service to
both authors and publishers; their services are not what the
subscription money is being spent on.)
Letter: Scientific publishers, in
collaboration with academic institutions, scientists, and libraries,
have been at the forefront of innovations that have improved and
continue to improve access to research information. As a result, more
scientific papers are now available to more people than at any time in
history.
Absolutely true, and commendable, but irrelevant. Because it is not
enough. Substantial amounts of potential research impact are still
being needlessly lost, cumulatively, in an online age when this loss
can easily be prevented, once and for all, at long last.
The supplementary self-archived author's draft is for all those
would-be users whose institutions cannot afford the above-mentioned
"innovations and improvements." For without the author's self-archived
version, they have
no access at all.
For an estimate of how many users are being denied access -- and hence
how many authors are being denied impact -- simply look at the
studies
thay show the degree to which self-archiving enhances article usage and
impact.
Letter: Even when federal funds support
the research reported in journal articles, these funds do not cover the
costs associated with turning raw data into archived scientific
manuscripts. The cost of peer review, copy editing, formatting,
printing, online publication, search engine development, and permanent
archiving ranges from $2,500 - $10,000 per article.
Even without challenging those figures, one can point out that all
those costs are currently being paid, in full, by subscriptions, with
no evidence that self-archiving reduces those subscriptions. If and
when self-archiving should ever reduce those subscriptions enough to
require another way of meeting those costs, the costs will be met out
of the windfall subscription savings.
But for now, this is mere speculation. The only thing that is not
speculation is the demonstrated benefits of OA self-archiving to
research and researchers, in enhancing research usage and impact.
Nor -- as long as we are speculating -- is it at all clear that if
self-archiving were indeed ever to induce subscription cancellations,
that "the cost of peer review, copy editing, formatting, printing,
online publication, search engine development, and permanent archiving
[$2,500 - $10,000 per article]" would all prove irreducible:
It is not only hypothetically possible but quite likely that the cost
of implementing peer review [since the peers review for free] could
turn out to be the only essential remaining publication cost, and that
is only about $500 per article.
The value of copy editing remains to be determined empirically, but
formatting, printing, online publication, search engine development,
and permanent archiving look very much like the kinds of things that
could readily be offloaded onto authors and their institutions, with
their distributed network of OA IRs and their distributed and hence
much diluted costs per article, nowhere near the current $2,500 -
$10,000 figure.
"The
True Cost of the Essentials (Implementing Peer Review)" (Feb 2000)
"Hypothetical
Sequel"
The above is of course all just speculation too, but hypothetical
speculation invariably breeds
counterspeculation.
The only certainty here is that mandated OA self-archiving will be
highly beneficial to research usage and impact, as has already been
repeatedly demonstrated empirically.
Letter: At present, publishers cover
these publication costs through the sale of subscriptions. A Federal
policy mandating public access after six months would threaten the
financial viability of many of these journals through the loss of
subscription revenues, forcing them to identify other means to cover
costs.
First, to repeat: There is no evidence to date that this hypothesis is
correct, even in fields that have been self-archiving at 100% for years
now.
But should the hypothesis ever prove true, then, yes, it will be
necessary to "identify other means to cover costs" (whatever those
irreducible costs turn out to be). And the other means of covering
those costs is already obvious: Author-institution payment of
publishing costs out of institutions' own windfall subscription savings.
Even without cost-cutting and new efficiencies (such as phasing out the
paper edition and relying on the worldwide network of OA IRs to provide
access, hence leaving only the cost of implementing the peer review
service), a forced shift to the OA publishing cost-recovery model
after
100% OA had already been reached via mandated self-archiving would
merely mean that the money that currently changes hands between
institutions and publishers in the form of subscription costs would
instead change hands between institutions and publishers in the form of
publishing costs.
Note, though, that no matter how shrilly one raises the volume on the
hypothesizing and counter-hypothesizing, it is still merely a
speculation that mandated self-archiving will force a shift in
publishing models. The only objective certainty is that mandated
self-archiving will greatly benefit research impact.
Letter: One such means is to shift the
costs to the scientists/authors. This is the business model currently
used by the Public Library of Science, for example, which recently
increased fees to $2,500 per manuscript. These fees either come from
[1] the author's Federal research grant -- thereby decreasing the
amount available for research -- or [2] from the university, which
could ultimately lead to higher institutional costs than those needed
for journal subscriptions.
PLoS and other OA publishers today are struggling to make ends meet in
a world where spontaneous OA self-archiving is still only hovering at
15%, and 100% of institutional journal budgets are still tied up in
covering subscription costs. Hence these brave new OA publishers need
to find other sources to pay their OA publishing costs.
But on the above hypothetical scenario, a forced shift to OA publishing
caused by mandated self-archiving would result from institutional
subscription cancellations! Hence the institutions could then use their
own windfall savings to pay the irreducible costs in another way: via
the OA publishing model. No need to poach from either research funding
(1) or other institutional resources (2).
Letter: In fact, some studies have
already shown that research intensive universities would have to pay
considerably more to gain access to the same amount of research under
an author-pays model than a subscription model.
This is compounding speculation with speculation, since no one knows
what the true costs would turn out to be, under pressure from
subscription revenue declining to unsustainable levels because of
institutional cancellations.
There is clearly more than enough money in the system already to
sustain publication today. Research-intensive universities are also
subscription-intensive universities, so one would have to see just what
assumptions are being made by studies that claim that these
universities would be worse off if there were ever a transition to OA
publishing.
The only thing that is sure is that all research institutions would be
far better off in terms of their own research impact (and access). The
rest is all speculation, assumptions, and guesstimation.
Letter: Mandating free dissemination of
scientific manuscripts within six months would significantly limit the
ability of non-profit and commercial publishers to cover the upfront
reviewing, editing, and production costs of creating these manuscripts.
Some journals would simply cease to exist. Others would be much less
able to support innovation in scientific publishing and archiving.
Ultimately, this could lead to a system in which NIH and other federal
agencies must sustain a significant portion of the research publishing
enterprise, maintaining 100+ years of archival journals, as well as
producing new research articles.
Not only is this merely a shriller version of the speculative scenario
already mooted above, at a still higher volume, but it throws in a
nonsensical and irrelevant alarum about legacy archiving, something
that is not even at issue in the FRPAA self-archiving mandate, which
only covers prospective author self-archiving, not retrospective
journal archiving. (Let the journals hand over their legacy archives,
and I'm sure the research and funder community will know what to do
about them: don't fret about the cost...)
On the coverage of the prospective costs if/when subscriptions should
become unsustainable, the obvious answer remains the same: institutions
will cover those costs out of their own subscription savings.
Letter: As a member of the Senate Budget
Committee, you are certainly sensitive to the various forces that shape
and reshape the Federal budget from year to year. Recently, for
example, we learned that the Biomolecular Interaction Network Database
-- the world's largest free repository for proteomic data -- lost its
funding and curtailed its curation efforts. As leaders in our
respective academic institutions, we are profoundly concerned that one
unintended consequence of S. 2695 would be to put both our current
research publications and our research archives in jeopardy.
The FRPAA self-archiving mandate devolves on the distributed network of
institutional repositories (IRs) of all the US research institutions.
In the unlikely event that someone would ever want to pull the plug on
a major central repository such as PubMed Central, the primary research
providers, the universities themselves, are certainly likely to become
more and more reliant on the IRs, rather than less and less, in our
distributed online, networked age. And the costs of creating and
maintaining individual OA IRs are so risibly low that it is absurd even
to discuss them.
So the obvious and optimal prophylaxis against any risk of central
funding loss for central archives is for researchers to do all their
self-archiving locally, in their own institution's IR, and let central
collections be harvests from those IRs, rather a locus for direct
central self-archiving.
"Central
vs. Distributed Archives" (began Jun 1999)
"PubMed
and self-archiving" (began Aug 2003)
"Central
versus institutional self-archiving" (began Nov 2003)
"Harold
Varmus: 'Self-Archiving is Not Open Access'" (began June 2006)
(APhS) Given the widespread access to the
scientific literature that already exists and the negative unintended
consequences this bill will have on the academic community, we urge you
to reconsider whether S.2695 is needed.
Translation: Based on our evidence-free and counter-evidential
speculations about risk to publishers, we urge you to renounce the
demonstrated benefits to research, researchers, and the tax-paying
public that funds them.
Thank you for considering our request.
Sincerely yours,
Robert R. Rich, MD, Senior Vice President and Dean, University of
Alabama at Birmingham School of Medicine, Birmingham, AL
Richard P. Saller, Ph.D., Provost, University of Chicago,
Chicago, IL
John R. Sladek, Jr., Ph.D., Vice Chancellor, Research, University of
Colorado Health Sciences Center, Denver, CO
Kenneth L. Barker, Ph.D., Provost and Vice President for Research, SUNY
Upstate Medical University, Syracuse, NY
Mary J.C. Hendrix, Ph.D., President & Scientific Director,
Children's Memorial Research Center, Northwestern University
Feinberg School of Medicine, Chicago, IL
Bruce A. Holm, Ph.D., Senior Vice Provost, SUNY at Buffalo and
Executive Director, NYS Center of Excellence in Bioinformatics &
Life Sciences, Buffalo, NY
Leonard R. Johnson, Ph.D., Vice Chancellor for Research, University
of Tennessee Health Science Center, Memphis, TN
Barbara A. Horwitz, Ph.D., Vice Provost-Academic Personnel, University
of California, Davis, CA
Richard J. Traystman, Ph.D., Associate Vice President for Research,
Planning, and Development, Associate Dean for Basic Science Research, Oregon
Health and Sciences University, Portland, OR
David E. Millhorn, Ph.D., Vice President, Office of Research and
Economic Development, University of Tennessee System,
Knoxville, TN
About
the DC Principles Coalition for Free Access
The DC Principles for Free
Access to Science Coalition represents more than 75 of the nation's
leading nonprofit medical and scientific societies and publishers. The
not-for-profit publishers are committed to working in partnership with
scholarly communities such as libraries to ensure that these
communities are sustained, science is advanced, research meets the
highest standards, and patient care is enhanced with accurate and
timely information.
As noted above, it would be absurd for the research community to keep
sustaining its needless annual impact losses and just sit waiting
passively for publisher voluntarism to decide whether and when to
remedy them: The voluntarism of the
DC
Principles Coalition is far too little, too late.
Stevan Harnad
American
Scientist Open Access Forum