[OAI-eprints] Rebuttal of STM Response to RCUK Self-Archiving Policy Proposal

[Stevan Harnad]

        ** Apologies for Cross-Posting **

31 August 2005

Professor Ian Diamond
Chair, RCUK Executive Group
Councils UK Secretariat
Polaris House North Star Ave 
Swindon SN2 1ET UK

Dear Ian,

The STM have written a response to the RCUK proposal in which they too, like the
ALPSP a few weeks ago, adduce reasons for delaying and modifying the
implementation  of the RCUK self-archiving policy.

All the STM points are very readily rebutted: Most are based on rather profound
(and surprising) but easily corrected misunderstandings about the policy itself,
and its purpose. A few points are based on a perceived conflict of interest
between what is demonstrably best for British research and the British public's
investment in it and what STM sees as best for the STM publishing industry.

The principal substantive misunderstanding about the RCUK policy itself is that
the STM is arguing as if RCUK were proposing to mandate a different publishing
business model (Open Access [OA] Publishing) whereas RCUK is proposing to mandate
no such thing: It is merely proposing to mandate that RCUK fundees self-archive
the final author's drafts of journal articles resulting from RCUK-funded research
in order to make their findings accessible to all potential users whose
institutions cannot afford access to the published journal version -- in order to
maximise  the uptake, usage and impact of British research output. As such, the
author's free self-archived version is a supplement to, not a substitute for, the
journal's paid version.

STM (like ALPSP) express concern that self-archiving may diminish their revenues.
It is pointed out by way of reply (as was pointed out in the reply to ALPSP) that
all evidence to date is in fact to the contrary. STM express concern that
self-archiving will compromise peer review. It is pointed out that it is the
author's peer-reviewed  draft that is being self-archived. STM express concern
that self-archiving the author's version will create confusion about versions: It
is pointed out that for those would-be users who cannot afford the paid journal
version, the author's version is incomparably better than no version at all, and
indeed has been demonstrated to enhance citation impact by 50-250%.  STM express
concern about the costs of Institutional Repositories (IRs): It is pointed out
that IRs are neither expensive nor intended as substitutes for journal publishing,
so their costs are irrelevant to STM. STM then express concern that the OA
publishing business model would cost more than the current subscription-based
model: It is pointed out that the OA model is not what is being mandated by RCUK.

The point-by-point rebuttal follows. It is quite clear that the STM has no
substantive case at all for delaying or modifying the RCUK policy proposal in any
way.

I would close by suggesting that it would help clarify the RCUK policy if the
abstract ideological points, which currently have no concrete implications in
practice, were either eliminated  or separated from the concrete policy
recommendation (which is to require self-archiving and perhaps to help fund OA
publication costs). The 'preservation' components are also misplaced, as the
mandate is to self-archive the author's draft, not the publisher's version (which
is the one with the preservation problem). It would also be good to remove the
confusing mumbo-jumbo about 'kite-marking' so that ALPSP and STM cannot argue that
RCUK is proposing to tamper with peer review. And the less said about publishing
models, the better, as that is not what RCUK is mandating.

Best wishes,

Stevan Harnad
Professor of Cognitive Sciences
Department of Electronic and Computer Science
University of Southampton
Southampton UK
SO17 1BJ

Linked version of the following rebuttal is at:
http://openaccess.eprints.org/index.php?/archives/25-guid.html

    Pertinent Prior AmSci Topic Threads:

    "ALPSP Response to RCUK Policy Proposal" (began Jul 2005)
    http://www.ecs.soton.ac.uk/~harnad/Hypermail/Amsci/4623.html
    http://www.ecs.soton.ac.uk/~harnad/Hypermail/Amsci/4625.html
    http://www.ecs.soton.ac.uk/~harnad/Hypermail/Amsci/4674.html
    http://www.ecs.soton.ac.uk/~harnad/Hypermail/Amsci/4701.html

    "Critique of STM Critique of NIH Proposal" (began Nov 2004)
    http://www.ecs.soton.ac.uk/~harnad/Hypermail/Amsci/4174.html   

    "STM Talk: Open Access by Peaceful Evolution" (began Feb 2003)
    http://www.ecs.soton.ac.uk/~harnad/Hypermail/Amsci/2687.html
    
    "Book on future of STM publishers" (began Jul 2002)
    http://www.ecs.soton.ac.uk/~harnad/Hypermail/Amsci/2127.html

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The following is a point-by-point rebuttal of:

    STM's RESPONSE TO THE RCUK PROPOSAL
    http://www.stm-assoc.org/

    STM: "business models must prove to be optimally of service to all
    constituencies and... decisions and choices [must be] made freely
    by those constituencies based on open evaluation, not ideology or
    belief, and without government intervention or mandates"

(1) The RCUK access policy for the research it funds is not a business model, and
hence not a publishing business model.

(2) The only constituencies involved in setting the conditions on research funding
are the British research community itself, plus the British public, which provides
the research funds. 

(3) No government intervention is involved in research funding. Research funding
is disbursed on the basis of peer review and the conditions on its disbursement
are set by the research community, based on the interests of research and of the
public that provides the research funds.

(4) The decision to use the new medium (the Internet) to maximise the access to
and the usage and impact of UK research, in order to maximise  the return on the
British public's investment in research is a natural one, and arises from the
availability and potential of the new medium. The decision is not based on
ideology or belief, but on objective data demonstrating the power of the online
medium to enhance research potential.

(5) The mandate to self-archive research in order to maximise  its accessibility,
usage and impact is no more nor less of a mandate than the mandate to publish
research (or 'perish': i.e., not to be further funded). That researchers should
publish their research is presumably an interest of publishers. That researchers
should wish to maximise  their research's accessibility, usage and impact should
also be a wish of publishers. 

(6) Even if it should happen to turn out to be the case that maximising research
accessibility, usage and impact -- which is indisputably optimal for research,
researchers, research-funders and the British public that funds the funders and
for whose benefit the research is being conducted -- proves less than optimal for
publishers (and there is no evidence that it will be) -- then publishers will need
to adapt to the new optimum, rather than intervene in the conduct of UK research,
the disbursement of UK research funds, or the conditions on the disbursement.

    STM: "STM fully supports the [RCUK's first] fundamental principle:
    (1)... 'public funding should lead to publicly available outputs'"

The support is much appreciated, but it is based on a misunderstanding if
'publicly available' is taken to mean merely 'available for purchase by the
general public,' because most peer-reviewed research is not of direct interest to
the general public. The British public's interest is in maximising the impact of
the research that it funds, and for that the research must be accessible to the
researcher-specialists  who will use it, apply it, and build upon it. 

Publishers are the providers of paid access to that funded research, for all those
researchers and their institutions worldwide that can afford their product, and
that is fine. It is fair that publishers should get free value from researchers'
(freely given) output, because they add value to it  -- by implementing the
all-important peer review (which researchers themselves provide for free as
referees, but publishers administer, funding the services of the expert editors
who choose the referees and adjudicate the reviews and revisions) as well as
providing the print product and distribution, and the enriched online product and
distribution, with copy-editing, reference-linking, mark-up and many other
valuable enhancements. It is only fair that publishers should be able to recover
their costs and make a fair return on their investment in exchange for the value
they add.

But researchers (and research) are also concerned with the potential usage and
impact from those researchers whose institutions cannot afford their publishers'
value-added product. A growing body of evidence across all fields is now
demonstrating that those articles for which journal access to the publisher's
value-added version is supplemented by a self-archived version of the author's own
final draft have 50-250% greater citation impact than those for which only the
paid version is accessible: http://opcit.eprints.org/oacitation-biblio.html  

It is in order to close this 50-250% research impact gap that RCUK is mandating
self-archiving for the research it funds; and it is in this way that the British
public's interest in maximising the return on its research investment is best
served. (We will return to this when we deal with STM's analogy to 'public
transport.') 

    STM: "the RCUK conclusions are precipitous and lack scientific rigour"

On the contrary. All the scientific evidence (see bibliography) supports the
RCUK's conclusions, and the evidence is very strong: Self-archiving has been
demonstrated to enhance research impact dramatically. What would be unscientific
-- indeed illogical -- would be to imagine that the optimal conditions under which to
fund research are somehow connected with publishers' business models (one way or
the other). Publishers make a valuable contribution to research communication, but
research is not done in the interests of supporting the publishing business.
Publishers are meant to be helping to increase the usage and impact of research,
not to be trying to prevent it from being increased.

Nor are the conclusions precipitous. They have a long history, starting in the
early 1990's, with various memorable milestones  since, such as Harold Varmus's
Ebiomed Proposal in 1999, the Public Library of Science Open Letter in 2001, and
the UK Select Committee deliberations in 2003. All sides have been heard across
these years, many times over, and the optimal path is already clear (and has
already been embarked upon by about 15% of the world research community):
Self-archiving needs to be done to supplement paid access, so as to make research
accessible to 100% of its would-be users world-wide. That is what the RCUK policy
proposes to do for UK research output, and the policy is not precipitous but
obvious, optimal, and long overdue.

    STM: "[RCUK] appear to presuppose that there are unsolvable  problems
    in the current scholarly information system, without debate or
    analysis"

Not at all: The problem (providing access to British research for those
researchers in the UK and worldwide who cannot afford paid access, in order to
maximise  research impact and progress) is eminently solvable, and RCUK has
proposed exactly the right solution. What there has been, exclusively, for too
many years now is debate. The empirical and logical analysis has been done. The
results are in. Self-archiving works, and it delivers what it promises to deliver:
50-250% greater research impact. And it does so within the 'current scholarly
information system,' without any change in business models, just a few keystrokes
from authors to deposit their final draft when it is accepted for publication.

    STM: "we think... the creation of a new more routinised publishing system through
RCUK-mandated repositories and systems as proposed will [1] decrease diversity in
journals and the peer review process... [2] threaten the value of investments made
by STM publishers... [3] improve neither access nor quality for scholars... [4]
exacerbate the... problem of differing versions of research papers... with researchers
unsure which has been subject to peer review 

First, there has been no proposal for a 'new, more routinised publishing system.'
The RCUK is proposing a supplement to the current publishing system:
self-archiving the author's version for those would-be users whose institutions
cannot afford the publisher's value-added version. 

(1) This does not entail any change in either the diversity in journals or the
peer review process. (Authors are to self-archive their own final drafts of
articles that they continue to publish in the current peer-reviewed journals,
leaving both their diversity and their peer review untouched.)

(2) There is no evidence at all that self-archiving has any effect on the
investments of STM publishers. Self-archiving has been practised for nearly 15
years now, and in some subfields of physics has even reached 100%, yet both of the
major physics publishers (APS and IOPP) report that they can detect no
cancellations associated with this growth.

(3) There is now a great deal of incontestable evidence that self-archiving
improves both access and impact for scholars. (No claims were made that it would
improve research quality -- though that has not been tested: it may well be the
case that enhanced access, usage and impact enhance research quality too!)

(4) There is no 'version problem,' there is an access problem: Those researchers
who cannot afford access to the publisher's version are not the ones raising the
hue and cry about versions. Is STM proposing to speak for them, suggesting that
they should rather do without than be subjected to access to the author's version'

    STM: "There is substantial and compelling evidence that the current
    publishing and licensing systems of STM publishers [have] created
    a vibrant research infrastructure in the UK in which all four RCUK
    principles are embodied and are functioning with enormous success.
    There is no evidence to the contrary, although there are concerns
    about appropriate budgeting to support ever-increasing research
    outputs"

The RCUK policy to supplement paid access to the journal version with free access
to the author's self-archived version for those would-be users who cannot afford
the journal version does not imply that the journal version does not continue to
be valuable, vibrant or successful. The evidence that we can still do much better
comes from the 50-250% impact enhancement data. 

    STM: "The Government itself, in its November 2004 response (the 'UK
    Government Response') to the report of the Science and Technology
    Committee of the House of Commons called 'Scientific Publications:
    Free for All', noted that it did not see any /major problems
    in accessing scientific information', nor 'any evidence of a
    significant problem in meeting the public's needs in respect of
    access to journals'"

The government evidently did not see (or perhaps understand) the growing body of
access/impact data. But the RCUK (being researchers) evidently did.

    STM: "[Even though] most STM member publishers permit authors to
    deposit their works in the authors' institutional repositories ('IR'
    or 'IRs'), such repositories do not appear yet to have created a
    substantial archive of research material."

It is not clear exactly what STM mean here, but if they mean that there are not
yet enough IRs in the UK and they do not yet archive most of their own
institutional research output, STM are quite right, and that is one of the things
the RCUK policy is intended to remedy.

    STM: "Only about a fifth of the CIBER survey respondents had deposited"

That sounds right. Estimates  of the current proportion of annual research article
output that is currently being self-archived vary by field, but they all hover
around 15%, as noted (though a recent JISC survey finds that 49% of authors report
having self-archived at least once).

The purpose of the RCUK policy is to raise that 15% to 100% for UK research
output.

    STM: "Institutional repositories do not seem to be able to provide
    improved access to verified research results"

Now this observation, in contrast to the preceding one, is very far from correct!
Author self-archiving (whether in IRs or anywhere else on the web) has been
demonstrated in field after field to improving research citation impact by
50-250%. Since citing research results is rather more than just accessing them, we
can safely conclude that self-archiving must be improving access by at least that
much too.

What is certainly true is that providing Institutional Repositories  for them is
not enough to induce enough UK researchers to self-archive spontaneously: The same
JISC survey that was cited above has also reported exactly what more is needed,
and it was the authors who indicated what that was: an employer/funder requirement
to self-archive. Of the over 1200 authors surveyed, 95% replied that they would
comply with such a requirement -- and the only two institutions that have already
adopted such a requirement (University of Southampton's ECS Department and CERN
Laboratory in Switzerland) both report over 90% compliance, exactly as predicted
by the JISC survey.

(And, by way of a reminder: the author's final, refereed, accepted draft is the
'verified research results.')

    STM: "the potential costs to improve such repositories to enable them
    to be successful have not been analysed properly to determine whether
    they are significantly less expensive than current publishing models."

It is very thoughtful of STM to worry about IR costs for the research community
(just as it worried about the risks of exposure to the author's version) but STM
will be reassured that the costs of creating and maintaining IRs are not only
risibly small (amounting to pennies per paper), but they are irrelevant. Because
what IRs need in order to be successful is not pennies but the RCUK policy itself
(as the JISC study showed), requiring researchers to deposit their 'verified
research results.'

In any case, the costs of self-archiving have nothing whatsoever to do with the
costs of publishing, since self-archiving is not a substitute but a supplement,
provided to those who cannot afford the costs of the published version.
Self-archiving in IRs is not a competing business model for publishing, but a
complement to the existing publishing system.

    STM: "'public access' does not necessarily mean 'free access', in the
    same way as 'public transport' does not mean 'free transport', even
    though in this country tax payers seem to contribute as significantly
    to the latter as they do to scientific research."

'Public access' does not mean free access, but 'open access' does. And open access
is concerned with goods from which (unlike the products and services of the public
transport industry) one of the two co-producers (and the primary one) seeks and
receives no sales revenue whatsoever: The researchers give their writings to their
publishers, without asking any royalties or fees, in exchange for the peer review
and publication they receive, which in turn brings them a certain measure of
research impact, which is what they really seek. But in the online age it turns
out that researchers are losing 50-250% of their potential impact if they do not,
in addition to giving away their research to their publishers for free, also give
it away online for free. 

Moreover, there is in a sense a third co-producer, or at least a co-investor in
the 'product,' along with the researcher and the publisher, and that is the
British public, the tax-payer who funds the research: Like the researcher and the
researcher's institution, the public's interest is in maximising the degree to
which its research investment is used, applied and built-up, in other words,
maximising its impact, which in turn depends on maximising access to it.

The publisher is a co-producer, having added value, and is fully entitled to seek
revenue for that contribution. (The publisher, after all,  unlike the researcher,
is not publishing merely for impact -- although the publisher too co-benefits from
enhanced impact.) But the researcher (and the third co-producer, the public) are
just as entitled to supplement the impact their research received from the
publisher's version with the potential impact from the self-archived supplement,
provided for those who cannot afford access to the publisher's version (exactly as
reprints were provided by authors to reprint-requesters in paper days).

(Now please find a counterpart for all that in the 'public transport industry'
analogy!)

    STM: "The concept of 'reasonable access' is probably more appropriate
    in this case."

What is reasonable is that when a new medium is invented that makes it possible to
enhance research access and impact substantially, no one should try to restrict
research impact simply because such a possibility had not existed in paper days.
Or, more succinctly, it is not reasonable to expect research and researchers and
the public that funds them to renounce potential research impact in the online
era.

    STM: "Researchers report a high level of trust in existing
    peer-reviewed journals."

Indeed they do. And it is the articles published in those trusted peer-reviewed
journals for which the author's versions are now to be self-archived in order to
maximise  their research impact, in accordance with the RCUK policy.

    STM: "Quality can always be improved, but it is difficult to imagine
    how author-pays business models or repositories will be more effective
    with respect to quality than existing publishing systems."

That may well be, but it is absolutely irrelevant to the matter at hand, since the
RCUK is not proposing to mandate author-pays business models, but author
self-archiving. And it is not mandating self-archiving primarily to improve
quality but to improve impact. And in this respect the IRs are a means (to improve
impact), not an end in themselves (although IRs have other institutional uses
too).

    STM: "Mandating a centralised peer review system for repositories
    will not be an improvement on the current journal-based and highly
    diverse review procedures."

That is absolutely correct, and no one is proposing to mandate a centralised peer
reviews system for repositories. RCUK is proposing to mandate the self-archiving
of the author's version of peer-reviewed journal articles.

    STM: "the argument has often been made (and never successfully refuted)
    that the mixing of scientific and financial barriers to an author
    accessing the journal of his/her choice may lead to unintended
    consequences with respect to reviewing standards."

The argument may (or may not) be sound, but it is absolutely irrelevant to the
matter at hand, since the RCUK is not proposing to mandate the mixing of
scientific/financial values, nor to mandate the author's choice of journal. RCUK
is proposing to mandate the self-archiving of the author's version of
peer-reviewed journal articles. 

    STM: "Many reports have now indicated that major research institutions
    would have to pay more for author-pays business models than in the
    traditional subscription models."

That may (or may not) be true, but it is absolutely irrelevant to the matter at
hand, since the RCUK is not proposing to mandate author-pays business models, but
self-archiving. 

    STM: "The cost of maintaining a large number of independent
    repositories... is likely to be significantly higher and less
    cost-effective than current publisher-hosted systems."

It is again gratifying that STM is so concerned about RCUK and university IR
costs, but let them be reassured that not only are those costs happily low, but
IRs are not intended to be substitutes  for publisher-hosted systems but
supplements to them, for those researchers who cannot afford the publisher's
version. Hence there is not even any point in comparing their costs, which are
orthogonal.

    STM: "STM agrees that there are significant and important concerns
    about the ever-increasing gap between the relatively high level of
    research funding, resulting in ever-increasing output of research
    results, and the relatively static level of library funding. This
    issue deserves serious debate and consideration, but the RCUK
    proposals do not seriously address these issues, if at all."

That is correct. The RCUK policy is not intended to generate more revenue to pay
for more paid access, but to supplement the existing paid access, such as it is,
for those would-be users who cannot afford it, in order to maximise the impact of
the research that the RCUK funds.

    STM: "The British Library maintains one of the most complete
    academic libraries in the world, and the university research
    library community is similarly focused on preservation.  Many UK
    university libraries now have access to very large collections of STM
    journals... The cost of duplicating such archives in digital form
    on various e-repositories, as appears to be suggested by the RCUK,
    is daunting and unnecessary."

Journals are not to be duplicated, authors' drafts are to be self-archived, to
maximise  their impact. The costs, such as they are, are not pertinent to STM, so
it is unnecessary for STM to be daunted by them.

    STM: "we welcome new publishers and new business models to our
    markets.  We see nothing new in the RCUK proposal other than unfunded
    mandates that arbitrarily favour some models over others."

The RCUK proposal is not about new publishers or new business models, nor does it
favour any model. It is about self-archiving RCUK-funded research in order to
maximise  UK research impact. (It is unfunded because IRs are keystrokes are
distributed and cheap, and that's all that's needed.)

    STM: "STM submits that the research community, and the four RCUK
    principles, are well served by the many dynamic business models
    that are currently in existence and experimented with, as a result
    of competition and innovation, in the marketplace."

STM may well be right. But well-served as they are, the British research community
would quite like to improve this excellent service with the 50-250% impact that
the 85% of British research that is not yet self-archived is still currently
losing, needlessly, daily, monthly, and yearly.
  
    STM: "In summary, STM believes that it would be in the interest of the
    research community and the broader community as a whole if STM and
    RCUK start a serious and systematic dialogue, based on the mutually
    agreed 'four principles', by jointly assessing and evaluating areas
    where the research information infrastructure can be improved and
    working with both the publishing and research communities to achieve
    this, including by the development of mediation and investigative
    bodies for research ethics issues, the support of the development of
    technical standards to identify versions and forms of research papers,
    and the like.  This way we can all avoid the trap of prematurely
    promoting solutions that are based on unproven assumptions."

It is an excellent idea for STM to confer and collaborate with RCUK on ways to
improve things over and above the long-overdue self-help policy that the RCUK is
already planning to adopt for British research output. Such collaboration would be
very useful -- but certainly not instead of implementing the self-archiving policy,
as and when planned. None of the above misunderstandings about the nature and
objectives of the policy, nor all the irrelevant points about alternative business
models, add up to any sort of rationale for deferring or diverting the
implementation of the policy in any way at all.

Stevan Harnad