Response to REF 2029 Open Access Consultation

The University’s Library and Collections submitted a response to the REF 2029 Open Access Consultation, which was opened by the four UK higher education funding bodies.

Response ID ANON-RE72-PNYX-F

Submitted to REF 2029 Open Access Consultation
Submitted on 2024-06-06 15:35:59

Transparency Statement

Your Details

1 Are you answering on behalf of your organisation or institution, or as an individual?
Organisation or institution

2 What is your organisation/institution?
Organisation:
University of Edinburgh

3 Country
Scotland

Other:

Section A: open access developments in the sector

4 What are the most important changes in the open access landscape since the development of the REF 2021 open access policy?
1) How do these differ across disciplinary areas?
2) What are the implications of these changes for the REF 2029 open access policy?

OA landscape changes:

Since the last REF, the Open Access landscape has changed considerably, The main changes are:

• Mandatory deposit and green Open Access have become routine in most universities, driven by the OA policy of the last REF.
• Implementation of Plan S, and associated changes to UKRI Open Access Policy have supported the normalization of OA, and have moved us away from
  paying hybrid APCs.
• There is a rapidly increasing number of UK institutions implementing rights retention (RRS) policies.
• Transformative agreements are impacting how journal articles are made OA with a proportional move away from green OA in STEM subjects.
• Increase in APC costs charged by publishers.
• The introduction of authorship policies, more contribution to the literature from a wider range of academics.
• Widespread adoption of so-called ‘read and publish’ deals amongst larger and research-intensive HEIs, which not all institutions benefit from.

The journal OA environment is highly advanced but the same infrastructure is not in place for long-form publications. Inclusion of OA for longform publications would have a huge impact on institutions, and we have concerns that the publishing landscape is not ready for this. The costs are anticipated to be considerable.

The open access landscape for longform publications remains underdeveloped at present, and a robust funding model to enable a collective shift to open access publication at scale is not yet in place. Until such a model is well-established, the burden to fund open access publication will fall on individual HEIs, and (when limited HEI resources are exhausted or prioritized elsewhere) on individual researchers and teams. The changes can have negative effects on emerging and non-mainstream disciplines, and on the most vulnerable and precariously-employed researchers.

The number of outputs within scope will be low if we take into consideration exempt outputs, and the two sets of requirements will be difficult to administer. Our preference would be for these requirements to be implemented from the next REF exercise. Longform submissions for REF2029 will take a number of forms: non-open access books with contracts before 1 January 2026; non-open access books that are exempt, and open access books that fall within the proposed terms and timetable. There is scope for confusion and inadvertent contravention of the rules.

Section B: journal articles and conference proceedings

Section B: publication, deposit

5 Should deposit requirements post acceptance be maintained where publication isn’t immediately open access?

Not sure

If yes, why? What would be an appropriate time limit for deposit post acceptance?:

There are mixed views on this within our University. One face of it this seems like a sensible idea, however the general consensus is that institutional processes should still work on the basis of depositing papers within a certain period after acceptance and not publication. This is because:

• Current processes rely on getting researchers to deposit AAMs upon acceptance and a change to requirements would entail a change in processes and
  messaging to authors.
• Deposit upon acceptance has become habit for many academics and the worry is that a change in requirements could jeopardize academic engagement
• For some disciplines, the long period between acceptance and publication would mean the tracking of these papers and obtaining AAMs at publication
  could be problematic.

Deposit requirements on acceptance have helped administrators manage compliance. If the requirement to deposit accepted versions is changed to one month from publication, there some concerns that compliance will be missed. In many Arts and Humanities disciplines, journals are published by small
organisations and by small teams of largely volunteer editors.

STEM disciplines and Library staff are more supportive of the idea of removing the requirement to deposit on acceptance. We need to remain mindful of the sound ED&I reasons why a deposit or OA threshold may not be met (parental leave, long-term sickness etc). One option could be to retain the deposit rule as a non-auditable requirement.

Section B: access, licensing

6 Do you agree with alignment to the UKRI open access policy in respect of licensing for journal publications by requiring licensing terms equivalent to CC-BY or CC-BY-ND licensing for journal publications?

Yes

What, if any, negative or positive impacts might there be from this change?:

We agree in principle, but further clarification is required on licence requirements, does this apply to green OA only or also include gold OA?

Further clarification also requested on wording of licence requirements, is this the preferred licence or mandatory?

We would like to see a compliant CC-BY-NC option as well as the CC-BY-ND.

Section B: pre-prints, alternative platforms

7 Do you agree with recognition of alternative platforms as meeting open access requirements as primary platform for publication?

Yes

Please provide any further comment:

In principle we are supportive of this change, however, clarification is need on what constitutes an acceptable alternative platform.

If we are talking about established non-commercial platforms, such as ArXiV, Wellcome Open Research, or similar, then we support this. In fact, this would be vital for some disciplines were platforms such as ArXiv were integral to satisfying REF2021 OA requirements.

Section B: embargo periods

8 Do you agree with the proposed changes to embargo periods for journal publications for main panels A and B (12 months reduced to six months) and main panels C and D (24 months reduced to 12 months), in light of changing standards and practice?

Not sure

What, if any, negative or positive impacts might there be from this change?:

STEM subjects are more in favour of this change and it has been noted that our Rights retention Strategy will help manage any change in embargo periods, overall, we are in a good position. However, some concerns that the shortening of embargo periods within REF policy does not reflect the larger publishing environment, for example, Society publishers who still require long embargo periods.

There is the potential that reducing embargo periods could have a knock-on effect with future negotiations with publishers around transformative agreements.

Arts and Humanities academic reported that small learned societies that rely only on two or three journals to keep them afloat may struggle with a 12-month embargo. In some of our disciplines, the most prestigious journals are based in countries other than the UK where pressures to move toward
open access models are much weaker. Although some of these journals make allowances for European-based authors, we cannot expect all to comply with shorter embargo periods just because it is a requirement here in the UK. It would be a real loss of academic impact to lose access to prestigious
journals due to embargo requirements. For this reason, and to ensure the survival of these journals and societies, we recommend the retention of the 24-month embargo period for journal articles within the remit of Main Panels C and D.

We would hope that this shortening of embargo periods could be associated with exceptions to cover such publishers.

Section B: tolerance limits, implementation date

9 Do you agree that changes to the open access policy for journal-based publications should be implemented from 1 January 2025?

No

Please provide any further comment:

1 January 2025 does not give enough time to implement changes across Pure, communicate change to researchers or update guidance to all staff members involved in REF exercise.

An absolute minimum 6 months needed from formal announcement of policy before implementation, but 12 months would be preferred.

Further clarification required on what is meant by 1 January, (is this date for submission, acceptance, or publication)?

We have concerns around running two separate OA compliance schema in Pure at the same time, preferred option would be to have a blanket exception for all outputs accepted before new policy comes into play.

There is a general feeling that implementation of the new policy depends on how different and potentially how complex new policy is in comparison to
previous REF policy.

10 Do you consider that tolerance limit for articles and conference proceedings should be retained at 5% of any submission?

Not sure

please provide any further comment :

Clarification is needed as to whether the 5% tolerance refers to just in-scope records or the whole submission. REF2021 submission had a lot of REF2s that weren’t in scope so restricting the 5% to just in-scope would greatly reduce leeway.

If we are required to deposit within 1 month of publication (with no deposit within 3 months of publication exception) then there would be a lot less time
to ensure compliance so a 10% tolerance would allow more room for, inevitable, error.

Section B: exceptions

11 Do you agree with the proposed exceptions for journal publications?

No

Should any of the above be removed?:

No

What, if any, additional exceptions might be required?:

We have received a suggestion for an ‘Admin’ exception to be used if compliance was affected by administrative mistakes.

It was noted that there was no longer an exception to allow for the use of publications authored prior to a staff member coming to institution. This was an exception that was used extensively in the 2021 submission. It was noted this was probably the result of the decoupling of people and outputs.

We need clarification on what is meant by a ‘substantial connection to institution’ means to understand whether any resulting exception would be
needed.

There should be an exception for publications that actively disallow OA publication (or at least CC licencing) which is more common in some disciplines.

There should be a ‘deposit within three months of publication’ exception. One month from publication is too short a time especially when many researchers are not notified when their papers are published.

Would it be easier to reinstate the ‘other’ exception?

Section C: longform outputs (monographs, book chapters and edited collections)

Section C: publication, deposit and embargo

12 Do you agree that there should be no deposit requirement for longform publications, but that they should be made immediately available as open access upon publication (or no later than 24 months following publication if subject to an embargo)?

No

Please provide further comment:

Whilst we fully support the aim of Open Access for long-form publications, we feel that this should be part of a longer-term goal, as the infrastructure is
not yet in place for this.

Fundamental change across the publishing landscape needs to happen first. We have significant concerns that the policy is trying to shoehorn long-form publications in journal article procedures when this is unlikely to be possible, practically.

We have serious concerns about the affordability of book-processing charges (BPCs), beyond UKRI and Wellcome Trust, no funding is in place for this. For a research-intensive University like ours, this could costs millions of pounds, and publishers will be quick to cash in on this. There is not a level playing
field across the UK and publishers would likely raise BPCs knowing that HEIs will need to pay them to meet REF requirements.

We have concerns about the accessibility of green OA for longform publications. This is not necessarily desirable for readers. There are issues around readability and accessibility that may conflict with University of Edinburgh accessibility policies.

The University has serious concerns about the affordability of Open Access for long form publications where no funding is in place and about the EDI repercussions of the requirements.

13 Do you agree with the proposal of a maximum embargo period of 24 months for longform publications?

Not sure

Please provide any further comment:

We prefer for there to be no access requirements for monographs, but if there were, then 24 months would be the minimum acceptable embargo period.

We need to understand what data is that supports the proposal for a 24 month embargo and not unsubstantiated statements about most book sales being in the first 2 years.

Could embargos be based on something other than time, maybe book sales instead?

There is an assumption in this consultation that green open access for books is viable without considering issues around accessibility for long documents.

Section C: access, licensing

14 Is licensing for third party materials not being granted a reasonable ground for exemption from open access requirements?

Yes

Please provide any further comment:

As above, we prefer for long-form publications not to be included in the policy, but in case they are then this would be a necessary exemption. This is a common problem in arts subjects.

15 Is sharing of a version of an output without third-party materials if licensing can’t be obtained, mirroring the UKRI open access policy for longform outputs, appropriate to meet the open access requirements for REF 2029 policy?

No

Does this present issues for output submission and assessment?:

Third-party materials are often an essential part of the research output and the publication makes little sense if they have been excluded, for example maps and images. There are also accessibility issues to consider as mentioned in other questions responses.

Section C: tolerance level

16 Do you agree with the principle of a tolerance level for non-compliant longform outputs?

Yes

Please provide any further comment:

If there will be OA requirements for longform outputs then there absolutely will be a need for a tolerance level. The publishing landscape would mean that 100% compliant records simply would not be possible.

17 Do you agree with the proposed tolerance level of 10% for longform outputs?

No

Please provide any further comment:

We need clarification on what 10% tolerance level means; i.e., 10% of in-scope record or submission? If there is to be a tolerance level for longform outputs then it should be greater than 10%. Some units are small enough that a single non-compliant record would mean they exceed the required
tolerance level. We would recommend a tolerance level upwards of 10% if this policy goes ahead.

Section C: implementation

18 Do you agree with the proposed date for implementation of an open access policy for longform outputs in REF 2029 being for all longform publications for which contracts are agreed from 1 January 2026?

No

Please provide any further comment.:

We note that most in-scope long-form submissions would be under embargo at the point of the REF submission, given the long lead-in time for publication after agreeing a contract.

Due to timescales, our preferred option would be that OA policy for long-form publications is implemented from the very beginning of the publications window for the next REF (post-2029) cycle where it would be part of an entire REF cycle. This will be cleaner, easier to manage and allows more time for the change to come about. REF 2029 will likely have very few monographs that need to comply the policy in any case.

Section C: exceptions

19 Do you agree with the proposed exceptions for longform publications?

Not sure

Should any of the above be removed?:

We need clarification on what the OA options are for longform outputs before we can consider exceptions properly.

Is REF expecting institutions to pay for OA monograph publishing? If so, this would place considerable extra financial burden on institutions.

We need clarification on what level of evidence would be needed for the use of exceptions, what sort of scrutiny would REF perform on monographs and what would be auditable.

Are there other exceptions you think are necessary for longform outputs? Please provide evidence in support.: