Government of India Department of Biotechnology and the Department of Science and Technology (DBT / DST) Proposed Open Access Policy
Comments submitted by Heather Morrison to the Open Access Policy Committee and cross-posted to Sustaining the Knowledge Commons http://sustainingknowledgecommons.org/ and The Imaginary Journal of Poetic Economics http://poeticeconomics.blogspot.ca/
Congratulations to the Open Access Policy Committee for a proposed policy that can be considered a new model for the world in almost every respect!
My two suggestions to perfect this policy are as follows:
1. After this sentence on page 1: “Grantees can make their papers open-access by publishing in an open-access journal or, if they choose to publish in a subscription journal, by posting the final accepted manuscript to an online repository”, this sentence were added: “Grantees who publish in an open-access journal should post the final published manuscript to an online repository based in India”.
Rationale: journals and publishers are free to come and go and change business models as they please. A journal that is open access today could cease to exist, or be sold to a publisher that uses a toll access business model in the future. The only way to ensure ongoing open access to publicly funded research is through the use of repositories under the direct or indirect control of the funding agency.
2. p. 2: “Suggest that the period of embargo be no greater than one year” – change “Suggest” to “Insist”, and add this phrase: “Future revisions of this policy will look to decreasing and eventually eliminating accommodation for publisher embargoes”.
“Suggest” to “Insist”: the experience of one early open access policy leader, the U.S. National Institutes of Health, illustrated very well that certain publishers will take every advantage of any policy loophole available. The 2004 policy merely requiring open access had a dismal compliance rate; this changed dramatically with the strong 2008 policy. If researchers have options, publishers will refuse open access or demand longer embargoes. If policies are strong, publishers adjust as can be easily observed through the Sherpa RoMEO Publisher Copyright Policies and Self-Archiving service, which illustrates the shifting landscape of scholarly publishing overall towards compliance with open access policy as well as concessions for specific policies.
“Decreasing and eventually eliminating…publisher embargoes”: the purpose of permitting publisher embargoes is to give the industry time to adjust. Publishers have now had more than a decade to adjust to open access policies around the world, including many by the world’s largest research funders. There are now close to 10,000 fully open access peer-reviewed scholarly journals, employing a variety of business models, including commercial operations that are quite successful financially. There is no reason for publishers to continue to need the “training wheels” support of embargo periods indefinitely.
There is no reason to delay the advance of research by one year at every step. We need clean energy solutions and answers to tough questions like climate change today. Since scientific advance is incremental in nature, a one-year embargo at every step towards an advance can mean an actual delay of many years in achieving a breakthrough.
Particular strengths of this policy that I would like to highlight:
p. 1: “DBT/DST will not underwrite article processing charges levied by some journals”.
Bravo! The purpose of public funding of research is and should be to facilitate the conduct of research, not to subsidize secondary support services such as scholarly publishing. The priority for DBT/DST funding should be ensuring that India’s research facilities are state of the art and providing salaries for Indian researchers and support for Indian students.
Also, there are areas (with this policy being a good example) where government policy is the best approach, and other areas that are best left to the market. It is appropriate for governments to direct researchers benefiting from public funding to make their work openly accessible. However, there are reasons to leave business models to the market. One reason is that commercial companies employing the article processing fee method are likely to be subject to the same market forces that caused distortion in the subscriptions market, and targeted government funding in this area could easily exacerbate the problem. Another is that currently many publishers using the open access article processing fee approach provide waivers for authors from developing countries; this may even be the default. This information is from my research in progress (my apologies that my data is not yet ready to share; it will be posted as open data as soon as it is ready). If governments provide funding for authors from developing countries for article processing fees, this concession may well disappear and have a severe impact on authors without the benefit of such funds.
p. 1: “The DBT/DST affirms the principle that the intrinsic merit of the work, and not the title of the journal in which an author’s work is published, should be considered in making future funding decisions. DBT/DST does not recommend the use of journal impact factors, as a surrogate measure of the quality of individual research articles, to assess an individual scientist’s contributions, or in hiring, promotion, or funding decisions”
Bravo! This is the approach recommended by the San Francisco Declaration on Research Assessment http://am.ascb.org/dora/, and an approach that I heartily support. Among other things, heavy reliance on the impact factor as surrogate for quality of academic work has been a factor in market distortion in scholarly publishing. Also, reliance on impact factor has been an incentive for scholars to focus on topics of interest to high impact factor journals generally based in developed countries. For scholars in the developing world, this is an incentive to redirect focus from problems and issues of local concern to topics of interest to the developed world. This has also been a disincentive to development of local scholarly publishing systems. The ease of publishing on the internet means that it is timely for scholars in India and elsewhere to consider growing local scholarly publishing initiatives, providing opportunities for local leadership, outlets for research on topics of particular interest to India, and taking advantage of local currency and economic conditions to get the best deal on publishing services.
Other strengths shared with previous open access policies:
· The policy is required, not just requested
· Strong incentives for compliance (compliance considered in future funding and promotion requests)
· Immediate deposit of final manuscript post peer review is required, even when access must be delayed due to publisher embargoes
In summary, India’s DBT/DST proposed open access policy is sound, innovative, and in my expert opinion, sets a new standard for the world. The two recommendations for improvement is to ensure that all articles are deposited in a local open access repository, including articles published in open access journals (which may in future cease to exist, change ownership or business model), and to insist on rather than suggest an embargo of no more than one year with language indicating eventual elimination of embargoes. Particular strengths highlighted are the refusal to provide funds for article processing fees and the direction to consider the quality of the work, not the impact factor of the journal in which it is published.
Dr. Heather Morrison
École des sciences de l'information / School of Information Studies
Master of Information Studies (M.I.S.) program accredited by the American Library Association
Maîtrise en sciences de l’information (M.S.I.) accréditée par l’American Library Association
University of Ottawa
July 5, 2014