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”.
Rationale
“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.
Respectfully,
Dr.
Heather Morrison
Assistant
Professor
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
Heather.Morrison@uottawa.ca
July
5, 2014
