From: Jan Velterop <[log in to unmask]>
Date: Sun, 24 Mar 2013 19:08:54 +0100

These criteria are curious and in places quite problematic. Some are
quite sensible, but others betray little understanding of OA and even
electronic publishing, as well as little understanding of what it
entails to start a new OA journal or publishing venture in the
non-western world. Put yourself in the shoes of a genuine start up in
a developing country, and think about the consequences of these
negative criteria (the criteria are all formulated in a negative form,
you will have notices). It would be helpful if that were turned around
and a list of positive criteria of when a new OA journal/publisher can
be seen as serious and acceptable.

A few examples (pretty random; certainly not comprehensive) of
problematic criteria:

> *Depends on author fees as the sole and only means of operation with
> no alternative, long-term business plan for sustaining the journal
> through augmented income sources.

Like BioMed Central, you mean? Or Hindawi?

> * Begins operations with a large fleet of journals, often using a
> template to quickly create each journal’s home page.

Again, like BioMed Central, you mean?

> * The name of a journal is incongruent with the journal’s mission.

What does 'incongruent' mean here? That the journal title isn't clear
about what the contents are about? Something like 'Vital', say?
(http://www.nature.com/vital/index.html)

> * Has no policies or practices for digital preservation.

It could well be argued that publishing with true OA, a publisher can
legitimately leave that to repositories and libraries.

> * Use language claiming to be a “leading publisher” even though the
> publisher may only be a startup or a novice organization.

Well, 'leadership' is often easier for a start-up than for a large
traditional organisation set in its fossilised ways.

> * Do minimal or no copyediting.

You mean like what is the norm in much of traditional publishing?

> * The publisher does not use ISSN numbers

It could well be argued that the ISSN is a relic of the traditional
print/subscription model. Evidenced perhaps by the stipulation that
"the ISSN must be printed on each issue of the journal" (ISSN site).
It is also typically used to identify journals for subscriptions. OA
journals have no subscriptions.

> * Publish papers that are not academic at all, e.g. essays by laypeople or
> obvious pseudo-science.

As in e.g. the journals on 'homeopathy' published by otherwise
reputable traditional publishers?

Enfin, you get the gist.

Jan Velterop