From: Jean-Claude Guédon <[log in to unmask]>
Date: Sat, Nov 17, 2018 at 5:37 PM

In response to the criticisms aimed at Plan S (
https://sites.google.com/view/plansopenletter/open-letter), the Fair Open
Access Alliance has issued its own answer:

*The Open Letter: Reaction of Researchers to Plan S: too far, too risky.*

*A response of the Fair Open Access Alliance*

*We write to provide a counter view to the recent open letter (“Plan S: Too
Far, Too*

*Risky”), [https://sites.google.com/view/plansopenletter/open-letter
<https://sites.google.com/view/plansopenletter/open-letter>] partly based
on our FOAA recommendations for the implementation of Plan S. *

*[https://www.fairopenaccess.org/2018/10/21/foaa-recommendations-on-the-implementation-of-plan-s/
<https://www.fairopenaccess.org/2018/10/21/foaa-recommendations-on-the-implementation-of-plan-s/>]
*

*We are glad to note that the researchers who have signed the open letter
support open*

*access as their very first principle. However, the letter itself goes on
to make a number*

*of highly problematic and logically fallacious statements with which we
strongly disagree*

*and here contest.*



*More broadly, the letter fails to provide any solution to address the
problematic situation*

*academia has maneuvered itself into with regards to scholarly publishing.
As it stands,*

*the open letter is a set of demands on the funders, without any
responsibility assumed*

*by the researchers themselves for the ongoing serials crisis, nor for
providing solutions.*

*In this document we review the items in the open letter systematically.*



*1. Hybrid (society) journals*



*The Letter states: “The complete ban on hybrid (society) journals of high
quality is a big*

*problem, especially for chemistry.” This statement is not correct. First
of all, Plan S does*

*not ban hybrid journals, it simply aims at persuading funders to stop
paying APCs to*

*them as these titles have proved an ineffectual mechanism for a transition
to OA.*

*Beyond the fact that it is unclear why chemistry thinks itself exceptional
here, Robert-Jan*

*Smits has explained on several occasions that Plan S will allow
researchers to publish in*

*hybrid journals íf the article is published simultaneously in a repository
or archive*

*without an embargo and under a CC BY license. In the Wellcome Trust’s*

*implementation of Plan S, the version that must be available is the AAM
(author’s*

*accepted manuscript). Several publishers, such as Emerald and SAGE,
already offer*

*zero-embargo green OA. In addition, while coalition funders will not pay
APCs for hybrid*

*journals, they will not prevent authors from finding research funding from
other sources.*



*Contrary to the claims of the Letter, Plan S takes into account the full
landscape of open*

*access, as clearly acknowledged in Principle 3: “In case such high quality
Open Access*

*journals or platforms do not yet exist, the Funders will, in a coordinated
way, provide*

*incentives to establish and support them when appropriate; support will
also be provided*

*for Open Access infrastructures where necessary;” and Principle 8 “The
importance of*

*open archives and repositories for hosting research outputs is
acknowledged because of*

*their long-term archiving function and their potential for editorial
innovation;".*



*The open letter claims that researchers (at least in chemistry) “won’t
even be able to*

*legally read the most important (society) journals.” This is nonsense.
This claim implies*

*that researchers will cease to have legal access to these journals through
subscriptions.*

*If this were the case, it is very unclear how Plan S could be held
responsible. The intent*

*of Plan S is that journals flip to open access which would mean they were
legally*

*accessible to everyone. However, if as seems to be claimed in the letter,
libraries were*

*to cancel subscriptions, this would not be in response to Plan S but due
to the*

*unsustainability of ever increasing subscription costs. The letter goes on
in the second*

*point to acknowledge the issue with exploding costs to subscriptions
without offering any*

*solutions to the problem. Furthermore, the authors assume without argument
or*

*evidence that all journals (at least in chemistry) “with a valuable and
rigorous peer-*

*review system of high quality” will either fold or fail to adapt.*



*The open letter also assumes that Plan S will lead to the death of learned
societies.*

*Indeed, learned societies that publish academic journals sometimes derive
considerable*

*profits or surpluses from the subscription system, and have benefited
substantially in the*

*past decade from funder requirements to make research open access under
the hybrid*

*system. As an example, the American Chemical Society has a highly complex
fee structure *

*for article processing charges,
[https://pubs.acs.org/pb-assets/documents/4authors/ACS_SalesChart.pdf
<https://pubs.acs.org/pb-assets/documents/4authors/ACS_SalesChart.pdf> ] *

* taking full advantage of the situation, where a funded non-member from an
institution that does not subscribe *

*must pay $4000 for immediate access (a requirement of the funding paying
the APC) and a surcharge of*

*$1000 for CC BY (again a requirement of the funding paying the APC), a
total of $5,000*

*– when the average APC is approximately $2700. These profits or surpluses
are often*

*used to support research activities. As a result, learned societies have a
financial*

*interest in maintaining the subscription, and specifically the hybrid,
system. It is true that*

*there are large differences between research fields here, in that
chemistry derives more*

*money from the (hybrid) subscription system than other fields.*



*A more productive approach to the conversation would be to focus on
alternatives to*

*subscriptions that pay for society income rather than attacking Plan S.
For it is, indeed,*

*bizarre that library budgets should bear the brunt of funding disciplinary
activities. That*

*said, an alternative income for scientific societies is possible under a
publication-fee*

*model as well. For example, the publication fee is capped under Plan S,
which allows for*

*a difference between the real cost of publishing and the cap paid by the
funders which*

*could be reserved for the learned society. This solution does require that
the cost of*

*publishing is made completely transparent by publishers (societies in this
instance).*



*FOAA recommended cost transparency as a crucial factor for the
implementation of*

*Plan S. We believe publishers should be required to provide the actual
breakdown of*

*costs contained in the publication fee, and make this information publicly
available. An*

*example of how this works in practice is the 2016 release by eLife of
their costs to*

*publish.
[https://elifesciences.org/inside-elife/a058ec77/what-it-costs-to-publish
<https://elifesciences.org/inside-elife/a058ec77/what-it-costs-to-publish>] *

*Without this transparency the cap will be established as a new price-point
that*

*will allow publishers to renegotiate it every few years, and allow those
with actual costs*

*below the cap to raise their costs to meet the cap. A subset of publishers
have already*

*agreed to the FOAA cost transparency proposal in the Transparent
Transition to Open*

*Access (TTOA consortium).*



*2. A transition from hybrid to full Open Access*



*We further recommend that a policy be defined to help publishers and
Editors-in-Chief of*

*hybrid journals to transition to full open access within a 3-4 year
period, reporting on*

*progress every year. The transition of hybrid journals to non-hybrid or
full Open Access*

*journals will need an infrastructure in line with Principle 3 of Plan S:
FOAA has taken an*

*initiative to help journals transition to open access in the aftermath of
Plan S with its*

*TTOA platform. *

*[https://www.fairopenaccess.org/wp-content/uploads/2018/05/Public-statement-TTOA-consortium-30may18-def.pdf
<https://www.fairopenaccess.org/wp-content/uploads/2018/05/Public-statement-TTOA-consortium-30may18-def.pdf>]*



*Nobody wishes to ‘ban’ society journals: the request here is to use
imaginative ways to*

*make the transition of those journals to an open access model, which would
do much*

*more for the societies’ disciplinary advocacy work. A number of journals
have already*

*gone that route, and have – in a very short time - been able to fully
maintain their*

*readership and reputation in their communities (see the highly successful
transition of*

*the editorial board of Elsevier subscription journal Lingua to Fair Open
Access Glossa,*

*and that of Springer’s Journal of Algebraic Combinatorics to Algebraic
Combinatorics).*

*These journals have shown that the scientific reputation of a journal lies
with its editorial*

*team, not with the name or with the publisher. If editors in linguistics
and mathematics*

*can flip their prestigious journals to open access, at no cost to their
reputation, editors in*

*other fields should be able to do so as well. A transition to full open
access is the best*

*thing editors of prestigious journals can do to help establish the
reputation of younger*

*scientists with access to cOALition S funds.*



*Further, the authors of the Letter claim that they “expect that a large
part of the world will*

*not (fully) tie in with Plan S”. In the meantime, important funders such
as the Wellcome*

*Trust and the Gates Foundation have already joined Plan S. For Plan S to
succeed, it is*

*essential that not only funders take a principled stand, but that editors
of hybrid journals*

*join forces to urge their publishers to flip the journals to full open
access.*



*3. The cost of publication*



*The signatories of the letter say they understand concerns about exploding
costs of*

*journal subscriptions. But they also state that “with its strong focus on
the Gold OA*

*publication model, in which researchers pay high APCs for each
publication, the total*

*costs of scholarly dissemination will likely rise instead of reduce under
Plan S”.*

*However, Plan S does not mention APCs nor Gold OA. It refers only to
Publication Fees:*

*this is a much broader term that encompasses multiple options. One example
is the*

*SCOAP3 consortium where libraries pay a ‘subscription’ to journals that
are openly*

*accessible. This approach opens the possibility that no-fee journals can
also be*

*compensated for their efforts. Thus, Plan S provides funding for all
publication venues*

*with the exception of hybrid journals. Furthermore, APCs need not make the
total costs*

*of dissemination rise further: the average cost to the international
community of a*

*research article under the current subscription system is currently about
$3800. *

*[https://pure.mpg.de/rest/items/item_2148961_7/component/file_2149096/content
<https://pure.mpg.de/rest/items/item_2148961_7/component/file_2149096/content>]
Even a*

*generous cap of $2000 per article will almost halve that cost. Plan S
clearly states that it*

*will cap open access publication fees, a fact that the signatories of the
Letter ignore.*

*There is no reason that researchers would be confronted with high APCs if
editors are*

*incentivized to transition their high-quality journals to open access with
a standardized*

*publication fee paid for every article.*



*4. Academic freedom*



*The Open Letter states that ‘Plan S is a serious violation of academic
freedom’. Yet the*

*claim that academic freedom is being violated is overstated. At its heart,
academic*

*freedom concerns the freedom of inquiry and the freedom to communicate
research*

*results and ideas without reprisal. In that sense, Plan S actually
guarantees a greater*

*academic freedom than that afforded by the authors of the Letter: open
access will mean*

*that the greatest number of readers will have access to published ideas,
rather than*

*debate being hampered by a paywall. It is highly debatable whether
academic freedom*

*should extend to the freedom of researchers to choose their publication
venue: an*

*author’s freedom to publish wherever they want ends where the reader’s
right to freely*

*access research starts. In actual fact, researchers never enjoy complete
freedom of*

*publication, as papers are often rejected, and subsequently published in a
journal that is*

*not the journal of original choice. Funders, by contrast, have the right
to determine how,*

*or at least under what access terms, the research they fund should be
published: he*

*who pays the piper calls the tune. Nobody is forcing researchers to accept
grants from*

*these Funders if they truly believe their choice of publication venue is
being restricted by*

*them.*



*In conclusion, the Letter offers plenty of unargued criticism, but no
viable alternative to*

*the currently unsustainable academic publishing landscape. Worse, it fails
to grasp the*

*opportunities offered by Plan S to do so.*



*Jos Baeten*

*Martin Paul Eve*

*Saskia de Vries*

*Danny Kingsley*

*Johan Rooryck*