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*