SPARC Europe responds to the UK House of Lords Select Committee for Science & Technology inquiry into the UK Government’s policy on Open Access and its implementation by RCUK

The Government should take steps quickly to consult widely with the research community and allied groups of stakeholders. At the time of writing a BIS consultation on the topic of Open Access has been announced, which is welcome. SPARC Europe will be responding to that inquiry with evidence on the issues outlined.


1. SPARC Europe (Scholarly Publishing and Academic Resources Coalition) is pleased to have the opportunity to comment on the issues listed below. SPARC Europe welcomes the UK Government’s positive interest in Open Access (OA), the Finch report on expanding access to research publications and the Research Councils’ active engagement in developing policy.


2. SPARC Europe’s response to the Finch Report is a public document and details our reservations about the direction and conclusions of the report. We will not repeat those here but wish it to be noted that we have serious concerns in two areas – there are factual inaccuracies in the report and there are a number of assumptions or conclusions that are not evidence-based. We point these out in order to flag up points that the Committee may wish to note in its own considerations and because these contribute to our analysis and response to the Finch study and its conclusions.


a)  Factual errors. The report:

  • Implies that ‘Green’ Open Access is always embargoed (delayed by publisher embargoes on permission to put papers into repositories). This is incorrect: 60% of journals allow immediate opening-up of the peer-reviewed version of the article and a further 27% permit the opening-up of the submitted version. 16% even allow the published version (the Version of Record) to be placed in a repository immediately upon publication.
  • Reports that the impact of repositories (Green OA) is limited except in those disciplines that support large-scale subject repositories. In fact, repositories are providing seven-eighths of the 40% of the UK’s research outputs that are Open Access, and the amount of Green OA is greater than Gold OA (openly-published in journals) in every field except the life sciences.
  • Reports that Green OA cannot be given a liberal licence to allow text- and data-mining. This is incorrect: there are many examples of liberally-licensed Green OA material and these are growing.
  • States that most Open Access journals charge article-processing fees. This is incorrect: the majority of OA journals (70%) do not charge a publication fee.
  • States that publication fees are paid by authors. This is misleading, since most publication fees are paid by the institution (24%), by the funder (59%) and only in 12% of cases by the author. There are implications here for the public purse.


b)    The lack of an evidence base for some of the important assumptions made, and some analytical errors:

  • Concludes that Green OA with short embargo periods may damage publishers. This ignores the complete lack of evidence for this and the substantial body of evidence against it, which we detail below in this response.
  • Concludes that repositories have a role merely in preserving the literature and for archiving theses and grey literature. This is a strange conclusion given that virtually all repositories were built specifically to provide Open Access to the journal literature and in the UK have succeeded in providing this at way above global average levels.
  • Uses an above-average value for publication fees in the calculations of the cost to the UK of Gold Open Access. The value used in the study was £1500-2000 (based on the publication fees being paid by the Wellcome Trust for authors to publish in Gold OA journals in the life sciences). The global average is USD 907 (c£570)[1]. This is important because the overall Finch recommendations are for the UK to move to all-Gold Open Access (i.e. pay for every article published) and Government-level acceptance of such a high value for publication charges may lead to publishers putting their charges up to this level if they feel the money is there.
  • Does not take into proper account the existing policies from governments and research funders. There are over 50 funder policies[2] on Open Access, all of which align except for detail and all of which focus on Green Open Access using repositories. The Finch conclusion – to focus on Gold Open Access – is an outlier (though the aim is, apparently, to ‘lead the world’).
  • Assumes that potential users will want the Version of Record (VoR). Potential users may prefer the VoR but this requires Gold OA for all articles – an expensive option for the UK. For most potential users, the Green version is perfectly adequate.
  • Assumes that innovative SMEs all need liberally-licensed research outputs so that they can carry out text-mining. While this is the case in some sectors (e.g. biotechnology), for the majority of sectors the need is simply for humans to have access to articles to read them.


3. Given these inaccuracies, SPARC Europe cannot fully endorse the conclusions of the Finch report, nor support the specific shape of the subsequent RCUK policy based upon the report. No national policy should be based on flawed or missing evidence and we exhort the Committee to pay attention to the facts when considering what its own recommendations might be.


4. From another perspective we question the over-weighted ‘Gold’ thrust of the Finch report and the RCUK policy. Economic modelling[3] has indicated that the cheapest way for the UK to become an ‘Open Access nation is to transition through ‘Green’ OA to a final ‘Gold’ OA world. The benefits of OA accrue throughout the transition, but the costs of transitioning are much less. This delivers value back to taxpayers at the same time as achieving the goal. We do not understand the thinking behind spending precious research funds on publishing activities when OA can be delivered more cheaply and as effectively in other ways. There is a policy opportunity with respect to Gold OA, especially with respect to the opportunity to help create a better market for publishing services, but we do not agree that the RCUK policy approaches it in the best way.


Now we turn to the issues highlighted by the S&T Committee for specific consideration.


5. Support for universities through funds to cover article processing charges

Even before the Web made the case for Open Access compelling, there was a market problem in academic publishing. The market is far from perfect because there is no proper competition between products; users of the products (researchers) are not the purchasers (libraries are) so pressure on prices is reduced and price elasticity of demand has been low. As a consequence, journal prices have risen inexorably over the decades.


6. Open Access provides the opportunity for publishers to change their business models to provide free access to readers and to cover their costs by making a charge for their services rather than for their products. Such as system should naturally adjust the market by putting researchers who are – as authors – the customers for publishing services into the position of purchaser. This will create a more competitive market as publishers will need to compete on service quality and price.


7. Unfortunately, the proposed system of block grants to institutions will hinder the development of a more competitive market. Authors will be one step removed from the purchase decision by dint of an inevitable allocation system within each institution. Already one very large publisher is attempting to do a national-level deal with libraries to make all the RCUK-funded articles that this publisher published in 2012 Open Access. The proposed block grant approach will simply turn the current ‘Big Deal’ system for subscriptions into a Big Deal system for article processing charges. There will be many losers, as there are from the Big deal subscription system, not least small publishers that cannot compete with the might of the publishing giants.


8. Embargo periods for articles published under open access

The term ‘articles published under Open Access’ implies those published as ‘Gold’ articles in journals and as such there should never be any embargo at all. Gold OA is, by definition, immediate online access upon publication in the journal.


9. If what is meant here is rather about the issue of embargoes applied to Green Open Access (work deposited in OA repositories), the policy position on ‘Green’ Open Access should be that:

  • all articles must be deposited in an OA repository at the time of publication or before (preferably once the article has been accepted after peer review)
  • if the publisher requires an embargo, this will be honoured, though maximum embargoes should be 6 months for science, technology, engineering and medicine (STEM) disciplines and 12 months for humanities and social sciences (HSS) in the interests of the public which ahs funded the research


10. The upshot is that provided deposit of the paper in the repository takes place at or before the time of publication, then during the course of the embargo period the metadata describing the paper and heralding its existence will be visible (metadata are not copyrighted and cannot be embargoed) even though the full text of the article is not openly visible.  Authors can fulfil requests to supply a copy of their work to individuals who learn of its existence (because Web search engines index the metadata) and ask for the article by email. This is not Open Access, and it is a temporary measure for the duration of the embargo period, but it fulfils the requirements of would-be readers who have an urgent need to access the article while honouring publisher embargoes on generalised access


11. It is worth noting that the Finch report states that embargoes of less than 12 months are ‘unreasonable’. It bases this on the claim by subscription publishers that immediate Green OA threatens their businesses, yet no evidence to support this claim has ever been produced. There is no evidence at all that short embargoes – or even no embargo at all – damage publisher subscription businesses (what has caused relentless attrition in journal subscriptions over 30 years is the equally relentless above-inflation increase in subscription prices).


12. On the contrary, the two main society publishers in high-energy physics have publicly stated that they have seen no damage to their businesses from 20 years of Green OA (where there is no embargo at all) in this discipline. The National Institutes of Health (US) policy, a ‘Green’ Open Access policy that has been in place since 2007, requires authors to deposit their articles in the OA repository called PubMed Central – and the publishers of thousands of journals also voluntarilysubmit their own articles to PubMed Central, not something they would do if it damaged their businesses[4]. And Nature, the most prestigious scientific journal of all, says, “We have, to date, found author self-archiving [Open Access] compatible with subscription business models, and so we have been actively encouraging self-archiving since 2005.”


13. It would seem not unreasonable then to conclude that Green Open Access does not (yet) harm subscription publishers: and the recently-completed PEER project, a publisher-led, EU-funded study to gather evidence of the effects of Green Open Access, concluded exactly that[5].


14. Engagement with publishers, universities, learned societies and other stakeholders in developing the new open access policies

SPARC Europe can only speak for itself here. The Finch group was composed of a number of representatives from publishers, research libraries and universities, and research funders. As far as is apparent, there was no consultation more widely with any other stakeholders, including expert advocacy organisations such as SPARC Europe: this contrasts markedly from practice in other countries, notably the US where open consultations take place to gather views and evidence from all interested parties before conclusions are drawn.


15. RCUK revised its original Open Access policy in 2012.RCUK did offer the opportunity for stakeholders to respond: issued its draft (revised) policy early in that year presumably took responses into account in its own deliberations. This was not a formal consultation where responses were published, but it was at least an opportunity for interested parties to provide their views.


16. There is a considerable body of opinion that feels that the Finch study gave overmuch weight to publisher fears (evidence-free) about their businesses and sought to promote a route to Open Access that put publisher interests above those of the research community and the public that funds research. SPARC Europe concurs with this in general, though our view is nuanced: we believe that it is possible to develop a policy position that achieves Open Access within a reasonable period, supports innovative publishing services and new business models, delivers a competitive market and returns value to the taxpayer. What the Finch report concluded and recommended does none of these well.


17. How the Government should address the concerns raised by the scientific and publishing communities about the policy

The Government should take steps quickly to consult widely with the research community and allied groups of stakeholders. At the time of writing a BIS consultation on the topic of Open Access has been announced, which is welcome. SPARC Europe will be responding to that inquiry with evidence on the issues outlined.


SPARC Europe is an organisation that promotes change in scholarly communication for the benefit of research and society.
This submission was written by Dr Alma Swan, Director of Advocacy Programmes
18 January 2013


  1. [1] Solomon DJ and Björk B-C (2012) A study of open access journals using article processing charges, Journal of the American Society for Information Science & Technology  63 1485-95  DOI: 10.1002/asi.22673
  2. [2] Registry of Open Access Repository Mandatory Archiving Policies (ROARMAP):
  3. [3] Houghton J and Swan A (2013) Planting the Green seeds for a Golden harvest: clarifications on ‘Going for Gold’. D-Lib Magazine, Jan/Feb 2013 19(1/2) doi:10.1045/january2013-houghton
  4. [4] The NIH Public Access Policy. Director’s report, February 2012:
  5. [5]
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