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Re: Rebuttal of STM Response to RCUK Self-Archiving Policy Proposal



[NOTE: Resending as several readers say they didn't receive the message's content.]

Dear Ann, As Professor Harnad has applied the Open Access principle to
private correspondence such as our letter to the Chair of RCUK by widely
publicising a 'rebuttal' to it, I feel it is only fair to let the readers
of this list serve have access to the 'rebutted' original as well.

Pieter Bolman
CEO STM Association

___________________________

The Hague, August 22nd, 2005


Professor Ian Diamond
Chair, RCUK Executive Group
Councils UK Secrerariat
Polaris House
North Star Ave
Swindon
SN2 1ET UK

Re.: ACCESS TO SCHOLARLY RESEARCH: AN STM RESPONSE TO THE RCUK PROPOSAL

Dear Professor Diamond,

The International Association of Scientific, Technical and Medical Publishers ("STM") welcomes the debate and discussion concerning access to scholarly research as outlined in the May 2005 Research Council UK (www.rcuk.ac.uk <http://www.rcuk.ac.uk/> ) statement on the dissemination of and access to journal articles and conference proceedings. STM member publishers have made significant investments in electronic infrastructure and innovative licensing programmes to improve research access and to drive down the cost of access, the results of which are demonstrably and dramatically improved access to research journal content.

STM represents nearly 100 professional and scholarly publishers from 26 countries, including the UK, and includes commercial and not-for-profit organisations, representing many who experiment with "Open Access" programmes as well a variety of other business models. The STM sector is vital in evaluating and communicating the latest research results in the fields of pure and applied science, medicine and technology, and thereby supporting innovation in medical treatment, consumer and industrial products, product design, telecommunications and computing. STM is 'business model neutral' and does not favour one model over another. Its overriding concern is that business models must prove to be optimally of service to all constituencies and that decisions and choices are made freely by those constituencies based on open evaluation, not ideology or belief, and without government intervention or mandates.

STM member publishers have developed and continue to develop innovative and accessible business models to broaden information access such as:

* freely accessible abstracts or summaries;

* flexible subscription licensing arrangements for electronic journals;

* "pay per view" article access for those unable to = subscribe;

* in some cases an "author pays / open access" option for the whole
journals programme, in other cases for selected journals and /or
scientific disciplines

* the implementation of discovery tools such as links to articles in
thousands of journals from hundreds of different publishers (through
CrossRef, see www.crossref.org <http://www.crossref.org/> ) and novel
searching tools;

* the development of PatientINFORM projects with the American Cancer
Society and the American Heart Association, and related projects such as
the Diabetes Learning Center. This initiative will be expanded to other
diseases and to other countries (including the UK) and assists patients to
expert information on and free access to the latest articles on their
particular ailment.

STM publishers have also formed and been significant contributors to
projects such as HINARI and AGORA to ensure broad access to core health
and agriculture materials for developing countries.

The four RCUK principles

STM fully supports the four fundamental principles for scholarly and
research publishing identified by the RCUK. These can be summarized as
follows:

(1) wide-spread and rapid access to publicly-funded research ("public
funding should lead to publicly available outputs");

(2) journal specific quality control assurance through rigorous peer
review procedures;

(3) efficiency and cost-effectiveness (publishing should be cost
effective, financially sustainable and able to take full technological
advantage of new discovery tools); and

(4) long-term preservation and archival access, undiminished in quantity
and quality.

We find the RCUK recommendations for online subject matter and
institutional repositories, requirements for publicly-funded authors to
deposit articles in such repositories, and apparent support for open
access (author pays) journal business models rather intriguing non
sequiturs, as if the current publishing environment does not and can not
possibly adhere to the four requirements noted above.

In our view, the RCUK conclusions are precipitous and lack scientific
rigour. They appear to presuppose that there are unsolvable problems in
the current scholarly information system, without debate or analysis, and
without apparently considering the enormous strides that have already been
made and continue to be made towards full adherence to the above
principles. New solutions are then proposed without analysing the likely
results and impact on the current information infrastructure and without
apparent concern for the continuing quality of service to the scientific
community. As we will demonstrate below, we think it far more likely that
the creation of a new more routinised publishing system through
RCUK-mandated repositories and systems as proposed will decrease diversity
in journals and the peer review process, will threaten the value of
investments made by STM publishers, and will improve neither access nor
quality for scholars. The proposal will also exacerbate the nascent
problem of differing versions of research papers existing on multiple
systems, with researchers unsure as to which version has been subject to
peer review and editorial rigour.

There is substantial and compelling evidence that the current publishing
and licensing systems of STM publishers, combined with the practices of
major institutions and resources such as the British Library, the NESLI
and JISC national model licences, and the major university libraries, have
created a vibrant research infrastructure in the UK in which all four RCUK
principles are embodied and are functioning with enormous success. There
is no evidence to the contrary, although there are concerns about
appropriate budgeting to support ever-increasing research outputs.

1. Access

The Publishers Association survey from January 2005 on "University Library
Spending on Books, Journals and Electronic Resources" (the "PA
Survey")[1], notes that the number of scholarly journal subscriptions has
essentially doubled over the past five years, from approximately 550,000
nation-wide in the 1998-1999 school year to approximately 1,100,000 in
2002-2003 (the last year for which there is data). This is presumably in
addition to access to purely electronic journal content (as some UK
institutions have switched from print plus electronic access to
electronic-only). A recent article by Simon Bevan in the July 2005 issue
of Serials[2] described a recently concluded JISC study on the effect of
current "big deal" journal licencing practices in the UK (NESLI),
indicating that the number of downloaded articles increased by 42% from
January 2003 through June 2004, to a total of 2,200,000 articles. The
same report went on to state that the cost for access was described in the
survey as low in relation to interlibrary loan costs and current
pay-per-view charges.

These figures are confirmed by the feedback from researchers themselves as
reported in the 2004 study "Scholarly communication in the digital
environment: what do authors want?" (the "CIBER survey")[3], where 76% of
researchers report that access is significantly easier than five years
ago. The Government itself, in its November 2004 response (the "UK
Government Response")[4] to the report of the Science and Technology
Committee of the House of Commons called "Scientific Publications: Free
for All?", noted that it did not see any "major problems in accessing
scientific information", nor "any evidence of a significant problem in
meeting the public's needs in respect of access to journals..." The
Government further noted that "increasing amounts of material become
accessible from the researcher's desktop," with the annual volume of
downloads from UK publisher's material reaching 1 billion per year.

With respect to access through public libraries and university libraries,
the UK Government Response lauded the British Library's document supply
service and criticised the practices of academic libraries in restricting
public access. Public access through "walk-in" license provisions are
permitted by most STM member publisher licenses, as well as the NESLI and
JISC model licences.

Notwithstanding the fact that most STM member publishers permit authors to
deposit their works[5], in some form, in the authors' institutional
repositories ("IR" or "IRs"), such repositories do not appear yet to have
created a substantial archive of research material. Only about a fifth of
the CIBER survey respondents had deposited any type of material in an IR
(and only a small minority were research papers), and many expressed
doubts about the viability of IRs. The UK Government Response is
supportive of IRs, but notes that uncertainties exist about costs,
technological aspects, coverage or scope, and quality. Institutional
repositories do not seem to be able to provide improved access to verified
research results, and the potential costs to improve such repositories to
enable them to be successful have not been analysed properly to determine
whether they are significantly less expensive than current publishing
models.

Finally, it needs reminding that 'public access' does not necessarily mean
'free access', in the same way as 'public transport' does not mean 'free
transport', even though in this country tax payers seem to contribute as
significantly to the latter as they do to scientific research. The concept
of 'reasonable access' is probably more appropriate in this case.

2. Quality Control

Researchers report a high level of trust in existing peer-reviewed
journals. Existing open access journal publishers such as BioMedCentral
and the Public Library of Science (PLoS) emphasise their peer review
systems as important "selling points". STM is not aware of any
assertions, proposals or studies that suggest that existing STM publishers
are not doing an effective job in coordinating the peer review system for
their journals. Quality can always be improved, but it is difficult to
imagine how author-pays business models or repositories will be more
effective with respect to quality than existing publishing systems.
Mandating a centralised peer review system for repositories will not be an
improvement on the current journal-based and highly diverse review
procedures. In fact, the argument has often been made (and never
successfully refuted) that the mixing of scientific and financial barriers
to an author accessing the journal of his/her choice may lead to
unintended consequences with respect to reviewing standards.

3. Cost

The enormous increases in access noted above, largely resulting from
electronic access and innovative licensing schemes, have not involved
commensurate cost increases. The PA Survey, which as noted above
identified a greater than 100% increase over the past five full school
years in available subscriptions, described only an approximately 40%
increase in journal expenditures. The UK Government Response indicated
that an explanation may be that "bundling deals do provide a means of
increasing value", and noted that "spending on journal subscriptions
continues to be only a small proportion of [the higher education sector's]
total research costs... equat[ing] to 1% of HEFCE funding."

Many reports have now indicated that major research institutions would
have to pay more for author-pays business models than in the traditional
subscription models. The UK Government Response noted "that the UK would
end up paying more being a net exporter of scientific information" given
the large number of UK researchers and the volume of UK research output.
The Government notes that the UK generates "5.3% of articles to global STM
journals, but only contributes 3.3% of the global subscription market."
Any alternative business models, including the author-pays model, would
have to deal with the difference between research output and current
subscription expenditure. The Government report concluded that it "has
seen no convincing evidence that the author pays model would be cheaper to
operate than... under the current model." Finally, the Government also
identified the problem of industry "free riders", noting that in an author
pays system, companies would pay less (as they consume more than they
produce), and would thus force the Government to pay more.

The cost of maintaining a large number of independent repositories,
especially ones that would have substantial scale, is likely to be
significantly higher and less cost-effective than current publisher-hosted
systems.

STM agrees that there are significant and important concerns about the
ever-increasing gap between the relatively high level of research funding,
resulting in ever-increasing output of research results, and the
relatively static level of library funding. This issue deserves serious
debate and consideration, but the RCUK proposals do not seriously address
these issues, if at all.

4. Archival issues

The British Library maintains one of the most complete academic libraries
in the world, and the university research library community is similarly
focused on preservation. Many UK university libraries now have access to
very large collections of STM journals. With respect to digital
archiving, most STM member publishers have made significant commitments to
maintaining an internally-hosted permanent archive of their publications,
and many have made arrangements with the Royal Library of the Netherlands,
in the Hague, for an external archival deposit. STM member publishers are
highly supportive of the archival mission, and many have had discussions
with the British Library on archiving similar to the project with the
Royal Library.

The cost of duplicating such archives in digital form on various
e-repositories, as appears to be suggested by the RCUK, is daunting and
unnecessary. Although such decisions in the context of institutional
repositories are ultimately the prerogative of the individual
institutions, such policies ultimately would require the UK tax payer to
foot the (double) bill.

Conclusion

Scientific disciplines differ widely in their scholarly communication
practices. Journals differ from one another in their editorial content,
features, sales models, and how they serve the needs of their specific
research communities. As noted, many STM members are currently
experimenting with business models that incorporate elements of "Open
Access" principles, whether in permitting authors to self-archive their
papers on open institutional web sites, in providing open web sites for
journals, or in providing such access via the Internet for journal issues
within a certain period of time selected by the publisher as relevant for
the particular scientific discipline. Some STM members have been engaged
in Open Access journal projects for many years, although not (yet?) in
ways that demonstrate significant longevity and sustainability.
Generally these programs continue to require subsidy funding of one kind
or another, and in that sense require publishers or sponsors with
substantial funding capacities.

The multitude of business models that have emerged over many years serve
the needs of authors and customers by ensuring the wide and continuous
dissemination of consistently high-quality, independently validated
research, and we welcome new publishers and new business models to our
markets. We see nothing new in the RCUK proposal other than unfunded
mandates that arbitrarily favour some models over others.

STM submits that the research community, and the four RCUK principles, are
well served by the many dynamic business models that are currently in
existence and experimented with, as a result of competition and
innovation, in the marketplace.

In summary, STM believes that it would be in the interest of the research
community and the broader community as a whole if STM and RCUK start a
serious and systematic dialogue, based on the mutually agreed "four
principles", by jointly assessing and evaluating areas where the research
information infrastructure can be improved and working with both the
publishing and research communities to achieve this, including by the
development of mediation and investigative bodies for research ethics
issues, the support of the development of technical standards to identify
versions and forms of research papers, and the like. This way we can all
avoid the trap of prematurely promoting solutions that are based on
unproven assumptions.

Yours sincerely,

Pieter S.H. Bolman, PhD
Chief Executive Officer
London office per September 1st, 2005
Suites 301-302
344-354 Gray's Inn Road
Kings Cross, London WC1 8BP

[1]See
<http://www.publishers.org.uk/paweb/paweb.nsf/0/460034df9bc9868b80256ffe003fddbf/$FILE/University%20Library%20Spending%20Update%202005.pdf>=20

[2] "How usage statistics can inform national negotiations and
strategies", Bevan et al., Serials 18-2 (UKSG), July 2005

[3] See http://www.ucl.ac.uk/ciber/documents
<http://www.ucl.ac.uk/ciber/documents>

[4] See
http://www.publications.parliament.uk/pa/cm200304/cmselect/cmsctech/1200/1200.pdf=20

[5] See the Romeo project on the Sherpa site,
http://www.sherpa.ac.uk/romeo.php?all=3Dyes

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