Our reponse to the HEFCE consultation on open access argues for clearer wording of criteria, point-of-publication access to outputs, and distinct HEFCE policy on embargoes and licensing
Response submitted 2013
The Royal Geographical Society (with IBG) welcomes the scope of the proposals and the manner in which the consultation has been handled.
We disagree with the criteria because we feel that the wording needs to be clarified and assurances given, as set out below. Subject to that clarification taking place, we agree with the three themes of the criteria.
We would urge a rephrasing of the first criteria which is unnecessarily ambiguous, and probably unintentionally so (given the clearer statement in paragraph 29). It is important that the repositories are aligned with the agreed embargo periods in terms of access to the final peer reviewed text, otherwise green embargos have no meaning. However, as currently worded the statement could be read to mean that UK HEI repositories may choose not to respect green embargo periods.
If the third criteria can only be delivered through a CC-BY licence, we do not support it; however if the third criteria can be met with more restrictive licenses, including CC-BY-NC-ND then we agree with the statement. We urge you please to clarify this as considerable confusion appears to exist across the sector regarding this point.
We believe it right that the outputs be made available as the final peer-reviewed text and not as the publisher’s edited and formatted version.
While this is primarily a matter for HEIs to respond to HEFCE upon, some disciplines will be well served also by subject repositories. Thus, learned societies as well as HEIs should be involved in these discussions and the development of advice to ensure users and disciplines as well as funders and universities are appropriately served.
We do remain concerned that there is an inadequate appreciation of the resources needed to develop and maintain repositories and the future-proofing required to ensure a sustainable legacy archive of scholarly outputs. There is potential for the extensive duplication of repository provision, which could see costs escalate. HEFCE should use this juncture to consider the full implications of separate institutional repositories before moving forward.
It is also likely that confusion about different versions of publications and data sets will emerge due to the multiplicity of repositories and the mobility of authors who may deposit research in a number of institutional repositories worldwide. Appropriate kite marking and author ID initiatives (e.g. CrossMark, ORCID) should be explored fully.
There are widespread misunderstandings throughout the HE sector in terms of copyright and usage licences so institutions will need to be capable of providing advice to authors on an individual basis, another burden.
The RGS-IBG is strongly of the view that outputs should be made available through institutional repositories (IRs) at the point of publication (for Gold OA) or, in the case of articles subject to green embargos, on completion of the agreed period of embargo from the point of publication. Further clarification with respect to articles subject to green embargos would be helpful; specifically to make it clear that deposit of the basic information (author, title and place of publication, date and duration of embargo) should take place on publication, with the full article to be released after the agreed embargo period.
There are at least three practical reasons for our preference for point of publication:
Deposit prior to publication would mean that those articles published Gold would lose the advantage of having only one, final version out in the world as authors would have to archive their non-publisher PDFs.
Licence type is agreed after acceptance in many cases and the listing or archiving in the IR will require the licence to be specified. Likewise, third party copyright agreements are often negotiated between acceptance and publication.
Many publishers’ copyright agreements state that authors must include a link to the final published version; this is only available on publication.
Do you agree with the proposed requirements for appropriate licences?
While the use of REF main panels provides a simple approach that does accommodate broad differences across the sciences, social sciences and humanities, there are disciplines that do not follow these patterns. Mathematics is a clear example where 11 usage and citation half-lives are more akin to those in HSS disciplines. Disciplines vary within REF main panel definitions and the proposed embargo periods should be set at sub-panel level, but within an overall framework of embargo length policy.
Given the nature of geography and the variety of institutional contexts (departments/schools) in which the subject finds itself in UK HEIs, we expect that there will be a number of cross-referrals between sub-panels in different main panels (B7 and C17 in REF 2014). Some human geography will be returned to B7 and referred to C17. This raises questions about appropriate embargo periods and compliance rates.
We believe it vitally important that HEFCE has its own policies regarding embargo periods. HEFCE policies will impact much more fully on the research community than RCUK policies. Furthermore, there is still much dispute and concern over RCUK policy (which sets a maximum of 6 and 12 month embargos in STEM and HSS respectively), a concern that has been temporarily assuaged for many (but not all disciplines) by the longer embargo periods that are allowed during the transition period where funding for APCs is unavailable to an author.
By having its own policy, HEFCE is enabled to take a leading, independent role in finding the appropriate balance between open access, excellence and the sustainability of the UK’s leading journals.
We believe it right for HEFCE to reserve its position at this point in time on licensing, since this area needs more consideration. As a point of principle, we strongly recommend that, in whatever form, non-commercial and non-derivative licences be permitted in both Gold and Green routes to open access in order to protect academic integrity against careless, arbitrary or subversive reuse of research findings. Additionally, we do not support external commercial operations (especially non-UK ones) raising revenues on the back of freely available and publicly funded research.
We believe it is inappropriate to expect repository of monograph text and strongly support its own special-case exception. The output of monographs varies significantly across disciplines (and sub-disciplines) and the balance of those disciplines varies across institutions. Without a blanket exception, this will be a very uneven burden across institutions.
The issue of monographs also needs to be thought about broadly to consider edited volumes and book chapters.
Some clarity would be welcome on whether monographs are wholly exempt from the percentage compliance rates or whether monographs, as non OA publications, are expected to be included within the percentage non-compliant submissions to REF post 2014.
Disagree. We would suggest a notice period of three years, 2017.
Some journals in geography have long publication pipelines, in excess of two years, so articles to be published after the 2016 deadline may already have been accepted.
An alternative approach would be to reduce the proposed percentage compliance rate so that papers already submitted to journals with long pipelines can readily be included within the allowable percentages of non-compliance.
Agree. It would not be appropriate to require academics coming into the UK to have met open access requirements whilst working in a setting that may not have supported (nor required) open access publication.
There remains ambiguity, however, in relation to those who are not employed by an institution but have an unpaid affiliation to it. This could disproportionately affect certain groups – for example Early Career Researchers.
Additional points of detail: The wording of this issue is confused throughout the consultation document. The summary page suggests only those articles with a UK HEI in the address field can be submitted to REF (not that submissions to REF only have to be OA under this condition). In addition, paragraphs 41 and 58 also do not specify whose address - this only applies to the researcher being submitted, not if one of their colleagues was based in the UK at the time but they were not.
B Percentage target
Agree (depending on how blanket exceptions apply to these e.g. books).
Vary by REF main panel.
The administrative burdens imposed by a case by case approach, and the potential subjectivity involved, make this approach unworkable.
We strongly support the idea of varying the percentage target, as a pragmatic approach to some of the issues that have been raised. Until more data are available we do not know if the variation between disciplines is such that percentages would be better varied by sub-panel rather than main panel. We ask HEFCE to keep this under review for subsequent REF exercises.
Our own data gathering (based on analysis of submissions to the geography sub-panel for RAE 2008) suggests the target is attainable, but data for REF 2014 will give clearer insights (and the policies of publishers and journals are actively evolving). Much will depend on resources available (for Gold OA) to academics across disciplines and institutions.
We recommend that the percentage stipulated be realistic in order to take account of the needs of some disciplines (e.g. where there are long publication pipelines or significant international collaboration with countries/publishing in overseas journals where Open Access publication is less supported). We encourage HEFCE to set the bar at a sensibly achievable level at this stage.
We urge HEFCE to continue to monitor the compliance of overseas journals to inform appropriate future percentage targets.
As a matter of principle, HEFCE will, we hope, allow academic colleagues to be the decisionmakers as to where they publish their papers; and thus be prepared to be flexible in continuing the percentage approach so that it can allow for those academics who have good reason to wish to publish in a non-compliant journal.
Our evidence submission advocates for the role of geography in education, and the timetabled provision of geography in primary schools.
We argue the proposals penalise geography' success; that teaching costs, particularly from fieldwork, have been underestimated; and that HEFCE's approach rewards higher-fee institutions.
Our response welcomes a clearer progression in content and framework from Key Stage 1 - 3 to GCSE. We also suggest formalising requirements for quantitative skills in geography, and the use of short annual fieldwork returns.
Our response to this DfE consultation on HASLOC suggests clarifications and changes, and notes the Society's relevant experiences with BS 8848.
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