Our response to the 
Call for evidence on Open Access

February 8, 2013 in Announcements, Research

The UK Business Innovation and Skills Committee have asked for written evidence about the UK’s new Open Access strategy. We here at the Open Knowledge Foundation support this strategy and so have submitted some evidence to the inquiry. The submission we sent just before 5pm on Thursday 7th February is here below:

Response to the 
Call for evidence on Open Access

Executive Summary:

The Creative Commons Attribution licence (CC BY) is certainly the most appropriate for publicly-funded academic research. Of the Creative Commons licences it is the only one which is actually compliant with the formal definition of Open Access. Some publishers charge extremely high APCs which do not reflect the actual cost of production or work, therefore RCUK should restrict the maximum amount payable for any one publication. Exceptions to this maximum amount paid for an APC should only be allowed if justified to and agreed by the funding body.

The submitter:

My name is Ross Mounce. I am a final year PhD candidate at the University of Bath. I am also an Open Knowledge Foundation Panton Fellow. I have reviewed and published peer-reviewed research and of particular relevance to this call for evidence, I will be starting a BBSRC postdoc working on text and data mining techniques to extract new and open knowledge from the literature from October this year.

An introduction:

Open Access to publicly funded research is inevitable. Even Philip Campbell of the for-profit publisher Nature Publishing Group has publicly said so. Subscription access to research is extremely expensive and this cost is growing all the time. No library anywhere in the world can afford access to all subscription journals. Even Harvard University Library warned the world last year that their $3.75 million annual spend on journal subscriptions in 2012 was not enough to get what they needed (and this is just access for one institution). Prices for online access to the contents of two particular publishers have risen by 145% over the past 6 years. Any judgement on the cost of a managed transition to open access has to bear this in mind. We need to move, it’s just the question of how soon and by what strategy.

Given the costs, and yearly rises (mostly above the rate of inflation in the UK) in cost to access subscription access research the sooner we make the transition to 100% open access the better (in the long term). This is especially obvious when one considers that UK copyright law allows publishers to keep on renting access to research for typically up to 70 years after it was first published. Even the simplest back of the envelope calculations would show that even with relatively high APCs for 100% gold open access, it is in the interest of both UK & countries worldwide to make their research open access. Most countries around the world are thus already actively working towards this goal in some form.

For further insight into the inefficiency and dysfunction of the subscription access market, and non-substitutive nature of academic articles (we need access to them all), I highly recommend the Committee read Stuart Shieber’s writings on this matter.

I want to make it clear to the Committee that the gold open access route does not have to be as expensive as was originally forecast in the Finch report. A paper by Solomon & Bjork (2012) shows that the average price of most APC’s where they are offered is just $906, far less than the value quoted in Finch. The discrepancy arises perhaps because the Finch report assumes that authors will continue to publish in the same old for-profit commercially run journals they used to publish in. If the new RCUK policy can provide a little, but not too much scarcity of publication funds, then academics will be newly-pressurized into publishing in more cost-effective journals (that are of the same quality and peer-review as their ‘traditional’ journals).

Furthermore the Committee should be clear that there exist a multitude of good quality, often subject specific gold open access journals that are fee-free (APC=0), hundreds of which are depicted below. Solomon & Bjork (2012) show that the majority of gold open access journals operate on a fee-free basis, relying on institutional support and volunteered time.

Figure 1: the plot from by West, Bergstrom & Bergstrom (paper in prep). There is no strong relationship between APC paid & number of citations accrued by articles in these journals.


The definition of Open Access as defined by the original and recently reaffirmed Budapest Open Access Initiative statement permits any and all users to “…read, download, copy, distribute, print, search, or link to the full texts of these articles, crawl them for indexing, pass them as data to software, or use them for any other lawful purpose, without financial, legal, or technical barriers other than those inseparable from gaining access to the internet itself.”

Thus Creative Commons licences such as CC BY-NC, CC BY-NC-ND, and CC-BY-NC-SA are thus by definition not open and not compatible with the term ‘open access’ as the NC module clearly blocks some potential re-users and the ND module clearly excludes some types of re-use (e.g. format shifting and excerpts). The NC module can have some highly undesirable consequences for content published with this module, my colleagues at the Open Knowledge Foundation have translated a good guide to some of these.

One striking example is that the NC module prevents re-use in Wikipedia. This website is often the fount of the world’s open knowledge. It would be a shame to prevent RCUK academic work from being re-used with attribution on this vitally important website.


It would not surprise me if commercial publishers write to this Committee to object to the CC BY licence. It is a little known fact that some STM publishers, particularly in the pharmaceutical sector can provide the publishing sector extremely lucrative profits from providing physical, paper-copy ‘reprints’ of papers to companies who in-turn then flood doctors with these. I strongly recommend the Committee read this paper published in the British Medical Journal about the ethics of this, and it’s implications for open access licensing:

Handel, A. E., Patel, S. V., Pakpoor, J., Ebers, G. C., Goldacre, B., and Ramagopalan, S. V. 2012. High reprint orders in medical journals and pharmaceutical industry funding: case-control study. BMJ : British Medical Journal 344. 

If RCUK were made to water-down their policy to also allow the CC BY-NC licence for gold OA it would allow commercial publishers to retain their monopoly over reprint orders (which as can be evidenced in the above paper are extremely lucrative in some disciplines). The beauty of the CC BY licence is that it expressly allows commercial re-use. Thus any company can produce quality reprints of CC BY open access papers, I’m hoping this will spur market innovation and create new business opportunities for print-on-demand companies to compete to provide paper-copy research reprints. Without this liberal license the publisher has a monopoly over reprints for a particular article and thus can charge what it wants, restricting the availability of paper copies of publibly funded research.


Text & data mining. I mentioned at the start of this that I do text & data mining research. The business case for CC BY open access, and in particular the gold open access route is considerably strengthened by the potential and as yet unrealised benefits of mining on open access research. In this area licensing is crucial. Only research material published under liberal licences like CC BY are legally ‘safe’ to mine from a legal point of view. The potential commercial benefits from increased mining access to open access research are immense. The JISC report on the Value and Benefits of text mining clearly shows this:

If text mining enabled just a 2% increase in productivity corresponding to only 45 minutes per academic per working week, this would imply over 4.7 million working hours and additional productivity worth between £123.5m and £156.8m in working time per year.”


The ‘green’ route to open access is agnostic with respect to licence and this causes great problems for innovative re-use methods like text mining. Sure, the green route is cheaper than the gold route, but you’ll also get less economic benefit, through less re-use potential via the green route. Not to mention the inefficiency of the delay caused by the embargoes often levied on green open access routes by publishers.

Finally, there are lots of silly, completely illogical arguments sometimes written against the green open access route particularly short embargo lengths. One such is that in Humanities and Social Sciences (HSS) older articles are often cited, and thus have a longer ‘citation-half life’ and that this somehow translates into a need for a longer embargo period. Whilst it may be true that HSS articles have a long citation life. That is also very true of other disciplines e.g. Palaeontology and Geology. Here even 19th, and early, middle and late 20th century papers can be routinely and appropriately cited in an average research paper. As an example analysis I have data to show that the average age of a cited paper in palaeontology is >18 years old.

…and this does not hinder most palaeontology and geology journals from having short embargoes as can be demonstrated by data from Sherpa/Romeo. I encourage the Committee to look for facts and real evidence in their decisions on permissible embargo lengths. Not ‘surveys’ of opinion and illogical speculation.


Please also read complementary evidence from other scientists: Peter Murray-Rust’s evidenceStephen Curry’s evidence and Mike Taylor’s evidence.




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